1 DRAFT FOR COUNCIL REVIEW
Port of Oakland
Environmental Programs and Planning Division
Colleen Liang
530 Water Street
Oakland, CA 94607
SUBJECT: OAKLAND INTERNATIONAL AIRPORT TERMINAL MODERNIZATION AND DEVELOPMENT PROJECT DRAFT EIR (SCH#: 2021050164)
Dear Colleen Liang,
The City of Alameda is in receipt of the Draft Environmental Impact Report (EIR) for the proposed Terminal Modernization and Development Project (Project), released for public review in July 2023. We appreciate the cooperation the Port of Oakland (Port) shows when the City and Port have mutual interests regarding transportation, environmental protection, infrastructure development, and other elements of our shared proximity, such as coordinating on projects addressing sea-level rise adaptation measures, water shuttle and bike/ped bridge studies, and the noise forum for addressing airport operational impacts to Bay Farm Island residents.
The City also appreciates the continued cooperative efforts to comply with the various settlement agreements and monitoring programs related to community noise and other shared interests and impacts of the airport and believe this project may warrant amendments to those agreements based on the passage of time and the expanded scope of the Project and overall airport operations.
The City recognizes the important role of Oakland International Airport (OAK) in connecting our region to other parts of the state and the nation and in supporting the regional economy. For the Project to be successful, the EIR must adequately identify environmental impacts to surrounding communities and offer reasonable and feasible mitigation. In particular, the noise, air quality, safety and ground transportation impacts to Alamedans may require additional measures to reduce them as much as possible. To that end, the City offers the following comments on the DEIR:
• Assumptions. Fundamental to the EIR analysis is the stated assumption that the passenger and freight activity will increase whether or not the Project proceeds (see for example pages 2-6,
3.1-1, and 4-11). This assumption leads to conclusions regarding impacts, mitigation measures and alternatives that justify expanding the number of terminals and reconstructing and modernizing major portions of the airport. Therefore, the impacts of that increased activity are at least indirectly related to the physical Project that is proposed and should be the subject of the analysis in the EIR. In other words, “but for” the Project, the increased activity and related impacts would not occur or would be lessened, and therefore the project description and the alternatives analysis should be revised, and then the impact analysis should be reconsidered so that reasonable and feasible mitigation measures can be formulated. • P
otential Impacts . The City is concerned about the proposed Project’s potential impacts to the community, including noise, air pollution and safety, as follows:
2 • Noise Impacts. Although noise contour maps show that there would be no residences within the 65 CNEL contour under future project-based conditions, the methodology does not account for single event noise, night-time noise, resulting in sleep disturbance and interference in regular enjoyment of indoor and outdoor environments, and other sensitive receptors such as schools, churches, and hotels. Using an average noise level calculated over the course of an average day from an average year does not accurately represent the noise impact of OAK. The noise analysis must also discuss the impacts from frequency of overflights, single-event noise levels, the altitude of aircraft, the hours of operation, and impacts from low frequency noise, all of which are documented environmental impacts from the airport on surrounding communities. • Air Quality Impacts. Air quality and greenhouse gas impacts are analyzed as if the flights were part of the Project (impacts are determined significant and unavoidable, and beyond the ability of the Port to mitigate). This indicates that the activity is part of the Project and should be evaluated as such, with appropriate mitigation and could include provisions for more alternative fuels. We note that the measurement stations for existing conditions are located in Oakland, some distance from the airport and not reflective of the communities that are most directly affected. Impact assessment should be based on more precise and meaningful analysis.
• Safety Impacts. Safety of the community is addressed in passing on page 3.8-24 of the Draft EIR. The City has adopted the Safety Element as part of the Alameda General Plan 2040
(*https://irp.cdnwebsite.com/f1731050/files/uploaded/AGP_Book_June2022_Amend-
1.pdf). The Element includes an overriding objective to “[p]rotect Alameda residents from the harmful effects of exposure to excessive noise from aircraft, buses, boats, trucks and automobiles, and adjacent land uses.” The objective is followed by numerous policies and actions, many of which address aircraft noise, as well as safety and air quality impacts. These should be noted in the EIR and addressed as criteria in the Land Use and Planning chapter and other chapters that address impacts to the City in light of the designated Airport Area of Influence (see Figure 7.4 of the Element). • Transportation Impacts. Alameda has an adopted General Plan that includes a Mobility Element with programs to reduce vehicular travel in order to improve the environmental impacts, safety and convenience of an equitable multimodal transportation system. The EIR does not address conformance with any of the policies and actions contained therein. Furthermore, the assessment minimizes the effects of the project on Alameda roadways, residents and visitors, particularly related to the Maitland parking lot. Aside from traffic impacts, the EIR should evaluate noise, light/glare, and air quality impacts of that location and consider alternatives.
The City offers these comments in the spirit of cooperation to ensure full disclosure of the impacts and reasonable alternatives so that the community can participate in a dialogue with the Port about the impacts and potential mitigation measures that would address reasonably foreseeable impacts of the Port’s actions. We request that the Port provide detailed responses to each community comment and provide a forum for addressing impacts that are directly and indirectly related to the Project, i.e. those measures and alternatives that could further the goals of the Project while also minimizing impacts to Alamedans.
3 Please also confirm that the Port remains committed to continuing the Airport Noise Program and ongoing stakeholder outreach, as well as advocating on behalf of the airport communities with the Federal Aviation Administration to address noise concerns. We request that the Port meet with community stakeholders to discuss the project and how to minimize its impacts before certifying the EIR.
Additionally, the City formally requests that the Port of Oakland enter into an interagency Memorandum of Understanding (MOU) with the City to update and memorialize the existing terms of prior settlement agreements in light of the changes in circumstances over the past 20 years and looking forward to ways the Port and City can coordinate and partner over the upcoming decades.
We look forward to collaborating with the Port to ensure that community concerns about the Project are fully addressed.
Sincerely,
Jennifer Ott
City Manager