August 4, 2024
Ms. Corinna Sandmeier
Principal Planner
City of Menlo Park
via email to: cdsandmeier@menlopark.gov
Re: Comments on Draft Environmental Impact Report, Parkline Project
Dear Ms. Sandmeier,
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 submit the following comments for the DEIR for the Parkline project at the old SRI site. The Parkline project is a wonderful opportunity to transform the heart of the City. While we share the general concerns about traffic and housing, we wish to focus here on the mix of uses proposed for this infill site, in particular the mix of housing with research labs.
Life Sciences have brought many benefits to mankind and the industry is important to the Peninsula. Biomedical researchers around the world work every day to improve global health. The Sierra Club is very supportive of the industry. However, Life Sciences labs, at the “high-containment" levels, are researching dangerous and, frequently, lethal pathogens. This can be dangerous and should not be mixed with housing.
Life Sciences labs are rated for biohazards with safety ratings ranging from biosafety levels 1 through 4 (BSL-1 thru BSL-4). While the majority of BSL-1 and BSL-2 labs are not all that different from commercial office buildings, at biosafety levels 3 & 4 (BSL-3 and BSL-4) they can be dangerous as they are working with extremely dangerous pathogens. It is of great concern that, while SRI accommodated biohazardous research on their campus in the past, the same is now being considered in a Mixed Use setting with residential buildings in close proximity to potentially highly infectious disease research facilities.
In addition, in the DEIR, biotech labs should also be recognized as one of the more unsustainable building types on the Peninsula.1 Given that Climate Change is a serious and growing concern, mitigation of these environmental impacts takes on greater urgency.
1. Aesthetics
BSL-4 labs at University of Texas at Galveston
Exhaust stacks on rooftops are required for all levels of biolabs. BSL-3 and BSL-4 labs require more effective advanced mechanical systems to maintain negative air pressure to contain and safely exhaust highly infectious, often lethal pathogens. BSL-3 labs research airborne diseases, these can sometimes be more difficult to contain.
Exhaust vents similar to Albany Medical Center, shown here, 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
Screening requirements should include the restrictions on exhaust systems.
Verify the height requirements for BSL-3 lab exhaust systems to provide appropriate mitigation for extreme height requirements and ensure these are screened from view.
2. 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 lab areas at uninterrupted negative air pressure with “fail safe” requirements, in order to safely contain and safely exhaust highly infectious, often lethal airborne pathogens. However, these systems are vulnerable to mechanical failure and human error. 4 5 The fact that BSL-3 labs did exist on the SRI campus is not a sufficient reason to continue this practice when allowing Mixed Use. The inherent risks are compounded with the public moving onto and through the campus, and housing being allowed on the site. With appropriate protocols and oversight, which, unfortunately, is not always available for private labs, infectious disease sources need to be located at least 1⁄4 mile distant from any sensitive receptors.
San Mateo County Emergency personnel reportedly are not trained in biohazards and the State databases that they depend upon also do not include the biohazard information that they might need.
If BSL-3 labs are included on the site, provide separation of 1⁄4 mile for sensitive receptors, and robust requirements to attempt to notify and alert residents of any BSL-3 level accidents endangering the residential community, along with training for San Mateo County Emergency Response teams in BSL-3 biohazard accidents and clean up. Also include mandatory immediate notification requirements for the public entering the site.
Mitigation for longer periods of power outage, as could be increasingly experienced, are not sufficiently covered by the emergency generators provided.
3. 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 mechanical equipment and numerous tall exhaust stacks required. It is essential to include and evaluate the energy consumption, assuming potentially 100% of the commercial space will be labs, within the framework of the City’s Climate Action Plan.
Provide appropriate mitigation based on these revised calculations and assumptions.
4. Greenhouse Gas Emissions
In addition to traffic-generated GHG, we note that there will be emergency generator requirements. Gas powered generators are less polluting than diesel powered generators. However, if BSL-3 labs are allowed and animal research labs are allowed, then we question whether there is sufficient emergency power. We can anticipate longer outages than normally experienced in the past and outages also tend to coincide with disaster events.
In addition, electric battery storage is becoming rapidly more economically viable. These are less polluting and quieter in a residential neighborhood. Microgrids can be combined with battery storage for energy conservation and GHG reduction.
Do we need longer emergency generation periods if BSL-3 labs and animal research labs are allowed, in order to reduce risk?
Should a microgrid be required in order to provide more resilience to the system? Will solar panels be required on site as part of a microgrid?
Will electric battery storage be required, instead of only gas powered generators, as mitigation for the amount of emergency generators being used and for the noise considerations near housing?
5. Hazards and Hazardous Materials
In addition to the hazards of allowing BSL-3 labs, live animals in research present a particular hazard for the environment and for a Mixed Use campus. The provision for their care, handling, disposal, and, in particular, basic requirements for their containment, health and safety during disasters and emergencies need to be spelled out in the DEIR.
Include discussion of this issue in the DEIR. In particular, provisions need to be included for the health and safety of the animals in the event of disasters or prolonged utility shutdowns. Please include careful and clear requirements, in the mitigation, if live animal research is an allowed use on-site in this Mixed Use site in the center of the City.
The use of natural gas or other flammable gasses in laboratory research includes the potential release of toxins in explosions. This is not adequately addressed for BSL-3 labs where infectious agents may be located in proximity to other labs with flammable gasses.
Include discussion of this issue in the DEIR. In particular, provisions need to be included for immediate alerts and notifications to residential neighbors within a specified radius in the event of accidents. Mixing housing into uses that were previously confined to Industrial Zoning requires certain responsibilities for alerts and notifications to neighbors in the interest of reassurance as well as security and public safety.
6. 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 can be 30 ft tall. Noise attenuation is required to meet noise standards in proximity to Mixed Use facilities.
With residential buildings that are closer than 1⁄4 mile from lab buildings, mechanical equipment will need more serious sound attenuation than the sound attenuation provided by normal acoustic screening. Appropriate sound attenuation would probably include solid concrete panel enclosures.
For noise mitigation, provide clear standards for sound mitigation for mechanical equipment, both rooftop mechanical as well as emergency generators, with the difference that there are multi-storied residential buildings adjacent to biolabs.
7. Utilities and Service Systems
- Water: Biolabs with wet laboratories consume 4 to 5 times more water than other uses and cannot utilize recycled water (except for landscaping). 7
Biotech research and manufacturing rely heavily on water for many uses: chemical reactions, refrigeration, cleaning and irrigation. Sustainability goals require ambitious - and measurable - standards.
The increased water demand compared to current usage and the impact on the local water supply must be more carefully evaluated, considering other projects in the pipeline for approval as well. It is essential to determine whether the impact that the project will have, with a 100% lab scenario, is acceptable for the overall water budget.
In this era of water scarcity, the impact on the City’s emergency water supplies must also be assessed.
Therefore
- Will the Parkline project have a water budget?
- What would be a total maximum allowable square footage for biolabs in the project OR what is the total allocation of water for biolabs. This is necessary 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?
- Waste: Labs generate significant amounts of waste and particularly single use plastics.8 Biomedical researchers work every day to improve global health. However, as part of this work, modern labs use and discard a significant amount of single-use plastics, most of which ends up incinerated, in landfills. Research scientists have largely gone unnoticed as major users of non recyclable material. Usually, laboratory waste plastics are bagged and “autoclaved”, an energy- and water-intensive sterilization process often using pressurized steam, and then they are sent to landfill. Labs are under pressure to decrease their waste because the reality of increasing plastics pollution is outweighing their convenience.
“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 (were used before) – sometimes for good reason.” 9
Government and City policies are critical to reducing plastics usage. In California, the single-use plastic bag ban, which went into effect nearly a decade ago, has already reduced the use of plastic bags by 70% in the state.10
Mitigation requirements should include a waste management plan provided to the City, including monitoring requirements, detailing how the project applicant plans to minimize waste to landfill and incineration and to meet Climate Action Plan goals. 11
- Deliveries and Loading areas: It is well understood that labs frequently have to operate all night and that labs are very dependent on multiple deliveries and other outside services. For this reason, such activities need to be restricted to daylight hours in proximity to residential neighborhoods and in Mixed Use areas where residential buildings are allowed.
As mitigation, service, delivery and pick up hours should be limited to daytime hours and service driveways and entry areas located away from residential buildings.
- Light at night: Lab buildings often operate through the night with lights on all night. Lab buildings that face residential or Mixed Use buildings should also be required to provide shielding at night such as automatic shades that are timed to close after daylight hours so that residents can get rest and landscaped areas are allowed to be generally darkened except for wayfinding lighting directed downwards.
As mitigation, because biotech labs often require operating through the night, require automatic shades that are timed to close after daylight hours for facades facing residential areas and all landscaped areas which provide habitat for nature, including insects, to respect the diurnal cycles of nature.
In summary, we also recommend that the DEIR include the following.
- A recommendation that BSL-1 and BSL-2 labs are a conditional use if it is within 1⁄4 mile of residential property, schools, community centers or creeks in order to have an orderly process to address issues of safety as well as noise, lights at night, alerts, deliveries, animal lab facilities, smells from exhausts, transport of potentially hazardous agents, and other concerns residents may reasonably have.
The intent is not to discourage business applicants, but to secure public safety in a Mixed Use area and to ensure the City and County Emergency Response Team personnel are made aware of and are trained to respond to the presence of approved hazardous materials in buildings in an emergency or disaster situation. - A recommendation that BSL-3 & BSL-4 research labs are not allowed in this proposed infill Mixed Use development, in the center of the City, for public safety reasons.
Nearby cities have recently restricted BSL-3 labs from all parts of the city (San Carlos) or from Mixed Use neighborhoods (Redwood City Downtown area). It is essential that the City examine the potential environmental impacts of biotech labs on the City's public health and safety as well as its environmental sustainability and on its Climate Action Plan (CAP). We believe it could be helpful to review the following documents.
- “Guidelines for BioSafety Labs”, Sierra Club Loma Prieta, Sustainable Land Use Committee, specifically to help decision makers plan for biotech labs
- Redwood City’s Amendments: Conditional Use Permit for Research and Development (page 10) that addresses these issues for Mixed Use neighborhoods
- Menlo Park’s Life Sciences District ordinance and include appropriate mitigation for the RBD-SPU sustainability concerns that are addressed
Thank you for the opportunity to comment on these important issues in the DEIR. We look forward to continuing to work with the City on this transformational infill Mixed Use project in the heart of the City.
Respectfully submitted,
Gita Dev, FAIA, Chair
Conservation Committee
Sustainable Land Use Committee
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, an 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 Biotech’s (other) Liquidity Problem: The area's most prized industry is the biggest contributor to water scarcity. Boston Business Journal. Nov. 2023
My Green Lab “It might surprise you to learn that laboratories can use a lot of water. Cage washers, autoclaves, DI water, and single-pass cooling all contribute to the substantial water requirements of many labs.”
8 Can Laboratories Curb Their Addition to Plastics? The Guardian
9 Single Use Plastics in the Lab, Climate and Pharma, September 2020
10 We are Drowning in Single-use Plastics. Here’s Why and What We Can Do About It.
Univ of Colorado, Boulder, April 2024
11 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.