Archive for April, 2008

TPIA’s response to Sutro Tower Environmental Impact Report (EIR)

April 24th, 2008

This letter is written in response to the January 5, 2008 Notice of Preparation of an Environmental Impact Report regarding to the above referenced project.   In sum, the Twin Peaks Improvement Association advocates that:

February 1, 2008

Bill Wycko
Acting Environmental Review Officer
San Francisco Planning Department
1650 Mission Street, Suite 400
San Francisco, California 94103

Re:     Sutro Tower NOP/IS
Case No. 2007.0206E

Dear Mr. Wycko:

This letter is written in response to the January 5, 2008 Notice of Preparation of an Environmental Impact Report regarding to the above referenced project.   In sum, the Twin Peaks Improvement Association advocates that:

1) The time period for review and comment of the proposed scope of this EIR be extended;

2) The City and County of San Francisco retain an independent peer reviewer with expertise in the hazards posed by telecommunications towers and broadcast related operations to assist with the proper scoping of the EIR with regard to the proposed project (in light of the fact that the Sutro Tower is located within striking distance of thousands of homes, three emergency/essential water reservoirs, and Clarendon Elementary School);

and

(3) The Notice of Preparation of EIR be corrected and re-circulated so that meaningful comment on the scope of the EIR can be made by the public as the Notice of Preparation of the EIR fails to wholly consider very real dangers posed by the project.
Extension of Public Comment Period

At the outset, the comment period for this project must be extended.  The Sutro Tower is unlike any other structure in San Francisco.  Given the complexity of the Tower and its importance as an Essential Telecommunications Facility, and that the Tower is used for emergency telecommunications, the Notice should have been sent to a greater number of stake holders, including other communities, that rely upon Sutro Tower’s emergency broadcasts.

Moreover, the City must retain outside independent peer reviewers who specialize in identifying the hazards and dangers posed by telecommunications towers and broadcast related activities to assist both the Planning and Building Departments in the assessment of the risks posed by this type of project to the community, so that a proper EIR can be prepared to protect the public interest.

Placing the onus of identifying the hazards of this project as well as all future projects and the public response regarding this project upon the neighbors who live under the Sutro Tower, without including independent experts comment regarding the scope of the EIR, is inadequate.

Improper/Incomplete Description of the Project  and Project Area

The Sutro Tower telecommunications compound sits precariously close to three of San Francisco’s essential water reservoirs.  Any compromise in the Sutro Tower structure of the “unplanned” removal of any structure/antennae/equipment off the Sutro Tower presents a potentially fatal threat every day to the residents who live in the vicinity of the Sutro Tower.

Moreover, it is impossible to comment upon the scope of the EIR as the Notice fails to disclose or address the ambient broadcast strengths of the proposed new antennae.

Potential Seismic Impacts

The Notice of Preparation of the EIR improperly suggests that Sutro Tower and The Project do not pose a seismic hazard or that seismic hazards are less than significant “due to the high elevation and distance of the project site from a large inland water body.”

Given that Sutro Tower is located within striking distance of (1) three water reservoirs containing thousands upon thousands of gallons of water sited directly above residential housing, and (2) more than 1000 homes are located within the “fall zone of the Sutro Tower”, and (3) Clarendon Elementary School is also located within the “fall zone of Sutro Tower”, the Planning Department’s conclusive language in the Notice (page 37, lines 1 thru 10) is at best ill conceived, and at worst, demonstrates that the Planning Department fails to comprehend the impact of the Sutro Tower as well as the Proposed Project upon the neighborhoods below.

Location of Ancillary Equipment

By their own admission, the building located at the base of Sutro Tower is at capacity and over the years equipment has been added atop the transmission building and behind screened areas and located upon “equipment pads” at the base of the Tower.  Contrary to the assertions in the Notice of Preparation, this unsightly equipment is clearly visible from public roads and can be seen in plain view from the living room windows and gardens of many homes located in San Francisco.

The Notice fails to provide an adequate description of the ancillary equipment, whether or not the equipment will generate noise or create other impacts on the neighborhood, so accordingly because of this failure it is impossible to comment upon the proper scope of the Notice.

Conclusion

Because the Notice of Preparation does not provide drawings or plans or schematic representations of the proposed locations of the Proposed Project, fails to disclose the nature and use of the proposed antennae, fails properly describe the existing area, fails to address where the ancillary equipment is to be located, (inside or outside), fails to address or disclose the issues pertaining to terrorism, security, and seismic hazards, and the conversion of the Tower to other uses not related to fm broadcasting, the Notice of Preparation is defective, must be revised and re-circulated.

Very truly yours,

Doris S. Linnenbach
Twin Peaks Improvement Association

cc: President and Members, Planning Commission
President and Members, Board of Supervisors