301 Shoreway Environmental Impact Report Scoping

City of Belmont Planning Commission
Via email: PlanningComm@belmont.gov

Subject: Comments - 301 Shoreway EIR Scoping – July 16, 2024 Agenda Item 8

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 have investigated extensively into potential health and environmental impacts associated with life science (biotech lab) facilities. As a result of that, the Sierra Club requests that the EIR include a detailed analysis of the potential impacts of this proposed biotech development as it relates to both public health impacts as well as environmental impacts.

Sierra Club is very supportive of the Life Sciences industry and the benefits that it brings to our communities. To educate and raise awareness of the complexities of biohazards and public safety, we have compiled materials for reference of public officials, available at this link: Planning for Life Sciences Development in Bay Area Communities.

A Life Science facility is not your typical office development. It may include offices, but its core is the biotech laboratory which researches a wide array of health issues ranging from the common cold to deadly Coronavirus and Ebola. Therefore, based on the type of research anticipated, they can come with a heightened level of health risk. Life Sciences labs are also one of the more environmentally unsustainable building uses that are being proposed on the Peninsula, entailing intensified water and energy use, waste disposal issues, and animal research concerns.

All Life Sciences labs are required to be rated for their biohazard level. Biosafety levels are standards set for the different levels of contamination, risk, and protective measures needed in laboratories for specific activities. Biosafety levels (BSL) are primarily for the benefit of the workers in laboratories but also raise risk considerations for the general public and the environment. There are 4 biosafety levels; levels 1 and 2 are lower risk and comprise almost all of the biotech research. However, the more esoteric labs researching highly infectious diseases, BSL 3 and 4, involve agents lethal to human life, from Coronavirus and Tuberculosis to Ebola that require very rigorous procedures and specialized high containment buildings.1

Belmont’s Safety Element fails to address these new biohazards. San Mateo County Environmental Health staff, similarly report2 that they have no authority or responsibility for biohazard incidents, except for tracking the Coronavirus. The state hazardous materials data bases, which emergency responders depend upon, do not have a category for these new biological hazards.

Are our emergency responders equipped to address a potential biohazard release resulting from a major earthquake, flooding or power-outage event? Realizing the answer is “NO”, cities around Boston, San Carlos and Redwood City have adopted ordinances banning BSL 3 and 4. The intent is not to discourage business applicants, but to secure public safety, and to ensure the City and County Emergency Response personnel are aware of and can respond to the presence of approved hazardous materials in buildings in an emergency situation.3

Some of the potential environmental impacts of a biotech lab include:

Flooding and Earthquake Liquefaction. This parcel is located adjacent to Belmont Creek and on bay fill, in a high liquefaction zone. The surrounding area has a history of flooding during king-tides, especially when coinciding with storm events, and is subject to earthquake liquefaction. In the event of a fire, flooding, earthquake or any sustained power outage, failure of any one of a number of containment systems could lead to failure of containment systems or release of toxic or deadly pathogens to either the air or water. Any release of toxins adjacent to creeks or lagoons that connect to the bay multiply the public health risk. High-containment labs (BSL3 & 4) and subterranean parking should not be permitted in FEMA flood zones, areas prone to flooding, sea level rise or liquefaction, or in populated urban areas.
 
Energy Use. Biolabs use 5 - 10 times the amount of energy as other traditional offices in order to operate complex equipment, exhaust and containment systems. Therefore, the added energy use needs to be accounted for in the climate action plan. Unfortunately, they often cannot use rooftop solar panels due to many required tall exhaust systems. Lab research also requires the use of natural gas or other types of tanked flammable gasses, and, if BSL3 or 4 labs are allowed, on-site explosion carries the risk of potential escape of deadly bio-toxins.
 
Light at night. Lab buildings often operate through the night. Therefore lights are on 24/7. Given the buildings’ proximity to Belmont slough, a wildlife habitat area, it is important to shield wildlife from light at night. As mitigation, consider automatic shades that are timed to close after daylight hours so that night foragers are not disturbed in their feeding schedules.
 
Noise and Odors. Prominent rooftop mechanical equipment critical to required ventilation systems and, if BSL levels are not regulated, to possible hazardous materials containment, generates noise 24/7 and chemical odors are sometimes generated from extensive lab exhaust systems. Mitigation should include target maximum noise levels.
 
Water Use. If there are “wet” labs, Biolabs use 4 - 5 times more water than other uses, and cannot use recycled water (except for landscaping). The applicant needs to identify anticipated water usage and the City’s water budget should be analyzed to include this as well as the other approved lab buildings that are already in the pipeline to see whether additional emergency water supply is required. The impact of lab water usage on water rationing for residential communities nearby should also be examined. The Climate Action Plan needs to be adjusted for the added consumption.
 
Waste Disposal. Labs generate large amounts of single use plastics that need to be accounted for in the City’s Climate Action Plan (CAP) and waste reduction targets, and also non-recyclable biohazard waste which requires specialized disposal measures and transport on public roads.
 
Animal Research. Will research animals be allowed on site? If this is allowed, Emergency Response teams need to be educated in developing safe emergency procedures for the health and safety of the animals under a disaster scenario.
 

We therefore recommend that the EIR analysis include, as the preferred option, a plan that would prohibit the inclusion of any BSL-3 or 4 research and/or manufacturing activity in this proposed development and include strong mitigations for sustainability items listed as well as the handling, monitoring and transportation of hazardous waste, especially under 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 carbon action plan (CAP).


Respectfully submitted,

Gita Dev, FAIA
Chair, Conservation Committee and Sustainable Land Use Committee
Sierra Club Loma Prieta Chapter

Cc: James Eggers, Executive Director, Sierra Club Loma Prieta Chapter
Jennifer Hetterly, Bay Alive Campaign, Sierra Club Loma Prieta

1 98% of biotech research involves BSL 1-2. Only 1 - 2% of all labs worldwide are BSL-3 or 4 labs and there are many more places in the world more suitable for these higher-risk laboratories than in a high population region such as Belmont

2 In an interview with the San Mateo County Office of Environmental Health and the Sierra Club Biosafety working group

3 98% of biotech research involves BSL 1-2. Only 1 - 2% of all labs worldwide are BSL-3 or 4 labs and there are many more places in the world more suitable for these higher-risk laboratories than in a high population region such as Belmont