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December 20, 2019
Executive Director
San Francisco Regional Water Quality Control Board
1515 Clay Street
Oakland, CA 94612
We are writing to support the technical recommendations of GEI Consultants, hired by the Brickyard Cove Alliance for Responsible Development (BCARD) to review the October 2019 Remedial Design Report for Terminal One. The specific concern is contaminant discharges to the Bay and the technical review was for slurry wall design.
For 8 years we have surveyed the abundant avian species (waterbirds, shorebirds, Osprey) foraging, nesting, wintering/migrating at Ferry Point, Brickyard Cove, the Richmond Entrance Channel breakwater offshore from Terminal One, and Miller-Knox Regional Shoreline. We are very concerned that the October 2019 Remedial Design slurry wall construction design and plan, materials (e.g., choice of bentonite), and the proposed limited length of time monitoring of the effectiveness of the slurry wall, have notable deficiencies and will therefore will not protect this special site’s ecosystem, nor its inhabitants.
We ask that you require effective, modern, site-specific /appropriate slurry wall construction, with third-party quality control, and monitoring of the slurry wall in perpetuity, to ensure protection of the species-rich Point Richmond littoral, subtidal and benthic zones, and the Pacific Herring Fishery.
GEI Consultants’ recommendations regarding the October 2019 Terminal One Remedial Design Report are contained in two emails found at the California geotracker website:
Reports resulting from review by consultants of BCARD of the Environmental Report prepared by the consultant originally commissioned by the City of Richmond and Laconia, identified a number of serious deficiencies in the testing and remediation of the contaminated soil at the Terminal One project site.
We are particularly concerned about issues raised regarding leaking of contaminated groundwater into the adjacent shoreline around Ferry Point and Miller-Knox Regional Shoreline. This shoreline hosts part of the largest meadows of eelgrass (Zostera marina) extant in San Francisco Bay. Eelgrass is a critical component of a healthy San Francisco Bay. Eelgrass habitat acts as a protective nursery ground for finfish and shellfish, as an important food source for both waterbirds and a large variety of invertebrates, and as protection to coastal areas against shoreline erosion. (https://richardsonbay.audubon.org/all-about-eelgrass).
At Ferry Point and along the Richmond Entrance Channel breakwater, large annual spawning events occur when the Pacific Herring (Clupea pallasii) arrive to deposit their eggs on the eelgrass and other aquatic vegetation. The Pacific Herring Fishery is the last remaining fishery in San Francisco Bay. (https://www.wildlife.ca.gov/Fishing/Commercial/Herring).
A large number of people also take advantage to harvest these herring from the shoreline and pier. The following video, taken at Ferry Point, conveys the excitement and magnitude of these spectacular winter natural events, which attract many thousands of birds, including Scoters, Scaup, Pelicans, Bufflehead, Widgeon, Cormorants, at least 5 species of Gulls, and California sea lions and Harbor seals. (https://youtu.be/KfYZs-qgSAk)
As well as eelgrass, other types of aquatic vegetation (including Gracilaria, Fucus, Ulva) also occur at this location and provide habitat and other valuable “ecological services”.
Fish species such as Jacksmelt and Surfperch also spawn at this location. The (insufficient) measures that have been proposed by Laconia and the City of Richmond to prevent release or leaking of toxic groundwater would likely result in injection directly into the intertidal zone exposing the marine vegetation and fauna to maximal levels of contaminants. This could occur during preparation and execution of remediation, and then subsequently during construction, and indefinitely thereafter if remediation and prevention are inadequate. Such contamination is unacceptable.
Highly conservative design and execution of all steps and stages of this project is essential. The previous testing, proposals and communications by Laconia and the City of Richmond fail to provide confidence that such a rigorous approach has been considered. It is evident that measures to effectively protect this site’s littoral, subtidal, benthic and shoreline environments/habitats, and the myriad species that rely on them, as well as the health of future human residents, will not be put into place unless the Developer and City of Richmond are required to do so by the Regional Water Quality Review Board.
Thank you for your consideration.
Yvonne McHugh, Ph.D.
Anthony Brake, Ph.D.
Pt. Richmond, CA
