Neighbourhood Action and Preservation Association: No Big Lake!

acting to preserve San Bernardino's oldest historical neighbourhood

formerly Feldheym Neighbourhood Association, Preservation Committee

To: Valerie Ross, City Planner, City of San Bernardino, Development Services Department;

Randy Van Gelder, Assistant General Manager, San Bernardino Valley Municipal Water District.

Cc: National and international press; interested activists, environmental or otherwise.

From: Matthew K. Owen, Consulting Analyst, Neighbourhood Action and Preservation Association.

1) De-watering as a liquefaction mitigation measure: In May 4th, 2002, Diaz, Yourman, and Associates prepared a report on a dewatering investigation for 1331 South E St: after a previous report by Converse Consultants, published in 2001, recommended grouting to mitigate liquefaction, Diaz, Yourman, and Associates were hired, : “The only constraint imposed on the geotechnical engineer was to include dewatering wells as one of the methods to evaluate.” (Diaz, Yourman, and Associates, 2002, p. iv, emphasis added.) Of the sources cited in the bibliography of the 2002 study, only California Division of Mines and Geology, 1997, Special Publication 117, Guidelines for Evaluating and Mitigating Seismic Hazards in California, mentions dewatering as a liquefaction mitigation measure: the sources cited in this publication, however, make no mention of dewatering as a liquefaction mitigation measure: specifically, in American Society of Civil Engineers, 1995, Soil Improvement for Earthquake Hazard Mitigation, various methods of soil improvement are examined: dewatering is not among them. Therefore: the Environmental Impact Report must reference studies that demonstrate the efficacy of dewatering as a liquefaction mitigation measure.

2) Subsidence: on p. 34 of Diaz, Yourman, and Associates, 2002, they note that, with regards to the very limited project under their study, “Additional ground settlement may occur because of dewatering…The maximum settlement will be less than 1 inch and angular distortion will be in the range of 1/400 to 1/500 at a distance of approximately 250 to 600 feet from a pumping site.” (Diaz, Yourman, and Associates, 2002, p. 34, and Figure 14: Dewatering Settlement Profile, emphasis added.) However, if we look at United States Geological Survey, 1971, Estimated Subsidence in the Chino-Riverside and Bunker Hill –Yucaipa Areas in Southern California for a Postulated Water – Level Lowering, 1965 – 2015, the abstract notes that: “Based on 1965 – 2015 water – level changes postulated by the California Department of Water Resources and on available subsidence / head decline ratios, as much as 6 feet of subsidence might occur northeast of the San Jacinto fault between Loma Linda and San Bernardino, in an area of more than 350 feet of projected water – level decline. Also, as much as 1.5 feet of subsidence might occur in the vicinity of Ontario.” (USGS, 1971, p. 5, emphasis added.) Further, in the conclusions, we note that: “Maximum subsidence is immediately east of the San Jacinto Fault near Loma Linda and has been about 1.3 feet from about 1943 to 1968-69.” (Ibid. p. 17, emphasis added.) As noted in USGS, 2001, Circular 1182, Land Subsidence in the United States, subsidence has adversely affected such diverse areas as the Zocalo in Mexico City (the Cathedral leans 8 feet to the left, and in some places, subsidence is as much as 30 feet); the Dutch polders, where efforts to build new polders in the Zuider Zee / Ijseelmeer have caused subsidence of existing polders; the Signal Hill oil dome, where pumping out of oil led to subsidence in Long Beach; and the Deitz coal mine, which caused subsidence pits and troughs near Sheridan, Wyoming. (USGS, 2001, pp. 2-3.) The case of the Leaning Tower of Pisa anticipated the Zocalo subsidence by several centuries (Adam in Nature, 8 September, 2000, Lean on me: Efforts to save the leaning tower of Pisa are succeeding, David Adam reports.) Southern California, with its porous soil, is especially susceptible to variations in ground levels due to changes in the aquifer: indeed, they are so pronounced that they overshadow any changes in ground level that might be due to seismic activity (Clarke in Nature, 23 August 2001, Water thrown on earthquake prediction: Los Angeles’ ups and downs confuse quake scientists.) Moreover, as noted in Ball in Nature, 26 June 2001, Ground Swell sensed from space: Satellites spot aquifers filling and emptying, “Just as water swells in a sponge, ground water swells the porous rocks that hold it. Conversely, when water is withdrawn from an aquifer, the rock can collapse, leading to subsidence. If the water level falls too low, the rock becomes compacted, and the subsidence is permanent.” (Clarke in Nature, 2001, p.1, emphasis added.) Therefore, we at the NAPA maintain that the Environmental Impact Report must comprehensively and conclusively address the concern of subsidence as a result of dewatering.

3) Historical Resources: In the Initial Study / Notice of Preparation for the North Lake Area and South Lake Area Project, one of the sources cited was the Summary of Historical Resources Survey done by CRM Tech in 2000: however, no mention was made of the study the City of San Bernardino commissioned in 1991, and the NAPA located hundreds of homes mentioned in the 1991 study, but omitted from the 2000 study, as still standing, and still architecturally intact. The Environmental Impact Report must explain why these homes were omitted, and what the impact of the project will be on them.

4) Cost of displacement of residents to those residents and to the City at large: on the one hand, the JPA repeatedly reassures the residents of the impacted area that they will receive “fair market value” for any properties taken for the project, without reference to the effects of the project or any other activities, or lack thereof, by the City on the market value of their properties. On the other hand, the JPA also reassures taxpayers that the cost of the project to City taxpayers will be minimal, and its benefits will be substantial. The Environmental Impact Report must reconcile the objectives of fair market value to displaced residents with minimal cost to taxpayers, and must do so comprehensively and accurately.

5) Demonstrated efficacy of water – themed redevelopment that displaces existing residents and businesses: Many times, the JPA has cited various existing and planned water – themed redevelopment projects. Which of these, if any, have displaced existing residents and businesses? The Environmental Impact Report must reference studies that demonstrate the efficacy of water – themed redevelopment that displaces existing residents and businesses.

6) Effects on water quality and availability: During the recent wildfires in the San Bernardino and San Gabriel mountains and foothills, residents were advised not to water their homes, in order that water might be made more readily available to firefighters. Water availability has long been a major concern in Southern California: indeed, concern for the effects on water availability on incorporation into the Los Angeles Metropolitan Water District led to the formation of the San Bernardino Valley Municipal Water District. The Initial Study / Notice of Preparation for the North Lake Area and South Lake Area Project makes note of the plume of contaminants now being cleaned up in San Bernardino, but fails to note the difference in levels between that plume and the water table in the area in question, the probable effects of the North Lake Area and South Lake Area Project on the existing efforts to clean up the plume, or the probable effects of bringing water now protected and treated in an aquifer to the surface, where it will be exposed to surface contaminants. The Environmental Impact Report must comprehensively and accurately deal with these issues of the effects of the North Lake Area and South Lake Area Projects on water quality and availability in San Bernardino and adjacent communities.

7) Housing discrimination: According to the last several censes, including the 2000 Census, the North Lake Area is home to a large number of retired, low – income, or minority residents: The Environmental Impact Report must show how the North Lake Area Project neither intends to, nor in fact discriminates against these residents.

These are some of the issues we at the Neighbourhood Action and Preservation Association feel must be addressed by the Environmental Impact Report on the North Lake Area and South Lake Area Project: if we have any additional concerns, we will submit them to you.

Sincerely, Matthew K. Owen, Consulting Analyst, Neighbourhood Action and Preservation Association.

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