Scoping Comments on the October 12, 2010 North Embarcadero Port Master Plan Amendment Environmental Review Notice of Preparation

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1 Scoping Comments on the October 12, 2010 North Embarcadero Port Master Plan Amendment Environmental Review Notice of Preparation Submitted by Don Wood, November 12, 2010 These comments are based on over thirty years experience in downtown waterfront planning, experience serving on the 1990 Downtown Community Plan Update committee, dozens of bayfront design planning workshops and charettes and many meetings of the Board of Port Commissioners where they discussed the future of San Diego s downtown waterfront. While I am a member of numerous downtown and waterfront planning organizations, these comments are mine alone. My goals in submitting these comments is to ensure that this EIR process fully considers alternatives that could create a more balanced and economically healthy embarcadero while increasing public access and utilization of this unique place in the world. Please ensure that the EIR process fully considers and vets the issues and concepts outlined below and that the studies requested are completed as part of the EIR process before a draft EIR is developed. These comments are formatted in a manner generally consistent with the listing of issues in the NOP. 1. The existing Port Master Plan (PM) provides specific recommendations for each section of the North Embarcadero. We believe that the NEVP EIR should carefully discuss each of the individual changes being proposed to the existing PMP and the NEVP MEIR, explaining the specific changes each would mean along the Embarcadero, the impacts each would have on public access to the bayfront, along with all related environmental impacts caused by each change and the specific actions the Port is proposing to fully mitigate said loss of public access and environmental impacts. 2. The Notice of Preparation (NOP) is far too vague, because it does not accurately or completely describe any specific project. While listing a number of ideas for changes to the current Port Master Plan (PMP) the NOP does not say specifically what the Port is proposing to build on the North Embarcadero. As part of a public planning process, a more complete and detailed project plan should be prepared listing the specific text and graphic changes being proposed to the current PMP and describing in detail what the area will look like when the all proposed projects resulting from the changes being proposed to the current PMP 1

2 have been completed. Once completed, that more detailed plan, along with all alternatives studied as part of its development, should be subjected to an EIR review and comment process. Limiting the NOP and EIR only to a set of proposed zoning changes denies parties commenting on the NOP the opportunity to fully understand exactly what the Port is proposing to do, making fully informed comments on the NOP and any proposed changes to the current PMP impossible. This problem could be somewhat mitigated by holding the draft EIR review process in abeyance until the Port staff has conducted an open public planning process, utilizing the proposed NEVP citizen s advisory committee and a series of public planning workshops, to arrive a more complete plan, including preferred alternatives and various alternatives considered. 3. The Port Master Plan Amendment (PMPA) planning process should start with the adoption of a clear set of planning principles and guidelines that will shape future redevelopment of the North Embarcadero. A set of such principles and guidelines were adopted as part of the original 1998 NEVP, but have not always been adhered to the Port since they were adopted. It is time to revisit them and update them for today s environment. The updated planning principles guidelines should adhere to today s planning laws and regulations, including but not limited to AB 32, SB 375, the California Environmental Quality Act (CEQA), the California Coastal Act, and modern urban planning principles that support the accommodation of people over ships, cars and trucks. 4. The redevelopment of the North Embarcadero should provide full mitigation for the loss of public views and access the public has experienced along the South Embarcadero, and for the loss of a public community gathering space and bay view corridors eliminated by construction of the new terminal building on the Broadway Pier. Preservation of public view corridors over the Broadway Pier was a key mitigation for the loss of views caused by berthing the Carrier Midway at the Navy Pier and was required by the provisions of Port Master Plan Amendment 27, adopted in The Port should clearly indicate how it proposes to make up for the loss of that mandatory mitigation measure required in the current Port Master Plan. 5. All previous port commitments to preserve and expand public access and views to the Bay must be adhered to, including the completion of a new public park on the Navy Pier. 2

3 6. The Port should conduct a comprehensive feasibility study that considers the Tenth Avenue Marine Terminal (TAMT) as a new cruise-ship facility for purposes of relocating the some or all of the ships currently berthed at the B Street Pier and BP terminals. The feasibility study should include an accurate description of the process and possible timeline for relocating one or more cruise ships to TAMT, if relocation is found to be feasible and cost effective for one or both terminals. TAMT is already a secure facility; on the issue of traffic, TAMT includes more than 900 acres of surface space, some of which could be used for cruise passenger parking, along with the nearby parking garage east of the new Hilton Bayfront Hotel. In terms of vehicle access, TAMT is already served by roadways that would be modified to serve cruise ships as well as freight vessels at secure facility designed for lots of delivery trucks. This could create new synergies that would help revitalize the local commercial fishing industry as outlined below. Since the Port has already planned and allocated funding to retrofit TAMT with cold ironing shore power facilities, and cruise ship passengers could use the new Bayfront Shuttle to get to and from the cruise ships at TAMT and Lindbergh Field, adding cruise ships to the mix if vessels using TAMT would not impact the air quality of nearby Bario Logan, which will be improved as shore power is implemented at the site. If the Port decides to relocate the proposed Spinnaker Hotel and build it above the new parking garage east of the Hilton Bayfront Hotel, consideration should be given to better integrating the operations of the convention center, the hotels south of the convention center and a new cruise ship terminal on the TAMT to see if San Diego can integrate and enhance its existing convention and cruise ship businesses in a manner currently practiced in Vancouver. The additional foot traffic that having cruise ships berthed at TAMT would create would also increase the potential viability of any new retail operations that might be located along the east side of an expanded convention center. 7. The Port is currently completing the construction of a new cruise ship terminal on the 2.8-acre Broadway Pier. That action has been challenged in a lawsuit filed by the Navy Broadway Complex Coalition (NBCC) on the grounds that it violates provisions of the California Environmental Quality Act (CEQA). The current Port Master Plan requires the preservation of public views across the Broadway Pier as part of the master plan amendment (27) that allowed the Midway aircraft carrier to be berthed at Navy Pier. The new terminal building blocks those views in mitigation of the Midway projects monitoring and mitigation plan. If the courts do not order the Port to demolish or move the new terminal from the Broadway Pier, or if the Port fails to reach a legal settlement of the lawsuit with the NBCC, then this planning and EIR process should address and provide full mitigation for the loss of full-time public access and views across the Broadway Pier called for in the existing PMP, by providing an additional 2.8 acres of public pier space elsewhere along the North Embarcadero 3

4 at or near the foot of Broadway and provide significant new public views from Pacific Highway to the bay in the same area. 8. All new parking created between the Bay and Pacific Highway along the North Embarcadero should be located one level below grade. Above ground parking garages would block public access and views to the bay and crate an improper use on our limited public tidelands. According to the Lane Field planning team, the water table below the North Embarcadero is located 12 below grade, providing sufficient space to build one level of underground parking all along the embarcadero without any engineering or technical problems related to ground water control. Below grade parking is currently being planned for the new Lane Field Park on the western portion of the Lane Field hotel project site, and is considered the standard for all new buildings built downtown by the City of San Diego. If the planning process results in a new bayfront setback park along Harbor Drive, the new park should built above a large new Port public parking facility constructed one level below grade under the new park. 9. Existing public transit systems should be extended downtown to better serve the North Embarcadero, including extending the trolley to the airport and creation of the proposed new Bayside Shuttle, (also referred to as the Circulator Shuttle in the Port s proposed NEVP Phase 1 CDP) which should run from the Tenth Avenue Martine Terminal (TAMT) on the south to the airport in a continuous loop (utilizing both Harbor Drive and Pacific Highway). The new shuttle should operate every day of the year from 7 am to 11 pm in order to maximize visitor and tourist utilization. The shuttle fare should be equal or less than alternatives transportation alternatives serving the embarcadero area in order to build customer market share. The Port should work with SDG&E s alternative fuels vehicle group, the California Energy Commission and the federal government, to identify project capital and operational funding and obtain technical assistance to create the new Bayside Shuttle that should operate on something other than gasoline or diesel fossil fuels. 10. Wherever possible, new east/west pedestrian and view corridors should be created linking central downtown to San Diego Bay, including the reopening of B St. from Harbor Drive to Pacific Highway among other opportunities to better tie downtown to its own waterfront and the bay. People should be able to easily walk from their homes or workplaces downtown to the bayfront to see and touch the water. Wherever possible, new bayside beaches and/and new bayfront connections to the water should be created where people can allow their dogs to swim in the bay. 4

5 11. The Port should work with the city to redesign and realign key waterfront streets, especially Harbor Drive, to make them friendlier to pedestrians and families than to cars and trucks, including narrowing Harbor Drive and adding traffic calming elements to make it a meandering bayside scenic lane instead of a heavy usage freeway; with most north - south traffic along the harbor front shunted onto Pacific Highway, which is currently underutilized. The planned esplanade, the proposed setback park and a realigned and narrower Harbor Drive should be comprehensively planned and designed to better accommodate more pedestrians and recreational uses of our waterfront tidelands than they have been in the past. This should also include a full vetting of the concept of widening Laurel St in a manner that allows all traffic to access Pacific Highway directly from the airport instead of routing it south along Harbor Drive north of Grape St. 12. The current Holiday Inn complex leaseholder has approached the Port asking for an extension of their leasehold with the intention of remodeling their facilities to bring them up to today s standards. As part of any leasehold extension and facility remodeling project negotiations, the Port should require the leaseholder to clear, design, construct and maintain 205 or more of the western side of their leasehold, stretching from B St. north to Ash St. to accommodate the new setback park, and reconfigure their hotel complex to front on Pacific Highway instead of Harbor Drive. The section of the park west of the Holiday Inn hotel complex should be designed in a manner consistent with new 2.41 acre park/plaza space west of the Lane Field Hotel Complex, and new public space west of the County Administration Center parcel and on the west portion of the block between West Hawthorne and Grape Street. This alternative should be examined in context with the rest of the 205 setback park running from B St. North to West Hawthorne St. Existing water and electrical facilities under the setback park area could easily be relocated beneath a narrowed and realigned Harbor Drive. 13. The Port should recruit the County of San Diego to rejoin the NEVP Alliance and join the NEVP JPA, in order to ensure that new parks and gardens planned the Port along the North Embarcadero are designed in coordination with the County s planning for its new park at the County Administration Center. 14. Along the North Embarcadero, design and creation of new public spaces and viewsheds should be given priority over private commercial development and 5

6 cruise ship operations, with plentiful public restrooms and comfort stations sited along the embarcadero from the airport to Ruocco Park. 15. The waterfront should be home to more iconic civic buildings and public parks. We need fewer sterile condo towers on Centre City Development Corporation (CCDC) controlled property near the tidelands and more schools, museums and arts facilities built around the Embarcadero in order to better activate the area s public spaces. The Port should work more closely with CCDC and the City of San Diego to ensure that new buildings planned and built east of the tidelands will work with new public parks and other public amenities developed on the tidelands. 16. All parties need to better understand the economic benefits that come with the creation of activated public space along the Embarcadero. Investments by the Port in public spaces and amenities along the Embarcadero add value to the adjoining CCDC controlled properties. This increase in property values must be recognized and a significant portion of that value should be rebated back to the Port by CCDC, using the NEVP Joint Powers Authority to facilitate revenue sharing, 17. All North Embarcadero public and commercial spaces should be programmed and activated to make the waterfront a focal point downtown, and an unconscious destination like Balboa Park and the Gaslamp District are today, 18. Navy Pier s primary use should be for public park and recreation. Most if not all vehicle parking must be relocated off the pier as required by the existing PMP mitigation and monitoring plan. Planning for the pier should be conducted in a transparent manner, with full participation by the public in the planning process. Vague language like including a park does not indicate the specific uses the Port is proposing to use the pier for. Any private commercial uses of the pier should be limited and consistent with public park activities. No portion of the pier should ever be fenced off solely for commercial uses. 19. The NOP proposes eliminating the public crescent pier at the foot of Grape Street required by the current PMP, but is unclear on how the loss of that public pier would be fully mitigated. A drawing attachment to the NOP is labeled 6

7 remove Crescent Pier and consolidate 3 existing piers to 1-public and 1- excursion, but that one sentence does not provide any specific details of what the Port is proposing to do. Figure 11 of the current approved PMP shows a large graceful public pier curving into the bay from the foot of Grape St. At the October 28 PMPA EIR scoping hearing, Port Area Manager Shaun Sumner announced that Port staff has done engineering estimates of size of the pier shown in Figure 11 of the PMP and has estimated that it would be approximately 100,000 square feet in size. He also noted that the text in the current PMP describes the size of the pier as being only 30,000 square feet. On October 28 planning director John Helmer told me that the new public pier being proposed to replace the crescent pier will be the same size as the crescent pier envisioned in the current Port Master plan. The planning process should provide clearer information on what the Port is proposing to build in lieu of the crescent pier. If the 100,000 square foot public crescent pier reflected in the current PMPA is to be eliminated, the Port must clearly indicate how the loss of that key public amenity required in the current PMP will be fully mitigated. Creation of a smaller replacement public pier and a new pier used to serve private commercial excursion craft would create a net loss of public benefits of approximately 50,000 square feet of public pier space compared to the existing PMP. Any replacement public pier should be as large or larger than the crescent pier shown in figure 11 of the current PMPA. 20. The EIR should fully consider alternative locations for any new replacement public pier along the North Embarcadero, including directly to the west of the County Administration Center (CAC), designed in close coordination with the plans the County has already developed for construction of a new park on that site. 21. In the past, the Port has proposed creation of a new mega-yacht berthing area somewhere along the North Embarcadero, but no such area is shown or labeled in the drawing attached to the NOP, or mentioned in the NOP itself. The EIR should fully also address any mega-yacht berthing proposal in context with the rest of the North Embarcadero and not attempt to deal with that proposal in a separate planning process. 22. The NOP proposes to incorporate the constraints of homeland security requirements on maritime facilities and public access, but no explanation is included in the NOP describing what those specific requirements are. Specific references to what the port considers homeland security requirement constraints must be spelled out, along with the details of any project the Port is proposing to 7

8 undertake to comply with those constraints. This includes the permanent regulations adopted by the United State s Coast Guard in 2003 requiring 100 year wide exclusionary zones surrounding all cruise ships entering and leaving San Diego on both the land and water sides of the bulkhead line. These constraints must be clearly detailed in the EIR and should be further addressed in the feasibility study of moving cruise ships from the B Street Pier to the more secure TAMT site outlined below. 23. The NOP proposes to change the designated land use zoning of the 9.1 acre B St. Pier to remove reference to Commercial Recreation and expanding the exiting Marine Terminal zoning to the entire pier. Approximately half the pier is currently designated as marine terminal and half is designated for public commercial and recreational uses. At the October 27 PMPA EIR scoping meeting, port planning director John Helmer said the current land use designations on the acre B St Pier in the current PMP envisions the construction of restaurants and other commercial facilities on half the B St Pier, and would allow the public to have access to that portion of the pier during the days and the evenings every day of the year. At the October 28 PMPA EIR scoping meeting port planner James Hirsch confirmed that the current public recreation and commercial use designation covers approximately half of the B St. Pier. Any rezoning of the pier for the exclusive private use of cruise ships as a secured marine terminal would represent a loss of public access equal to half of the existing B St. Pier, or 4.6 acres of public pier space. The NOP and materials provided by port staff at the EIR scoping comments do not mention any plans for the mitigation of this loss of 4.6 acres of public pier space. This loss of public space should be fully mitigated as part of the PMPA planning and EIR process. 24. Before any changes in designated uses or zoning of the B St Pier are considered, the PMPA planning process and draft EIR should include the completion of a detailed feasibility study of an alternative that would move the cruise ships that currently use the B St. Pier to a new cruise ship terminal that could be constructed on the northern portion of the Tenth Avenue Marine Terminal (TAMT). The costs of building a new terminal on the TAMT site that could serve up to three cruise ships should be compared with the cost of building a new cruise ship terminal on the B St. Pie to serve only two ships. The cost of complying with federal homeland security laws and regulations the costs of complying with those same rules on the B St. Pier should be compared with the cost of complying with those same regulations at the already secure TAMT site. Creation of new cruise ship facilities currently at the 9.1 acre would require less than 10% of the more than 99 acres at the TAMT. 8

9 Any cost comparison study should compare like for like facilities. For example, if the port is proposing to remodel the existing 90 year old former cotton shed terminal building, on the B St Pier, the cost of that remodel should be compared with adaptively reusing one or more of the existing warehouses on the northwest side of TAMT for cruise ship terminal purposes. If the Port is proposing to build a new larger terminal structure on the B St Pier, the cost of that new terminal should be compared with the cost of constructing a new terminal of the same size at TAMT. The cost of creating new cruise ship passenger parking at a larger B St. Pier terminal should be compared with the cost of utilizing existing parking already available on the TAMT site and in the already completed parking structure east of the Bayfront Hilton Hotel complex. The study should assume the same level of roadway access and service to the alternative terminal facilities at each site. The potential for improved utilization of the 99 acre+ TAMT site, which is currently operating at only a fraction of its potential capacity, should be considered, along with the potential for alternative revenue producing uses of a remodeled public B Street Pier for recreation and maritime related commercial, retail and visitor serving uses, including new restaurant facilities, and potential use of the pier to accommodate growth of the expanding antique vessel fleet of the San Diego Maritime Museum, as long as that use did not require any portion of the public pier surface to be fenced off from public use. 25. While we support the idea of a new public hostel or similar low cost visitor accommodations along the North Embarcadero as required in the current Lane Field hotel project Coastal Development Permit, the NOP does not specifically indicate where the Port proposes to build such a new facility, or what the facility would look like, or how large it would be. The drawing attached to the NOP shows two potential sites for such a facility, on the existing 1220 Pacific Highway parcel currently lease by the Port to the U. S. Navy and at some kind of new potential multi-use/parking facility at West Grape Street and Pacific Highway. The Port s new plan must be more specific about where it proposes to build a new hostel or other low-income visitor serving accommodations. 26. The NOP proposes to evaluate potential new multi-use/parking facility at West Grape Street and Harbor Drive. Any new facility to be considered at this location should utilize below grade parking only, and accommodate the proposed 205 wide setback park running from Hawthorne St. South to the Lane Field site. The specific uses the Port plans to put on this block should be more clearly spelled out in the PMPA planning process outlined above. 9

10 27. It is unclear that the Port means by specify excursion facility locations. Does this mean the location of excursion craft, ticket booths for harbor excursions, docking facilities for existing excursions boats, or facilities to support new excursion boat operations? The planning process should address this in far more detail. New facilities for excursion craft could be located at one of the existing piers at the foot of Grape Street, at a new pier, or at the pier currently being used by the San Diego Maritime Museum, if some or all of that organization s operations were moved to a public B St. Pier. Excursion vessels could also be berthed at a public B St Pier if cruise ship operations there were moved to TAMT. Each of these alternatives should be addressed in the PMPA EIR. 28. The term memorial park is used in the NOP, referring to the G St. Mole. The term is also used in the current PMP to describe the new park to be built on Navy Pier. The Port should better define the term and explain how the memorial park mentioned on the G St. Mole would relate to the new memorial park on Navy Pier required by the existing PMP. 29. The NOP mentions assigning development parameters and standard for the parcel of land commonly known as 1220 Pacific Highway. The Port has signed a Memorandum of Understanding with the Navy giving it the option of buying out the lease the Navy currently holds on this parcel. The 1220 Pacific Highway parcel is mentioned in existing plans for the Lane Field hotels project. On November 9, 2010 the Port Board approved a Memorandum of Understanding committing to allocate funding for the design and construction of new public park/plaza space on the western 150 of the 1220 Pacific Highway parcel by the time the first hotel opens on the Lane Field site or by the substantial completion of NEVP phase 1 construction, whichever happens first. The Port should further clarify how and when it plans to re-acquire control of this site from the Navy, and rezone the western portion of the site for public park/plaza use, and how it proposes to utilize the remainder of the parcel. Is it to be used to support the Lane Field hotel project? To reopen B St.? To accommodate a new public hostel facility? To provide a site for a new hotel or space to accommodate a reconfiguration of the existing Holiday Inn hotel complex? If the Port is proposing specific uses or proposing a specific project on this site, it must be clearly spelled out in the new plan and EIR process. 30. The planning and EIR process should provide very clear new PMP language the Port proposes to add to the existing PMP and specific edits being proposed to the current PMP, in order to allow parties to fully understand what change the Port is proposing, and what the entire North Embarcadero would look like if all 10

11 those changes were adopted by the Port and approved by the California Coastal Commission and the courts. This should include very clear, detailed schematic drawings and renderings clearly labeled for each part of the proposed PMPA. In the past there have been misunderstanding and disputes over differences between the text and renderings included in previous coastal development permits and PMPAs. Let s not allow the same kinds of misunderstandings and disputes to be created by this planning and EIR process by using very specific language describing what changes are being proposed to the current PMP, that match very specific detailed drawing and renderings, with clear financing plans and project schedules and deadlines. What is being proposed, why is the Port proposing it, and when will any proposed PMP amendments result in competed projects? 31. The NOP proposes to Identify and analyze a minimum of 2.5 acres of additional open space and public access opportunities that will include, but not be limited to the following options: An open space set back park with the eastern edge of the park in line with the center of the west wall of the County Administration Center (approximately 205 ) along the east side of North Harbor Drive from West Broadway to West Hawthorne Street; including the US Navy property (1220 Pacific Highway, Holiday Inn Property and Solar Turbine s parking lot property. It notes that the CAC property is not affected by this process and that the Lane Field site would have a 150 setback park on the west side of that property. The NOP also mentions Narrowing Harbor Drive between West Grape Street and West Broadway and providing additional open space on the west (bay front) side of North Harbor Drive. The NOP also mentions closing and narrowing portions of Harbor Drive between West Hawthorne Street and West Broadway. The traffic study should study alternatives that would keep Harbor Drive running along the west side of the setback park and alternatively, realign Harbor Drive so that it would run along the south edge of the setback park, providing additional vehicle access to the western edges of the reconfigured Holiday Inn and Lane Field hotel complexes. 32. We note that the Port has already begun a North Embarcadero traffic study as part of Phase 1 of its NEVP planning process. We strongly recommend that this traffic study be expanded to address the options listed above, including the concept of converting North Harbor Drive into a meandering two lane bayside road, with traffic calming features which would divert the majority of through traffic onto Pacific Highway, instead of using limited waterfront tidelands to accommodate large volumes of vehicle traffic. The traffic study should be done in cooperation with the Lindbergh Field Airport Authority s own traffic planning processes, so that new traffic coming from the airport doesn t further congest Harbor Drive, but instead would be shunted onto currently underutilized 11

12 Pacific Highway. An alternative that entails use of the new Bayfront Shuttle to move airport and cruise ship passengers back and forth from Lindbergh to a new cruise ship terminal at the TAMT via Pacific Highway and south Harbor Drive should be fully addressed in the new planning and EIR process. 33. The North Embarcadero should be designed to accommodate visitors and local residents who want to spend a quiet day along the waterfront, and regular street fairs where locals can celebrate and take back the streets for bicycle and pedestrian uses along North Harbor Drive and the setback park. It should be a magic place connecting our downtown with our bay, with unique public art and other features that will attract visitors and locals alike. The traffic and parking study should analyze several alternative routes for a narrower Harbor Drive, one along the west side of the setback park, effectively separating the new esplanade from the setback park, and another meandering along the eastern side of the setback park, allowing the esplanade to butt up directly against the setback park, creating more public space along the west side of a realigned North Harbor Drive. An eastern alignment of Harbor Drive should address short-term means for people and cruise ship passengers to access the Bayside Café and the existing B. St Terminal, perhaps entailing use of the new Bayside Shuttle. 34. We support the creation of a comprehensive study evaluating parks, plazas gardens and other public spaces along the North Embarcadero, including an evaluation of the size and functionality of all existing and planned public spaces. Such a study should also look at how these public parks; plaza and public spaces can be woven together to create a string of pearls park concept called for in the original NEVP. The network of public parks should encourage greater public use of our tidelands while also accommodating commercial operations to serve both visitors and local residents. They should also be planned in a manner that better links them to and interacts with new downtown public parks currently being planned by CCDC. 35. The NOP proposes to identify opportunities to enhance pedestrian circulation and program events to activate open spaces along the North Embarcadero Waterfront. We strongly support this kind of effort. The North Embarcadero is currently missing the kind of pocket parks, public plazas, gardens, sidewalk restaurants and mobile food vendors that make Little Italy and the Gaslamp Quarter renowned destinations where San Diegans come together to enjoy our city, our cuisine and our climate. There is currently no there, there on the north embarcadero, and it sits mostly empty on weekends when cruise ships are not in port. It needs more exciting public places where people can gather to 12

13 enjoy our bayfront, the water and our city. There should be more places where residents can bring their pets, let their dogs swim in the bay, and let their children play in safety. It should be the place where our downtown and our bay merge seamlessly. People should be encouraged to come walk along the embarcadero on their breaks from work and their lunch hours during the week, and bring their families to picnic, shop and stroll on the weekends. There should be more interesting activities for them to see and enjoy as they walk along the waterfront. 36. If the study proposed above to test the feasibility of moving the cruise ships that currently use the B St. Pier to TAMT is completed and the Port finds it more cost effective and beneficial to make such a move, the Port should retain and expand the existing B St. Pier s public commercial and recreational use designation, and redevelop it as a place where locals and visitors alike could enjoy sightseeing, harbor excursions, marine related retail shops, seafood restaurants and wide pedestrian walkways around the perimeter of the pier, and view smaller commercial fishing boats and other marine watercraft tied up along the edges of the pier. The Port is currently trying to figure out a way to revitalize the local San Diego Bay commercial fishing industry. Local commercial fishermen advising the Port have indicated they need a place that are places more visible to the public to tie up and unload their fishing boats, process and sell the unloaded fish, and allow customers to eat some of the fish in nearby seafood markets. The EIR should look at adaptive reuse of the 9.1 acre B St Pier to create our own version of San Francisco s Fishermen s Wharf. Some of the local fishing craft could be permanently tied up at the B St. Pier, with the overflow craft accommodated at an enhanced Tuna Harbor just south of the G St Mole. Renowned seafood restaurants like Scoma s or Jake s might be interested in operating new restaurants facilities on the remodeled B St. Pier. The Port is required by the 1962 Port Act to support the local fishing industry, perhaps bringing fishing vessels back to the G St Pier is one way to do just that. Instead of relocating the existing harbor excursion vessels to a new pier near the foot of Grape Street, they could instead be berthed at the new public B St Pier, keeping them closer to the heart of downtown. Perhaps some of the antique sailing vessels currently operated by the Maritime museum could also be berthed along the remodeled pier, as long as doing so does not entail fencing off and privatizing any portion of the pier s surface. Perhaps some of the scientific craft currently being used by Scripps Institute of Oceanography to map the bottom of the bay could be berthed at a rejuvenated B 13

14 St Pier. Perhaps Scripps would be interested in building a downtown annex facility on the pier. These alternative uses of the B St Pier should all be fully assessed and addressed in the PMPA EIR. All of them would make the North Embarcadero a friendlier place for the public than a line of huge private cruise ships would be. 37. The NOP proposes to identify transit stations along the North Embarcadero. It should do more than that. The new Bayfront Shuttle operation should be designed to work seamlessly with existing trolley and bus operations along the embarcadero. People should be able to come to the downtown waterfront using the trolley or local busses, then walk to the esplanade, without having to bring a vehicle along. Those who are carrying picnic baskets and other paraphernalia, and those who may have difficulty walking, should be able to hop onto the Bayfront Shuttle and get wherever they want along the embarcadero. The transit and transportation circulation plan for the embarcadero should make full use of the region s trolley and bus capabilities. The Port should encourage SANDAG and the Metropolitan Transit System to extend the Trolley and local bus service to better serve Lindbergh Field and the North Embarcadero as well. 38. The NOP indicates an intention of incorporate the NEVP Parking Management Plan into the Port Master Plan as part of this process. As we understand it, the NEVP parking plan is in a state of flux. It should be refined to clearly indicate where parking displaced from the Navy Pier will be accommodated along the North Embarcadero, and to focus more on building below grade parking then on any new above grade parking garages. All new parking along the North Embarcadero west of Pacific Highway should be built below grade, since the existing 12 water table (identified as part of the Lane Field project planning process) will allow one level of parking to be created below grade all along the North Embarcadero. The NEVP Parking Master Plan should be updated to reflect this policy before being incorporated into an amended PMP. 39. The NOP calls for reconfiguring the land use designations at the foot of West Broadway to recognize current property ownership and permitting jurisdictions, but does not indicated what that property ownership and permitting jurisdiction is. The planning process should more fully explain what the Port is referring to in that bullet point far more clearly. 14

15 40. To our knowledge, no comprehensive investigation has ever been conducted to identify all the active earthquake faults that lay beneath the north embarcadero between Pacific Highway and the bulkhead line. Existing California seismic laws and regulations prohibit the construction of habitable buildings and structures over active earthquake faults beneath fill like that found on the downtown tidelands. Such a comprehensive study should be conducted as part of the PMPA EIR process. An unbiased nationally recognized third-party seismic engineering consultant using state of the art seismic testing equipment should do the study. The study report should be peer reviewed and circulated to the public for review and comments, with the draft study report and back-up documentation submitted to the California State Geologist s office and the California Coastal Commission for further review and approval as part of the EIR process, before any new habitable buildings are constructed on the north embarcadero. 41. San Diego and California are facing a growing shortage of drinking water. The PMPA EIR process should address ways to reduce the amount of potable water currently being used along the north embarcadero, and ways to capture and recycle all runoff water for reuse supporting new parks, plazas and fountains along the waterfront. Future redevelopment along the north embarcadero should be planned in a manner that will add no new net water demand in the area. 42. All new structures planned for the North Embarcadero should be designed in a manner that adds no new net energy demand to the area. All new buildings should meet U.S. LEED (Leadership in Energy Efficiency Design) certification standards and meet LEED Silver standards at a minimum. 43. The Navy Broadway Complex Coalition filed scoping comments on the original Notice of Preparation of a Draft Environmental Impact Report for North Embarcadero Port Master Plan Amendment on October 29, Those comments are hereby incorporated by reference. All issues raised in those comments should be fully addressed as part of this North Embarcadero PMPA planning and EIR process. Don Wood 4539 Lee Avenue La Mesa, CA