Response to Comments - Presidio Trust

The financial analysis in Appendix A of the Final SEIS provides a realistic view of the costs associatedwith the PHSH project, including anticipated initial development costs. The Trust expects that leases (fornon-residential buildings) would be structured as “triple net” leases under which the tenant is typicallyresponsible for many of the building’s operating costs. For a long-term lease, it is normal to shiftvirtually all operational costs to the tenant.Many of the costs associated with the project would typically be borne either by the developer (e.g.,upgrading utility systems within buildings and leased areas) or by all tenants through the Service DistrictCharge (SDC). The Trust uses the SDC mechanism to recover costs associated with providing municipallikeservices such as road and sidewalk maintenance and police and fire services.Finally, while virtually all operating costs are expected to be borne by the developer or through the SDC(to the extent any are borne by the Trust), there is no reason to expect a material difference in operatingcosts among the alternatives (other than the Requested No Action Alternative). Thus, while operationalcosts would generally be expected to increase with the reactivation of the district under any of thealternatives other than the Requested No Action Alternative, Alternatives 1 through 4 are not expected tohave material differences (if any differences) in costs not covered either by the developer or through theTrust’s SDC.1.6 DISTRICT-WIDE PLANNING (DP)DP-1. Development Plans for the Entire DistrictRPN and NAPP stated that the Draft SEIS does not analyze alternatives that encompass district-wideplanning. “While the PTMP considered the PHSH site as a 42-acre whole, the Draft SEIS, despite someallusions to the entirety of the site, is really only a development plan for the 18 acre Lower Plateau,featuring more dwelling units than was contemplated under the PTMP.” They maintained that by notengaging in district-wide planning, the Trust may be reserving its right (“leaving the door open”) toengage in new construction on the upper plateau in the future. They viewed the Trust as positioning thedistrict for maximum flexibility, and asserted that “we cannot know what the PHSH district will becomeand thus cannot effectively evaluate the alternatives presented.” And, “[w]ithout a district-wide approach,the cumulative impacts of revitalizing the PHSH district are understated and the environmental analysis isincomplete.” The LSRA and the PHRA concurred, offering that, without district-wide planning, thecumulative adverse impacts of the entire site on both the adjacent neighborhoods and on park land wouldbe underplayed.Response DP-1 – The commenters’ earlier requests for a district-wide plan were responded to inAppendix A, Section A.1.5 (District-Wide Plan Alternatives) of the Draft SEIS (page A-5 and elsewhere)and are repeated and expanded upon here.The currently proposed project involves reuse of buildings within the PHSH district and includesalternatives that would rehabilitate and reuse buildings on the upper and lower plateaus. In addition, one24 Responses to Comments Public Health Service Hospital