HomeMy WebLinkAboutAgenda Bill 4ALate2 12/21/2009From: Tom & Kris Brown [katchat@sonic.net]
Sent: Monday, December 21, 2009 1:35 PM
To: - City Clerk
Subject: Dutra Asphalt - NBRC Itr Sonoma County BOS 2009-12-13.pdf - Adobe Reader
Attachments: Dutra Asphalt - NBRC Itr Sonoma County BOS 2009-12-13.pdf
Importance: High
Attn: City Clerk,
Please add the attached letter of 12/13/2009, from North Bay Rowing Club to the Sonoma County Board of Supervisors,
to the record of comments on the revised Dutra Project at Haystack Landing for tonight's meeting of the Petaluma City
Council.
Thank you,
Tom Brown
President, North Bay Rowing Club
x A f S
i
O ` Z ' a ,.
December 13, 2009
Supervisor Paul Kelley, Chair
Sonoma County Board of Supervisors
575 Administration Drive, Room I OOA
Santa Rosa, CA 95403
Re: PLP04-0046, Dutra Materials, Inc. Comments on revised Haystack Project
Dear Chair Kelley and Members of the Board of Supervisors:
North Bay Rowing Club (NBRC) is a Petaluma -based non-profit corporation formed to promote
the sport of rowing. Our facility at the foot of 2°d Street in Petaluma supports approximately 75
adult members from all over Sonoma, Marin, & Napa Counties, a Juniors Program with 20 local
high school athletes, and the 48 athletes who comprise the Sonoma State University Rowing
Club. Rowers are typically on the water every day of the week, usually in the morning, with the
SSU Crew typically currently convening at 5 a.m.
NBRC has followed this project since reviewing related documentation last fall. NBRC has
reviewed and rejects the revised project in accordance with prior correspondence incorporated by
reference and attached below. While your Board imposed Conditions of Approval that resolved
two of our concerns (#108, which prohibited the proposed moored barge from blocking any
portion of the navigable channel; and #138, which requires the operator to meet with NBRC to
ensure no conflict with our annual regatta), the Applicant now requests your Board to remove the
restriction against the barge blocking any portion of the navigable channel. After investigating
the justification for the latter, our concern for safety on the river, ongoing ability to host a
regatta, and the long-term health of athletes is now greater, not smaller. I will address these in.
turn.
Hazard to Navigation: Allowing a Barge to be Moored in the Navigable Channel
We appreciate that.our request of October, 2008 to seek the opinion of the US Coast Guard and
upstream barge ope'rators about the navigational hazard presented by a barge moored at Haystack
Landing has been heeded. However, the manner by which the determination of navigational
hazard was sought, from those parties makes their conclusions problematic because the record
shows that the width of the navigable channel was consistently misrepresented to be wider than
authorized. We therefore contend that the argument to modify your Condition of Approval to
allow the Applicant to moor their barge within the navigable channel cannot be sustained.
P.O. Box 192 Petaluma, CA 94953 a Boathouse at Foundry Wharf
The Authorized Federal Navigation Channel in the Petaluma River, as verified by my personal
communication on or about Dec 1, 2009 with Steve Chesser, Dredging Program Manager, US
Army Corps of Engineers, San Francisco District, is 8' deep by 100' wide by 14 miles long.
In contrast, Steve Padovan's staff report in the packet for this hearing states the dredged channel
varies between 100' and 130' wide in this reach: "The revised plans, attached at the end of the
applicant's September 15th letter under EXH-3, indicate that the barge will encroach up to 50
feet into the dredged channel, which varies in width from 100 to 130 feet in this part of the
river." (PLP04-0046, December 8, 2009, at Page 11). Having been advised by the Army Corps
of Engineers on this topic, we contend the dredged channel is limited in width to 100 feet.
The story presented to the US Coast Guard appears consistent with Mr. Padovan's apparently
incorrect statement. Captain Gugg, Captain of the Port of San Francisco, in his letter regarding
this project dated November 24, 2009 states: "Based on review of your updated proposal, it does
not appear that the additional 20 foot encroachment into the channel will create any significant
navigational hazard..." The record of Applicant's meetings with the USCG indicates that an
initial proposal, assuming the barge could be moored in a location recessed into the riverbank,
would leave 107 ft of clearance. When it was determined by the Applicant that it was infeasible
to cut a berth into the bank, USCG was approached a second time with a proposal that indicated
86' of clearance. This provides the basis for Captain Gugg's reference to an additional 20 foot
encroachment into the channel. In both cases, however, the clearance identified was measured to
a point well beyond the edge of the Corps Channel, only 50 feet away. Although the Corps
Channel is clearly called out in the Applicant's submittal for this current (BOS) hearing (EXH-2
on page 9 of Exhibit B), it is delineated but not called out on either of the photomaps that were
provided by the Applicant to the USCG. The two USCG letters, photomaps provided by the
Applicant to the UCSG in support of these letters, and Applicant's EXH-2 are provided below as
Appendix A to this letter.
We contend that the Corps Channel, the only portion of the river authorized to be maintained at a
depth suitable for commercial operations, is the only reference relevant for making a long-term
determination about the effect of a moored barge on navigation.
Furthermore, inspection of Applicant's drawing labeled EXH-2 makes it clear that it will be
difficultto avoid bank erosion and damage to Mr. Yee's property by tugs as they operate when
positioned at either end of the barge at its indicated moored position. To minimize the risk of
damage, it may be necessary to moor the barge even further into the channel than depicted,
which would further aggravate its navigational hazard.
With regard to the effect of the moored barge upon upstream commercial traffic, the Applicant
produced letters from Westar and Jerico stating that the moored barge will not reduce
navigational safety.
Westar's letter, dated 5 Oct 2009, indicates their finding is based upon a copy of "Corps Federal
Channel Exhibit 14," which "...Calls out a distance of 107 feet to the opposite edge of the actual
NBRC: Comments on Revised Dutra Project PLP04-046 Page 2 of 6
channel." Perhaps Westar's conclusion is based upon the same photomap provided to the USCG
in February, 2009 — the one based upon a mooring location later abandoned for being infeasible.
Regardless, the 107 ft clearance assumed by Westar is greater than either the 50 ft distance to the
edge of the Corps Channel or the 86 ft distance called out in EX14 Navigable Channel Exhibit
relied upon by the USCG in their letter of 24 Nov 2009. Therefore, Westar's conclusion
regarding navigational safety is useful only for documenting that they were provided incorrect
information upon which to make their finding.
Westar makes further reference to two other nearby channel constraints. One is the approximate
107 ft distance from a barge moored at the Shamrock Offloading Facility to the opposite edge of
the actual channel. This presents a different situation, though, as the barge moored at Shamrock
is on the inside of a turn in the river, not on the outside as Dutra's barge would be. The
momentum of a flat -bottom barge being turned will naturally carry it to the outside of a turn,
away from anything on the inside. The other constraint mentioned is the Petaluma Railroad
Bridge, with only 54 feet of clearance. That this is a tight squeeze is evident by the battering,
and sometimes breakage, sustained by the timbers that guard this bridge.
Jerico Products, Inc., in a letter dated November 12, 2009, also states that a barge moored at the
position proposed by Dutra will not present a navigational safety hazard to their operations.
However, this conclusion is conditioned by the requirement that "...Jerico is the exclusive Tug
Boat service provider for Dutra's barges (with the sole exception of the Dutra Tug `Sarah
Reed')..." Jerico indicates that it will need to "...Manage the location of Dutra's barges in
relationship to other barge traffic on the river." Jerico's letter states they will have a 20-year
marine services agreement with Dutra and three five-year extensions. Jerico also states that
recreational boats will not be obstructed or face a navigational hazard.
NBRC interprets Jerico's statement in several ways. First, Jerico stands to benefit financially
upon a vote in favor of the Applicant's proposal by your Board: they are not a disinterested
party. Second, their management of Dutra's barges as suggested indicates the potential for
multiple docking operations for any single barge visit. Each of these, if conducted during a time
rowers are in the vicinity, will obstruct rowers, for they generally must wait for tug operations to
be completed before being able to safely transit the same water. Finally, Jerico's contention that
these operations "...Will not obstruct or present a navigational hazard for other ... ... recreational
boats..." is not one that we agree with.
The extenuating circumstances described above that pertain to the manner by which letters were
obtained from USCG, Jerico, and Westar to indicate the barge moored as proposed by the
Applicant will not pose a navigational hazard gives us no assurance that our needs, and those of
the public, are supported.
However, on December 7, 2009, we had the surprise of receiving a telephone call from LT
Mausz, USCG, who serves the Captain of the Port of San Francisco as Chief, Waterways Safety
Branch. She called to inquire about the safety concerns of rowers, and offered to visit Petaluma
next week to gain first-hand knowledge.
NBRC: Comments on Revised Dutra Project PLP04-046 Page 3 of 6
Safety to Rowers
During the intervening period since the last hearing, our, concern for the hazards of increased
barge traffic were amplified when two boats with me and other highly experienced rowers
aboard were forced to the bank of the river opposite the proposed mooring site of the Dutra barge
on a falling tide and had to retract their oars to avoid damaging a passing barge. Had our rowers
been less experienced, or the tug crew further constrained in this twisty, narrow reach by a barge
moored as proposed by Dutra, the outcome could have been disastrous.
The safety issue posed by a barge moored at the Dutra site is more than that of just a stationery
obstacle, and additional barge trips. Some of the additional problems we foresee include:
0 Extended additional tug operations, with attendant turbulence and blocking of the river
(for safety, fragile rowing shells must almost always hold until tug crews complete their
operations before proceeding).
o Unlike the long straight sheet -pile -lined facility at Shamrock, Dutra's site is on a
curve that cannot be easily approached by a tug from either direction, thereby
requiring more time and skill for safe maneuvering.
o Jerico indicates they may have to move barges at the Dutra site to accommodate
upstream traffic. This would entail additional blocking of the river while extra
mooring operations are conducted, and it is possible that temporarily relocated
barge(s) may obstruct the river in other locations by an amount that exceeds
current practice.
0 Uncertain Mooring Duration: Although Dutra barges are expected to be unloaded within
four hours (USCG letter), the amount of time they may remain moored, and thereby
obstruct the channel, is unlimited.
0 Higher Frequency operations (more than two barges per week): During times when a
continuous, high volume supply of asphalt will be needed to support large contracts.
0 Generation of Boat -wrecking debris: Mr. Yee's docks,, and possibly more, will likely be
reduced to floating debris in short order.
0 Health Impacts: Rowers, when training hard, draw large volumes of air deep into their
lungs. With regard to tug operations, it is unclear if BOS Conditions #21 and 124, which
describe low -emission requirements for tugs, will extend to and be enforced for tugs
supplied by an entity other than Dutra. As the tiny particulates in diesel exhaust are
known to be detrimental to human health, and to lodge deep in the lungs, we appreciate
and wish to ensure the Board's low emission requirement will extend to all tugs
associated with this project. We are additionally concerned about the significant impacts
related to noise and air quality described for this project that would apply to people on the
river.
Lighting: the bulk of training for the collegiate crews on this river occurs in pre dawn
conditions of low light, if not total darkness during winter mornings. Exterior industrial
NBRC: Comments on Revised Dutra.Project PLP04-046 Page 4 of 6
lighting, if not carefully designed, can easily cause glare that prevents rowers and
coxswains from spotting boat -damaging debris the surface of the water alongside the lit
facility, and beyond, due to impaired night vision. The glare from industrial lighting
would overwhelm the navigation lights displayed by rowing shells, making them more
difficult for other river traffic to see.
Among the documents provided in support of the. Dec 8 BOS Hearing, the only statements
regarding navigational safety for non commercial users we noticed were provided by Jerico and
Christopher A. Joseph Associates. Both state there will be no problems for "recreational" users.
Prior to'December 7, 2009, when we received a telephone call from LT Mausz, USCG, neither
they, nor anyone else, sought our opinion. Jerico at least is fully aware of the presence of rowers
and goes out of their way to accommodate us. Until one has operated a small, unstable rowing
shell on a working river, though, it is difficult to comprehend the inherent safety issues.
While racing shells have been rowed on the Petaluma River since at least 1910, most non-
commercial activity is outside of the rowing that provides the specific perspective for this letter.
Examples of other such river users include many fishers, kayakers, four Hawaiian outrigger
canoe clubs, miscellaneous recreational boats of all types, and yacht clubs from all over the Bay
Area that schedule weekend visits to downtown Petaluma throughout their season.
Protection of NBRC's Wine Country Rowing Classic
We request assurance that your Board's Condition of Approval to .protect our annual regatta will
remain in effect even if tug boat service is assigned by contract to a non-Dutra operator, or if
Dutra is providing asphalt for a contract that calls for 24/7 operations. We refer to Condition
#138: "The operator shall meet annually in advance with the North Bay Rowing Club to ensure
that project related barge operations do not conflict with their annual club event."
Summary
NBRC urges the Sonoma County Board of Supervisors to deny this project unless it is modified
to effectively address the 'issues noted previously and above, to wit:
® Condition 108 remains unchanged such that the moored barge may not block any part of
the navigable channel;
m Condition 138 applies regardless of whom supplies tug boat service, and asphalt supply
requirements on the day of the regatta;
® Conditions 21 and 124 regarding low emission engines apply regardless of whom
supplies tug boat service; and
® Noise and air emissions are reduced to less than significant levels for people on the river.
NBRC: Comments on Revised Dutra Project PLP04-046 Page 5 of 6
Thank you for your consideration.
Sincerely,
Tom Brown, President, North Bay Rowing Club
Attachments:
Appendix A: USCG Letters of Approval and Applicant -Supplied Clearance Data
NBRC Letter to PRMD dated October 3, 2008
NBRC Letter to Supervisor Paul Kelley dated February 3, 2009
NBRC: Comments on Revised Dutra Project PLP04-046 Page 6 of 6
APPENDIX A
USCG betters of Approval and Applicant -Supplied Clearance Data
First letter offered by USCG,-
U.S. Department -of Ccnnnander
Homeland Security Sector San Feanr,sCo
United States
Coast Guerd
CSW,'Stuber-5troch Fngineering Group. Inc
Attn: Mr. Al Cornwell
45 lx%uroni Coun
Novjw. CA 94949
De'Ir Mr, C ol-IIIvcil:
i Yerha Buena Islana
San Francisco, CA 94130
Pnooe: t41 t1) 399-7436
Fax (415) 399-7440
16610
I V7is Is In response to your request of l ebzuttry 2 -,.'_t109 Concerning the proposed harge off-load
faciiitY near I lay,:tack Landing on the Petaluma River.
It is understood that the proposed facility replaces a previously used barge off-load t<tcilio- that
was located approximately one-half mile upstream of the proposed facility. The new facihl\ will
occommodate barges up to 4.000 tons, and approximately SO feet wide by 200 feet long. Barges
will iew e the Sari Rafael Rcki, Quarry facility at Point San Pedro and be I(Med to the Haystack
landing facility whera they will he unloaded. Utiluadint operations �-ill take approximately four
hours 4sith an avenafte of two harge trips per, week.
four propo,,ll dues nol appear to Create anti natigaiional ha,.lyd.s io I have no objection III the
hak iht% provided .'ou comply I ith all federal, State, and local requirements.
I'lease note ttlat this determination does not attest to the idequc,cy ot'picr-side depth or moorintt
fixtores since the berths.arC privately oetitled and maintained, Mis letter should riot he Construed
as a Coast Guard endorsement or recommend'tsti<n of these berths.
IC you havt,asty qu"tisins or rcyuire further assistance- please: contact the Chicf of my WatenvaN s
k'tanageniew Division, LiCtttl'ndnt Conrrminder Kevin Mohr, directly It (41 5) 399-7401 . -
/,..�ilnCe;CCIY.
`i
OUGG
t'aptatn, 1'. S. t.:oasi (1u<ard
C aplain ofthe Port San Franc•ik�co
Copy': t_ ,A)l I (dpw)
( T' Vessel l raflic `»crvice San l-'r nosco
NBRC: Appendix A (USCG Information) Page I of 5
Photomap supplied to USCG, indicating 107'of clearance, in support of initial request for
finding regarding a hazard to navigation:
Second (current) letter from USCG concerning hazard to navigation:
U.S. Department of
s!�R,it
Homeland Security ' ->.'
United States
Coast Guard
Commander
united Statos Coast Guard
Sector Sun F17n 3co
CSAQ Sauter-Stroch Lingi evMg (kottp. Inc.
Attn: Mr. Al Corltwcll
45 Lcv�troni Court
Novato. CA 949=19
Ikar :sir:
Yenta nuena Island
San Francisco, CA 94130
Phone: (415) 399-7443
Pax: (•1?5) 399-7480
16610
I his letter is in response to your revkcd request of (kno ber 01 2(MQ rtntrerrW, the• proNwl
l Irt:r ot), 1wid tacililt near I layystnek I,an+ling (-in the 1'etrhona kk(!r.
h is tnrdcl,"lood the propw<cd facility rel)laces a prvvitmsly usad harae t)1`I'WmW fatality that "As
It wal a{) mminmtc;ly,lueWfmilc upstream t)f &v pro)posm! llacihty l he new Nuilitt will
:tccvmntt.ul,ut° h;upm tll, to 41MO lvm and :altprWnalcly 50 Wet wWc by 200 Oct long. Barges
%%ill lease the'an Ritf(tel Rml (7wml at Point San 14dw and he ttmvd to the l laymnk 1-andian:
Wilit) where they will he unloaded. NOW, uperatitms still We appoArnawly ii)ur how-s
with an avcra e of two har'g4 trips lter %\cck.
Based on rcvic\v t)f vi)ur updatcd.I.tropu:al. it docs not ;appear that the additional ?U 1i)oi
encroachment into the channcl will create Any sig"nificant navigational hazard: thcrel'ore. I helve
no objections to the facilities mooring arrangement. Inovided t'Otl ec)ntply tVilh all Federal. Stag.
anti lt)cal rcyuirernenis.
I'1 asc noic that this dcict-min.nio,n dt)es rlru attest tt) tile adecluacv 0l'l')icr Side drltth ur 1110orilt',
f fixture:: See the berths axe priv ely owned anti maintained. 'I iris leticr shold'd not )c construed
-is a Cvar:t (ivard entlorsentent 01' rectmrntendutit)n of these berths.
!! etas bare am iµlcsut)ns or ra{afro lurillcr..tssistance; 1)lcasc contact Lieutenant Simone -Mausz
of, Illy W"w:-'tvays S awly st:twat tit 15) 399- 443 t)r e-mail at shmonc,tnuu0pamc;_r.mil.
Sill CWY--
q I'.��i/�C;tliili
tiilt. ( �. Coastera<t (laded k I)t
t al)1aiit 11m.1 S"m 1'rUttCli;ir'
t apt: C601 I tdpttl
CI ; vTIQ'
NBRC: Appendix A (USCG Information) Page 3 of 5
Photomap supplied to USCG, indicating —86' of clearance, in support of the current finding
regarding a hazard to navigation (USCG letter dated November 24, 2009):
C
NBRC: Appendix A (USCG Information)
Z
s '
o I
i
4
1 I
Page 4 of 5
EXH-2 on page 9 of Applicant's Exhibit B (in BOS packet for 8 Dec 09 Hearing on Dutra): Note
the identification of the I00' wide Corps Channel, with half of it obstructed by the downstream
end of the barge.
LEGEND:
MLW MEAN LOW WATER -0.12 (NGVO 29)\\
MLLW MEAN LOW LOWER WATER •1.05 (NGVD 29)
MHW MEAN HIGH WATER 4.97 (NGVO 29)
W MHHMEAN HIGH HIGHER WATER 8.54 (NGVD 29)
HT HIGHTIDE Graphic Scale (in feet)
WO .):!q;;;;!,; WETLAND'WO• PER SHEET EXH9 0.18 ACRES
(CSW SECTION 404 JURISDICTIONAL WETLAND) as 4 Ba 120
NOTES:
1. DOLPHINS AND 18' STEEL PIER PIPES ARE ESTIMATED TO BE 50' DEEP.
2. 71DAL DATA BASED OFF OF NOAA PID# JT0770. PETALUMA RIVER, UPPER
I Inch = 60 ft.
SHOLLENSERGER TRAIL ----
APPROXIMATE TOP OF BANK
i MA
O - —
� .. .:._ RIFF
-
R
..-. i,�:•� `-'anal ' -
�.
ATR -COOR-
-6
.1
MIAC NVEY
FLOATING BARGE
DOCKED 2 TIMES
• " PER WEEK, AVG -'
MLW. :-0.i2.....w •. :.
-
16"ST-EELPIER-PIP.E(4)t
_ MRHW!!�.54
91HWw.e7DOLPH(N`
.7.0100 YR �TOP OF BANK _ ~ • i� "%� YEE RtSIDEN� ,
FLOOD EL. ? � 1 jam.
\1 r J 100 FILOOD L 1
COVER 1 r �_P
COWEYOR /
JYEE PROPERTY ` b\
PROPERTY AP 019-220-001, VEGETATED
A \` \
BONDMY C ARTON-PROPERTY}--! ! \� I'I I '� •TREATMENT 1 1
^ 'AI SWALE
Rev. Date: 09-14-09
V S tlV I-S T 2 Job No. 591302 C3D Scale: V=60'
CSW/Stuber-Slroeh,Engineering Group, Inc. DUTRA HAYSTACK LANDING
ASPHALT CENTER
ClMasvucwral enpnasu 4cKvaWp sMapp:npl Enwpnmm:ai phrJnp
Laotl pbn0lnp lGsnsan�lon M.napamanllLan°scapn Arcnitngnra JARPA EXHIBIT -BARGE SITE PLAN
45 Lweroni Court tel: 415.883.9850
Novato, CA 94949 ra:4,5.883.9835 EXH 2
°'°°' SONOMA CALIFORNIA
NBRC: Appendix A (USCG Information) Page 5 of 5
3 October 2008
Messrs. Steve Padovan and Steve Dee
Permit and Resource Management Department
County of Sonoma
2550 Ventura Ave
Santa Rosa, CA 95403-2829
Via Electronic Moil
Re: DUTRA HAYSTACK LANDING ASPHALT & RECYCLING FACILITY (Final EIR)
Gentlemen:
We appreciate the additional time provided to review and comment upon the document referred to
above. The North Bay Rowing Club (NBRC) was founded in 1984 to support amateur athletics, including
the development of athletes for competition in national and international events. The Petaluma River is
one of the best bodies of water on the Pacific Coast for the sport of rowing. Members of both NBRC and
the Sonoma State University Rowing Club train on the Petaluma River year around, and are intimately
familiar with its upper reach.
The Final EIR indicates the proposed operation will require annual service by up to 125 each 4,000 ton
barges with nominal dimensions 200' long by 50' wide. The FEIR further indicates that these barges will
be moored against dolphins along on the riverbank at Parcel A located at positions such that the barges
will remain afloat within the existing river profile. Given that Parcel A is in a narrow part of the river that
is immediately upstream of a bend, we are concerned about the hazard this presents to navigation,
ranging from the delicate shells operated by rowers to other tugs and their barges that transit this
location. Figures 1 and 2 on the following page indicate that 200' x 50' barge, moored at the proposed
location, will occupy a significant width of the river, especially at low tide.
NBRC has conducted rowing races on the Petaluma River for many years. The current version, called the
Wine Country Rowing Classic, is developing into a premier event on the Fall regatta calendar. It
attracted 650 athletes last year (see appended Press Democrat article), and this year will serve
competitors ranging from club rowers from Alaska to returnees from the Beijing Games. Were a barge
to be moored as described in the FEIR (see Figures 1 and 2) during this event, NBRC would absolutely be
forced by safety reasons to cancel the regatta, one that now requires almost a year to plan. This is
because there would be insufficient width remaining in the river to safely enable racing boats to
approach the finish line should one be overtaking another, let alone to allow safe passage for boats
rowing downstream to the starting line. Consequently we have two requests:
P.O. Box 192 Petaluma, CA 94953 ® Boathouse at Foundry Wharf
Figure 1: Vicinity View
Shamrock Materials Barges
Shollenberger Park
Anticipated Outline of Moored 50' x 200' Dutra Barge
Distance mark for Wine Country Rowing Classic Regatta
Figure 2: Detail View
1. Has the mooring location been reviewed and found acceptable by the US Coast Guard and barge
operators who serve upstream locations? Again, this appears to be an extraordinarily unlikely
location.
In the event the project is approved as generally described, we request a condition of approval
that barge traffic for the proposed facility, and mooring of barge(s) adjacent to Parcel A, are
disallowed during the weekend the Wine Country Rowing Classic is held (generally the first
weekend in October), pursuant to Dutra receiving notice about the event schedule at least three
months in advance.
An eight -person rowing
shell is nearly 60' long
and 23' wide with oars
extended. These do not
turn easily, so require
room on either side for
safety, especially when
inexperienced coxswains
are on the helm. We
must plan for three boats
abreast at any point in
the Wine Country Rowing
Classic.
The safety margin must
be even larger for sculling
boats, for these are
steered by rowers who
must look over their
shoulder to see where
they are going.
In addition to the potential impact upon the annual regatta (which will include competitors from the
Beijing Olympics in this year's edition), there is a daily safety issue to attend to. Rowers, due to work or
school commitments, and a special desire for calm water, are most commonly on the river during low -
light conditions near dawn. Their boats are fragile, have minimal freeboard, are probably invisible on
radar, and are difficult, even with their navigation lights, to see from the bridge of a tug stationed
behind a barge. While rowing shells obviously give way to barges, more frequent barge traffic will
increase the safety hazard. To minimize this incremental hazard, we propose an annual meeting each
Fall (when new college athletes appear) between representatives of the applicant and local rowers to
discuss how to minimize this safety issue while also developing and maintaining personal relationships.
This is proposed as a preventive measure: rowers have great respect for professional tug crews (those
aboard the tugs operated on the river by Jerico Products, Inc., are amazingly accommodating and
sensitive to needs of rowers).
NPR(::: nrrrnr,W� (,)n Di,,tra FIR pays :3 c'j 4
NBRC supports comments raised by others who call for protecting local birds and aquatic species, and
for eliminating the nuisances of noise, dust, and odor that are typically associated with such facilities.
To succeed on these parameters would mirror the important energy -saving advantage provided via the
proposed barge transport, especially when the latter is amended as suggested above to support safe use
of the Petaluma River and personal connection with the spectacular nature preserve through which it
flows.
Very truly yours,
Ned Orrett
Secretary
cc: Planning Commissioner Don Bennett
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February 2, 2009
Supervisor Paul Kelley, Chair
Sonoma County Board of Supervisors
575 Administration Drive, Room 100A
Santa Rosa, CA 95403
Comments on the FEIR or Dutra Haystack Landing Asphalt and Recycling
Facility (SCH No. 2006022107)
Dear Chair Kelley and Members of the Board of Supervisors:
North Bay Rowing Club (NBRC) is a local, non-profit organization promoting the sport of
rowing to members of the community, which currently has about 50 active members from all
over Sonoma, Marin & Napa Counties. NBRC also has an active Juniors Program for local high
school athletes, and SSU Crew, with over 100 athletes, rows out of NBRC's facility at the foot of
2°d Street. The Masters, Juniors and SSU Programs are typically on the water every day of the
week, usually in the early morning starting around 5:30 a.m.
Our primary concerns with the Dutra FEIR are three -fold:
1. Safety hazards due to high volume barge traffic and docking maneuvers in a
restricted location, on the Petaluma River with a berthing location for
planned 50' x 200' barges that obstructs navigable river channel.
The Dutra DEIR is inaccurate in the site plan presentation of the barge
docking view because it does not show the entire river, bank to bank. Figure
III-17 Detail Plan of the DEIR does clearly indicate the location of the
mooring dolphins are on the edge of the dredged river channel, which would
actually place a berthed barge within a navigable waterway. It is apparent
when both banks of the River are viewed that a 50'x 200' barge, docked as
shown, would actually be obstructing approximately half the navigable
portion of the river, as is evident when the barge is superimposed to scale on
a picture of thexiver. An extremely hazardous situation would be created for
other river users in the event normal barge traffic was attempting to pass a
docked barge at this location. There would be no safety margin or escape
route for other boats, especially man -powered.
2. Right-of-way conflicts with the Wine Country Rowing Classic (WCRC) Regatta; our
primary fund raising activity that attracts over 600 participants annually generally
held on the 1" Sunday in October;
P.O. Box 192 Petaluma, CA 94953 9 Boathouse at Foundry Wharf
The Wine Country Rowing Classic would not meet USRA safety guidelines
in the event regular barge traffic was to take place during the Regatta. A
berthed barge at the proposed Dutra facility would be an obstruction and
create a blind corner for rowing shells traveling down -river to the start line
and rowing shells racing up -river to the finish line.
Air pollution caused by asphalt manufacturing and'trucks that releases hydrocarbons
and particulates that are known carcinogens, as well as dust from recycling
operations.
Air pollution from the Proposed Dutra Asphalt Plant, as delineated in the
letter of.February 2, 2009 from the City of Petaluma City Council to the
Sonoma County Board of Supervisors, would be a serious health hazard to
all Petaluma River users and inhabitants. The dangers of inhaling Polycyclic
Aromatic Hydrocarbons (PAHs), diesel fumes, and particulates deep into the
lungs are well documented. Athletes training and racing in the vicinity
would be especially at risk from these emissions at the proposed Dutra
Asphalt Plant. This would be particularly hazardous to young athletes, such
as high school age members of our Juniors Rowing Program and Sonoma
State University Rowing Club, who are more vulnerable to these toxins.
In summary, NBRC recognizes and supports the designation of the Petaluma River as a working
river. However, we reject the proposal that this plant, which does not represent state-of-the-art
technology, is a benefit to our County. For all the reasons stated above, NBRC urges the'Board
of Supervisors to deny this proposal in its current form. Should our request for denial be rejected,
we request the Board to incorporate in total the following comments, in addition to those from
the above -referenced letter from the Petaluma City Council, into the final project mitigations and
conditions of approval:
Have the Coast Guard make a determination of the feasibility of the dock facility in the DEIR as
it relates to river navigation, and get feedback from tugboat captains about their ability to safely
dock barges at, and pilot other cargoes past, the proposed facility prior to acceptance of Dutra's
application. Require an agreement in writing that no barge will be berthed at the asphalt plant,
and all barge traffic will be barred for the duration of the Regatta.
Thank you for your attention to this request.
Sincerely,
Tom Brown, President
North Bay. Rowing Club
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