Public Comment on city's plan to trash the Market/Octavia neighborhood

Paul Maltzer
Environmental Review Officer
S.F. Planning Dept.
1660 Mission St., Suite 500
S.F. CA 94103

Public Comment on the Draft Environmental Report for the Market and Octavia Neighborhood Plan, Case No. 2003.0347E

1. The DEIR presents no justification for this project, which essentially involves encouraging housing development in the project area. According to the Planning Dept., there are already 10,500 housing units and more than 23,000 people living in the project area (Draft of the Market/Octavia Plan, page 45). For reasons unexplained, the Planning Dept. now proposes 4,440 new housing units for the area (1-2, DEIR), which would mean more than 40% more people living in that area. Since the “project sponsor” is the Planning Department itself, the final EIR needs to justify encouraging such a dramatic population growth for one neighborhood of San Francisco. The DEIR itself notes that, even without this project, the area will add 1,520 new housing units (4-43) in the same time frame. Why isn’t that enough housing growth for the area?

As the DEIR notes, there are already 800-900 new housing units planned for the old Central Freeway parcels. The proposed Plan recklessly proposes, without justification, encouraging more housing development in the area. Nor does the DEIR count of 4,440 new housing units by 2025 include the additional 450 housing units proposed for the old UC Extension site, which is in the center of the Plan area.

The DEIR talks about creating “a dense, vibrant and transit-oriented neighborhood” in the project area. Yet there already is just such a neighborhood in that area. The final EIR needs to make this counter-intuitive case: Specifically how will encouraging up to 10,000 more people to live in the project area improve that neighborhood/area?

2. Even though the Planning Dept. proposes a huge growth in the project area’s population, it wants to discourage developers from providing parking spaces for the new housing units. The theory behind this is that, since the project area is near the Market St. transit corridor, residents of the new housing units won’t need cars/parking. They can simply take a streetcar or a bus, or, even less plausibly, ride a bike. But it defies common sense to think that anyone who can afford an apartment in the project area---especially the market-rate housing units, which the DEIR notes at 4-209, will be 90% of the new units---will not own a car. The final EIR needs more than a dubious interpretation of selected census data to justify the irrational parking policy proposed in the DEIR.

3. Octavia Blvd.: “The new Octavia Boulevard (approved and under construction) would be the centerpiece of the neighborhood, accommodating both regional and local traffic” (1-6). Octavia Blvd. will carry six lanes of traffic through the heart of the project area. According to Caltrans and the US government, the Central Freeway used to carry 100,000 vehicles a day over the project area (“San Francisco Central Freeway Replacement Project: Environmental Assessment,” 1997, page 3). How many of those vehicles will be using the new Octavia Blvd. when the new freeway ramp opens up on Market St.? It’s irresponsible of the Planning Dept. to encourage development in an area that already faces serious traffic problems without this project. The final EIR must contain an honest appraisal of the area’s traffic both before and after implementation of this plan and, in particular, after the new freeway ramp becomes operational on Market St. later this year.

4. “San Francisco does not consider parking supply as part of the permanent physical environment” (4-204). The city invites litigation on this issue if this assumption is included in the final EIR. Indeed, in the very next paragraph the DEIR back-pedals, as it notes that the “social effect” of deliberately encouraging inadequate parking for new housing units “may lead to physical environmental impacts such as increased traffic congestion at intersections, air quality impacts, safety impacts, or noise impacts caused by congestion.”

5. Travel Demand, Methodology/Approach (4-205): This section of the DEIR does not include any realistic assessment of the impact of the new freeway ramp on Market St. across from Octavia Blvd. Since the ramp will open up before the end of this year, the EIR should include a specific study of the impact the ramp is already having on the project area.

6. The DEIR is basing its analysis of the project’s impact on public transit on 2002-2003 SF Muni data, which was collected before the recent round of cuts in Muni service due to budget problems (4-196). It should be noted that all of the transit lines in the area are already standing room only during commute hours.

7. Residential highrises: The Plan also rather casually proposes an undetermined number of “elegantly designed” residential highrises up to 40 stories high for the area, which would mean a radical change in demographics (many more wealthy people), physical character, and population density in general for the area. This is not prudent planning. Rather, it is reckless social engineering that will be impossible to undo once it is done. Again, as in the Plan in general, there is no justification even attempted for this radical change in the physical and demographic character of that part of town.

8. A note on style: Everyone in the Planning Dept. should be prohibited from using the overused word “vibrant” in all public documents. Its use in this DEIR is particularly inappropriate, since that part of town is already “vibrant” enough, thank you, without any misguided “enhancing” or “improvements” from the Planning Dept.

In short, the big question unanswered---in fact, no answer is even attempted---in the DEIR is, How will radically increasing the population density and altering the physical makeup of this area “enhance the neighborhood character of the Project Area”? (4-337) The final EIR should at least try to answer that question.

Rob Anderson