December 14, 2007

Craig Middleton, Executive Director
Board of Directors
John Pelka, Compliance Manager
Presidio Trust
34 Graham Street, P.O. Box 28052
San Francisco, CA 94129

Re:  Comments on Scoping for Preparation of a Supplemental Environmental Impact Statement for the Main Post District

Dear Mr. Middleton, Members of the Board and Mr. Pelka:

Neighborhood Associations for Presidio Planning (NAPP) is a coalition of 11 neighborhood groups bordering the Presidio.  NAPP delegates from these groups have been meeting monthly since 1989 to monitor activities and respond to issues related to the Presidio and how they affect our neighborhoods.  We respectfully submit our comments on the scope of impacts to be addressed in the Supplemental Environmental Impact Statement for the Main Post District.  We incorporate by reference our letter to the Presidio Trust dated October 15, 2007 regarding Comments on Scoping for Preparation of an Environmental Impact Statement for the Public Museum at the Presidio on the Main Post, and only address below additional comments resulting from information learned at the November 28 and December 3 public meetings.

Before doing so, however, NAPP acknowledges that in calling for a fuller SEIS for the Main Post in its entirety, the Presidio Trust has recognized that the cumulative impact of a major new cultural institution, a new lodge, a rehabilitated and expanded theater, the Disney museum and a revitalized Parade Ground for special events may be significant, and that the Main Post district requires careful and thorough examination as new uses are considered.  We applaud the Trust for engaging in comprehensive planning for the heart of the Presidio, its main historic and cultural landscape.

NAPP specifically requests that the SEIS address the following:

1.  A Full Range of Reasonable Alternatives.

At the November 28 hearing, Mr. Pelka announced that in the expanded SEIS, the Trust would look at three alternatives:

1)     One museum at the south end of the Main Parade Ground, a new lodge on Graham Street, and the rehabilitation of the Presidio Theater with a building addition;

2)     One museum at the Commissary, a new lodge at Pershing Hall and the rehabilitation of the Presidio Theater;

3)     The status quo – a no action alternative.

NAPP believes that this is not the full range of reasonable alternatives required under NEPA, nor is it the appropriate comprehensive planning for the Main Parade district the Presidio deserves.  Two proposals for cultural institutions have been submitted, both with substantial merit:  Contemporary Arts Museum of the Presidio (CAMP), the gift of a world renowned contemporary art collection by the Fisher family in a contemporary museum structure and a resource center in one of the Montgomery Street barracks; and the History Center of the West, an institution to honor the Presidio’s rich military and historic past and  San Francisco’s rightful place as the western edge of the frontier and gateway to the Pacific.  By limiting the alternatives studied, the SEIS will artificially require the Trust to consider these as either/or proposals.  To fully anticipate the future uses of the Main Post district, the Trust should look at a minimum at a fourth alternative, where two additional museums are  located in the Main Post vicinity in addition to the new lodge and theater.  Each of the newly proposed museums has the potential to revitalize the Main Post, and the Trust should look at the possibility of two such valuable resources adding to the cultural richness the Presidio for the visiting public.  In our prior letter, we made some recommendations as to potential alternative sites.  One possibility would be to look at one museum at the south end of the Main Parade ground, and the other at the Commissary.  By studying the possibility of two museums in addition to the development already underway at the Main Post, the Trust and the public will become fully aware of the worst case scenario as far as environmental impacts are concerned.

2.  The Impact on Historic Resources at the Main Post.

In our prior letter, NAPP expressed concern that “the proposed 100,000 square foot contemporary structure has the potential of visually dwarfing the 40,000 square foot historic barracks and other buildings of architectural and historic distinction nearby.”  Now that NAPP has seen the renderings for CAMP, NAPP continues to be alarmed by its scale, and whether it will compromise the Presidio’s most significant National Historic Landmark District.  NAPP requests that this be fully explored, and that a team of architects and historic preservationists be assembled to assist the Trust in ascertaining and understanding the impact of this innovative structure on the historic integrity of the Main Post.  Unlike the De Young, MOMA and the Academy of Sciences, this new museum will be immediately adjacent to significant historic buildings of completely different stature and materials and it will be the focal point of a historic landscape, the military parade ground.

Searching scrutiny and analysis is necessary to determine if either of the proposals for new construction at the south end of the Main Parade Ground, in combination with new construction of the adjacent lodge, will compromise the rich historic integrity of the Main Post district..

3. Sustainable Design

NAPP requests that the SEIS address whether each of the new construction projects further sustainable design goals.  In particular, NAPP requests the SEIS to look at each project’s use of alternative energy sources and “green” building materials.

4.  The Traffic and Parking Impacts on the Presidio and Surrounding Neighborhoods.

The combination of 2-3 new cultural institutions, lodging, a theater, a visitor center and a revitalized landscape for special events such as Shakespeare in the Park, concerts, and outdoor movies, promises to do what the Presidio is seeking:  to draw the public to the Main Post in vast numbers.  These new uses in combination will literally add hundreds of thousands, and more likely, a million or more visitors to the Main Post District annually.  NAPP requests that the Trust devote the personnel and resources to study the transportation impacts of these major changes thoroughly and professionally.  To fail to do so will have negative impacts on the Presidio which may take years if not decades to overcome.

NAPP specifically requests the Trust to analyze the number of visitors and their modes of transportation fully.  Rather than rely solely on the formulaic methodologies employed in the PTMP analysis (looking at type of building use by square foot to project number of visitors and daily vehicle trips), NAPP specifically requests that the Trust study the real impact of cultural institutions of a similar magnitude, including MOMA and the De Young and Legion of Honor museums.  Mr. Fisher made clear that CAMP will have traveling shows and rotating exhibits just like these museums. Thus, the SEIS must examine not only daily and peak hour demand, but also look at the potential for extraordinary demand from blockbuster exhibits.  For example, in 2004 MOMA had 768,483 visitors annually and in 2006 560,469 visitors.  But in October 2002, the Chagall exhibit attracted over 115,000 in one month alone.  For the year ending June 30, 2007, and De Young and Legion of Honor museums combined had visitors totaling 1,673,269.  The Environmental Assessment for the Disney museum estimated that it would attract 400,000 visitors a year, with only 24,000 square feet of exhibit space.  The SEIS must look at the very real potential for a huge influx of visitors generated by the new museums and lodging, particularly if CAMP will be free of charge to the public.  On MOMA “free” days, their visitor count rises from approximately 1800 per day to 4,000 per day (based on 2006 figures).

NAPP requests that the SEIS specifically analyze where the bulk of these visitors will be traveling from and all of the anticipated modes of transportation: – by car, tour bus, public transit,  PresidiGo shuttle, taxi, foot etc.  The SEIS must examine anticipated traffic flow within the Presidio, increases in gate volumes at the Lombard, Marina Boulevard, and Presidio Boulevard gates, new access from Doyle Drive, and NAPP specifically requests that the Trust examine impact on the surrounding neighborhoods within a one mile radius of each of these entrances.  The SEIS must consider expanded MUNI service to accommodate the additional influx of visitors and the potential routes of such buses.  It must also consider the location and placement of a taxi stand to accommodate the many tourists from downtown areas.

Finally, the SEIS must fully address the increased parking demand that the new museums, lodging and theater will bring to the Main Post district in addition to the multitude of current uses by the Bay School, the Presidio Trust administration, the Gordon and Betty Moore Foundation, the San Francisco Film Center and a host of other organizations and businesses,  The Environmental Assessment for the Main Parade Ground dated November 2007 indicated that future parking demand for the revitalized parade area was 2115 spaces.  This figure will need to be revised dramatically, and specific locations for parking at the Main Parade Ground must be identified so that their impact on environmental and historic resources can be analyzed.  CAMP has now indicated that it would put in underground parking with 100 spaces.  The History Center intends to have underground parking of 130-190 spaces.  Both of these will most likely be inadequate to meet the increased demand that such institutions will generate.  In comparison, MOMA’s parking garage has 411 spaces, and there are numerous other parking garages in the immediate vicinity. The Golden Gate Park Concourse garage designed in conjunction with the opening of the new De Young has 800 spaces.  NAPP urges the Trust to take into account that the Presidio is difficult to access other than by car, and that therefore the Trust must anticipate that the increase in vehicle traffic will be substantial.  There must be adequate parking to satisfy this demand – the Trust cannot just simply wish it away by not providing adequate parking facilities.  The surrounding neighborhoods have already been impacted by visitors looking for free parking on city streets.  NAPP urges the Trust to adequately plan for the increased visitor usage, and thereby avoid the unpleasantness of neighborhood skirmishes post-construction.

Finally, NAPP urges the Trust to undertake the detailed environmental impact analysis suggested before making any final decisions on which cultural institution(s) to negotiate with and where to locate these institutions within the Main Post district.  This district is too vital to the Presidio’s identity as a National Park to rush into a decision on its hallmark tenants and structures without careful study, thorough planning and ample input from the public, for whom the Presidio is to be preserved and enhanced in perpetuity.

Sincerely,

Judith Hulka
NAPP President

cc: 

Mayor Gavin Newsom
Supervisor Michela Alioto-Pier
Supervisor Jake McGoldrick
Kyri McClellan, Mayor’s Office      

 

October 10, 2005

Presidio Trust
34 Graham Street, P.O. Box 28052
San Francisco, CA 94129

Re:  Comments on Scoping for Preparation of an Environmental Impact Statement for the Public Museum at the Main Post

Dear Mr. Middleton, Members of the Board and Mr. Pelka:

Neighborhood Associations for Presidio Planning (NAPP) is a coalition of 11 neighborhood groups bordering the Presidio.  NAPP delegates from these groups have been meeting monthly since 1989 to monitor activities and respond to issues related to the Presidio and how they affect our neighborhoods.  We respectfully submit our comments on the scope of impacts to be addressed in the Environmental Impact Statement for the new Public Museum at the Presidio on the Main Post.

Because the Presidio Trust Management Plan did not envision a newly constructed world-class contemporary art museum as part of the revitalization of the Main Post (arguably the heart of the Presidio and the area of greatest historical distinction),  NAPP believes that the Trust must undertake a most thorough and expansive environmental impact review before embarking on this project.  While the museum proposed by the Fisher family would indeed be an invaluable cultural asset to the city of San Francisco, its placement on the Main Post raises many concerns which must be addressed, particularly with respect to the cumulative impacts presented by this museum, the Main Post Lodging and the redeigned Main Parade Ground – all of which will dramatically alter the Main Post’s current uses.  With this great gift comes great responsibility on the part of the Trust to adequately plan for the throngs of visitors the new museum will generate.  The Request For Proposal indicates that 4.6 million people visit the Presidio annually.  The addition of the Fisher Museum promises to raise this figure dramatically. 

Specifically, NAPP requests that the EIS address fully:

1. The Location of a Museum of this Magnitude on the Main Post.

As noted above, the PTMP did not envision a 100,000 square foot museum at the southern end of the Main Post.  Rather, it envisioned a cultural institution at the site of the former Commisary, now occupied by Sports Basement.  The EIS should study placing a museum of this magnitude at several sites within the Presidio including, but not limited to, the Main Post, the former Commissary and Fort Scott.  These sites should be evaluated for public accessibility, aesthetic suitability, access to main traffic corridors and availability of adjacent parking as well as other potential impacts. 

2.    Whether a Contemporary Arts Musem Best Serves Park Values.

An EIS is intended to study a reasonable range of alternatives, and in this case, the proposed action, a public museum at the Main Post, could provide a variety of cultural experiences in keeping with the identity of the Presidio as a national park.  The EIS should address in particular how a contemporary arts museum is the appropriate centerpiece for a national park created from a former military base.  The Request for Proposal and the Notice of Intent both state that one of the project objectives is to “Provide a cultural experience of distinction at the Main Post that engages the public and that enhances the Presidio as a national park.”  The EIS should spell out how a contemporary arts museum would enhance the Presidio, and whether there are other types of museums that might also or better suit the Presidio’s identity as a national park.  For example, a military history museum, a museum of San Francisco’s history, a museum of the American West, an environmental education center and museum, and other such uses.

3.  The Need for Comprehensive Planning of the Presidio’s Cultural Institutions.

NAPP recommends that the Presidio Trust draw up a comprehensive plan for the type of museums and cultural institutions it believes best suit the Presdio’s park values, rather than allow the park’s cultural identity to be determined on a tenant by tenant, or location by location basis.  How will a contemporary arts museum fit in with the Disney museum close by?  What is the common thread between these and other potential museums?  In the Request for Proposal, the Trust asserts that “the presence of a major cultural institution [at the Main Post] . . . would be a catalyst for attracting other compatible uses to the Main Post.”  What compatible uses will a contemporary arts musuem foster?  Are there other types of museums that would be more compatible with the rehabilitation and reuse of the neighboring Montgomery Street barracks?  Has the Presidio Trust actively solicited other cultural institutions to submit proposals for the site – for instance, would the Smithsonian be interested in having a Western outpost in the Presidio?  Finally, and most importantly, would the impact of such a large and distinguished contemporary arts museum and its attendant impact on traffic and parking foreclose the possibility of siting other cultural institutions at the Main Post or in other areas of the park?

4        The Aesthetic Impact a Large Contemporary Structure Will Have on Historic Resources at the Main Post.

The proposed 100,000 square foot contemporary structure has the potential of visually dwarfing the 40,000 square foot historic barracks and other buildings of architectural and historic distinction nearby.  Its proposed height of 45 feet, its placement at the crown of the Parade Ground and the proposed display of art on the roof levels, indicate that this building will have a significant aesthetic impact on the Main Post.  NAPP is particularly concerned about how this new construction will impact the historic integrity of the Main Post and the other locations the EIS studies.

5. The Traffic and Parking Impacts on the Presidio and Surrounding Neighborhoods.

There is no doubt that a collection of contemporary art as significant as that held by the Fisher family will draw substantial crowds to the Main Post, particularly if the museum will have revolving “blockbuster” exhibits from time to time as museums of its stature do.  As an example, in October 2002, San Francisco MOMA had 115,000 visitors in one month alone for the Chagall exhibit according to its website.  Visitors to the Fisher museum will be coming by car, by tour bus, by city bus and by foot.  The potential for this traffic to overwhelm the Main Post is significant.  The EIS will need to thoroughly examine the impact of the proposed Museum on traffic and parking, looking not only at how it will affect traffic flow within the Presidio, but also on surrounding neighborhoods, particularly Cow Hollow and the Marina.  The EIS should provide a detailed analysis of traffic on the surrounding city streets and at the access points to the park.  The EIS should also detail the amount of parking that will be required by the projected use of the museum, where it will be located, what it will cost, and how it will impact parking in surrounding neighborhoods.  NAPP is concerned that in the Request for Proposal and its Design Guidelines, there is almost no mention of parking other than to specify that Montgomery Street is the preferred street for access to parking and for loading docks.  NAPP urges the Presidio Trust to require the museum to provide underground parking to accommodate the increase in visitor volume and to minimize the visual impact at the Main Post.

6. Cumulative Impacts of the Public Museum, Main Post Lodging and Intended Uses of the Main Parade Ground Must be Analyzed.

In order to be comprehensive, the EIS must examine the cumulative impact on transportation, traffic and parking that the museum, the Main Post Lodging and the revitalized Main Parade Ground will have.  The redesign of the Main Parade Ground is intended to provide a venue for performances and special events.  Conferences at the lodge, performances on the green and blockbuster exhibits at the museum could combine to create a traffic and parking nightmare at the center of the Presidio if thorough planning and analysis is not undertaken.  Thus the traffic and parking analysis must look at the intended uses of the Main Post as a whole, taking into account the traffic generated by the new museum, the Disney Museum, the anticipated lodging, the foundations, the Presidio Trust offices, the Bay School, the nearby Lucas Digital Arts center, the restaurants and all other existing and anticipated uses.  NAPP has repeatedly asked the Presidio Trust to engage in comprehensive transportation planning within the Presidio as a whole.  The addition of a major museum at the Main Post now compels that this be given the attention that has been lacking.

NAPP looks forward to working with the Trust on this unusual opportunity, and exploring how thorough and responsible planning will permit a new museum of such stature to best serve the Presidio as a national park.

Sincerely,

Judith Hulka
NAPP President