BCDC studies project that much of the project area could be inundated with rising water levels caused by global warming.
Technically, the lead agencies have the authority to extend EIR comment periods, but because they are controlled by mayoral appointees, the coalition is appealing to Newsom. The coalition letter notes that the project will nearly double the population of Bayview-Hunters Point, and that the newly released DEIR was nearly two years in the making.
"The city's project staff reasonably took the time to provide what in their opinion is an adequate review of the project," the coalition wrote. "The public similarly deserves 12 weeks to examine and comment on your work."
City officials have been patient with Lennar, recently granting the company a six-month delay in construction of housing at Phase 1 of the development, which sits at Parcel A of the shipyard. As a result, construction for Phase 2 is not expected to start until 2015 and continue until about 2035.
So coalition members say at 45-day delay isn't asking much. The letter makes clear that the coalition isn't opposed to the project or Newsom's administration, but that its members expect "public engagement and transparency in government."
"It is our view that a 45-day public review period for a document as complex and lengthy as the DEIR is simply inadequate under any circumstances," the coalition wrote, adding that the document's release over the Thanksgiving, Christmas, Kwanza, and Hanukkah holidays is "particularly troubling." By contrast, Santa Clara Countyoffered an extended comment period for its DEIR on its proposed new 49ers stadium.
"By releasing a six volume, 4,400 page document a week and a half before Thanksgiving, you have demanded that the public and community based organizations choose between civic duty, prearranged vacation time, and obligations to family and faith," the coalition wrote, noting that the city effectively shortened even this prep time to 25 days by holding public hearings one month after the DEIR's release.
Unlike Prop. G or previous discussion about Phase 1 of the project, the coalition reminded Newsom that an EIR is an administrative decision document, and the DEIR is the part of the approval process where ideas become concrete plans to be approved in a lawful process. "Transparency in government is not just a matter of letting the public see information," the coalition observe in the letter. "The capacity to act on what one sees is critical to transparency and the length of the look has a direct effect on the quality of observation."
Or as Bloom warned the Guardian, the current 45-day review period will likely result in a polarized dialogue. "It will lead to the squeezing out of any of the middle-of-the road perspective from folks who are not opposed to development but think the proposed project could be better," Bloom warned. "And if that happens, no modifications will be possible."
The DEIR will be the subject of two public hearings: Dec. 15 at 4 p.m. in City Hall Room 416 by the Redevelopment Agency and Dec. 17 at 1:30 p.m. in City Hall Room 400 by the Planning Commission.