February 1, 2008

Jeff Philliber
Environmental Planning Group
Lawrence Berkeley National Laboratory
One Cyclotron Road, MS 90J-0120
Berkeley, California 94720

Re: Comments on the Lawrence Berkeley National Laboratory (LBNL) Draft Environmental Impact Report (DEIR) for the Helios Energy Resource Facility (Helios)

...[Piedmont Way is] extended eastwardly to the mouth of the valley [Strawberry Canyon] or gorge in the mountains, which is a part of the property of the College. This lane is extended up the gorge, first, however, crossing to the other side. Thence it is intended to follow up the course of the brook, as close upon its banks as is practicable, until the point is reached at which the branch enters from the left. There the lane should fork, being carried up the branch to the left with such curves as will be necessary to reach the small table land. From this it would return on the left bank of the southerly branch of the stream to the main stem, crossing near the fork by a bridge. There should be a convenient stopping-place for carriages upon the table-land from which a walk should be formed to the highest point of the knoll around which the lane passes. At this point there is a very interesting view through the gorge and out upon the Bay, and it would be a suitable place for a small summer-house or pavilion. The lane within the gorge would have to be formed by excavation on the hillside and a thick plantation should be carefully established on the upper slope so as to confine attention to the damp ravine below and the opposite bank, which to a considerable height is abundantly covered with native foliage of a very beautiful character.

As the road follows a stream of water from the open landscape of the bay region into the midst of the mountains, it offers a great change of scenery within a short distance, and will constitute a unique and most valuable appendage to the general local attractions of the neighborhood.

Frederick Law Olmsted, 1865

...It [University property] is in area 200 acres, is watered by numerous springs in the hills, and the collection and disposal of this will furnish hereafter abundant study and practice to the engineering student. With the spring water and surface water saved, the grounds [Campus site] could be thoroughly irrigated throughout the year, and made to blossom as the roseŠ Beyond, toward the Monte Diablo Range, the ground rises into hills, the highest of which is 884 feet above the base of the south college. The average height of the tract is 400 feet above tide-water. The hilly portion could be well utilized for forestry. The University is supplied with water from a reservoir of 38,000 gallons capacity, situated at the foot of Strawberry Cañon, and at an elevation of 205 feet above the basement of the south college. It will carry water entirely over any building contemplated. Other springs of large resources will be reclaimed and brought in from time to time. Strawberry Creek is for a large portion of the year a beautifully clear stream; during the winter it discharges an enormous quantity of water, and runs between the steep banks ten to fifteen feet in depth, and with a span from thirty to one hundred feet. Along it are found many shady, quiet nooks, gracious to the scholar, philosopher, and naturalist. The soil of the lower portion of the site is a deep, rich adobe, capable of being wrought into a soil of great productiveness; on the plateau it is a lighter kind. On the hills there is a thin soil of decomposed shale rock, etc. It would be difficult to find within so small an area as the University site a spot with so many varieties and capabilities in the way of soils, irrigation, and exposure.

Frank Soulé, Jr., 1875

Dear Jeff Philliber,

The Berkeley Architectural Heritage Association (BAHA), an organization dedicated “to educate the community to encourage and secure the preservation of those structures, sites, and areas which have special architectural, historic, or aesthetic value contributing to the enrichment of the Berkeley environment and to the understanding of its heritage,” and representing over 1,200 members, urges the Regents of the University of California (University) to re-consider placement of the Helios project in Strawberry Canyon. The University’s own beginnings in the 1860s were predicated upon the discovery that Strawberry Canyon had a bounty of water so wonderful and a landscape so grand that the grassy plains below provided the ideal site for an institution of higher learning for the State of California. Yet the DEIR for the Helios project fails to adequately acknowledge Strawberry Canyon as a unique cultural landscape, opposite the Golden Gate, revealing significant historical events (“it is not clear that it has characteristics that would warrant nomination...” DEIR 4.4-1). The DEIR, likewise, fails to elucidate the potential impacts that the Helios project would have upon the integrity of the Canyon and its historic environment, nor does the DEIR put forth project alternatives truly feasible off the LBNL hill site.

To begin, it should be noted that the DEIR excludes relevant information concerning the common boundary between Strawberry Canyon’s “urban forest” of today and the University of California Campus with its surrounding residential neighborhoods. In 1865, when Frederick Law Olmsted laid out his vision for the first Campus plan and for the Berkeley Property neighborhood he foresaw a natural divide between the “civilized” Campus buildings and homes, built upon the sloping contours of a new townscape, and the beautiful terrain of the Canyon’s steep ravine. Indeed, over the last 100 years an urban interface has developed distinguished by some of the finest examples of the San Francisco Bay Tradition architecture. Most immediately, Bowles Hall, the University of California Memorial Stadium, and the Panoramic Hill Historic District, each listed on the National Register of Historic Places and contributing significantly to this shared sense of place, are enhanced by and enhance the powerful presence of the Canyon's landscape. In accordance with the obligation to recognize impacts that might adversely affect environmental resources, please address the following:

  • The DEIR for the Helios project lacks a definition and adequate analysis of the interface between Strawberry Canyon and the adjacent significant historic resources (specifically Bowles Hall, Stadium, and Panoramic Hill), inclusive of the Central Campus “Classical Core” and the Landscape Master Plan, and;
  • In light of the context of the adjacent historic environment and the Campus cultural landscape, when/who/what gives the Molecular Foundry building (approved without the benefit of an EIR) and/or the “Redwood cluster” merit to be the standard for design guidelines for the Helios project? Please give an adequate explanation, even if based upon 2006 LBNL LRDP, and;
  • Does not the cumulative size, massing, materials and design of the proposed Helios project, coupled with the Molecular Foundry building, promise to dominate and, thus, have significant, unmitigating effects upon the distinct adjacent historic Campus/urban environment below (the view analysis is not adequate)? Please adequately analyze.

The Helios DEIR also excludes relevant discussion concerning the shared interface between Strawberry Canyon and the East Bay Regional Park District, founded in 1934. The Park District, the largest urban park in the United States, expanding across the eastern ridges of Coast Range, protects and preserves a wealth of natural resources for the benefit of future generations. In 1930, the University sponsored the “Report on Proposed Park Reservations for East Bay Cities” (Olmsted Brothers, Landscape Architects, and Ansel Hall, National Park Service), under the direction of Professor Samuel C. May, Bureau of Public Administration, advocating the establishment of these vast parklands. Strawberry Canyon, then, was largely viewed as a contiguous natural landscape, save the 19th and early 20th century introduction of the eucalyptus trees, the newly located Botanical Garden, and the Stephen Mather Grove. The “Olmsted-Hall Report” reflected the long held vision of Oakland/Berkeley planners (see Werner Hagemann, “Report on a City Plan for the Municipalities of Oakland and Berkeley,” 1915) that canyons and creeks were to be properly planned as parkway areas “extending out into the hills” with a seamless boundary. Strawberry Canyon remains a significant historic landscape serving as the single visible “urban forest” corridor or gateway—opposite the Golden Gate—connecting the watershed territories of the nine East Bay counties and the urban density of the East Bay.

Growing concern for the environmental health of Strawberry Canyon began as a result of WWII activity and continued development for research, educational, recreational, and parking facilities. The incremental loss of integrity to the hsitoric landscape, including compromise of the watershed, has not gone unnoticed by the University prior to this date. The University took action in 1968 to designate Ecological Study Areas (ESA) toward “...the guiding principle in the development of Strawberry Canyon and the Hill Campus should be ... maximum use consistent with conservation of native values.” It would appear to be an obligation that the LBNL environmental review for the Helios project include those internal University reports that have discussed development in the Canyon. These reports/studies do not concur with the statement in the Helios DEIR: “...The proposed project is consistent with this changing and ongoing pattern of development in the area” (4.4-2). For instance, see the 1976 report by Garrett Eckbo & Associates for the University’s Office of Architects & Engineers, “Strawberry Canyon, A Land Use and Vegetative Management Study.” To quote the conclusion of the Eckbo Study:

...The larger question, which is central in these recommendations, is that whoever uses the Canyon area, for whatever purposes and in whatever part of it; and whoever looks at or into the Canyon from outside, or passes through or over it; are all experiencing it as a total landscape structure or complex, a total people/nature artifact. Its impact on all of these experiences, visually and through the other senses, is one of its primary functions. Therefore we have viewed the Canyon as a potential work of landscape art, including and transcending all of its multiple technical, functional and cultural aspects. We believe that the comprehensive view will enhance relations between all of these component aspects, and improve each one. Institutional uses cannot expand much beyond their current areas...

The Eckbo Study is not the only report meriting public discussion in the EIR process if a fair argument is to be made regarding the location of the Helios project on an LBNL hill site. In accordance with the obligation to recognize impacts that might adversely impact Strawberry Canyon, please address the following:

  • The Eckbo Study discusses the health of the Canyon, based on thorough consultation, recommending that institutional uses not expand substantially. The massive size, infrastructure, footprint, and cumulative impacts of the Helios project, and the completed “Redwood cluster,” would suggest a far greater impact than any use the Eckbo Report contemplated. An adequate analysis is needed of the comparative conclusions of the DEIR and the Eckbo Study made 30 years ago of potential detrimental effect upon the Canyon, and;
  • Note the “UC Berkeley Hill Campus Working Paper, A Study in Support of the 2020 Long Range Development Plan,” December 2002, co-chaired by Beth Burnside, Vice Chancellor for Research, and Tom Lollini, Assistant Vice Chancellor for Physical and Environmental Planning, does not appear to advocate institutional expansion in the location of the proposed Helios project. Again, please give adequate analysis, and;
  • The value and purpose of the ESA designation needs to be presented in the Helios DEIR vis-a-vis Helios potential impacts. The standing recommendations for ESA expansion, management, and preservation are ignored and disregarded by the LBNL environmental review, including that the location of the Helios project would have significant, unmitigating effects. Again, please give adequate analysis.

Since first learning of LBNL’s intent to expand further on the LBNL hill site, BAHA has dedicated its own research and membership activities toward gaining a greater understanding of the Strawberry Canyon landscape. Please find BAHA materials included here reflecting these endeavors. Also, please find included here copies of BAHA's letters of concern and comment regarding the LBNL expansion plans.

BAHA supports the timely motion made by the Berkeley Landmarks Preservation Commission (LPC), a California Certified Local Government entitlement under the National Historic Preservation Act of 1966, when they made comment on the 2006 LBNL Long Range Development Plans DEIR:

It is the considered assessment of the LPC that 1) the Strawberry Canyon Area is a potential Cultural Landscape and that it merits documentation as such; 2) because the Strawberry Canyon Area may be eligible for designation as a Cultural Landscape, the Draft Environmental Impact Report is inadequate as it does not acknowledge the adverse impacts that the proposed development(s) might cause to significantly change the natural setting and particular features of this irreplaceable resource; 3) Significant alteration of the Strawberry Canyon Area may not be mitigable, and, therefore, alternatives, including alternative sites for the proposed development(s), need to be identified and analyzed in the EIR.

It would seem that the LBNL environmental review for the Helios project is not sufficient until a cultural landscape report is prepared.

The obligation to undertake a cultural landscape report for Strawberry Canyon could begin with an adequate understanding of the regional and local history, which is only superficially and minimally outlined in the Helios DEIR (see 4.4-2). Furthermore, while the current ongoing work of the Pacific Northwest National Laboratory to complete “...a series of reports to identify, survey, and evaluate 245 buildings and structures at the LBNL site for potential eligibility for listing in the National Register” (4.4-3) is important documentation for potential nomination of LBNL buildings, such work does not address the comprehensive geographic area. Strawberry Canyon is a natural landscape with important traditional values. Its unique landscape heritage can not be segmented. Certainly the Landscape Heritage Plan for the Central Campus “Classical Core” could be used as a guide, observing nearly parallel framework of historical events: a Picturesque era, 1865–1898, a Beaux-Arts Era, 1899–1940, and a Modern Era, 1940–1970.

BAHA appreciates the ongoing environmental review process for proposed LBNL development projects, inspiring BAHA to learn about and to understand that Strawberry Canyon is a significant and distinct landscape that does reveal a historic, natural, and cultural relationship to our collective quality of life and sense of place. However, BAHA understands that the failure of the Helios DEIR to include relevant background material and cultural resource information both thwarts a public understanding of the project impacts and may cause the Regents to preclude informed decision making.

Sincerely,

Carrie Olson, President

Enclosures:

“Strawberry Canyon, A Mountain Gorge: Berkeley’s Natural Landscape Framing the Stadium.” The BAHA Newsletter, No. 119, Summer 2005

“Sunday Summer Afternoon Ramble & Picnic in the Berkeley Hills,” with the California Native Plant Society, June 25, 2006

“Opposite the Golden Gate, Two Summer Evenings with Charles Birnbaum, FASLA, FAAR, including Talk, Ramble and Barbeque,” with the American Society of Landscape Architects, August 9–10, 2007

Tour brochure: “Cultural Landscapes, Panoramic Hill.” Tour led by Grey Brechin

Tour brochure: “Cultural Landscapes, University Botanical Gardens.” Tour led by Linda Govan

Tour brochure: “Cultural Landscapes, Strawberry Creek—Its Sources.” Tour led by Robin Freeman

Tour brochure: “Cultural Landscapes, Monument Hill Vista.” Tour led by Michael Kelly

“Canyon Recreational Center, Wurster, Bernardi & Emmons, Architects, 1957–59”

“Strawberry Canyon, A Summer Sojourn,” The BAHA Newsletter, No. 126, Summer 2007

BAHA letter to LBNL re: Notice of Intent to Adopt a Negative Declaration for Construction and Operations of Proposed Berkeley Lab Guest House, May 29, 2007

BAHA letter to LBNL re: Lawrence Berkeley National Laboratory 2006 Long Range Development Plan Draft Environmental Impact Report, March 23, 2007

BAHA letter to LBNL, Lawrence Berkeley National Laboratory Computational Research and Theory Facility Draft Environmental Impact Report, January 4, 2008


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