Introduction

A choice between the former Terminal 3 Control Tower (1411 Harbour Way South) and the Riggers Loft as a the location for a Operations and Security Center comes before the City Council on June 5. With the additional information requested by City Council now in, the choice is clearly in favor of the Riggers Loft.

In the Agenda Report on Item K-1, the staff report is much more balanced than previously, but unfortunately, it still comes down in favor of 1411 Harbour Way South, a conclusion that is clearly not supported by the facts.

For additional background, see:

• Richmond Council Delays Port Security Project, Continues to Weigh Options, May 2, 2012
• Tom Butt Goes to War With the Port, May 23, 2012

Basis of Design

For weeks, I have been asking Port staff for any regulations that form the basis of design for the Operations and Security Center (OSC)[1] or as it is also called, the Emergency Operations Center (EOC). Whenever this issue came up, staff continued to make vague and unsubstantiated references to “Coast Guard” requirements, “Homeland Security “requirements” or CalEMA requirements.
I checked with all of these agencies, and all of them confirmed that they had no specific requirements, and staff has been unable to cite or produce any.

That is until Friday, June 1, when the staff report for Item K-1 noted “However, staff is concerned with locating an essential facility at this site” and went on to cite as an authority the Unified Facilities Criteria, “Emergency Operations Center Planning and Design. Matzorkis stated:

The OSC is designed in accordance with guidelines provided by the Unified Facilities Criteria, “Emergency Operations Center Planning and Design.” According to this document, the OSC shall:

1. Be located far from areas of fire pathways or conflagration. Canal Boulevard is the only roadway available to access the Riggers Loft. The road is bisected with fuel-oil pipelines as well as several petroleum distributors. If an earthquake causes the pipelines to rupture and a fire results, emergency personnel could potentially be hindered in being able to access the OSC.

2. Assure that the OSC is located in an area where it can be secured. At least a portion of the Riggers Loft would need fences and gates to separate it from public areas.

Applicability

After failing to respond to me previously, I don’t know how the Port concluded at this 11th hour that the Unified Facilities Criteria, “Emergency Operations Center Planning and Design” was the guiding document for design of the OSC/EOC. According to the document itself, the Unified Facilities Criteria, “Emergency Operations Center Planning and Design” is intended for Department of Defense installations, not civilian operated ports.

The Unified Facilities Criteria (UFC) system is prescribed by MIL-STD 3007 and provides planning, design, construction, sustainment, restoration, and modernization criteria, and applies to the Military Departments, the Defense Agencies, and the DoD Field Activities in accordance with USD(AT&L) Memorandum dated 29 May 2002. UFC will be used for all DOD projects and work for other customers where appropriate.

I queried the responsible staff at the United States Coast Guard about regulation pertaining to the Port of Richmond OSC, and received the following from Paul R. Martin Jr., Port Security Specialist, USCG Sector San Francisco, 415-399-7327, Paul.R.Martin@USCG.MIL:

Question: The Port of Richmond is planning to construct a security and operations center. Are there any requirements regarding what should be included in a security and operations center and where it should be located?

Answer - The MTSA regulations (33CFR105) require that the Facility Security Officer (FSO) be able to effectively communicate within the facility, with visiting vessels and with the USCG (33CFR105.235).  The FSO must also be able to control and monitor access to the facility and its security related systems and equipment (33CFR105.250 & 33CFR105.255).  How/where these security objectives are attained should be spelled out in the facility's security plan.  Larger facilities (such as Chevron Oil) have a dedicated operations center, smaller facilities do not.

No Security Plan

Nothing in 33CFR105 describes design and siting criteria for an OSC or EOC, but it does reference a security plan. The Port of Richmond does not have a security plan. Here is the exchange I had with USCG Port Security Specialist Martin:

Question: Does the Port of Richmond require a Coast Guard approved security plan? Does such a plan exist?

Answer - MTSA regulations require seaport facilities that receive vessels required to have security plans to also have security plans.  This does not necessarily mean that the seaport administration itself must have a security plan.  Many seaports in California are "landlord ports", that is, the seaport owns the property and leases/rents it out to a facility; thus the facility that leases/rents the property and revives vessels MUST have a USCG approved MTSA security plan.  As I stated in the above background information (paragraph A2), the Port of Richmond did undertake a risk assessment with Contra Costa County Sheriff's Office, which might have lead to a Port of Richmond Security plan.  To date I have not seen such a plan.  The both persons that worked on this issue for the Port of Richmond (Mr. Wilson and Mr. Chan) no longer work for the City.

Even if the Unified Facilities Criteria, “Emergency Operations Center Planning and Design” is the operative design and siting guideline for an OSC/EOC, it has been quoted out of context by staff and cherry picked to support its recommendation while ignoring  pertinent content that does not support its recommendation.

Fire Pathways or Conflagration

The staff report says an OSC/EOC should be located “far from areas of fire pathways or conflagration.” What the document actually states is:

3.5.1.2 If a risk area is identified, the EOC should be located as far from the area of highest risk. Examples include locating an EOC away from major fault lines, flood surge zones, flood plains, dam inundation zones, fire pathways, central areas subject to conflagration, avalanche paths, areas of unstable soil, hazardous material storage, downwind of hazardous gas processing and storage facilities, nuclear plants or toxic waste storage or transportation pathways, flight approach paths, and railways that transport chemicals or pressurized gas. If the location options place the EOC within a zone of the a hazard source, the Explosive Safety Quantity Distance (ESQD) arc, or within a prescribed 10 mile radius of nuclear power plants Emergency Planning zone, determine the level of mitigation that may be required in response to the hazard. Locate the EOC a safe distance from known hazardous materials. Appropriate safety zones are defined for materials in the Emergency Response Guidebook (ERG2000).

It should be noted that the reference to “conflagration” in “Emergency Operations Center Planning and Design” is actually more fully defined as “central areas subject to conflagration,” which refers to something like an urban area consisting of densely situated frame buildings. There is no mention of petroleum pipelines in 33CFR105 or “Emergency Operations Center Planning and Design”. A research of the literature indicates the term “fire pathways” is most commonly used to describe characteristics of vegetation and terrain associated with wildfires on undeveloped land, not urban areas. Again, this term does not appear to be associated with the location of the Riggers Loft. The same pipelines that Matzorkis is now characterizing as dangerous also run along Cutting Boulevard adjacent to Washington School. Canal Boulevard tank farms are located only a few feet from residences at Seacliff Estates, yet neither Port staff nor the Richmond Fire Department has ever characterized them as a potential danger before now.

The Honda Port of Entry EIR dismissed the potential hazard from these pipelines by describing automatic shutdown in case of an earthquake:

BP and Kinder Morgan currently maintain and actively monitor their pipelines via alarmed pipeline pressure and control valves that automatically shut down pumping operations when a change in system pressure or flow is detected. Kinder Morgan also has standard emergency operating procedures that include shutting down the system after an earthquake, maintaining minimum pressures to detect leaks when shut down, and following up with pipe investigation if damage is suspected. Kinder Morgan performs regular testing and maintenance and provides training for emergency responders on request by local agencies.[2]

The issue of emergency access to PPMT came up during the CEQA review of the Honda Port of Entry Project.  At that time, neither the Police Department nor the Fire Department had any concerns, and what concerns they had were focused on grade crossings potentially blocked by trains, not petroleum pipelines or tank farms. the DEIR concluded that Implementation of the following mitigation would reduce the impact of any emergency response issues to a less–than–significant level:

Mitigation Measure 5–9. The project sponsor shall prepare and implement an Emergency Response Plan, subject to review and approval by the Richmond Fire Department and Richmond Police Department, that addresses continuous emergency access to all properties potentially blocked by train crossings or switching operations. Possible approaches to improve or guarantee emergency access could include some or all of the following strategies:

• Install mobile communications devices on trains so that they can communicate their location and time at crossings with fire and police personnel.
• Install GPS tracking devices on trains so that fire and police dispatchers can track train locations.
• Install web cams at rail crossings so that motorists and emergency vehicle personnel can remotely monitor the rail crossings for blockage via computer, PDA, or smart
phones.
• Install a railroad preemption/warning system to alert motorists of crossing trains so that they can use alternate routes.
• Investigate the potential to locate a police and fire substation south of Cutting as a long–term solution.
• Investigate the potential to create a grade–separated crossing in the area.
• Schedule train traffic/switching after 6 p.m. since vehicle traffic on Wharf Street drops significantly after that time.
• Investigate the potential for an emergency access through PPMT facility to the east side of the rail yard. A locked gate to the proposed new BP/Arco entrance road could be established, with access codes or keys provided to emergency personnel (fire and police).

Interestingly, our newly safety-conscious Port has failed to implement any of them.

The “railways that transport chemicals or pressurized gas” cross access routes to the Harbour Way site just as much as they access businesses along Canal Boulevard. However, the Dornan Drive/Seacliff Drive access to the Riggers Loft avoids much of the railroad crossings and petroleum storage facilities along upper Canal Boulevard. Note that both sites have similar prospects for blocked rail crossings, but Harbour Way South  is probably worse because of the mile-long trains that BNSF runs through the area.

Security

The staff report also quoted the Unified Facilities Criteria, “Emergency Operations Center Planning and Design” as having a requirement to “Assure that the OSC/EOC is located in an area where it can be secured, “ and added, “ At least a portion of the Riggers Loft would need fences and gates to separate it from public areas.”

A careful reading of the Unified Facilities Criteria, “Emergency Operations Center Planning and Design” indicates that staff is both misquoting and misinterpreting it.

What the Unified Facilities Criteria, “Emergency Operations Center Planning and Design” actually says is:

3.5.1.5 Assure that the EOC is located in an area where it can be secured. Identify site perimeter, perimeter barriers and fences, control gates and other means of securing site perimeters.

3.5.1.12 Avoid locations that can have impaired access caused by collapsing bridges, damaged or flooded roadways, blocked rail crossings, or other man-made or natural impairments to access.

3.7.1 Controlled Access Area. The operations area of the EOC should be designed as a controlled access area. The area must have a continuous secure perimeter. The number of egress points must be kept to the building code mandated minimum.

5.1.8 SECNAV Instruction 5200.1R provides criteria for design of the controlled access area. Controlled Access Area (CAA) this term is a clarified definition of the current NAVSO P-5239-22 CAA: A physical area (e.g., building, room, etc.) which is under physical control and to which only personnel cleared to the level of the information being processed are authorized unrestricted access. All other personnel are either escorted by authorized personnel or are under continuous surveillance. A CAA shall comply with the physical security requirements of Section 3 of Appendix B to NAVSO P-5239-22. Within a CAA, a protected distribution system (PDS) will not be required for classified information processed at or below the classification level of the CAA. While unprotected cables may be run within the CAA, they will not be run outside the perimeter of the CAA.

The Riggers Loft is no less secure than 1411 Harbour Way South. There are only two ways to access the Riggers Loft. One is through Auto Warehousing, which is already secure. The other is via the loop road that is now known as Canal Boulevard. A securable gate across the end of the loop road would easily satisfy 3.5.1.5. The other security references are to building access, not site access. In either case, security of the building itself is more critical and readily achievable than security of the site. A pair of bolt cutters and a couple of minutes is all that is needed to breach the site of either building.

Requirements Ignored that Contradict the Staff Recommendation

While staff has cherry picked content of Unified Facilities Criteria, “Emergency Operations Center Planning and Design” that appear to support the staff recommendation, it has ignored other content and other facts that directly contradict the staff recommendation.

View and Visibility

For example, in the Port Of Richmond - Operations and Security Center - Comparison Of Site Alternatives, Matzorkis cites view as an advantage of the 1411 Harbour Way location:

There is a better, more comprehensive view of the Inner Harbor and other Port facilities from inside the building,

And staff cites a lack of visibility as a limitation of the Riggers Loft:

There is a limited view of the Inner Harbor and other Port facilities from inside the building.

In  fact, the Unified Facilities Criteria, “Emergency Operations Center Planning and Design” makes no mention of view or visibility as a desirable characteristic. Instead, it actually encourages subgrade locations and discourages locations on upper floors, like the Terminal 3 Control Tower:

Location within a Building. First consideration should be given to subgrade locations, where the EOC is protected from blast, wind-borne debris, windstorms and other hazards. Special caution should be given whenever proposed EOC locations are proposed on upper floors of structures. Access can be hindered with elevators out of commission and egress stairs compromised. Upper floors may be more susceptible to windstorm damage. Coordinate EOCs in subgrade locations with paragraph titled, “Site Evaluation.”

Exterior Envelope. Consider placement of EOCs in subgrade structures to provide the best protection from damage. Alternative strategies can include using earth berms to protect ground level building envelopes. Coordinate location of EOCs in subgrade structures with paragraph titled, “Site Evaluation.”

While staff has touted the extensive glass and high visibility of the Terminal 3 Control Tower as desirable characteristics, the Unified Facilities Criteria, “Emergency Operations Center Planning and Design actually discourages them:

5.2.2. Doors and Windows. The EOC should have a minimum number of door, window and vent openings. While windows are discouraged, if exterior windows or glazing is required, provide in accordance with UFC 4-010-01 and Physical Security requirements. Windows and air vents should be protected from flying objects and inundation.

3.1.1.4. Constructed so that assigned personnel can operate without being observed.

An OSC/EOC is principally a communications center, not the bridge of a ship where emergency managers visually observe the battle and direct responses. The obsolete control tower at 1411 Harbour Way South is simply not suited to be an OSC/EOC.

The Unified Facilities Criteria, “Emergency Operations Center Planning and Design” lists the “Basic Functions” of an EOC, all of which are communications-related:

2.1.5 Basic Functions. Basic Functions of the EOC may include the following.

• Receive, monitor, and assess disaster information.
• Receive, assess, and track available resources.
• Operate a message center to log and post all key disaster information.
• Conduct preliminary damage assessment and maintain documentation on extent of damage.
• Make policy decisions and proclaim local emergencies as needed.
• Provide direction and control for EOC operations, set priorities and establish strategies.
• Provide direction for recovery assistance missions in response to the situations and available resources.
• Keep senior, subordinate and tenant commands informed.
• Keep local jurisdictions (City, County and State) informed.
• Develop and disseminate public information warnings and instructions.
• Provide information to the news media.
• Execute tactical operations to implement policy, strategies and missions, and monitor and adjust tactical operations as necessary.
• Assess needs and coordinate evacuation and shelter operations.
• Monitor, assess, and track response units and resource requests.
• Coordinate operations of all responding units, including law enforcement, fire, medical, logistics, and coroner.
• Organize staging area and assignments for volunteer personnel.
• Augment radio communication from EOC to any field operation when appropriate.
• Maintain EOC security and access control.
• Provide for relief and necessities of response for EOC personnel.

Access

Staff maintains that there is only one major roadway to the Riggers Loft (Canal Boulevard), while stating the advantage of two major roadways to 1411 Harbour Way South (Harbour Way South and Marina Bay Parkway). That is not an accurate statement. Presumably, by “reached” staff means via I-580 interchanges. In addition to the Canal Boulevard interchange at I-580, The Riggers Loft can be reached via the Richmond Parkway/Castro Street Interchange using Dornan Drive and Seacliff Drive, which incidentally avoids any railroad grade crossings.

Staff cites distance from the Richmond Police Station as a factor, saying that the Riggers Loft is located 2 miles from the Police Station while 1411 Harbour Way South is only one mile. Staff also cites, without authority, that “The site shall be located near Highway 580 to limit travel time” and maintains that travel time is 2 minutes to 1411 Harbour Way South and 8 minutes to the Riggers Loft. I have driven both, and at the speed limit, the time from I-580 to the Riggers loft is 5 minutes, not 8 minutes.

Staff goes on to calculate the cost of staff travel to the two sites:

Riggers Loft: Per week, intraday travel for Port staff will be about 480 minutes or 8 hours. At $150 per hour, the total staff cost due to travel is $1,200 per week.

1411 Harbour Way South: Per week, intraday travel for Port staff will be about 120 minutes or 2 hours. At $150 per hour, the total staff cost due to travel is $300 per week.

In either case, that works out to 12 trips a day. What staff did not acknowledge is that the Port Administration Office is already located near the Riggers Loft at the former Shipyard 3 First Aid Station, and the Port Operations office is already located very near the Riggers Loft. Most of the Port business, in fact all of the operational Port Tenants but one, are located at Point Potrero Marine Terminal, not 1411 Harbour Way South. If the projected daily trips are to deal with Port business, the Riggers Loft is in the heart of the Port. If daily trips are maybe to go to lunch at Salute, 1411 Harbour Way South would definitely be closer.

As far as distance to the Police Station, there is no evidence that in case of activation of the OSC, personnel are going to race from the Police Station to the OSC and that a time difference of 3 to 5 minutes is critical. This is not a medical emergency. If they do race from the Police Station to 1411 Harbour Way South, they might find their way blocked by a mile long train and have to take a circuitous detour. In fact, Port staff has no plan for how the OSC will function, and when and if it becomes operational in an emergency.

Economic Factors

Cost

According to an email from Port staff dated April 5, 2012, the scope reduction would eliminate the 6,321 SF of additional floor area and simply renovate the existing 3,370 SF building and add an elevator. At the current projected cost of $3,295,994, that works out to a staggering $978/ square foot.  Spending the same amount of money to put the OSC in the 27,000 square foot Riggers Loft works out to $122/square foot. Staff has continued to characterize the 1411 Harbour Way South as requiring less work to make it meet essential facility requirements; however, it actually requires more work than the Riggers Loft. 2

Jobs

Most of the public testimony at the May 22 meeting focused on jobs. The fact is that both projects will result approximately the same number of construction jobs within the same time period, so there is no advantage either way there. However, with over 20,000 square feet of leasable space resulting from the Riggers Loft location, the prospects for long term jobs at the Rigger Loft are significant compare to 1411 Harbour Way South. Depending on the use of 20,000 square feet that could accommodate offices, industrial uses, or storage uses, the number of employees could range from 40 to as many as 200.

Port Revenue

Richmond has recently made a proposal to lease a portion of the Riggers Loft to the National Park Service for $0.75 per square foot per month. The market rate of rents for space comparable to the Riggers Loft ranges from $0.40/square foot to over $1.00/square foot, depending on the level of tenant improvements. The Riggers Loft could yield gross revenue to the Port ranging from $176,000/year to over $240,000/year.

Conclusion

All of the original impediments Port staff cited for using the Riggers Loft as an OSC/EOC have been eliminated. It is entirely suitable for use as an essential facility, and in fact, requires fewer and less expensive seismic and accessibility upgrades to function as such compared to the 1411 Harbour Way site. The time constraints for the two sites are now the same. Of significant economic importance is that while the cost of the two alternative is comparable, the Riggers Loft can be completed for a fraction of the cost per square foot compared to 1411 Harbour Way South. The Riggers Loft has the potential to create revenue for the Port and to create jobs, using the 20,000 or so square feet of additional space. The City of Richmond has just submitted a proposal to the General Services Administration/National Park Service to lease a portion of the Riggers loft for storage of artifacts from the San Francisco Maritime National Historical Park, thus providing dual returns for funds invested in an OSC/EOC at the Riggers Loft. The building at 1411 Harbour Way South is an obsolete, single-use building that has no clear advantages for use as an OSC/EOC or any other contemporary purpose.

[1] Terminology continues to be a challenge, using the terms Operations and security Center (OSC) and Emergency Operations Center (EOC) interchangeably. The “Fiscal Year 2008 California Port and Maritime Security Grant Program (CPMSGP)” described the facility as “ Operations and Security Center…The Operations and Security Center would provide a location in which to monitor and respond to any type of incident in the Port Area and not only would serve as the Port EOC, but could be used as part of the region wide resiliency plan. It also will provide the location to bring in all the data feeds being developed as part of the Port of Richmond security build out. This project mitigates some of the gap in MDA situational awareness.”
2 To make the building at 1411 Harbour Way South occupant ready  as an essential facility, it requires (1)Remove metal overhang, scales, and miscellaneous items from the site; 2) Install piles to accommodate Site Class F soils; 3) Strengthen the structure to the requirements of an essential facility; 4) Add elevator tower to the building; 5) Install seismic bracing to accommodate the essential facility designation; 6) Develop building floors as follows: a. Floor 1: Security Center – Open meeting area, private breakout space, and restroom b. Floor 2: Port Operations – Open floor plan, break room, and restrooms c. Floor 3: Port Administration – Conference room, private offices, and restroom 7) Provide new heating, cooling, and ventilation systems; 8) Provide network data room as head end for surveillance system and interconnect to emergency services; 9) Provide backup generator and solar array; 10) Rehabilitate the exterior cladding, window, and roof; 11) Rehabilitate interior spaces; 12) Eliminate the site work except as required for accessibility and to repair damaged surfaces.