10.0 Section 4(f)

SECTION 4(f)

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Central Subway

ThirD street light rail phase 2

Section 4(f) Report

[begin insertion] October 2007 [end insertion] [begin deletion] SEPTEMBER 2008 [end deletion]

Prepared for:

FEDERAL TRANSIT ADMINISTRATION

Region IX

201 Mission Street, Suite 1650

San Francisco, CA 94105

SAN FRANCISCO PLANNING DEPARTMENT

City and County of San Francisco

Major Environmental Analysis

1650 Mission Street, 4^th Floor

San Francisco, CA 94102

Prepared by:

San Francisco Municipal Transportation Agency

and PB/Wong Joint Venture

821 Howard Street

San Francisco, CA 94103

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TABLE OF CONTENTS

1.0 BACKGROUND INFORMATION......................................................................................................................... 10-7

1.1 Section 4(f)................................................................................................................................................................... 10-7

1.2 Purpose and Need....................................................................................................................................................... 10-9

1.3 Project Description.................................................................................................................................................... 10-11

1.4 Build Alternatives..................................................................................................................................................... 10-12

1.4.1 Alternative 2 - Enhanced FEIS/FEIR Alignment........................................................................................ 10-12

1.4.2 Alternative 3 – Fourth/Stockton Alignment Option A (Locally Preferred Alternative - LPA)........... 10-13

1.4.3 Alternative 3 – Fourth/Stockton Alignment Option B (Modified LPA)................................................ 10-15

1.4.4 North Beach Tunnel Construction Variant................................................................................................. 10-16

1.5 Other Project Alternatives....................................................................................................................................... 10-16

1.5.1 Alternative 1 No Project/TSM...................................................................................................................... 10-16

2.0 SECTION 4(f) RESOURCES................................................................................................................................ 10-17

2.1 Park Resources.......................................................................................................................................................... 10-18

2.1.1 Union Square.................................................................................................................................................. 10-18

2.1.2 Willie "Woo Woo" Wong Playground...................................................................................................... 10-21

2.1.3 Washington Square....................................................................................................................................... 10-22

2.2 Historic Resources.................................................................................................................................................... 10-25

3.0 IMPACTS TO SECTION 4(f) RESOURCES..................................................................................................... 10-28

3.1 Union Square............................................................................................................................................................. 10-29

3.1.1 Alternative 2 – Construction Impacts......................................................................................................... 10-29

3.1.2 Alternative 2 - Operation Impacts................................................................................................................ 10-29

3.1.3 Alternative 3 Option A – Construction Impacts....................................................................................... 10-31

3.1.4 Alternative 3 Option A – Operation Impacts............................................................................................. 10-32

3.1.5 Alternative 3 Option B – Construction Impacts........................................................................................ 10-33

3.1.6 Alternative 3 Option B –Operation Impacts............................................................................................... 10-34

3.2 Willy "Woo Woo" Wong Playground.................................................................................................................. 10-37

3.2.1 Alternative 2 – Construction Impacts......................................................................................................... 10-37

3.2.2 Alternative 2 –Operation Impacts................................................................................................................ 10-37

3.2.3 Alternative 3 Option A – Construction Impacts....................................................................................... 10-38

3.2.4 Alternative 3 Option A –Operation Impacts.............................................................................................. 10-40

3.2.5 Alternative 3 Option B –Construction and Operation Impacts............................................................... 10-40

3.3 Washington Square Park......................................................................................................................................... 10-40

3.3.1 Alternative 2 - Construction and Operation Impacts................................................................................ 10-40

3.3.2 Alternatives 3 Option A and Option B – Construction Impacts............................................................. 10-41

3.3.3 Alternatives 3 Option A and 3 Option B – Operation Impacts............................................................... 10-42

3.4 Historic Resources.................................................................................................................................................... 10-42

4.0 AVOIDANCE ALTERNATIVES.......................................................................................................................... 10-43

4.1 Evaluation of Avoidance Alternatives.................................................................................................................. 10-44

4.1.1 Location Alternatives.................................................................................................................................... 10-44

4.1.2 Design Alternatives....................................................................................................................................... 10-45

5.0 MEASURES TO MINIMIZE HARM TO SECTION 4(f) RESOURCES......................................................... 10-46

5.1 Union Square............................................................................................................................................................. 10-46

5.2 Willie "Woo Woo" Wong Playground................................................................................................................. 10-47

5.3 Washington Square Park......................................................................................................................................... 10-49

5.4 Historic Resources.................................................................................................................................................... 10-49

6.0 COORDINATION [begin deletion] AND DETERMINATION [end deletion] ..................................................................................................... 10-49

7.0 REFERENCES.......................................................................................................................................................... 10-50

LIST OF FIGURES

Figure 10-1 Location of Section 4(f) Public Parks and Project Alternatives................................................................. 10-10

Figure 10-2 Alternatives 2, 3A, and 3B............................................................................................................................... 10-14

Figure 10-3 Union Square Looking West From Maiden Lane......................................................................................... 10-19

Figure 10-4 Union Square Schematic Plan.......................................................................................................................... 10-20

Figure 10-5 Union Square Seating Area for Outdoor Cafe.............................................................................................. 10-20

Figure 10-6 Willie “Woo Woo” Wong Playground Looking North.............................................................................. 10-23

Figure 10-7 Plaque on the Wall of Pagoda/Hang Ah Alley............................................................................................. 10-23

Figure 10-8 Willie “Woo Woo” Wong Playground Schematic Plan.............................................................................. 10-24

Figure 10-9 Washington Square Park Schematic Plan...................................................................................................... 10-25

Figure 10-10 Plan Drawing of Union Square Station for Proposed Alternative 2.......................................................... 10-30

Figure 10-11 Plan Drawing of Union Square Station for Proposed Alternative 3 Option A......................................... 10-33

Figure 10-12 Union Square looking East, Potential Site of Future Station...................................................................... 10-35

Figure 10-13 Plan Drawing of Union Square Station for Proposed Alternative 3 Option B......................................... 10-36

Figure 10-14 Plan Drawing of Chinatown Station for Proposed Alternatives 2 ............................................................ 10-38

Figure 10-15 Shadow Analysis for Willie “Woo Woo” Wong Playground................................................................... 10-39

Figure 10-16 Washington Square Looking Northeast across Columbus Avenue......................................................... 10-42

LIST OF TABLES

Table 10-1 Permitted Events at Project Area Parks in 2006................................................................................................ 10-21

Table 10-2 Historic Districts in the APE Crossed by Alternative Alignments................................................................ 10-26

Table 10-3 Historic Architectural Resources within the APE in addition to those evaluated in

Corbett et al. (1997)............................................................................................................................................... 10-27

Table 10-4 Section 4(f) Properties.......................................................................................................................................... 10-28

Table 10-5 Summary of Impacts by Build Alternative......................................................................................................... 10-43

Table 10-6 Evaluation of Avoidance Alternatives.............................................................................................................. 10-48

APPENDICES

Appendix A Communication and Correspondence with San Francisco Recreation and Parks Department

ACRONYMS

APE Area of Potential Effect

BRT Bus Rapid Transit

CEQA California Environmental Quality Act

CRHR California Register of Historic Places

EIR Environmental Impact Report

EIS Environmental Impact Statement

FTA Federal Transit Administration

MTA Municipal Transportation Agency

Muni San Francisco Municipal Railway

NEPA National Environmental Preservation Act

NHPA National Historic Preservation Act

NRHP National Register of Historic Places

RTP Regional Transportation Plan

SEIR Supplemental Environmental Impact Report

SEIS Supplemental Environmental Impact Statement

SEM Sequential Excavation Method

SHPO State Historic Preservation Office

SXM Special Excavation Method

TBM Tunnel Boring Machine

TSM Transportation Systems Management

1.0 BACKGROUND INFORMATION

1.1 Section 4(f)

Section 4(f) is a portion of a Federal Law enacted as part of the Department of Transportation (DOT) Act of 1966 and set forth in Title 49 United States Code (U.S.C.), Section 1653(f). The provisions of Section 4(f) apply only to agencies within the U.S. DOT. Any proposed transportation project that affects a Section 4(f) resource must include a Section 4(f) assessment.

The intent of Section 4(f) is to determine that there is no feasible and prudent alternative to the use of Section 4(f) land or resources and to take all measures to avoid or minimize harm to public parks or recreation areas, wildlife and waterfowl refuges and significant historic sites. Per Section 4(f), a transportation project that involves the use of Section 4(f) resources will only be approved if there is no prudent or feasible alternative to using those resources and if the Project includes all possible planning to minimize harm. To determine that there is no feasible and prudent alternative to the use of Section 4(f) land, an evaluation must be undertaken that addresses location and design of alternatives that would avoid these properties. Supporting information must demonstrate that such alternatives would result in unique problems or unusual factors such as costs, social, economic, or environmental impacts, or community disruption of an extraordinary magnitude.

A Section 4(f) resource “use” occurs when land is permanently incorporated into a transportation facility or when the Project causes an adverse impact to the enjoyment or use of a Section 4(f) resource. There are different types of use defined under the Section 4(f) statute, which vary according to permanence and significance of impact. Use occurs when there is a physical take of a 4(f) property as part of a transportation Project, or when a transportation agency acquires a permanent or temporary easement of the property. A “constructive use” of a property can also occur when a Project does not physically incorporate the resource, but is close enough to substantially impair and significantly impact activities, features, or attributes that qualify a resource for protection under Section 4(f). Substantial impairment occurs only when the protected activities, features or attributes of the resource are substantially diminished.

Section 4(f) applies to historic sites that are listed or considered eligible for listing on the National Register of Historic Places, and to publicly owned parks and recreation sites. Section 4(f) is related to Section 106 of the National Historic Preservation Act (NHPA) of 1966 in that Section 106 must also be considered during Section 4(f) evaluation. Section 4(f) takes into account only those cultural resources that are determined significant through the Section 106 process. Whereas Section 106 requires consideration be given to the effects of a Project on cultural resources, Section 4(f) requires that a special effort be made to avoid the use of these significant historic resources. Section 4(f) does not apply to archeological sites where the transportation agency (Federal Transit Administration in this case), after consultation with the State Historic Preservation Office (SHPO) and the American Council on Historic Preservation determines that the archeological resource is important chiefly because of what can be learned by data recovery and has minimal value for preservation in place. Under Section 4(f) all possible planning must be made to minimize harm to public parks, wildlife refuges and historic sites caused by the Project.

Section 4(f) compliance involves three distinct steps: 1) identifying Section 4(f) resources that could be impacted by the Project; 2) developing alternatives to avoid impacts to resources; and 3) the Section 4(f) evaluation. Significance is determined through consultation with the federal, state or local official who has jurisdiction over the property. After significance is determined, the way in which the alternatives affect 4(f) resources are analyzed, including whether the alternatives use Section 4(f) properties, whether they are prudent and feasible, and to what extent the alternatives harm the resource. If more than one alternative uses a Section 4(f) resource, the alternative which is prudent and feasible and that has the least overall impact on the resource—including all practicable mitigation measures—must be considered. The analysis must consider the effects of the impact after mitigation, the severity and location of the use, and the probability that the remainder of the property will continue to serve the same functions as before the Project. If and when a Section 4(f) property is used for a Project, documentation must be prepared that shows there would be unique problems or unusual factors involved by alternatives not using Section 4(f) resources or that the monetary costs and social, economic, and environmental impacts resulting from such alternatives would be substantial.

In 2005, the first substantive revision to Section 4(f) occurred under Section 6009(a) of the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU). The act was created to simplify the process and approval of Projects that have only de minimis, or minor, impacts on Section 4(f) properties. Under the new provisions, once the U.S. Department of Transportation determines that a transportation use of Section 4(f) property results in a de minimis impact, analysis of avoidance alternatives are not required and the Section 4(f) evaluation process is considered complete for that particular resource. “De minimis” impacts are those that would not adversely affect the activities, features and attributes of the Section 4(f) resource. Concurrence must be obtained from officials with jurisdiction over the park, recreation area, or wildlife or waterfowl refuge or from the applicable State Historic Preservation Office (SHPO) or tribal historic preservation officer.

The proposed Central Subway Project involves the following parkland/recreational and historic resources:

· Union Square (Park and parking garage)

· Willie “Woo Woo” Wong Playground (formerly Chinese Playground)

· Washington Square (Park)

· Historic resources (including individual properties and historic districts) adjacent to stations and tunnel portals along the Project alternative corridors

These park/recreation resources in relationship to the Project alternatives are shown in Figure 10-1 and are described in Chapter 4.3.3 of the SEIS/SEIR. Historic Properties within the Area of Potential Effect are described in Section 4.4.3 of the SEIS/SEIR.

This Section 4(f) evaluation includes a description of each Section 4(f) resource that may be impacted by the Central Subway alternatives. The description of each resource includes: information on the location and history, physical features and uses of the park/recreation property; impacts on the property from alternatives; alternatives evaluated to avoid using the resource; identification of measures to minimize harm to the resources; and coordination with the agency having jurisdiction over the resource.

The Section 4(f) report is a separate chapter of the SEIS/SEIR available for public review and comment. This report [begin insertion] will also be [end insertion] [begin deletion] has been [end deletion] reviewed by the San Francisco Planning Department-Major Environmental Analysis, the San Francisco Historic Preservation Officer, San Francisco Recreation and Parks Department, the State Historic Preservation Officer (SHPO), the Federal Transit Administration (FTA) [begin insertion] and the Department of Interior [end insertion] before the Final SEIS/SEIR and the Record of Decision (ROD) [begin insertion] are [end insertion] [begin deletion] were [end deletion] issued on the Project.

1.2 Purpose and Need

The Purpose and Need for the Central Subway Project is described in Section 1.0 of the SEIS/SEIR and is briefly summarized here:

The Federal Transit Administration makes major transit funding decisions through a process designed to aid in the selection of transit solutions for the region. Through this process, FTA identifies transit investments that:

· Achieve transit service and mobility goals while minimizing social, economic, and environmental impacts;

· Increase transit use and reduce travel time at a reasonable cost;

Figure 10-1

Section 4(f) Properties

· Link public transportation investments with land use planning and community revitalization;

· Have strong public and political support and compatibility with local, regional, and state planning initiatives; and

· Enhance and preserve the environment, particularly in terms of reduced air and noise pollution and congestion relief.

As the Project sponsor, the Municipal Transportation Agency’s (MTA) objective for the proposed Central Subway Project is to address current and anticipated future (2030) mobility deficiencies in the transit system serving communities in the northeastern part of San Francisco and connecting to communities in the southeastern part of the City. The Project is intended to serve as a key infrastructure improvement to help ease congestion in the Project Corridor; improve transit service to the large transit dependent population that resides along the Corridor; serve mobility needs for the new jobs that are expected to be created in the Study Area; support economic and physical revitalization and improve Muni service reliability in the Project Corridor. Inadequate connectivity between corridor transit lines and other transit services, projected increases in 2030 transit and auto travel demand and transit travel times in the corridor, integration of transportation improvements with community revitalization, and air quality issues are other needs that the Project addresses.

Muni identified seven principal goals to guide the evaluation of the alternatives: 1) Improve Travel and Mobility; 2) Equity by Improved Access to Downtown and Chinatown; 3) Economic Revitalization; 4) Transit Supportive Land Use; 5) Environmental Protection; 6) Financial Feasibility and 7) Community Acceptance.

1.3 Project Description

The proposed Central Subway Project is the second phase of the San Francisco Municipal Transportation Agency’s (MTA) Third Street Light Rail Project. The San Francisco Planning Commission certified a joint Final FEIS/FEIR on December 3, 1998 and the FTA issued a Record of Decision (ROD) for the Project in 1999. The Supplemental EIS/EIR is evaluating potential changes to the Central Subway Project alignments since the FEIS/FEIR was certified including: the number and location of stations, the use of off-street station entries rather than station entries located within congested sidewalks, the provision for ventilation shafts, the use of a barrier type fare collection system, and the use of deep tunneling construction methods. The Phase 2 Central Subway Project would extend the existing T-Third line (Phase 1- Initial Operating Segment, IOS) from its current terminus at Fourth and King Streets to Stockton and Clay or Washington Streets in Chinatown, with a possible tunnel extension for removing construction equipment under Stockton Street to Union Street and Columbus Avenue in North Beach.

The Draft Supplemental Environmental Impact Statement/Supplemental Environmental Impact Report (SEIS/SEIR) updates the FEIS/FEIR that was approved in 1998. The 1998 FEIS/FEIR analyzed the entire Third Street Light Rail Project, including the Phase 1 T-Third Initial Operating Segment (IOS) and the Phase 2 Central Subway Project. This Draft SEIS/SEIR updates the evaluation for the Phase 2 Central Subway Project Alternative 2 - Enhanced EIS/EIR Alignment, modified since its inclusion in the 1998 FEIS/FEIR and includes analysis of two additional build options – the Alternative 3 – Fourth/Stockton Alignment Option A Locally Preferred Alternative (LPA), and the Option B Modified LPA. Analysis of Alternative 1 - No Project/TSM (Transportation Systems Management) is also included in the SEIS/SEIR. Further discussion on the differences between the original and enhanced alternatives is described in Section 1.5.1.

The 1998 FEIS/FEIR did not include a separate Section 4(f) evaluation because it was determined that the original proposed alignment did not propose use of any Section 4(f) property as station entrance locations; but instead the original project proposed stations would have been accessed from public sidewalks and tunnel ventilation shafts would have been located in the street right-of-way. While the Project did include information on existing parkland and historic resources, these resources did not need to be evaluated as Section 4(f) properties.

Because City fire code requires that ventilation shafts be located adjacent to the tunnels and not at the pavement surface of streets and because locating stations and station access in the heavily used sidewalk space would be disruptive to pedestrian flows, changes were made to the station designs. Because these changes would potentially affect Section 4(f) resources, the Phase 2 Central Subway Project Draft SEIS/SEIR includes a Section 4(f) evaluation.

1.4 Build Alternatives

Build alternatives being evaluated as part of the Project include the following:

1.4.1 Alternative 2 - Enhanced EIS/EIR Alignment

The Alternative 2 - Enhanced EIS/EIR Alignment is the same alignment along Third, Fourth, Harrison, Kearny, Geary, and Stockton Streets, as presented in the 1998 FEIS/FEIR, with a shallow subway crossing at Market Street. The Enhanced FEIS/FEIR alignment would extend the T-Third line north of King Street on Third and Fourth Streets traveling north along King Street to Third Street where it would proceed in subway northbound under Market Street. The line would continue east under Geary Street and then northbound under Stockton Street. The line would terminate in Chinatown at Stockton and Jackson Streets. The line would follow the same alignment southbound from Chinatown until the intersection of Third and Harrison Streets, where it would turn right on Harrison Street and left on Fourth Street before continuing to the King Street Station along Fourth Street.

The Enhanced EIS/EIR Alignment incorporates design changes to the 1998 FEIS/FEIR alternative to meet current fire codes and new Muni fare collection policy. To meet current fire codes, above-ground emergency ventilation shafts would be located in off-street right-of-way locations rather than the in-street ventilation system as originally planned. Station entries have been moved off crowded sidewalks to private or public property and combined wherever possible with vent shafts to address public concerns about pedestrian access and space constraints. The Enhanced EIS/EIR Alternative includes one surface platform station at King Street across from the Giants Ballpark and four subway stations at Moscone Center, Market Street, Union Square and Chinatown.

The Moscone Station would be located under Third Street with the station entrance located in the Tehama Pedestrian Way and vent shafts located in the northeast corner of the Moscone Garage. At the Union Square Station, two ventilation shafts would be integrated into the far eastern terraced edge of the Union Square plaza, and the main subway station entry would be located on the east side of the plaza in the middle of a stairway near an existing café. Two elevators would be located north of the station entrance and would be accessible from the sidewalk on Stockton Street. In Chinatown, the station would be located beneath Stockton Street between Sacramento and Washington Streets. Emergency ventilation shafts and the station entrance and elevators would be located between Clay and Sacramento Streets on the east side of Stockton Street on private property that Muni would acquire. The main station entry would be from Stockton Street; however, a second optional entry could be located on the east side of the station located adjacent to Hang Ah Alley, west of Willie “Woo Woo” Wong Playground; both properties are under the jurisdiction of the San Francisco Recreation and Parks Department (see Figure 10-2 for the Alternatives 2, 3A and 3B alignments).

1.4.2 Alternative 3 – fourth/stockton alignment option a (Locally Preferred Alternative-LPA)

Alternative 3 Option A would follow the same alignment beginning at Fourth Street and King Streets, continuing on and under Fourth Street (but not Third Street) and under Market Street in a deep tunnel, and continuing under Stockton Street before terminating in Chinatown. In Alternative 3A, the subway portal would be located on Fourth Street between Townsend and Brannan Streets. The trains would operate in semi-exclusive right-of-way for a block and a half south of the portal. This option would include three

Figure 10-2

central subway build Alternatives

Source: PB/Wong

Not to scale

subway stations: a Moscone Station on Fourth Street between Folsom and Howard Streets, a combined Union Square/Market Street Station on Stockton Street between Market and Geary Streets, and a Chinatown Station on Stockton Street between Sacramento and Clay Streets (same location as Alternative 2 above). The Moscone Station would be located under Fourth Street (not Third Street) with stairs and elevators in a property purchased by Muni on the west side of the street near Clementina Street. Union Square/Market Street Station, would be the same as described above for Alternative 2.

The ventilation shafts for Alternative 3A would be integrated into the Stockton Street side of the Union Square plaza terrace, which would also accommodate the main station entrance. As with Alternative 2, the Chinatown station ventilation shafts would be combined with the station entrance and located on private property, along the east side of Stockton Street, that Muni would acquire. This station location would be west of the Willie “Woo Woo” Wong Playground and Hang Ah/ Pagoda Alleys (refer to Figure 10-2 for the Fourth/Stockton Alternative 3A). The Alternative 3A also includes the provision for the North Beach Tunnel Construction Variant described below in Section 1.4.4 that would have a temporary construction portal for extracting the TBM from the tunnel adjacent to Washington Square park, in the center lanes of Columbus Avenue.

1.4.3 alternative 3 – fourth/stockton alignment option b (modified lpa)

Generally this alignment would be the same as Alternative 3A described above; however, for park properties there are some substantial differences. In the Fourth/Stockton Alignment Option B, the subway portal would be located under the I-80 Freeway on Fourth Street between Bryant and Harrison Streets (refer to Figure 10-2). Three subway stations would be included in the alternative: a Moscone Station under Fourth Street between Folsom and Howard Streets; a combined Union Square/Market Station under Stockton Street and centered at O’Farrell Street, with Union Square and Market Street subsurface pedestrian walkways and street access; and a Chinatown Station beneath Stockton between Clay and Jackson Streets. A surface station would be located on Fourth Street, north of Brannan, and would be reconfigured to accommodate rail with two-way traffic between Bryant and Townsend Streets. South of the portal, the northbound and southbound trains could operate on the surface in either semi-exclusive or mixed-flow traffic for three and a half blocks. The Moscone Station would be the same as that described above for Alternative 3A, but the Union Square/Market Street Station would be different than the Fourth/Stockton Alignment Option A above. The Union Square station entrance would be integrated into the southeast corner of the terraced plaza of Union Square park, accessible from Geary Street rather than from Stockton Street, and the elevators to the concourse level of the station would be on the eastern edge of the plaza, accessible via Stockton Street. Ventilation shafts for Alternative 3B would be integrated into the Ellis/O’Farrell Garage rather then along the eastern edge of Union Square for Alternatives 2 and 3A (refer to Figure 10-2 for the Fourth/Stockton Alignment Option B alignment). For the Chinatown Station, the ventilation shafts would be combined with the station entrance on private property that would be acquired by Muni, on the west side of Stockton Street at Washington Street. This station would be on a different parcel than that used for the Chinatown subway station entrance for Alternatives 2 and 3A, and would not be near Willie “Woo Woo” Wong Playground or Hang Ah Alley. The Fourth/Stockton Alignment Option B also includes the provision for the North Beach Tunnel Construction Variant with a temporary construction portal at Washington Square park in the middle of Columbus Avenue, the same as described for Alternative 3A.

1.4.4 North Beach Tunnel CONSTRUCTION Variant

The North Beach Tunnel Construction Variant would extend the Central Subway tunnel approximately 2,000 feet north of the Chinatown Station. This construction variant would be part of both Alternatives 3A and 3B. The tunnel would extend north under Stockton Street and would terminate under Columbus Avenue between Union and Filbert Streets across from Washington Square park, where a temporary construction shaft would be built in the center two lanes of Columbus Avenue. The tunnel extension and shaft would allow the extraction of the Tunnel Boring Machines (TBMs) and could be used to deliver finish materials to the Chinatown Station site. The shaft would be about 35 to 60 feet wide by 30 feet long and would temporarily occupy two traffic lanes. Following excavation, one half of the footprint would be decked over permanently. The remainder would be temporarily decked so the cover could be removed for construction activities. After TBM extraction and material delivery, the shaft would be permanently decked over, leaving no surface impacts.

Shaft construction would be expected to last about six months. If the shaft was used for materials deliveries, those would be done on an irregular basis over a two to three year period. Between deliveries the shaft would be decked over for use as a roadway. Delivery of construction materials could include track and systems equipment. At the conclusion of the construction period, the TBM would be extracted during the course of a week and the shaft would be decked over permanently.

1.5 Other Project Alternatives

1.5.1 Alternative 1 - No Project/TSM

The No Project/TSM Alternative would not involve the construction of a Central Subway light rail line through the proposed Project Corridor but would include the following elements:

· Programmed Projects in the approved and financially constrained Regional Transportation Plan (RTP);

· Operation of the T-Third line (Third Street Light Rail IOS) which opened in April 2007, as an extension of the Castro Shuttle to Visitacion Valley;

· Extension of the N-Judah from the Caltrain Terminal at King and Fourth Streets to a turnaround loop at 18th, Illinois, and 19th Streets, to provide additional service to the University of California San Francisco and Mission Bay development;

· Extension of the 45-Union/Stockton trolley bus service from the Caltrain Terminal through Mission Bay and Potrero Hill to a new terminus at Third and 20th Streets and;

· In conjunction with the 45-Union/Stockton extension through Mission Bay, the rerouting of the 22-Fillmore trolley bus line along 16th, Third, and Mission Rock Streets to a terminus in Mission Bay.

The No Project/TSM Alternative is used for comparison to determine the impacts of the build alternatives in the Supplemental EIS/EIR, but it is not analyzed as part of the Section 4(f) evaluation because it would not affect Section 4(f) properties.

2.0 SECTION 4(f) RESOURCES

This section describes the Section 4(f) resources that would potentially be affected by the Project Alternatives. All Section 4(f) resources are grouped as either park and recreation resources or significant historic resources and are described from the southern end of the Project Corridor to the northern end. The Central Subway Area of Potential Effect (APE) boundaries were determined through evaluation of the Project Corridor during the Section 106 process. The Project APE boundaries generally follow the proposed Alternatives alignments and extend approximately one parcel away from the alignment in each direction except for in areas where there are no buildings; in those cases, the boundaries generally extend one block-length away from the alignment. The APE around station entries and tunnel portals included adjacent properties and a second row of buildings. The APE maps and detailed descriptions of significant historic architectural properties are incorporated by reference from Sections 4.4 and 5.4 of the Draft SEIR/SEIS and from the separate technical report “Historic Architectural Evaluation Report for the Central Subway” by Garcia and Associates, April 2007. The APE maps are included as Appendix C of the SEIS/SEIR.

2.1 Park/recreational Resources

2.1.1 Union Square

Union Square is a 2.6-acre park located between Stockton, Powell, Post, and Geary Streets (see Figure 10-3). The park is an important open space and public plaza for residents and San Francisco visitors. The Union Square neighborhood is one of the main cultural and retail centers of the City and Union Square plaza serves as the focal point for the district. The park is under the San Francisco Recreation and Park Department’s jurisdiction.

Union Square park serves as the heart of the Kearny-Market-Mason-Sutter Conservation District, and the park is a designated California State Landmark No. 623 (CHL 1996: 220). Union Square has been determined eligible for the National Register of Historic Places and has been proposed for designation as a San Francisco Landmark, but it has not been listed in either the California Register of Historical Resources or the local register. However, the San Francisco Planning Code describes the park as “an integral part of the District that ranks with the finest open spaces in the country” and explains how the Kearny-Market-Mason-Sutter Conservation District “is further defined by the location of Union Square in its heart. This square is, in many ways, the premiere open space in the City, as well as a primary public forum” (Article 11, Appendix E, Section 5).

The park dates from 1847. In 1850, Colonel John Geary transferred the title of the land to the City “with the stipulation it be held in perpetuity for the park purposes” (Hupman 40). The park was named during the Civil War for pro-Union rallies held there. In the middle-to-late 1870s, it became a formally landscaped City park. Prior to that, the park was used for a variety of purposes ranging from industrial fairs and musical events to public meetings. Buildings across from the park on the east side of Stockton Street were burned down in 1906 after the earthquake, and by 1913 the street was lined with commercial structures (Hupman 40).

According to the San Francisco Beautiful, Landmarks Preservation Advisory Board Nomination Form quoted in the Planning Department’s Negative Declaration prepared for the Union Square Park Project in 1998, “the Square is significant because of its relationship to surrounding buildings and the urban setting, its history as one of San Francisco’s first public squares, and the successful integration of an underground garage, which was the first of its kind in the world.”[1]

Figure 10-3

Union Square looking west from Maiden Lane

Source: PB/Wong, 2007

The underground garage was built in 1938 by the Union Square Garage Commission which was formed to build an underground garage at the site. Today, Union Square is elevated above street level to cover a 985-vehicle underground parking garage administered by the MTA.

In 2002, Union Square was renovated with private and public funds. Royston Hanamoto Alley and Abey was one of several firms that developed the Union Square Master Plan. Patri Merker and Michael Fotheringham were the two firms that won the international design competition and completed the park’s redesign and renovation (Nelson 2006). The redesign transformed the area from an open grassy landscape to a completely redesigned hard-surface plaza with landscaped terraces above the historic underground parking garage (see Figure 10-4). The plaza is elevated above surface level at certain locations because of the parking garage and natural topography. Union Square contains terraced plazas and sitting areas as well as an area for staging outdoor exhibits and performances. The park has a fountain, memorial statue, a café with outdoor seating and a theater ticket office (see Figure 10-5).

The park is accessible from all corners and there are mid-block entries as well. The plaza is fully ADA accessible. Events on the plaza include occasional musical and dance performances. During the holiday season, a Christmas tree is displayed in the plaza. The Union Square Association estimates that

Figure 10-4

Union Square Park Schematic Plan

Source: San Francisco Recreation and Parks

Figure 10-5

Union Square seating area for outdoor café, looking north

Source: PB/Wong, 2007

approximately five events, including art shows and filming, occur at the park per week.[2] According to the Recreation and Parks Permits and Reservations Department records, approximately 79 permitted events were held at Union Square in 2006 (see Table 10-1).[3]

Table 10-1

Permitted Events at Project Area Parks in 2006

(Source: San Francisco Recreation and Parks Department, 2007)

Park usage figures for Union Square (or any of the City parks) are not maintained by any official agency or organization. However, the MJM Management Group has developed park usage estimates for Union Square.[4] According to MJM, the park receives 10,000 to 15,000 visitors per day in the summer months. In the winter months, the estimate is 8,000 to 10,000 visitors per day. MJM claims these visitor estimates do not include special events at the park, which, if added, would make the attendance figures higher. For example, the Christmas tree-lighting event at the park usually includes nearly 6,000 people.

2.1.2 Willie “Woo Woo” Wong Playground

Willie “Woo Woo” Wong Playground (formerly “Chinese Playground”) is a publicly owned park under the jurisdiction of the San Francisco Recreation and Parks Department. The park is one of the few open spaces in the highly developed, dense urban fabric of the Chinatown neighborhood and is the only open space in the Project Corridor on Stockton Street north of Union Square. The park has cultural significance, which is reflected in its namesake, Willie “Woo Woo” Wong, who was a local Chinese-American sports legend.

The park is located at 850 Sacramento Street in Chinatown at the intersection of Waverly and Sacramento Streets, east of a row of buildings along Stockton Street. The 35,724 square foot multi-level park was built in 1927 and includes a clubhouse with a recreation/meeting area with ping pong tables, a kitchen, and an office, as well as basketball, tennis and volleyball courts, a multi-use paved playfield and children’s and tots’ play areas (see Figure 10-6). According to a plaque on the wall of Hang Ah Alley (see Figure 10-7), the park’s club house was demolished in 1977 and new facilities and the club house were constructed in 1980 under the direction of the Chinatown Better Parks and Recreation Committee (see Figure 10-8). Pagoda Alley is under the jurisdiction of the San Francisco Department of Public Works and serves pedestrian access to the businesses on the alley. Hang Ah Alley is under the jurisdiction of the San Francisco Recreation and Parks Department and provides pedestrian access to Willie “Woo Woo” Wong playground.

2.1.3 WASHINGTON SQUARE

Washington Square park is a 2.26 acre publicly-owned park that was built in 1900. The park is under the Recreation and Park Department’s jurisdiction.

Washington Square is located off Columbus Avenue and is bordered by Stockton, Filbert and Union Streets in the North Beach neighborhood of the City. Strolling paths, small gathering areas, grassy open space, public seating, historic sculptures, restrooms and a children's playground are features of the park. Washington Square park is one of San Francisco’s three original parks and is located in a place that has served as a village green and civic space since 1850. The park has a number of mature trees that lend to the historic character of the park landscape. The park was designated as a local landmark in 1999, requiring it to undergo specific reviews for any future potential changes to the park. The square was designed by William Eddy (see Figure 10-9).

Across from Washington Square park is the small, triangular Marini Plaza. Marini Plaza was originally part of Washington Square park, but was severed from it in the 1870s after the construction of Columbus Avenue which cut through the southwest corner of Washington Square. The 2,730 square foot Marini Plaza is bounded by Columbus Avenue and Union and Powell Streets. Since 1905 it has served as a visual garden and break from the urban fabric, featuring trees, sculpture and a pond (San Francisco 2005).

Between 2003 and 2004, renovations were made to Washington Square park where root expansion had made certain paths uneven and unstable. The pathways were repaved using pervious concrete, and the southeast corner entrance was reconfigured to protect established Stone Pine trees (San Francisco 2005).

The park is used by local Tai Chi practitioners on mornings, and all-day and evening by local residents for activities including sitting in the sun, playing catch and walking their dogs. The park has a children’s play area that includes swings and climbing bars, and a restroom on the east side along Columbus Avenue. There are several mature trees in the park, as well as paved pathways and benches.

Figure 10-6

Willie “Woo Woo” Wong Playground looking north

Source: PB/Wong, 2007

Figure 10-7

Plaque on the wall of Pagoda/Hang Ah Alley

Source: PB/Wong, 2007

Figure 10-8

Willie “Woo Woo” Wong Playground Schematic Plan

Figure 10-9

Washington Square Park Schematic Plan

Source: San Francisco Recreation and Parks

2.2 HISTORIC RESOURCES

Section 4.4.3 of the SEIS/SEIR describes the historic resources identified in the Area of Potential Effect (APE) for the Central Subway Project and is incorporated by reference into this Section 4(f) Report. The following Table 10-2 summarizes the Historic Districts in the APE by Alternative.

There are eight existing or proposed historic districts of local or national importance and one local conservation district that would be crossed by the Central Subway alternatives (see Table 10-2). A historic district is a group of buildings that share a common history, visual character-defining features or development that meet the criteria for listing on the National Register of Historic Places. Historic districts include a cohesive collection of buildings that represent a particular period or architectural style that serves to characterize a neighborhood. Locally established conservation districts are groupings of buildings based on their architectural quality and contribution to the built urban environment.

There are 376 properties located within the APE, including buildings, structures (e.g., Lotta’s Fountain), and linear features (e.g., street lights, Stockton Tunnel). Of the 376 properties, 161 of the properties and

TABLE 10-2

HISTORIC DISTRICTS IN THE APE CROSSED BY ALTERNATIVE ALIGNMENTS

¹ Proposed districts; not presently on any city, state, or federal lists

eight historic districts were included in the Study Area previously evaluated by Corbett et al. in 1997 for the Central Subway segment of the Third Street Light Rail Project.

The Central Subway Historic Architectural Evaluation Report (as summarized in this SEIS/SEIR) has updated the findings of the Corbett et al. (1997) study by conducting evaluations on those additional properties included in the 1997 study that have become historic (45 years of age) in the intervening years (“newly historic”) and eliminating from further study those previously evaluated properties that were demolished between 1997 and 2006. It was also necessary to reevaluate properties in close proximity to the proposed station locations that were previously assigned a NRHP code of 4S (might become eligible for a separate listing in the National Register when more historical or architectural research is performed on the property) or 4D (might become eligible as contributor to a fully documented district when more historical or architectural research is performed on the district), so an explicit determination could be made about eligibility. As a result, 218 additional properties have been identified and categorized within the APE (see Table 10-3).

Table 10-3

HISTORIC ARCHITECTURAL RESOURCES WITHIN THE APE IN ADDITION TO THOSE EVALUATED IN CORBETT ET AL. (1997)

Source: Garcia and Associates, February 2007.

The remaining 218 properties in the APE of the Central Subway Project are the main focus of the SEIS/SEIR and this Section 4(f) Report. A review of the Directory of Historic Properties in the Historic Property Data File for San Francisco (OHP 2006) revealed 59 properties out of the 218 have been evaluated prior to the start of this SEIS/SEIR. Of those, 49 properties were evaluated as eligible for the NRHP; nine properties were evaluated as ineligible for the NRHP; and one property was determined to be eligible for local listing only.

Another 55 properties have been eliminated from consideration because they have been identified as being less than 45 years of age and do not appear to possess exceptional significance to qualify them as eligible for the NRHP/CRHR. These include 42 buildings and nine vacant parcels or parking lots that did not require evaluation and another four properties that have been demolished since the previous study. After eliminating these 114 properties from further review; 104 properties of the 218 properties required further evaluation for historic significance for the SEIS/SEIR. It was determined that 42 of the properties appear eligible for listing on the NRHP and the remaining 62 properties appear to be ineligible. Of particular relevance to this Section 4(f) evaluation are the two historic districts (KMMS and Chinatown Districts) that include the character-defining features of Union Square (in KMMS) and the building at 814-828 Stockton Street and the building at 933-949 Stockton Street (Chinatown) proposed as alternative station locations for the Central Subway Project.

3.0 IMPACTS TO SECTION 4(f) RESOURCES

Section 4(f) parks affected by the Central Subway Project are briefly summarized in Table 10-4.

Table 10-4

Section 4(f) park Properties

Source: PB/Wong, 2007

Union Square is the only Section 4(f) resource proposed for actual physical ‘take’ by the Project for a stairway/escalator and elevator entry to the subway station below Stockton Street and for ventilation shafts. The other two parks (Willie “Woo Woo” Wong and Washington Square) would have potential indirect “constructive use” because of adjacent construction-related activities that would last 5.5 to 6 years. Potential Project impacts to Section 4(f) resources are described in this section.

Of the historic properties evaluated during both phases of work, 36 properties in the previous study and 34 identified during the current study were determined to have some potential for temporary, construction-related indirect impacts from vibration or visual impacts from the presence of construction equipment within the Historic District under either the Enhanced EIR/EIS Alternative 2, Alternative 3A, or Alternative 3B alignments. Mitigation measures have been described to reduce potential vibration effects to less-than-significant or minor adverse effects. Some of these properties are within the listed or proposed historic districts and others are located outside established district boundaries. The station alternatives in Chinatown would have direct impacts to the Chinatown Historic District related to the demolition of the character-defining building at either 814-818 Stockton Street or at 935-949 Stockton Street. The removal of either of these buildings would result in a visual break in an otherwise contiguous block of historic buildings that would adversely affect the District. (There are 371 contributory buildings in the Chinatown Historic District.)

3.1 Union Square

3.1.1 Alternative 2 - Construction Impacts

Construction for Alternative 2 would be expected to last an estimated 66 months (5.5 years) and work on the Union Square Station would last for about 36 months. (See also, Section 6.0 Central Subway Construction Methods in the SEIS/SEIR.) During that time, access to Union Square plaza and park uses would be maintained. Access to the Union Square parking garage on Geary Street would not be obstructed. Pedestrian access along the west sidewalk on Stockton Street between Geary and Post Street would be closed for the entire duration of the station construction. Pedestrian access along the other three sides of the plaza would not be affected.

Noise, dust, and vibration would temporarily affect the recreational enjoyment of the eastern portion of Union Square until the [begin deletion] initial [end deletion] station excavation is decked over and construction activities can occur below the surface. It would take approximately two months for the [begin insertion] station to be excavated and [end insertion] [begin deletion] excavation to be [end deletion] [begin insertion] [end insertion] decked over.

The decked cut and cover excavation of the subway station at Union Square would require the closure of two lanes (out of four) on Stockton Street for the duration of station construction, approximately [begin insertion] 66 [end insertion] [begin deletion] 36 [end deletion] months. Spoils generated from excavation of Union Square Station and the guideway tunnels north of Union Square would be hauled to surface streets for off-site disposal. Overall construction at Union Square for Alternative 2 is [begin insertion] 66 [end insertion] [begin deletion] 48 [end deletion] months. No portion of the park would be used as a construction staging area.

3.1.2 Alternative 2 – Operation Impacts

Approximately 1,517 square feet of Union Square (1.35 percent of the total plaza area) would require a long-term encroachment permit from the Department of Recreation and Parks to MTA for the station entrance escalator, elevators and emergency ventilation shafts under Alternative 2 (see Figure 10-10). The station entrance would be located in the center of the stairway to the upper plaza, along the eastern edge of the square, near an outdoor seating area for a café. The café and outdoor seating would remain in operation.

The stairway provides access to the plaza from Stockton Street. Two ventilation shafts would be integrated into the terraced planters on the eastern side of the plaza south of the elevators. The ventilation shafts would be approximately 11 feet high and would use approximately 763 square feet of the plaza

Figure 10-10

plan drawing of union square station for proposed alternative 2

Not to Scale

terraced edge on the east side of the park. A reduction in both hard-surface and landscaped planters would occur. Elevators would be located to the northeast of the station entrance escalator off Stockton Street. The elevators would replace approximately 303 square feet of the landscaped terrace on the eastern side of the plaza.

The mid-block entrance stairs on the eastern side of the plaza would remain operational and accessible despite the placement of the station entrance escalator and stairs (451 square feet) at that location. The other park entrances would remain accessible as well. The station would displace 29 (of the 985) parking spaces in the Union Square garage below the plaza. MTA manages the Union Square garage on behalf of the Recreation and Parks Department and the revenue the City receives from parking fees is returned to the Recreation and Parks Department and is partially used to repay the revenue bonds for the Union Square renovation Project. Loss of revenue would not be expected to effect the debt service payment on the revenue bond as revenues exceed the debt service obligation. Transit access to Union Square would be improved with the subway station, and increased foot traffic on the Stockton Street sidewalks on the east side of Union Square would be likely due to the introduction of the new subway station.

Visual impacts are discussed in Section 5.5 of the SEIS/SEIR and it was concluded that the proposed changes to Union Square would not significantly detract from the dominant design features of the park or surrounding landscape or result in adverse visual impacts to the park. Nor would the proposed physical changes to the park substantially change the character-defining features of the KMMS Historic District. Union Square park was substantially changed in 1998 with the renovation of the Plaza. Because of the location and scale of the proposed elevators and ventilation shafts in the plaza terraces on the east side of the park, there would be no shadow impacts from Central Subway structures on Union Square.

Project-related changes to Union Square would not cause an adverse change to the historic integrity of Union Square or to the Kearny-Market-Mason-Sutter Conservation District, particularly since Union Square’s significance is derived more from its function as an open space and public square rather than its design or any specific physical attributes (San Francisco 1998). The open space and recreational function would remain in tact and would not be significantly affected by the station entrance or the additional foot traffic induced by its location.

Despite the use of a limited portion (about 1.35 percent) of park property for the Central Subway station facilities, the impacts on the park are considered de minimis under Section 4(f). [begin insertion] The San Francisco Parks and Recreation Department will need to concur with this finding. [end insertion]

3.1.3 Alternative 3 Option A - Construction Impacts

Temporary construction impacts to Union Square plaza would occur under Alternative 3 Option A the same as those discussed above for Alternative 2, however some differences related to the underground station location and construction methods would further reduce impacts and duration of construction.

Noise, dust, and vibration may temporarily affect the use of the eastern portion of the park until the excavation is decked over and construction activities occur below the surface. It is expected that it would take approximately two months for the excavation to be decked over. During that time, construction impacts would temporarily interfere with the use, enjoyment and recreational function of Union Square.

Access to Union Square under Alternative 3 Option A would be affected in several ways:

· The sidewalk on the western side of Stockton Street along the Square would be closed for the duration of station construction ( [begin insertion] 66 [end insertion] [begin deletion] 54 [end deletion] months).

· Pedestrian access along both sidewalks on Stockton Street between Geary Boulevard and Market Street would require protective cover for about 18 months.

· The cut and cover sections of Union Square/Market Street Station would require two lanes of Stockton Street to be closed to traffic for the duration of construction.

· A 7,600 square foot staging area for the Union Square station would be required on Stockton Street adjacent to Union Square.

· Construction of the North and South Cavern Access Shafts would require the temporary use of at least two lanes of Stockton Street to accommodate a crane and trucks for muck hauling.

· After construction of the shaft, intermittent use of Stockton Street would be needed for removal of the microtunneling machines.

Spoils generated from the excavation of the station would be hauled to the surface through off-street shafts at the Union Square Station before being hauled off site for permanent disposal. Spoils removal, excavation, and ground support for the guideway tunnels and stations would require approximately 20 months. The structural works would require approximately 24 months. The entire duration of construction [begin deletion] for this alternative [end deletion] would be 66 months.

3.1.4 Alternative 3 Option A – Operation Impacts

The Union Square/Market Street Station entrance escalator would be located in the middle of the stairway on the eastern edge of the Union Square plaza along Stockton Street in Alternative 3 Option A (see Figure 10-11), the same as where the station entrance would be located in Alternative 2. However, in Alternative 3 Option A, the elevators to the station’s upper concourse would be accessed from the plaza level and would be located directly south of the escalator. Two 11 feet tall ventilation shafts would flank the entrance escalator and, as in Alternative 2, would be integrated into the terraced landscaping on the eastern edge of the plaza. The ventilation shafts would be the same height as the existing structures they would be placed in front of and would not rise above the plaza because of their location on the terrace grade. The same as Alternative 2, Alternative 3 Option A would require approximately 1,525 square feet of plaza property (1.36 percent of the total plaza area) for use under a long-term encroachment permit from the Department of Recreation and Parks. Although there are slight design modifications between the two alternatives, the designs are similar enough that Alternative 3 Option A would have the same operational impacts as Alternative 2.

Figure 10-11

Plan Drawing of Union Square Station for Proposed

Alternative 3 Option A

Despite the limited use of the park for the Central Subway facilities, the impacts on the park are considered de minimis under Section 4(f). [begin insertion] The San Francisco Parks and Recreation Department will need to concur with this finding. [end insertion]

3.1.5 Alternative 3 Option B – Construction Impacts

Noise, dust, and vibration would temporarily affect the use and enjoyment of the eastern portion of Union Square until the excavation is decked over and construction activities occur below the surface, which would be expected to occur within six months. The relocation of utilities ahead of station construction would be required on Stockton Street between Post Street and Market Street and would generate noise and dust as well and would last approximately six months.

Access to Union Square would be affected in several ways during construction:

· The sidewalk on the northern side of Geary Street adjacent to Union Square would be closed for the duration of station construction.

· The relocation of utilities ahead of station construction would be required on Stockton Street between Post Street and Market Street and would disrupt traffic near Union Square for 6 months.

· To accommodate traffic flow, curb parking on Stockton Street across from Union Square would be eliminated during utility work.

· Traffic operations would be affected by the cut-and-cover sections of the station, which would require two lanes of Stockton Street to be closed to traffic for the installation of shoring and construction of the main platform box decking.

· Pedestrian access along both sidewalks of Stockton Street between Geary and Market Street just south of Union Square would require protective cover for the entire 12-month duration of shoring installation.

Spoils generated from the station excavation would be hauled to the surface through off-street shafts at Ellis Street and at Union Square before being hauled off-site for permanent disposal. Excavation and ground support for guideway tunnels and stations would require approximately 18 months. The overall construction duration for the alternative is [begin insertion] 52 [end insertion] [begin deletion] 60 [end deletion] months.

3.1.6 Alternative 3 Option B – Operation Impacts

Approximately 1,690 square feet (1.51 percent of the total plaza area) of the southeast corner of Union Square along Geary Street would be used for the subway station entrance in Alternative 3 Option B and would require a long-term encroachment permit from the Department of Recreation and Parks for physical use of the park (see Figures 9-12 and 9-13). The station entrance would replace a portion of terraced concrete seating (about 1,378 square feet) along the southeastern corner of the park, as well as landscaping. A palm tree planted in the affected plaza corner would be moved several feet to the south to allow room for the station entrance.

All entrances to the plaza would remain operational. Thirty-four parking spaces (of a total 985 spaces) in the garage below would be removed for station facilities. As previously noted, this would not be expected to impact the debt service repayment on the revenue bond for the Union Square renovation Project. Public access to the plaza itself and to the proposed Retail Historic Shopping District would be enhanced for public transit users because of the subway station location. Overall, the reduction in parking spaces would not be a significant impact on Union Square accessibility.

Figure 10-12

Union Square looking east, potential site of future station

Source: PB/Wong, 2007

Union Square could experience increased foot traffic from subway users needing to cross the plaza to gain access from the north or northwest sides of Union Square or to exit onto streets on those sides of the plaza. There would not be as much increased foot traffic for Alternative 3B as under Alternatives 2 or 3A, because subway riders using the station entrance would not be required to enter the plaza to access the station.

The landscaping and design of the plaza would be altered by the possible introduction of a protective canopy and stair/escalator on the southeast corner of the park but this would not detract from the dominant visual features and landscape character of the plaza and would not result in adverse visual impacts. The canopy design would blend with the design features of the existing café and ticket booth. No new shadows would be created by the new station entrance.

An elevator to the platform level would be located to the northeast of the station entrance off Stockton Street. The elevator would replace approximately 303 square feet of the landscaped terrace on the eastern edge of the plaza. Vent shafts for this alternative would be located in the Ellis/O’Farrell garage rather than the eastern edge of Union Square, further minimizing use of the park.

Figure 10-13

Plan Drawing of Union Square Station for Proposed

Alternative 3 Option B

Changes to Union Square would not cause a substantial adverse change to the character-defining features of the Kearny-Market-Mason-Sutter Conservation District, particularly since Union Square’ssignificance is derived from its function as an open space and public plaza rather than its design. The recreational function of Union Square would not be substantially impacted and the park’s appearance and activities would not be negatively affected. Despite the use of the park for station entry, the impacts are considered de minimis under Section 4(f). The San Francisco Parks and Recreation Department [begin insertion] will need to [end insertion] [begin deletion] has [end deletion] [begin insertion] [end insertion] concurred with this finding [begin deletion] (see Appendix J) [end deletion] .

3.2 Willy “Woo Woo” Wong Playground

3.2.1 Alternative 2 – Construction Impacts

The Chinatown Station would be mined using Sequential Excavation Method (SEM) methods and all station work would be installed from the surface through the off-street shaft on the parcel adjacent to Hang Ah Alley and Willie “Woo Woo” Wong Playground. Spoils from the station, crossover cavern and tail track tunnel excavation would be removed from the Chinatown Station shaft on Stockton Street for approximately 10 months. Excavation, ground support, and structural work would require approximately [begin insertion] 66 [end insertion] [begin deletion] 36 [end deletion] months.

No portion of Hang Ah Alley or Willie “Woo Woo” Wong Playground would be used for construction staging, and all staging would be located on the private parcel that is being acquired for the station entrance. The north elevation wall of the demolished building would be left in tact or a sound wall would be constructed to minimize noise and dust effects on the adjacent alley and playground. Construction activity would not alter or hinder access to the park from Pagoda and Hang Ah Alleys or from Sacramento Street. These construction-related impacts would be temporary, lasting approximately 36 months, and would not significantly impact the recreational function or enjoyment of the alley or park. No constructive use of park property would result from the temporary construction activities.

3.2.2 Alternative 2 – Operation Impacts

There would be no direct use of the Willy “Woo Woo” Wong Playground under Alternative 2 because the subway station entrance would not physically encroach on the playground or on Hang Ah or Pagoda Alleys (see Figure 10-14).

An optional station entry is proposed to open onto Hang Ah Alley. Access to the park from Hang Ah or Pagoda Alleys or from Sacramento Street would not be affected by the Project. Additional foot traffic around the park could result from the location of a subway entrance adjacent to the alleyway and park.

The existing building would be replaced by a new building that would be similar in height to the existing building. The new Central Subway station would be designed to be less than 40 feet tall to meet Prop K requirements and to avoid or minimize shadows cast on the park. The ventilation shafts would rise 10 feet above the station roofline and would be placed on the roof to minimize shadows to the playground. Both the building and the ventilation shafts would cast some shadows on the playground tennis courts, however, this would be minor in comparison to the adjacent four-story buildings that already cast shadows on the park.[5]

The vent shaft shadows would not substantially affect the use and enjoyment of the park (see Figure 10-15). Existing shadows would increase by 3 percent in March, 1 percent in June, 4 percent in September,

Figure 10-14

Plan Drawing of Chinatown Station for Proposed Alternative 2

and 3 percent in December. The park’s recreational uses would not be substantially affected. These impacts would not constitute a “constructive use” of the park for Section 4(f) and would meet the definition of “de minimis”.

3.2.3 Alternative 3 Option A – Construction Impacts

The proposed station entrance building footprint would be the same as under Alternative 2, but construction impacts under Alternative 3 Option A would be different because of different construction methods.

The Chinatown Station would be a SEM-mined excavation similar to the method used in Alternative 2. All construction activities for the alternative would be conducted from the off-street shaft. The off-street portion of the station access/head house shaft would be partially decked over and used as a staging area. A crane would be required for station and shaft excavation and construction. Temporary (one to two

Figure 10-15:

shadow analysis - willie “woo woo” wong playground

weeks) use of a higher capacity crane would be required to hoist the TBMs if they are retrieved through the Chinatown access shaft. Spoils generated from the station would be hauled to the surface through off-street shafts at each of the station locations for approximately 6 months and would be hauled off site for permanent disposal. Curb parking on Stockton Street would be used to accommodate trucks. Construction of the Chinatown Station and tail track tunnel would require approximately [begin insertion] 66 [end insertion] [begin deletion] 36 [end deletion] months. The structural work would require approximately 24 months.

The [begin insertion] north [end insertion] [begin deletion] east [end deletion] elevation wall of the demolished building would be left in tact or a temporary noise barrier would be constructed during the subway station construction to minimize noise and dust effects on the adjacent alleyway and playground. Construction activity would not alter or hinder access to the park. Construction impacts would be temporary and would not significantly impact the recreational function of the park.

3.2.4 Alternative 3 Option A - Operational Impacts

The operational impacts of this alternative would be the same as for Alternative 2 despite the slightly different configuration of the escalators, ventilation and elevator shafts under the two alternatives. As designed, a secondary station entrance would open to Hang Ah Alley, but would not encroach on the playground property. The same as Alternative 2 above, the new Central subway station would be designed to be less than 40 feet tall and the ventilation shafts would rise 10 feet above the development roofline.[6] Both the building and the ventilation shafts would cause some minor shadows to fall on the playground tennis courts during some times of the year. As shadows already currently fall on the tennis courts from taller buildings along the eastern side of Stockton Street, the shadows from the vent shafts would not substantially impair the use and enjoyment of the park or alley way. Additional foot traffic on sidewalks and the alley way near the park could result from the optional location of a secondary subway entrance adjacent to the alley. The recreational function of the park would not be disrupted, and the activities and appearance of the park would not be affected. These impacts would not constitute a ‘constructive use’ of the park for Section 4(f) and would meet the definition of “de minimis.”

3.2.5 Alternative 3 Option B – Construction and Operation Impacts

The Alternative 3 Option B station entrance would be on the west side of Stockton Street at Washington Street, and would not require the use of the parcel adjacent to the Willie “Woo Woo” Wong Playground and Hang Ah Alley; therefore, no operational or construction impacts to the Park or alley (Hang Ah Alley) would occur under this alternative.

3.3 Washington Square Park

3.3.1 Alternative 2 - Construction and Operation Impacts

Alternative 2 does not include the North Beach Construction Variant for TBM retrieval and would not have any impacts on Washington Square park.

3.3.2 Alternatives 3 Option A and 3 Option B – Construction Impacts

The proposed construction of the TBM retrieval shaft, which would occur in the middle lanes of Columbus Avenue, is expected to last six months. During construction of the shaft, traffic operations would be temporarily altered and increased traffic congestion on Columbus Avenue would occur. The construction would affect vehicle and transit access to the park from the southwestern side of Washington Square, but the park would be accessible via the other three sides of the Park. A construction method involving vertically-oriented shoring relative to the curb line would allow sidewalks adjacent to the park to remain passable during construction, and pedestrian access would remain possible during construction of the shaft. The shoring would be inclined to avoid potential impacts to tree roots along the Columbus Avenue side of the Park. The shaft would be decked over permanently after the TBM extraction. The duration of the TBM extraction would be approximately five days for each of the two TBMs.

Spoils generated from the excavation of the TBM retrieval shaft would be hauled to the surface at the shaft location for approximately 6 months before being hauled off site for permanent disposal. The TBM retrieval shaft would not be used for tunnel construction or tunnel spoils removal, but the shaft could be used periodically for night time delivery of materials to the tunnels. If the shaft were to be used for material delivery, materials could be delivered on an irregular basis over a two to three year period for several days at a time. Between deliveries the shaft would be decked over for use as a roadway. Materials delivery could include track and systems equipment. Construction deliveries would require cordoning off an area at the shaft about 40 feet by 100 feet and would cause traffic disruptions (see Figure 10-16).

Temporary increases in dust, vibration and noise levels could occur during construction of the shaft and during excavation spoils removal and materials delivery. During these times use and enjoyment of the west side of the Park would be temporarily impacted, but because of their temporary nature would be considered “de minimis”.

3.3.3 Alternatives 3 Option A AND Option B – Operation Impacts

The tunnel under Columbus Avenue would not be used for the Central Subway during operation of the Project. Neither the appearance nor the activities and recreational uses of the Park would be affected during operation of the Central Subway.

3.4 Historic Resources

Demolition of one of the two properties in Chinatown for a station entry and vent shaft (814-828 Stockton Street or 933-949 Stockton Street) would adversely affect the character-defining features of the two-block area of the Chinatown Historic District. (There are a total of 371 contributing buildings within the Chinatown Historic District.) Where known historic resources or resources appearing to be eligible for the National Register of Historic Places are affected, SHPO [begin insertion] concurrence is required [end insertion] [begin deletion] has concurred. [end deletion]

A summary of impacts on 4(f) resources by alternative is shown in Table 10-5.

Figure 10-16

Washington Square looking northeast across Columbus Avenue

Source: PB/Wong, 2007

4.0 AVOIDANCE ALTERNATIVES

Section 4(f) requires that an alternatives analysis be developed if a Project proposes to use a Section 4(f) resource. The alternatives analysis must show that the alternatives considered to avoid the use of 4(f) resources are not feasible and prudent and would result in unique problems or unusual factors such as costs or community disruption of an extraordinary magnitude. To determine that there is no feasible and prudent alternative to the use of a Section 4(f) property, an evaluation has been undertaken that addresses location alternatives and design shifts that would avoid the use of the Section 4(f) resource. Supporting information demonstrates that such alternatives would result in unique problems or unusual factors.

The discussion of avoidance alternatives focuses on Union Square, a parkland resource that would constitute a physical take for the Project and Chinatown where removal of an existing building to develop a station would potentially adversely affect the character-defining features of the Chinatown Historic District. [begin insertion] Concurrence from the SHPO of “de minimis” effects has been requested. [end insertion]

While temporary construction-related impacts to Willie “Woo Woo” Wong playground and Washington Square park are discussed, a physical take of either park for the purpose of the Project would not occur

Table 10-5

Summary of Impacts by Build Alternative

Source: PB/Wong, 2006

and measures to minimize construction impacts have been included in the Project. Therefore, avoidance alternatives for those properties are not described. If impacts to a resource have been determined “de minimis,” the Section 4(f) evaluation process is considered complete for that resource once concurrence is obtained from officials with jurisdiction over the Park, recreation area [begin insertion] , and from the SHPO [concurrence is needed] [end insertion] . The evaluation of avoidance alternatives would not be necessary for the Central Subway Project, if the impacts were determined “de minimis.”

The following avoidance alternatives include those that avoid a physical take of the Union Square Section 4(f) resource with a new alignment location or through design modifications. [begin insertion] These avoidance alternatives would be deleted from this section of the Final SEIS/SEIR if concurrence for “de minimis” impacts occurs between Draft and Final SEIS/SEIR. [end insertion] [begin deletion] The Recreation and Parks Commission concurred with the de minimis finding on February 21, 2008 (see Appendix J), therefore the following avoidance alternatives are not applicable. [end deletion]

4.1 Evaluation of Avoidance Alternatives

4.1.1 Location Alternatives

1998 Final FEIS/FEIR Preferred Alternative

In the 1998 Final FEIS/FEIR preferred alternative, the Union Square station entrances were located on the sidewalks on Stockton Street adjacent to Union Square rather than on any portion of the Park itself. The design was determined not prudent because it would not provide adequate space for pedestrians and did not include ventilation structures that would meet the Fire code. [begin deletion] The preferred alternative was also reviewed with the Union Square Association and the Union Square Merchants Association, and at public meetings. [end deletion] A workshop held in October 2003 with Muni staff and Central Subway Project team members, Parking and Traffic Department and San Francisco Planning Department evaluated the preferred alternative. Results from the workshop were published in the March 2004 Working Paper: Station Location and Access Recommendations – Union Square Station. In addition to the sidewalk, pedestrian and ventilation issues identified, the report also concluded that the entrance escalators that faced away from Union Square would negatively affect way-finding for transit users.

Union Square Station Entries North of the Park on Stockton

Another station entrance alternative considered at the October 2003 workshop was locating the station entrance on Stockton Street north of Union Square near the entrance to the Hyatt Hotel. The alternative was rejected as not practicable or feasible and the report concluded that the alternative would be too costly because of the right-of-way that would have to be purchased from the hotel for the entrance location.

Alternative 1 - No Project/TSM Alternative

Although the No Build alternative would avoid Section 4(f) resources, the No Project/TSM Alternative does not meet the Project purpose and need and cannot be considered an avoidance alternative for Section 4(f) purposes because it is not feasible and prudent. The alternative would not significantly improve transit service to, from, or within the Corridor; nor would it enhance mobility in the Central Subway Corridor. The alternative would not bring transit service to the level and quality of service available in other sections of the City, nor would it support economic revitalization and development initiatives in the corridor. The No Project/TSM alternative would not maximize transit ridership or reduce the number of auto trips in the corridor and would therefore not support Muni’s Transit-first Land Use Goal.

Eliminate the Union Square Station

Elimination of the Union Square Station would avoid impacts to Union Square but would not meet the transit accessibility goals for the retail district of the City or the future transit connection goals of the adopted Four Corridors Plan.

4.1.2 Design Alternatives

Alternative 3 Option B

MTA staff met with Recreation and Parks Department staff and representatives of the Union Square Merchants Association to discuss designs for a station access in Union Square and consensus was reached on the two design options for the escalator, vents shafts and elevator location to minimize impacts to the Park while providing improved transit access.

As discussed previously in the report, the station location and design of Alternative 3 Option B would not be as disruptive on the recreational uses of Union Square as would the station location proposed under Alternatives 2 and 3 Option A. Alternative 3B would locate the two vent shafts in the Ellis/O’Farrell garage rather than on the eastern edge of Union Square, thus minimizing the extent of the use of the Park to only one station entry escalator/stair located on the Geary Street corner and elevators on the Stockton Street sidewalk. Further suggestions for the Union Square Station design by the Recreation and Parks staff included: reducing or eliminating the protective canopy over the escalator; reducing the size of the Muni sign; and, reducing the scale of the retaining wall leading to the top of Union Square for Alternative 3B. Because it was determined that Alternative 3 Option B would have the least impacts (“de minimis”) on Union Square, Alternative 3 Option B would be a prudent and feasible design alternative for the use of the Park. Design alternatives [begin insertion] would [end insertion] [begin deletion] are [end deletion] not be required [begin insertion] if [end insertion] [begin deletion] because [end deletion] impacts are determined to be “de minimis.”

Elevator Access to Station and Ventilation Shafts Routed to Sutter/Stockton Garage

The October 2003 Workshop members looked at an alternative that would use elevators for access to the station rather than escalators because they would be less expensive and require less space. The elevators would require a 115-foot long vertical cut-and-cover box compared to 213 feet required for the escalators. Glass elevators were considered because they could provide visibility and ease safety concerns. Ventilation would be provided at the city-owned Sutter/Stockton parking garage. Although the combination of the design variations would eliminate the use of Union Square, the additional tunneling that would be required to construct the ventilation shafts and connect them to the Sutter/Stockton parking garage was found to be prohibitively expensive, and the elevators are viewed as problematic because they could not provide adequate or efficient access for the volume of transit users to the station. The design alternative would not be feasible or prudent.

5.0 MEASURES TO MINIMIZE HARM TO SECTION 4(f) RESOURCES

The Secretary of Transportation may approve a Project that involves the use of Section 4(f) resources only if there is no feasible or prudent alternative to using those resources and if the Project includes all possible planning to minimize harm to the park or historic site resulting from use. This section describes potential measures that could be used to minimize harm to the affected resource. Measures to minimize harm to Section 4(f) resources will be [begin insertion] finalized [end insertion] [begin deletion] included [end deletion] in the Final SEIS/SEIR and will be included in the Mitigation and Monitoring Plan and in construction specifications and plans for the project.

Although it was found that impacts would not substantially diminish the recreational uses or activities of the parks, measures to minimize indirect impacts to Willie “Woo Woo” Wong Playground and Washington Square Park are also discussed in this section.

5.1 Union Square

[begin insertion] Before either Alternative 2 or Alternative 3 Option A or Option B is selected as the preferred alternative, and before issuance of the Final SEIS/SEIR and Record of Decision, [end insertion] Conditions of approval will [begin insertion] need to [end insertion] :

a) Support a finding that use can be minimized by planning to reduce potential harm, including: minimizing the footprint of the entrance and all ventilation shafts and elevators to the greatest extent possible to minimize the physical take of Union Square; ensuring the subway entrance is located where disruptions to the Park are minimized to the greatest extent possible, as agreed on by Recreation and Park Department Commission or Department Director; ensuring station design is visually integrated with existing Park design features; minimize light and glare with direction shading of security lights; minimize noise, dust and vibration impacts to users of the park (particularly patrons of the outdoor café during construction); relocate and enhance outdoor seating or design an alternative location for café seating area effected by construction activity; and ensuring that subway access points in the plaza are regularly maintained around the station entry by MTA to keep them free of litter and graffiti in perpetuity.

Measures to minimize harm associated with construction impacts would include: using temporary construction barriers along sidewalks to control noise and dust; controlling dust and particulate matter by spraying water or the use dust palliatives in construction areas and covering dump truck loads with canvas or tarps; ensuring access to the park is maintained during construction; ensuring no part of the Park is used as a staging area for construction purposes ensuring Park access is maintained and proper signage is posted to alert park users about construction and any necessary re-routing.

Table 10-6 summarizes the evaluation of avoidance alternatives.

5.2 Willie “Woo Woo” Wong Playground

Measures to minimize harm to the playground and Hang Ah Alley under Alternatives 2 and 3 Option A could include ensuring that activities in the Park are not disrupted by its proximity to the subway station entrance, including making it difficult to use the Park as a shortcut to the station entrance. Shadow impacts would be minimized by maintaining a building height less than 40 feet, and locating the vent shaft to the west of the playground. Shadow impacts caused by the ventilation structures could be minimized through their design, location and orientation.

Measures to minimize harm to Willie “Woo Woo” Wong Playground and Hang Ah Alley during construction for both alternatives could include controlling dust, noise and vibration during construction with temporary construction walls and muffling construction equipment. Excessive idling of non-electric construction equipment could be avoided to minimize temporary increases in pollutant emissions. Construction crews could spray water or use dust palliatives in construction areas to control dust and particulate matter (PM 10 and PM 2.5). Air quality impacts could also be minimized by covering dump truck loads with canvas or tarps and washing truck tires. Air quality would be monitored in the playground during construction to make sure that established air quality standards are maintained. Construction would be halted if violations of air quality standards are exceeded. Monitoring reports would be provided quarterly to the City. Access to the Park would be maintained during construction.

Impacts from operation would be minimized by MTA providing trash and litter pickup in the Hang Ah Alley and providing regular security checks to monitor unauthorized use of the alley. Elimination of the second station entry on the alley side could be considered, if necessary.

5.3 Washington Square Park

For Alternatives 3 Option A and Option B, measures to minimize harm to Washington Square park could include controlling noise and vibration during construction with temporary construction walls and muffling construction equipment. Pollutant emissions from work trucks would be reduced with the use of electric equipment when possible. Excessive idling of non-electric construction equipment could be avoided to minimize temporary increases in pollutant emissions. Construction crews could spray water or use dust palliatives in construction areas to control dust and particulate matter. Air quality impacts could also be minimized by covering dump truck loads with canvas or tarps and washing truck tires. Access to the park would be maintained during construction. Tree root damage could be avoided through a technique using vertically-orienting shoring relative to the curb line. A certified arborist would be present during excavation to ensure that no tree roots for historic trees in Washington Square park are impacted.

Table 10-6

Evaluation of Avoidance Alternatives

Source: PB/Wong, 2006

The arborist would have the authority to stop construction if roots are observed. The shoring would be inclined at an angle to minimize potential impacts to tree roots near the park. Locating the shaft in a slightly different location on Columbus Avenue than the existing location would be possible if the area was found to be less harmful to tree and root systems.

5.4 Historic resources

Station design for Alternatives 2, 3A, and 3B in Chinatown will require design review and input by an architectural historian to include character-defining features compatible with adjacent buildings or using a portion of the existing building façade for the station to minimize contrasts with existing building materials, design features, and historic character of the Chinatown Historic District. Because there are 371 contributing buildings in the Chinatown Historic District and Grant Street, not Stockton Street, is the primary street that defines Chinatown’s historic character, removal of one building for the Chinatown station may be considered de minimis for Section 4(f) because neither of these buildings on Stockton Street are significant historic resources. [begin insertion] Concurrence with this finding by the SHPO and City Historic Preservation Officer has been requested. [end insertion]

6.0 COORDINATION [begin deletion] AND DETERMINATION [end deletion]

Potential impacts on publicly owned parks and historic sites were identified based on Project design plans, field visits and findings from the Section 106 process detailed further in Section 5.4. Properties identified as potential Section 4(f) resources were analyzed to determine whether they were indeed Section 4(f) resources and whether Project impacts would meet the criteria of a use according to Section 4(f) regulations. Impacts to Park properties as a result of the Project were discussed in meetings and correspondence with the San Francisco Recreation and Parks Department, which has jurisdiction over Union Square, Willie “Woo Woo” Wong Playground and Hang Ah Alley, and Washington Square park and with Gordon Lau School officials regarding the Gordon Lau School playground on Washington Street. The discussions included use of the parks, the significance of the parks and potential impacts to the parks.

Impacts to historic resources were evaluated as part of the Section 106 process. Findings from the Section 106 consolidation process with the SHPO are summarized for the historic resources. Detailed measures to minimize harm to historic resources [begin insertion] will be developed during [end insertion] [begin deletion] are part of [end deletion] the Final Section 106 [begin deletion] Memorandum of Agreement (Appendix C) [end deletion] [begin insertion] and SEIS/SEIR phase [end insertion] .

As described in Chapter 3.0 Impacts to Section 4(f) Resources, Union Square is the only park property that would have a physical take for the Project. For a de minimis finding, the officials with jurisdiction over a park or recreation area must also provide written concurrence that the Project will not adversely affect the activities, features and attributes that qualify the property for protection under Section 4(f).

On July 12, 2007, MTA submitted to the San Francisco Recreation and Parks Department a letter requesting concurrence for the de minimis finding for impacts to the Union Square Section 4(f) resource. A copy of this correspondence is included at the end of this section. [begin deletion] A “de minimis” resolution was passed by the Recreation and Parks Commission for Alternative 3B on February 21, 2008 (see Appendix J). [end deletion]

[begin deletion] FTA’s rule establishing procedures for determining that the use of a Section 4(f) property has a de minimis impact on the property is found at 23 CFR Parts 771 and 774. In accordance with the provisions of 23 CFR Part 774.7(b), FTA has determined there is sufficient supporting documentation to demonstrate that the impacts to Section 4(f) property, after avoidance, minimization, mitigation, or enhancement measures are taken into account, are de minimis as defined in Part 774.17 and the coordination required in Part 774.5(b) has been completed. [end deletion]

7.0 REFERENCES

Aviles, Marcello. 2006. Personal communication of December 8, 2006.Employee of MJM Group, San Francisco, California.

Central Subway Project Team, et. al. Working Paper: Station Access Recommendations – Union Square Station. March, 2004. San Francisco, California.

Fagan, Kevin (Friday, July 26, 2002). A Square is Born. Retrieved September 22, 2006, from http://www.sfgate.com/cgi-bin/article.cgi?file=/c/a/2002/07/26/BA82511.DTL.

Hupman, Jan and David Chavez. Archaeological Resources Investigations for the Third Street Light Rail Project – San Francisco, California. Prepared for ICF Kaiser Engineers, Inc. October 1997.

LaForte, Daniel, 2006. Personal communication of November 6, 2006. Park Planner, San Francisco Recreation and Parks Department, San Francisco, California.

Lee, Sandy. Personal communication of January 12, 2007. Principal Recreation Supervisor, San Francisco Recreation and Parks Permits and Reservations, San Francisco, California.

Nelson, Doug, 2006. Personal communication of December 7, 2006. Designer, Royston Hanamoto Alley and Abey, San Francisco, California.

San Francisco Planning Department. Negative Declaration: Union Square Park Project (File No. 98.257E). San Francisco, California, 1998.

San Francisco Beautiful, Landmarks Preservation Advisory Board Nomination Form, April 1995. San Francisco Planning Department.

San Francisco Planning Department. City and County of San Francisco Municipal Code Planning Code. Codified through Ordinance 289-06, File No. 061261, Approved December 12, 2006.
(Supplement No. 3, Update 2). Retrieved October 2006 from http://www.sfgov.org/site/planning_index.asp.

San Francisco Recreation and Park Department. Project Status Report: Union Square as of November 30, 2003. Retrieved October, 2006 from http://www.sfgov.org/site/uploadedfiles/recpark/Capital_Improvement_Division_New/capital_plan_pages/districts/UnionSquare.PDF.

San Francisco Recreation and Park Department. Project Status Report: Washington Square and Marini Park as of November 30, 2005. Retrieved October, 2006 from http://www.sfgov.org/site/uploadedfiles/recpark/Capital_Improvement_Division_New/capital_plan_pages/districts/WashingtonSquare.PDF.

Union Square Association. Union Square. Retrieved December 7, 2006, from http://www.unionsquaresf.net.

Wong, Samson. (2006). Playground Renamed after ‘Woo Woo’. Retrieved November 17, 2006, from http://news.asianweek.com/news/.

[1] Copies of the primary-source materials are available for review in the Project case file (File No. 98.257E) Union Square Improvement Project, 1998, at the San Francisco Planning Department.

[2] Retrieved December 7, 2006 from http://www.unionsquaresf.net. The Union Square Association is a private association of local businesses and merchants who plan and promote events in Union Square.

[3] Examples of recent permitted events at the three parks include a DVD Tour Mobile, a Star Wars promotion, a private conference reception, a Leukemia Society Walk-a-Thon, rallies for the AIDS Foundation, Falun Gong, and A.N.S.W.E.R. anti-war protesters, a San Francisco Women’s Nike Marathon Expo, the City of Hope 5K Walk and a Cable Car Bell Ringing Contest.

[4] The MJM Management group is a private company that oversees operation and events for Union Square Park.

[5] The Muni facility would require only one story. However, for the purpose of this analysis it is assumed that a 40-foot high building would be constructed on the site. The maximum allowable height for this property is 65-feet, but Muni would restrict the building height on the site to 40 feet to avoid casting shadows on the park.

[6] See above footnote.