High-density housing unsuitable for West Weddell Projects

The East Weddell Projects Draft Environmental Impact Report (DEIR) has failed to include two critical, and common, CEQA Categories from this report to adequately describe the environmental setting of the Sares Regis and Raintree Sites affected by hazardous contaminants (520-592 E. Weddell Ave. and 610 – 630 E. Weddell Ave, Sunnyvale) that could potentially pose a significant threat to human health or the environment:

  1. Geology and Soils
  2. Hydrology and Water Quality

Additionally, the East Weddell Projects DEIR also fails to report that the State of California and the Santa Clara County map the East Weddell Projects is the Seismic Hazard Zones:

  1. Liquefaction Hazard Zone
  2. FEMA Special Flood Hazard Area (northwest project area close to/or in)

Since liquefaction can occur when loose, water saturated, fine-grained soils (such as sands and silt) are shaken during an earthquake, what is the impact of the hazardous ground contaminants and proper mitigation, if any? Soil can temporarily become liquid like and structures may settle unevenly. If present, these weak materials can fail during an earthquake and, unless proper precautions are taken during grading and construction, can cause damage to structures

The East Weddell Projects DEIR identifies hazardous contaminants – Arsenic, VOC, tetrachloroethylene (PCE), vanadium, groundwater containing petroleum hydrocarbons in the diesel and motor oil, to name a few, which place residents at high risk for adverse health known to cause cancer. Analog Devices, at 610 East Weddell Drive, was listed as a registered hazardous waste generator and identified as responsible for the release of 100 gallons of liquid hydrogen during an incident in 2006. The failure to disclosure liquefaction and FEMA Flood Hazard Zone proximity is a disservice to the Sunnyvale residents and this report.

One DEIR Hazard mitigation measure suggests simply laying concrete over, or a fresh layer of soil. This does not seem to be an adequate remedy for areas where there is a potential for, or a historical occurrence of liquefaction, shifting of soil, and high probability for an earthquake disruption, as well, and water movement from the FEMA Flood Hazard Zone. These contaminates can move and/or dislodge.

The thresholds of significance may be vastly different combined with liquefaction and flood FEMA zone, particularly with water supply and rising sea levels threatening coastal real estate and habitat.

The U.S. Geological Survey’s Working Group on California Earthquake Probabilities estimated that there is a 62 percent probability that one or more Moment Magnitude 10 (MW) 6.7 or greater earthquakes will occur in the San Francisco Bay Area between 2002 and 2031, this is a grave concern.

The City of Sunnyvale is the lead agency for the East Weddell Residential Projects. According to CEQA, The lead agency must analyze project impacts to 18 different environmental resource factors detailed in Appendix G during their CEQA review, yet these important disclosures have not been made. Yet, some very important items have been omitted by direction of your staff.

California Public Resources Code Section 2696 requires the delineation and mapping of “Seismic Hazard Zones” in California. Affected cities and counties must regulate certain development projects within these zones. Construction or development including additions, on affected properties may be subject to the findings of a geological report prepared by a registered California geologist.

I would like to see a Geological and Soil Study and Hydrology and Water Quality Report. Given both the liquefaction and FEMA Flood Hazard Zones, combined with known ground hazardous contaminants, high density housing does not seem sensible, practical, nor safe for residential quality of health and living.

I would not recommend rezoning for high-density housing. Nor certify this East Weddell Projects Draft Environmental Impact Report. This report is inadequate and does not meet CEQA.

The East Weddell Project DEIR can be found at


Please send DEIR comments (due by Oct 23) to:


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