April 20, 2023
Mayor Gee and Members of the City Council
City of Redwood City
Via email: council@redwoodcity.org
Subject: Redwood Life project in Redwood Shores - Sierra Club recommends preserving the existing Westport Specific Plan and not allowing BSL-3 labs
Dear Mayor Gee and Council Members of Redwood City,
The Sierra Club Loma Prieta Chapter’s Sustainable Land Use Committee advocates for land use issues, and the Bay Alive Campaign advocates for the ecological health of San Francisco Bay. We strongly recommend that no Biosafety Level 3 or Level 4 labs (BSL-3 and BSL-4) be built in Redwood Shores or Redwood City.
Recently, the Sierra Club Loma Prieta Chapter organized a webinar, “Planning for Life Sciences Development for Bay Area Cities.” The event featured experts from the Boston/Cambridge area, a historic hub for life sciences in the US, and included biosafety experts. An important fact emerged, with decades of experience in the industry and the growing awareness of the increasingly lethal agents used in high-containment BSL-3 and maximum containment BSL-4 labs, several cities in the greater Boston/Cambridge metropolitan area are reversing or have already reversed their biosafety policies to no longer allow BSL-3 or higher labs in their cities, and more are joining their ranks. Some do not even allow BSL-2 labs. Please see here a partial list of cities and links to their ordinances.
BSL-3 high-containment labs, as defined by the U.S. Department of Health & Human Services,1 work with indigenous or exotic agents with known potential for airborne transmission or pathogens that may cause serious and potentially lethal infections.2 They require complete dependence on mechanical systems that can fail3 through human error, mechanical failure or disasters, as well as safety oversight issues.4 They may work well in institutions that have rigorous scientific safety oversight, committees that ensure an understanding of risks, transparency, regular reporting and inspections, and biosafety procedures for worker, public and environmental safety. Redwood City does not have such structures in place for this responsibility.
We note the following areas of concern regarding the Redwood Life proposed development, as well as concerns about its compatibility with Redwood City’s General Plan and Public Safety Element.
- Sea level rise is a serious problem for this highly vulnerable site. The proposed project sits atop the former Westport Landfill, which reportedly contains undifferentiated waste and has a history of various toxic contaminants.5 The fill has no lining underneath it and sits on bay mud through which groundwater can migrate with sea level rise.
The California Regional Water Quality Control Board, San Francisco Bay Region, is already concerned about the “inherent vulnerability” of this landfill to rising sea level, groundwater rise, and extreme storm events.6
The development proposes driving thousands of additional piles, breaking through the cap of the vulnerable landfill, for new 130’ tall high-rise buildings. Disturbance of the landfill, which is already a concern for water quality, could release toxins into the Bay water which would pollute the Redwood Shores Ecological Reserve wetlands in Belmont Slough.
- The project asks entitlements for Biosafety levels 1 thru 3 (BSL-1, BSL-2 as well as high risk, high containment BSL-3 labs). High-risk, high-containment labs adjacent to sensitive natural ecosystems of the Redwood Shores Ecological Reserve could detrimentally impact the Bay ecology itself. Wildlife and Bay water quality are at risk as Belmont Creek flows through this zone of sensitive wetlands in the Bay. Flooding and seismic events are extremely predictable hazards in this part of the Bay Area, therefore biosafety concerns related to BSL-3 labs are a critical issue.
- Building heights would far exceed Westport Specific Plan standards. Proposed 130’ tall buildings, plus potential 16’ to 26’ tall rooftop mechanical and lab exhaust equipment, would be much taller than allowed in the existing Westport Specific Plan (maximum 53’ heights) and would loom over existing housing. These would also potentially cause shading of wetlands of the Reserve that are vitally important for wildlife.
- The site adjoins residential development. The proposed Redwood Life project would allow high-risk, high-containment BSL-3 labs and animal research labs (A-BSL-3) in proximity to an already mature residential area and the Bayfront, potentially endangering residents as well as wildlife in the slough with unknown, highly infectious agents.
- Redwood Shores, especially this area, has a history of flooding and flood events are increasing with climate change. The proposed changes to the site, including raising the elevations at this site, could result in surrounding residential areas receiving more flooding. Rising ground water is also an increased risk in this low-lying neighborhood.
- The area is in a “high liquefaction” zone per the USGS seismic hazard maps. In a serious seismic event, which is very predictable, lab facilities and, especially, supportive utilities, necessary for containment of biohazardous agents, can be damaged and disrupted causing a biohazard event.
- Reduced setbacks in the proposed plan could constrain future sea level rise (SLR) protection options. It is anticipated that SLR projections will worsen over time. Thus, it is critically important that shoreline developments reserve sufficient setback/buffer zones to accommodate a variety of flood protection strategies that can be strengthened over time, including nature-based and hybrid solutions. A setback of 100 feet or more along the bay edge may be needed for this purpose.7
- Reduced setbacks in the proposed plan would exacerbate noise and air quality impacts on established residential neighborhoods. All biolabs require more HVAC equipment, exhaust systems and emergency generators than office buildings, and are more noisy than other commercial buildings. Indeed, several cities have adopted noise ordinances for labs as well as requiring lab buildings to be set back from residences as much as 500’.8 High containment Biosafety level 3 labs (BSL-3) are required to have additional dedicated air handling units, some with exhausts as tall as 26’, as well as redundant systems to contain highly contagious disease agents. The exhaust air quality can also be an issue for this industry as the air that the labs expel requires high levels of filtration using mechanical filters that can fail to perform perfectly and could exacerbate asthma and other disease risks in neighboring residential areas.9
- Peninsula counties and cities lack oversight policies and powers for biosafety and biosecurity. San Mateo County Environmental Health staff report that they have no authority or responsibility to inspect for biohazards or biohazard incidents, with the exception of the Coronavirus pandemic.10 The State hazardous materials databases, which fire departments and emergency responders depend upon, include chemical and radiological hazards but do not include biological hazards.
- The federal government and the scientific community are expressing increasing concern about proliferation of privately-funded BSL-3 labs where new risky research could be conducted and which are not subject to federal regulatory oversight.11 Concern about these risks of biotechnology is also growing world-wide.12 Allowing the proliferation of these facilities, without proper federal regulation and oversight, presents a significant risk to public safety. It is also incompatible with Redwood City’s General Plan Public Safety Element.13
- Finally, this proposal will seriously exacerbate the jobs/housing imbalance. Redwood Life will bring in about 10,000 new jobs, which will require approximately 6,000 new units of housing to maintain a rough jobs / housing balance. The proposed contribution of $85M will fund about 100 new units at today's high costs of $700,000 - $1,000,000 per unit.14 Redwood Life will just exacerbate the current housing shortage on the Peninsula. Redwood City would be far better off without this huge project.
In summary, it is time for Redwood City to draft an ordinance and zoning classification that considers the unique nature of the Life Sciences industry relevant to its BioSafety Levels and prohibits potentially hazardous, high risk, high-containment labs at Biosafety levels 3 and 4 including animal research labs (ABSL-3 & 4). A Life Science facility is not a typical commercial office; it may include offices, but its core is a biotech laboratory. At the higher biosafety levels 3 and 4, these can contain a wide array of biohazardous materials and experiments posing multiple local and even possibly global threats. Therefore, it is important to recognize that they come with a broad spectrum of risk. This is a safety issue of critical concern for public safety and security, for the environment, and for residents rightly concerned for their families.
For all the reasons given above, we strongly urge you to preserve the existing Westport Specific Plan at this site and also reject the establishment of any high-containment BSL-3 and BSL-4 labs in Redwood Shores and Redwood City.
Respectfully submitted,
Gita Dev, Co-Chair, Sustainable Land Use Committee, Sierra Club Loma Prieta Chapter
Gladwyn d’Souza, Chair, Conservation Committee, Sierra Club Loma Prieta Chapter
Jennifer Chang Hetterly, Campaign Coordinator, Bay Alive, Sierra Club Loma Prieta Chapter
Cc: James Eggers, Executive Director, Sierra Club Loma Prieta Chapter
Dave Pine, Chair, Board Of Supervisors, San Mateo County <dpine@smcgov.org>
Ray Mueller, Board of Supervisors District 3, San Mateo County <rmueller@smcgov.org>
Len Materman, OneShoreline, San Mateo County <Len@oneshoreline.org>
1 https://www.phe.gov/s3/BioriskManagement/biosafety/Pages/Biosafety-FAQ.aspx#biocont8
2 Gao-18-145, High-Containment Laboratories: Coordinated Actions Needed...
3 Boston University, June 1, 2016: “A malfunctioning network switch at BU’s National Emerging Infectious Diseases Laboratories (NEIDL) resulted in a shutdown of parts of the lab’s ventilation monitoring system ... The University has suspended BSL-3 research until the outside engineers review recommended remedial work to prevent future ventilation system malfunctions.” There are many such examples.
4 You should be afraid of the next “lab leak”, NY Times Nov 23, 2021. “....In fact, the most concerning aspect about high-containment biolabs is that, considered as a collective, they may only be as safe as the worst lab among them. A breach or a breakdown at one could imperil us all.”
5 GeoMatrix Consultants. “Revised Discharge Monitoring Plan Westport Landfill Site Redwood City, California,” pg. 9
6 https://www.waterboards.ca.gov/sanfranciscobay/board_decisions/adopted_orders/2022/R2-2022-0031.pdf Oct. 13, 2022
7 OneShoreline’s Planning Guidance Policy, Draft April 2023. Burlingame Sea Level Rise Ordinance, December 6, 2021: “Buffer zones extending 100 feet inland from the San Francisco Bay Shoreline are intended to provide an area to accommodate and maintain built and natural shoreline infrastructure for sea level rise protection, environmental enhancement, and public access trails.”
8 The City of Berkeley has a 500’ setback for BSL-2 labs and does not allow BSL-3 labs. “Commercial Physical or Biological Laboratories: Commercial physical or biological laboratories using Class 3 organisms are not permitted in the MU-LI district. Use of Class 2 organisms are permitted only in locations at least 500 feet from a Residential District or a MU-R district.” Several other cities have 500’ setbacks.
9 “Residential Proximity to Environmental Hazards and Adverse Health Outcomes” December 2011, National Library of Medicine, National Center for Biotechnology Information.
10 In meetings with the San Mateo County Office of Environmental Health and the Sierra Club Biosafety working group on January 9, 2023 and including San Mateo County Supervisor Pine and staff on February 2, 2023.
11 The National Institutes of Health (NIH) formed an advisory working group, the National Science Advisory Board for Biosecurity (NSABB). Two NSABB working group meetings in 2022 and 2023 concerned Biosafety and Biosecurity. In response to concerns over the “problem” of regulatory oversight gaps in privately funded research in Silicon Valley, 2023 draft NSABB Working Group recommendations include expanding regulatory oversight to privately funded research at institutions and private companies. Similarly, the Government Accountability Office (GAO), released its report in January 2023 and repeated its recommendation from a 2009 report for Health and Human Services (HHS) to identify a single government entity to assess the risk posed by the lack of oversight of privately funded research labs.
12 .Managing the Risks of Biotechnology Innovation, Global Health Program, Council on Foreign Relations, January 20, 2023
13 The Public Safety Element addresses those public safety issues that affect Redwood City, and promotes prevention, public education, and emergency preparedness as the approaches that will allow the community to minimize risks to life and property in the event of a disaster.
14 In 2019, the average construction cost of new below market rate housing in the Bay Area was $664,455 per unit...In particular, counties such as Alameda, San Francisco, San Mateo, and Napa have higher average per unit costs than the Bay Area as a whole