CMAC Responds to the Western SoMa Draft EIR
Recently, an Environmental Impact Review (EIR) was done to analyze the impact of redevelopment on the Western SoMa neighborhood of San Francisco.
Upon review, CMAC determined that this Draft EIR doesn't adequately address the impacts of the plan on existing nightlife businesses. Certain development aspects would have real, lasting, destructive impacts on SoMa cultural spaces, including venues that support the LGBT Community, multiple ethnic communities, and spaces that provide support to non-profits and serve as community resources to all of San Francisco.
Dear Members of the San Francisco Planning Commission:
The California Music and Culture Association (CMAC) urges you to amend the Draft EIR to correct inaccurate statements we have identified. We also respectfully highlight the absence of impact analysis on nightlife cultural spaces and outdoor events in the report.
The underlying plan would implement a new regulatory framework greatly expanding housing and for-profit development while ignoring longstanding historic and cultural resources, namely nightlife venues and outdoor events. This change would have real, lasting, and negative impacts on cultural spaces, including venues and events that support the LGBT Community and multiple ethnic communities, provide support to non-profits, and serve as community resources to all of San Francisco.
DEIR Factual Errors:
The DEIR fails to accurately represent the area the plan intends to represent. Specifically the DEIR refers to a map of the area (page 4.F-10; Figure 4.F-4) that is purported to include all of the area’s “Arts and Entertainment Establishments.” We have found by referencing the City Tax Collector records there are some 19 errors within the plan area and three on the boundaries, clearly within the area of impact.
Appendix A lists the summary of the errors highlighted by type of error and Appendix B shows the update of the Figure 4.F-10 map drawn with corrected information put in place.
DEIR Falls Short of Analyzing Impacts of Plan on Nightlife:
The DEIR fails to capture the impact the plan will have on cultural / historic nightlife spaces. The DEIR barely recognizes any impact, with a rare example in section 4D-24, where the DEIR suggests that historic and cultural resources impacted by the new plan could be respected by honoring these spaces with a plaque. With all due respect, destroying nightlife spaces to pave the way for new condominiums while leaving a plaque naming the destroyed cultural resource is no way to honor and maintain cultural assets in San Francisco.
The DEIR makes no mention of the impacts (transportation, public safety, and congestion) that will be created by the location of future entertainment venues to the “SALI” area bounded by Harrison and Bluxome Streets and between Fourth and 13th Streets. This is an area with no entertainment and is far from the Market Street transportation corridor, including, most importantly, BART.
This DEIR does not recognize the extraordinary challenges posed by placing housing in nightlife areas without those proposed residences having a buffer zone. Considering the substantial effort placed in creating buffer zones around identified housing enclaves, it seems an error to fail to note the impacts that will be felt by housing when it is placed in nightlife centric historic commercial areas. Specifically we know that the proximity of housing to facilities like entertainment, bars and restaurants is an important consideration to the peaceful and quiet enjoyment of those residents. We know that previous attempts to notify new residents through deed restrictions have had no legal standing and provide no protection for existing entertainment, bar and restaurant uses and ultimately favor the new residential use. Eleventh Street between Harrison and Howard is home to 7 entertainment and 4 eating establishments, and the DEIR contains no mention of this historically documentable impact.
Chapter 90-A of the San Francisco Administrative Code adopted in 2008 established San Francisco’s Music and Culture Sustainability Policy to support nightlife and entertainment venues as “a vital component of the quality of life for all the diverse communities of San Francisco.” The policy adopted by the City states that it is a priority for the City to foster, promote and sustain music and culture assets like nightclubs.
DEIR Falls Short of Analyzing Impacts Plan on Outdoor Fairs and Events:
Finally, the DEIR fails to capture any of the street fairs or exterior cultural and music events in the plan area that are impacted by the plan and whose impacts can be empirically measured. The DEIR barely mentions the existence of these significant cultural institutions, which is troubling when you consider one of those events is the third largest street event in California.
Page 2-17 mentions the Folsom Street Fair in the context of cultural events that are to be recognized and protected yet the mitigations suggested include “tax incentives, FAR exemptions, urban design and building height exemptions” which have nothing to do with an outdoor cultural event. The methodology that is being prescribed for mitigations is inaccurate and does not address the impacts that will be felt by these historic and cultural events.
Again the map found on page 4.F-10 attempts to locate these events within the district but fails to recognize the huge impact that other elements of this plan will have on said
events. We have already seen events forced to relocate (How Weird Street Faire) and change their configuration in an effort to ameliorate the impacts that have already been experienced in the plan area. No mention is made about the amplification of impacts that the plan will have on these renowned cultural institutions.
We appreciate the opportunity to make these formal observations and urge the Commission to consider appropriate amendments.