City of Belmont, Community Development Department
One Twin Pines Lane, Suite 310
Belmont, CA 94002
Attention Contract Planner, Chris Dacumos
Via email: cdacumos@goodcity.com
Subject: 1301 Shoreway Project EIR - Scoping comments
The Sierra Club Loma Prieta Chapter’s Sustainable Land Use Committee (SLU) advocates on sustainability and land use issues in San Mateo and Santa Clara Counties. In that role, we respectfully request inclusion of the following issues in the scope of the EIR for the project at 1301 Shoreway, Belmont. Life Sciences labs are one of the more unsustainable uses on the peninsula.1 Given that the City has a Climate Action Plan with measurable goals, mitigation of the environmental impacts takes on greater urgency.
Aesthetics
BSL-4 labs at University of Texas at Galveston
Tall exhaust stacks on rooftops are required for the fume hoods of all levels of biolabs. In addition, if BSL3 and BSL4 labs are included, they require advanced mechanical systems to maintain negative air pressure to contain and safely exhaust highly infectious, often lethal airborne pathogens.
Exhaust vents similar to Albany Medical Center are currently being installed at the Biotech lab building at 1091 Industrial Road, San Carlos.
This equipment can be required to be screened. However, codes may have several restrictions on obstructions, such as screens, for the high velocity exhausts required.2 3
Evaluate what is needed to make sure that unsightly stacks on the rooftop are completely screened from view.
Air Quality
Exhaust emissions from Biosafety Level (BSL) laboratories can be highly toxic and/or noxious, posing significant health risks ranging from mild irritation to severe illness. BSL-3 "high containment" laboratories rely on advanced mechanical systems to contain and safely exhaust highly infectious, often lethal airborne pathogens. However, these systems are not always fail- safe and are vulnerable to mechanical failure and human error. 4 5
Evaluate impact on air quality.
Biological Resources
The site is adjacent to Belmont Slough, which supports a substantial population of native and migratory birds. The North American avian population has declined by nearly 30% since 1970, with window collisions being a notable contributing factor. It is critical to evaluate the potential for avian collisions and mandate the use of bird-safe windows while reducing unnecessary interior lighting. Increased building mass necessitates additional setbacks and green infrastructure to mitigate glare, heat, and noise impacts on wildlife and humans. The reflective, heat-island, and noise effects on the adjacent bay trail and waterway must be assessed for their impact on both humans and wildlife.
Evaluate how effectively the project is preventing bird strikes, and whether bird-safe and whether bird-friendly design elements are going to be effective in this habitat-adjacent location.
Energy Use and Conservation
Biolabs consume 5 to 10 times more energy than typical office spaces due to their complex exhaust and containment systems, an impact that may be magnified tenfold for clean rooms and other specialized facilities.6 Rooftop solar panels are often not feasible due to the numerous tall exhaust stacks required. It is essential to evaluate the energy consumption (electricity and gas) relative to current usage and within the framework of Belmont’s Climate Action Plan. Evaluate the energy conserving measures of the project for meeting Climate Action Plan goals7.
Geology and Soils
The parcel, situated on bay fill, in a High Liquefaction zone. This presents earthquake-induced liquefaction risk and the potential threat to building foundations, utilities, and site access in the event of a major earthquake.
Evaluate the potential for loss of utilities and services due to seismic events potentially combined with soil liquefaction resulting in loss of soil integrity.
Greenhouse Gas Emissions
The proposed tripling of square footage will result in a significant increase in the number of jobs and site traffic, leading to higher greenhouse gas emissions. Given this, we need to evaluate the net increase in daily vehicle trips compared to current site usage and assess the overall greenhouse gas emissions from vehicle traffic and deliveries. It is also necessary to evaluate on- site energy consumption within the context of Belmont’s Climate Action Plan.
Evaluate the GHG impact of traffic and equipment emissions from labs and the mitigations required to achieve Climate Action Plan goals. What form of emergency generators will be used for the mandatory emergency power supply and what is its GHG contribution?
Hazards and Hazardous Materials
Evaluate the following items:
- In the event of fire, flooding, earthquake, or prolonged power outage, failure of biological containment systems could release toxic or lethal pathogens into the air or water. The risk of containment system failure and its impact on wildlife and public safety must be thoroughly evaluated.
- Also include the use of live animals in research and the provision for their care, handling, disposal, and, in particular, procedures for their health and safety during emergencies.
- Biolabs generate significant quantities of single use plastics, non-recyclable and potentially hazardous waste, requiring proper storage, handling, treatment, and disposal. Laboratory plastics account for about 5.5 million tons of waste per year. These can include anything from packaging to syringes to beakers, and they have supplanted many other materials that we used to reuse – sometimes for good reason. Labs are under pressure to decrease their waste because the reality of increasing plastics pollution outweighs their convenience.8
- The adequacy of on-site containment and disposal systems, as well as the risks associated with transporting hazardous waste, must be assessed.
- The use of natural gas or other flammable gasses in laboratory research necessitates evaluating associated risks during fires or natural disasters, including the potential release of toxins in explosions.
Additionally, the capacity of local emergency agencies to manage hazardous biological releases, unlike the normal hospital biological waste, must be assessed.
Hydrology and Water Quality
The parcel is adjacent to Belmont Creek, which has a history of flooding during king tides, particularly during storm events such as early 2023.
There is a risk of on-site flooding. The potential release of biological toxins and potentially deadly impacts on research animals during a flood-induced power outage or impaired site access must also be assessed, including the spread of toxins into nearby waterways and the bay, their threat to public health, and the ability of local emergency agencies to control exposure.
Evaluate its impact on the water quality of adjacent creeks, and wildlife habitat on Belmont Creek given the above concerns.
Land Use, Population, and Housing
The proposed tripling of square footage will result in a significant increase in employment. It is necessary to determine the net increase in jobs and assess Belmont’s capacity to expand housing stock, including the cumulative impact of other commercial projects in the pipeline, considering the rise in employment and subsequent housing demand.
Evaluate the jobs to housing impacts and impact on Belmont RHNA. Also analyze the jobs to housing “fit”.
Noise and Vibration
Biolabs require prominent rooftop mechanical equipment for ventilation systems essential for biological containment and odor prevention. These powerful air handling and exhaust systems are much noisier than conventional office equipment. Some of the exhaust stacks for BSL-3 labs can be 30’ tall. Noise attenuation is required to meet noise standards.
The noise impact of these mechanical systems on adjacent properties and the wildlife of Belmont Creek and Slough must be thoroughly evaluated and appropriate mitigation proposed.
Transportation and Circulation
The increase in employment necessitates evaluating the number and timing of daily vehicle trips and their impact on surrounding intersections, Highway 101, and Ralston Avenue, which are already heavily congested. What is the proposed Transportation Demand Management plan?
Evaluate the cumulative impact of project traffic combined with other pending developments in East Belmont and on Shoreway Road. The net increase in greenhouse gasses should also be evaluated within the context of Belmont’s Climate Action Plan.
Utilities and Service Systems
Biolabs with wet laboratories consume 4 to 5 times more water than other uses and cannot utilize recycled water (except for landscaping). The increased water demand compared to current usage and the impact on the local water supply must be evaluated, considering other approved projects as well. It is essential to determine whether the project will have a water budget and how laboratories will be held accountable for their water usage. The impact on emergency water supplies must also be assessed. Labs generate significant amounts of single- use plastics and non-recyclable biohazard waste, requiring specialized disposal and transportation. The anticipated volume of non-recyclable and biohazard waste must be assessed concerning the capacity of local disposal facilities and within the context of Belmont’s Climate Action Plan. A zero waste management plan, including monitoring requirements, should be provided to the City, detailing how the applicant plans to minimize waste to landfill and incineration per applicable regulations
Therefore
- Will R&D labs have a water budget? How will R&D labs be kept accountable for their water usage?
- Should there be a total maximum allowable square footage for biolabs in the DSPU to calculate water requirements?
- How will the water requirements for the project affect the emergency water supply available?
- Will there be a policy that lab water needs will not preempt City residential water needs in drought water rationing? If labs cannot function without water supply, how will the project ensure that residents will not experience water rationing, before labs do, during water shortage periods?
- With water shortages anticipated, the projected water needs of the Life Sciences lab buildings should be carefully evaluated to ensure that water supply will be adequate.
We therefore recommend that the EIR analysis include as the preferred option, a plan that would prohibit the inclusion of any BSL-3 research and/or manufacturing activity in this proposed development, especially so close to the slough that connects to rich habitat and the Bay itself, and include strong mitigations for the handling and monitoring of hazardous waste in disaster conditions.
It is essential that cities examine the potential environmental impacts of biotech labs on the City's public health and safety, environmental sustainability and on its Climate Action Plan (CAP).
Respectfully submitted,
Gita Dev, FAIA
Conservation Committee, Chair
Sustainable Land Use Committee, Chair
Sierra Club Loma Prieta Chapter
1 Connections between laboratory research and climate change: what scientists and policy makers can do to reduce environmental impacts, The Scientists Forum
“... In 2015, the global pharmaceutical industry had a carbon emission intensity 55% higher than the automotive industry
... Given the immense environmental impact of scientific research, a dramatic shift in how research is conducted and supported is necessary to help combat the global climate crisis ... While voluntary programs and individual laboratory initiatives can have significant effects, even greater lasting impact could be achieved through institutional, corporate, and government-level policy changes that incentivize and even require sustainability in laboratory environments.
2 American Laboratory: These shortcomings can be added to a relatively new concern in many locations, that is, the sight of tall exhaust stacks on a building’s roof, which usually imparts negative connotations in a community, in other words, another neighborhood polluter.
3 Rooftop Exhaust Fans: Environmental considerations,
Tall exhaust stacks ...Another consideration when retrofitting or designing new roof exhaust systems includes the aesthetics of stack height. The lowest possible profile not only eliminates the smoke stack look and negative connotations perceived by many people, but may also help conformance to applicable ordinances
4 American Laboratory: Exhaust discharges from BSL laboratories may be highly toxic (or noxious) or both. Their danger to people covers a broad spectrum, which may be mildly annoying to seriously unhealthy. Also, government agencies are continually setting more stringent standards, with allowable exposure limits dropping lower and lower. Obviously there is no room for tolerance with regard to possible contamination from some agents that are exhausted at BSL Level 3 and 4 facilities. In many cases, even if the fumes are not toxic, public tolerance for odiferous discharges has decreased sharply in recent years.
5 Rooftop Exhaust Fans: Environmental considerations, Exhaust re-entrainment can also be affected by building location, with regard to adjacent buildings, as well as prevailing wind and weather conditions. As a result, for both renovations and new construction, wind studies have become important with regard to IAQ, since harmful exhaust gasses must not be allowed to re-enter a building or adjacent buildings.
6 Laboratories for the 21st century Unfortunately, a laboratory is also a prodigious consumer of natural resources. For example, laboratories typically consume 5 to 10 times more energy per square foot than do office buildings. And some specialty laboratories, such as clean rooms and labs with large process loads, can consume as much as 100 times the energy of a similarly sized institutional or commercial structure.
7 The goal should be that R&D projects shall submit a zero-waste management plan to the city, with monitoring requirements, which will cover how the applicant plans to minimize waste to landfill and incineration in accordance with all applicable state and local regulations.
8 Single Use Plastics in the Lab, Climate and Pharma, September 2020