ML19269D061
| ML19269D061 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/1979 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | Wilson L OAKLAND, CA |
| Shared Package | |
| ML19269D057 | List: |
| References | |
| NUDOCS 7902270089 | |
| Download: ML19269D061 (1) | |
Text
4 UNITED STATES g "'%q)g NUCLEAR REGULATORY COMMISSION
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i OFFICE OF THE CH AIRM AN The Honorable Lionel J. Wilson Mayor of Oakland Oakland, California 94612
Dear Mayor Wilson:
Your letter of November 13, 1978 to Jay Solomon, Administrator, General Services Administration, concerning the proposed relocation of our Region V Office was forwarded to me for information on December 11, 1978.
j We appreciate your interest in this matter.
Our understanding of the i
status of the proposed relocation is discussed below.
1 As you know, Executive Order 12072 requires that GSA consult with appro-priate Federal, state, regional and local governments so that their recommendations and objections regarding proposed site selections can be considered.
It also requires that GSA consider the impact on the effective performance of the mission and programs of the agencies involved.
We have recently sent to GSA information on how the proposed relocation could adversely affect the performance of our mission. We have also requested that GSA delay the plan to relocate to allow a fuller evalua-tion of the many factors which must be taken into account in such a decision.
A copy of this letter is enclosed for your information.
Should you desire additional information about the status of relocation of the NRC office you or your staff may want to contact Robert Engelken, Director, Region V, Nuclear Regulatory Commission, Walnut Creek. The telephone number is 415/932-8300.
He will be pleased to assist you in this matter.
Sincerely, i
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' J6seph M. Hendrie Chairman
Enclosure:
Letter to Jay Solomon dated 1/4/79 i
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Mr. Jay Solomon, Administrator General Services Administration l!ashington, D. C.
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Dear Mr. Solomon:
This is in reply to your letter of October 4,1978, concerning the proposed relocation of the flRC Region V office from !!alnut Creek, California to downtown San Francisco.
Our August 22, 1978 letter to you uas based on the premise that Executive Order 11512 was the primary basis for the proposed move.
C-iven that this was true, we reluctantly agreed to such a move provided that the relocation was to San Francisco.
!!e also requested a delay until 1981 i
to minimize the disruption to our mission accomplishment and to provide time for our employees to adjust to the nove.
I By letter of October-20, 1978 froa your Regional Commissioner, the !!RC Regional Director was asked to comment on this relocation in accordance 3-with the provisions of the Intergovern., ental Cooperation Act of 1955, Executive Orde;-12072, and-the-Of fice of Management-and Eud;;et. Circular A-95.
Consideration of these pertinent references, particularly Executive Order 12072 which replaces Executive Order 11512, now convinces us that the decision as to implementation of the proposed plan to relocate the f!RC Region V office shouTd be deTayed to alTow for a fuTTer evaluation of the many factors which must be taken into account in such a decision.
Following such an evaluation, I t;ould like to meet with you to review the conclusions prior to a final decision.
Since 1974 when the regional office was coved by GSA from Berkeley to l!alnut Creek, many of the !!RC employees have settled in the l!alnut Creek area. A move of the reg-ional office into San Francisco would adversely affect a majority of the present employees.
(see attachment)
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It is dif ficult for us to believe thaf. the relocation of approximttely 70 federal employees to downtown San francisco uill, in itself, raake San francisco a incre attractive place to live and uark (E.O.12072, paragraph 1-101) or improve the environmental conditions of San Francisco (E.O.
120/2, paragraph 1-102).
Congressmn fliller co:.1.:ented on the latter point at length in his letter to you dated Septe.nber 20,19/8.
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Executive Order 12072. requires consultation with appropriate Federal, l
State, regionil, and local goverannts so that th :ir reco:..ondTtions for and objections to proposed site selection. are consid2 red Ue understand j
from Congressman !! iller's letter that this relocation uould conflict j
with t.he regional planning of the Association of Bay Area Coverrmants.
Executive Order 120/2, Section 1-203(a) specifically requires the ef ficient performance of the inissions and programs of the agencies to be considered.
He believe that a move to San Francisco inight adversely af rect such performance.
This order also addresses employee morale issues such as adequate housing and transportation.
Our Regional Office has provided te your Regional Commissioners detailed information concerning the impact of a relocation on the agency iaission, on employee morale, and on retention of the Region V of fice.
A copy of that response is enclosed with the attachment.
As noted, we believe that the foregoing matters, considered in accordance with Executive Order 120/2, require us to request that the proposed move to San Francisca he held in abeyance pending further review of those and other relevant factors.
As I indicated above I would like to meet uith you to discuss this revieu prior to a final decision.
I note that the lease. at. MalnuL Crcek expires on June 20, 1979 arid assume that. GSA will nake appropriate arrangements to extend the current lease.
I have instruct.ed our staf f to cooperate fully with GSA cons-istent with the above.
Sincere'y, i
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Joseph I1. Hendrie
Attachment:
11/29/78 lt.r to Barton from Engelken, with llRC Comments on the GSA proposal to Relocate the Region V Of fice from the City of Ualnut Creek, California to Downtown San Francisco
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Arthur 0. Barton Regional Commissioner, Public Buildings Service General Services Administration, Region 9 525 b rket Street San Francisco, California 94105 t
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Dear Mr. Barton:
As requested in your letter of October 20, 1978, enclosed are our comments concerning the GSA proposal to relocate the Region V office, 11RC, to the central business district'of San Francisco.
The enclosed coments will assist GSA in its preparation of a comprehensive analysis of the impact of the proposed move, including the effect it vould have on I;RC, the Region V office and its employees.
The f!RC supports the goal of using Federal s' pace to strengthen cities; however, the meeting of Federal space needs nust follow the process stated in Executive Order 12072.
The Executive Order, augmented by Office of fianagement and budget Circulars A-95 and A-116, requires that i
serious consideration be given to the impact a proposal will have on the social, economic, environmental and cultural conditions of urban com-munities. Therefore, before a decision is reached on the proposed relocation of the Region V office, we agree that the varicus impach must be deliberated in an orderly, thoughtful manner.
The impact analyses must address the affects applying to both the losing and gaining cities.
After careful review of the pertinent documents, and in consideration of significant prograrrmatic and organizational actions now underway by f4RC, we believe that 1981 is the, earliest date by which a final decision can be made in accordance with Executive Order 12072.
The Chairman, tlRC, has made known these views to Mr. Solomon, Administrator, GSA.
Our j
comments point out many of the factors and fiRC studies which must be considered in the development of an environmental impact analysis.
As i
noted in the enclosure, Items IV.l.c and V.1, tie are requesting a copy of the report of the resul. s of any GSA consultations with governmental t
and coaaunity groups conducted in performing this analysis.
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Arthur 0. Barton ' ~
The !!RC will cooperate fully with GSA aiming toaard a decision in 1931.
In the meantime, we request that your of fice expedite the negotiation of required additional space for prompt occupancy in '.'alnut Creek and extend the lease through 1981.
By separate correspondence, va have responded to Mr. Yiakis' request of l'ove.Tber 6,1978 for details on the additional space needed at our present location.
Sincerely,
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R. H. Engelken Director
Enclosure:
i As Stated i,
i cc U/ enclosures:
E. L. Kirby, P.cgional Facilities Planner, GSA l
J. P. Yiakis, Director, Space fianagement Div., PBS, GSA, Region 9 J. G. Davis, Acting Director, IE, fiRC J. M. Hendrie, Chairman, !!RC I
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Ui;1TED STATES i;UCLEAR REGULnT0?.Y CO: liSSIGl I:i G 10:1 V j
UAlf;UT CP. LEK, CALIFOR::IA f
!!RC CO.NMEi4TS ON Tile GSA PROPOSAL TO RELOCATE TliE REGIO!i V 0FFICE FR04 Tile CITY OF UAll1UT CREEK, CALIFORi!IA TO DOMiTO'.!;i SAii FRAi:CISCO 1.
Purpose This statemenc has been prepared in response to the October 20, 1978 request from A. O. Barton, Regional Co aissioner, Public Buildings Service, Region 9, GSA, in conforr.ance with Section 1-202 of Executive Order 12972, August 16, 1978.
The inforcation pro-vided in this statement will assist GSA in its preparation of a comprehensive Environmental Impact Statement pertaining to the proposed relocation of !!RC Region V as part of GSA's program of relocating Federal agencies to the central business district of major cities.
II.
Background _
Discussed herein are the numerous effects the proposed relocation vould have on the I RC and the Region V office and its cuployees.
Analyses of the costs and benefits of progracmatic, personnel and, l
environmental impacts are included.
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III. Impact on the Agency.
1.
Convenience and Cost of Location (a) Accessibility to Office There might be a slight improvecent in accessibility to the office by certain licensees and some c. embers of the publ ic.
A location in San Francisco would be closer to the San Francisco airport and to major hotels.
- However, any improvement in accessibility would be offset by increased operating costs incurred by visitors, the liRC and licensee organizations.
The cost of lodging and meals is significantly higher in San [rancisco than in the Malnut Creek area.
The $50 i
Federal per diem rates for San Francisco are over 40'/,
liigher than allowable rctes for Ualnut Creek.
Al though the cost of transportation from the San Francisco airport i
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to Walnut Creek is greater thin that to du.mtcun San Francisco, f or s tays ler.ger then two days, Ualr.ut Creak l.ts the j
competitive edge.
Therefore the cost of sup;mrting official business trips to an i;RC office in San Francisco versus the of fice in Ualnut Creek will in r.uny instances he greater for both private companies and federal agcacies.
(b)
Availabili ty of Acco rmadations The frequency of v.sitors and ic;al r ::cin.,s t a be2n increasing end will continue to do so in tna future.
Changes in operatior.21 techni<pm and practices ins resul ted in greater involveJ ent of Region V e.nployees in I!RC:!;Q: projects.
I'cre idC wployes are craveling to Region V with greater frequency for u etings, planning sessions and the conduct of joint I;RC-licensea se'ainars.
Of ten meetings and seminars are arranged on relatively short notice and require the leasing of conference roox.s at motels.
t Dur experience in arranging for lodging and meeting rocas I
is that space frequently is not available in San francisco.
On the other hand, motels in the Walnut Creek-Concord area have been able to provide such accomodations and at a cost substantially less than prevailing rates in San francisco.
If we had been located in San francisco, travel uould have been requircd outside the city to hold reeetings and seminars, resulting in lost time and in-convenience to attendees.
Retention of the office in Halnut Creek of fers i., ore benefits for accoma:odations than a city such as San francisco, i
(c)
Coa,munications With Other Federal Agencies Essentially all of our infrequent official contacts and dealings with other iederal agencies is by telephone or mail.
This holds true for those agencies located in San francisco.
Also, it is irr:r.aterial where our office is physically located since the method of contact would remain the same.
A San francisco location would offer no improvement in com.municat, ions With other federal agencies.
i Summary - Convenience and Cost of 1.ocation j
(d) lio benefits will a crue to the liRC, the public, ilRC licensees or other teral agencies by the Region V of rice being relocated to San francisco.
On the cont.rary, problems vould be created and additional costs would be f
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incurred by all parties.
Sections 1-lC?(b) and 1-105 of Executive Order 12072 have been considered and determined to have no applicability to the need for relocatien.
The convenience of the public served, as centioned in Section 1-203(a), may be adversely affected by a move to San Francisco.
2.
Mission performance (a)
New Programs Major codifications to GC programs are currently under consideration or in progress.
They are scheduled for completion or for -final de-ision in 1930.
A relocation of the Region V office fro, Walnut Creek prior to ccm-pleting the evaluation of these programs would have a disruptive effect on schedules and plans and might well be inconsistent with the final decisions that result from the studies.
Among the new programs are decentralization of HQs functions involving nuclear reactor licensing, liaison with State agencies and byproduct material licensinn, t;hich would require moving HQs personnel to the regions; a three-phased major modification of inspection programs conducted by regional inspectors which would revice inspection procedures and methods and possibly move more inspcctors to reactor sites; and, a restructuring of
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regional boundaries and offices which would consider consolidation of some offices and establishment of new of fices to meet shif ting work load patterns.
The dis-traction of a major relocation would impede implementation and possibly severely impact the expected beneficial l
results of these programs.
(b)
Employee Morale The majority of the Region V cmployees live within a short commuting distance of the Walnut Creek office.
Most of the employees purposely selected residences with i
the objective of minimizing commuting time and costs, conserving energy, and at the same time achieving desired community living.
The proposed relocation to San Francisco is completely contrary to their expectations for a con-tinued suitable work environment.
Employees will suf fer significant hardships in terms of a real dollar loss in l
take-home pay due to increased commute costs.
The in-creased cost is infictionary in that no benefit results i
from the additional expense.
Also, the employees and their families will suffer the loss of time at home due to increased commuting time.
The resulting negative impact on employees will have an adverse effect on morale uith possible negative effects on high standards of performance.
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(c) Recruiting Ue cannot stress enough the influence a good location, such as that offered by the City of Walnut Creek, has on our ability to recruit and retain experienced profes-sionals in the fields of nuclear engineering, radiation protection and nuclear material safeguards.
This is a j
major issue.
The liRC has faced this problem before and has been forced to relcrete regional of fices in order to attract and retain the nigh cali' ar pr ;fessicnals we c
require in our inspection programs.
The relocation away from an attractive work and r.earby resider tial envircraent to the central business district of a high-cost city with its attendant lack of parking, insdepate cransportation system and time consuming commutes will adversely affect our recruiting program.
The relocation night well impair liRC's ability to retain the present regional office staff.
Our ability to maintain high performance standards.
night well be adversely affected.
The recruiting issue must consider possible added costs to the agency and the taxpayer.
Each of our new in-spectors undergoes two years of intensive training b'efore l
being qualified to conduct inspections.
Both on-the-job f
and for.nal classroo.T training is provided at a cost of about $100,000 per employee.
Each loss of an experienced inspector because of a relocation will require an outlay of $100,000 to train a replacer.:ent.
This type of outlay l
benefits no one.
There is a high probability of losing at least three employees imcdiately upon relocation to l
San Francisco.
The !!RC recruiting experience over the years has shown that the staff is not recruited from large city popu-
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lations.
The industries from which nost of our employees come are not suited ta urban locations.
He do not draw employees from one lor ale, consequently our regional office would have little impact on local employment.
In fact, location of our of fice in San Francisco could i
displace an employer who night utilize the indigenous j
population.
l (d)
Emergency Response i
A relocation of the Region V office to San Francisco would disrupt the ability of the ilRC to carry out emer-gency response responsibilities.
As a result of public and congressional concerns, the t'RC has become increasingly sensitive to the matter of response to emergency situations W
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involving radiation incidents, r.ucl:ar, cower plant accidents, and threats to the security of ruclear materials or facilities using such meterials.
Prompt dispatch of properly equipped and fully infccmed investigative teams is a necessity.
The response process requires quick access to the regional office to establish and man a j
response center, provide staff members with the necessary material, and to make travel arrangements.
Since our senior professional and administrative staff is currently loca ted within 20 nicates of the '.:alr.ut Creek offic', '.ca can be ready to cope uid e.nergencies in e short time.
On the other hand, a cove to San Francisco would un-quastionably delay the prccess end deper.oir.g on the time of day, could add several hours to cur response tine.
There are witernatives to consider in responding to-emergencies.
Increased response time, however, would not be considered an acceptable option.
ile could maintain duplicate equipment and files at employee residences, or even provide around-the-clock coverage in the regional office.
These alternatives would be costly and not totally effective.
Additional files and equipment would have to be set up and additional staff might be required.
These actions would be contrary to Presidential and agency efforts to reduce federal spending and federal employmen t.
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'(e) Overtime Activ.ities A relocation to San Francisco will increase employee i
working days by two to three hours.
The increase will result from added commuting time.
The lengthened working day will reduce voluntary overtine work and adversely impact paid overtime.
The timely completion of priority assignments could be affected by the loss of overtice options.
Alternative considerations such as required overtime will i
not iz c3, uco ol e to s ta f f neahers.
Hiring additional staff to compensate for lost overtime is costly and counter to efforts to reduce federal spending.
Con-tracting work is not presently allowed.
(f) Oper? ting Costs Op:<31i... costs in San Francisco will be higher than that ex,nnri enc e?
a.'alnut Creek.
The added costs wili not beratit 'i'. !r the IRC or the taxpayer.
As one example of hM a rating costs, the r.onthly square foot rental co. _
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..ut Creek range frem 30 cents to $1.15.
The l oue" figur e applies te first class office space, the
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higher to premium space.
First class office space in San Francisco rents for Sl.C0 to 51.55 per square foot.
Additionally. from a business-cc.T?. unity stand point, the City of Halnut Creek would benefit more from the presence of this agency than uauld San Francisco.
There is space available in Halnut Creek at the lower figure, whereas the availability of first class space in San Francisco appears to be essentially unavailable until mid-1930.
Other economic M; acts such es the cost of nouang government vehicles and the cost of utilities must be considered.
(g)
Summary - Mission Ferforr:ance
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The proposed relocation of the Region V office, ISC, to San Francisco will adversely affect t!.e ability of the agency to efficiently and effectively perform its functions i
I and will have a detrimental impact on operating programs.
I There are no identifiable benefits accruing to the Government, the tiRC, or the public from the proposed j
move.
j Section 1-104(c) has been considered and determined to have only a negative impact.
The GSA proposed relocation j
will conflict with the policies of the Executive Order l
specifically resulting in actions contrary to the intent of Sections 1-201(a),1-201(d),1-203(a), and 1-203(d).
IV.
Impact on the Ecoloyees_
1.
Commuting (a)
Increased Costs About 905 of the Region V employees ucrking.in Walnut Creek spend less than 60 m-inutes per day corrauting between their residences and the office.
(Over 60", of the staff lives within ten miles of the office.
The minimum daily commuting time is less than 10 minutes.) These employees I
live in the Walnut Creek-Concord area or along direct commuting corridors to Malnut Creek.
Weekly commuting
- osts amount to less than $3.50 per employee.
Relocating the office to San Francisco would increase each individual's commuting time by minimum of two hourp per day.
There would be a minimum cf a threefold increase in daily coc. muting tre.
the average increase in commute time would be six times and the maximum 18 times current commuting times.
Depending on the mode of
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t transportation, individual cc:rinuting costs would increase in amounts ranging from S12.50 to $22.00 per week - up to a six fold increase in cc: muting costs.
The cost of automobile insurance would increase significantly for those employees using private vehicles for commuting.
In these dcys of diminishing purchasing power of the i
dolk.c and when federal cay raises lag behind the rate of inflaticn, it is dif ficult to justify '...y federal alcyees should part with hard-earned dollars to pay for commuting longer dis ter.ces.
It is equally di fficult to justify vhy employees should sacrifice, as a nini rn, an additional two hours per day - ten hours per. eek - 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per month - of their leisure time - time now spent at home with their families, for the purpose of commuting to a l-city 20 or 25 miles from their present location.
Other than remaining in the Ualnut Creek area, there are no meaningful alternatives to consider regarding additional co.rmuting time and costs.
(b) Commuting Options The manner and case by which Region V employees could get back and forth to San Francisco during peak commuting
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hours is an issue which must be addressed.
There is no alternative to consider except not to commute.
Since i
most of our employees will be taking the Concord-Walnut Creek path to San Francisco, there are only two options available -
by automobile along Route 24 or by BART.
The BART commute hour capacity is inadequate to handle the present volume.
Plans to alleviate the situation will not suf fice.
Forcing more riders on to BART will l
exacerbate the commuting situation.
The Route 24, I-580, Bay Bridge corridor is saturated with vehiclar commuting.
Driving is hazardous, nerve racking and time consuming; vehicle pollution is a major l
probicm and one that the Association of Day Area Governments I
l is diligently trying to overcome.
Parking in San Francisco is at a premium - both availability of space and cost -
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and will worsen because of a new policy in San Francisco of intentionally not providing parking for tenan'ts of new office buildings.
(The policy is to discourage the use of private automobiles in the city.)
The policy of GSA to encourage core commuting to San Francisc is contrary to Federal, State and Local Government programs to conserve energy and reduce environmental pollution.
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(c)
Summary - Impact Cn Employees - Cc. suting Not a single factor can be identified which would benefit the Government, the NRC, the publ.ic or NRC employees if the Region V office were required to relocate in San Francisco.
On the contrary, the proposed relocation would have significantly adverse impacts on the personal lives and i
I fincncial stetus of the NRC eralcyees and their families-On a collective basis, the relucaticr would result in an immediate loss of at least $30,000 annually to the employees.
More realistically, the annual loss probably would be close to $50,000.
Additionally, a binimum of 25000 hours would be added to the annual work effort with no apparent benefit to anyone.
The proposal by GSA to relocate the Region V HRC office is contrary to the requirements of Section 1-104(a),1-l 104(b) and 1-203(a) of the Executive Orders.
The proposal is not consistent with the criterion established in Section 1-104(e).
The Executive Order requires that GSA consult with and i
coordinate proposals with other governmental bodies and community groups.
Sections 1-20i(d),1-203(b),1-203(c),
1-203(d) and 1-204 are applicable to this catter.
The Region V office, URC requests copies of 'any GSA reports and analyses that resulted from these consultations.
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2.
Health and Uelfare (a)
Increased Use of Lehve Because of the necessity for maintaining health care facilities near one's residence, relocation of the Region I
V office to San Francisco will result in an increased use of sick and annual leave.
Many dentists and physicians do not have weekend hours.
Therefore, for personal and family health care situations, employees will be required to use more leave to attend to health matters.
The increased use of leave will deprive employees of-the use of annual leave for vacation or recreational uses.
Furthermore the increased use of sick leave adversely impacts the employee's ~ option of accumulating sick leave for eventual inclusion in the computation of retirement annuities.
The potential financial loss could be sub-stantial.
There is no stay to compensate for this loss.
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(b)
Loss of Personal Time Increased co:rauting tine to San Francisco will deprive the staff of time pre 5ently available fcc f amily purposes and community and cultural activities.
The added loss of personal time will have a detricental effect on the The general welfare of the regional inspection staff.
inspectors now spend a minimum of one-third of their weekdays away frcm hor.e.
Frearntly travel or inspectida ef fort. occurs on weekends.
The loss of personal tina due to increased cornuting will have an adverse effect on employee morale and will lead to intangible losses in employee productivity.
Both the employee and the agency will suffer as a result of required additional commuting time.
l (c)
Increased P.isk of Bodily Harm Employees will be subjected to increased risk of bodily harm as a direct consequence of increased travel on over-crowded highways to San Francirco during peak traffic times.
The chance of being involved in an accident will j
increase for those driving on Route 24 and I-580.
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(d) liousing i
The availability of adequate low and moderate housing for.
l federal employees and facilies is lacking in San Francisco.
I This would severely hamper the ability of ISC employees to find suitable housing at an affordable cost.
One viable alternative to the high cost of San Francisco',
which is available to both present and future employees, is to consider housing along the Route 24-680 corridors.
For new employees this means comuting.
Many of the professional employees are in their early or mid-career period.
They are still raising families and are engaged in cornunity, social and religious activities' resulting in a preference for suburban living.
These employees feel that they should not be required to b
sacrifice the advantages of surburan living and suffer the adverse effects on the quality of their lives that.
V ould result from relocating to an urban environment.
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(e)
Summary - Health and Uelfare of Employees The proposed relocation to San Francisco uill have a serious detrimental effect on the lives of the tRC employees and families.
While the adverse ef fects en the
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welfare of Region V employees ias no direct icg?.ct en other governm.cntal agencies or ne.rbers of the public, reduced cmployee morale could adversely affect the quality of the services rendered by these employees.
Consideration of the criteria set forth in Section 1-104(c),1-104(d) and 1-203(a) in evaluating the impact of the proposed relocation clearly establishes a severely Mothing can be adverse affect on the NRC employees.
identified that in any.:ay of f sets this a6. >. se impact.
G nera1 impact V-X 1.
Urban and Cccmunity The relocation of Federal agencies to the central business districts of selected cities as proposed by the General Services Administration includes a responsibility for CSA to prepare a comprehensive analysis of the cost, ber.efits end the impact on cities and communities as a consequence of that proposal.
I 16, 1978, requires that GSA de'velop OMB Circular A-ll6, August such analyses and that potentially adverse impacts be identified The impacts to be analyzed during the decision making process.
include those identified in Executive Order 12072 (Secticos 1-104(c),1-104(d) and 1-203(a)).
Additionally, Executive Order r
8 12072 identifies other requirements and criteria to be con-Examples are Sections 1-101,1-102,1-104(a),
sidered by GSA.
1-104(b),1-104(e),1-201(a),1-203(b),1-203(c) and 1-203(d).
OMB Circular A 95 (Revised - January 2,1976) requires the J
submittal of certain reparts to State and Local Governments and to Federal agencies.
The information developed for these reports as well as the impact analyses developed pursuant to OMB Circular A-ll6 and Executive Order 12072 will have a direct bearing on the proposed relocation of the URC Region V office.
Therefore, we request that copies of these reports and analyses be provided to URC.
In addition to other issues, ue believe the GSA analyses should address the following:
the overall impact of locating Federal agencies in the h
CBD of San Franc'isco, especially in light of the demand for space by private enterprises, the inadequacy of public ' transportation, and the lack of perhing the, optimum mix of public and private employment in the CBD of San francisco w
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5 the i.. pact on cities and con nunities losing f ederal cgencies under the G M proposed relocation progrca the criteria used in determining that the CBD of San francisco is in fact in need of revivification and in need of additional federal facilities to encourage development and redevelopment; and the impact statement addressing these scatters l
the cri terie u:;d n; appir. n tly de::c,'ini.-, cha t the City of Ualnut Creek does not need revivification and the presence of feJerci Gr.ili cies t a enccm;2 dev21opont and redevelo;r.'nt.
Regarding these issues, it is obvious that the loss of the IRC office to the City of Halnut Creek ticuld be measurable, thareas the gain to San francisco is theoretical at best.
The real socio-economic benefits derived by the City of Malnut Creek fro:n the presence of the i;RC office far out'aeigh the theoretical l
benefits that tiould result to the City of San francisco if it tiere to ba located there.
The costs to the I;RC, the public and the flRC employees, on the other hand, ere substential and considerably ouuteigh any benefits to be derived from such a relocation.
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