SAHPC: The Expert Testimony is In

On December 10th Judge Barbara Miller of the Alameda County Superior Court required all parties to the lawsuit against the University of California's plans to construct an athletic center just west of the California Memorial Stadium (CMS) to submit expert testimony as to whether the new center was entirely independent of - or an upgrade to - the stadium.

The issue is central to claims made by the City of Berkeley, the Panoramic Hills Homeowners Association, and the California Oak Foundation that the new athletic center is an upgrade to the stadium and therefore subject to a California seismic safety law, titled "Alquist-Priolo" (AP) that limits upgrades to structures like Memorial Stadium that sit astride active earthquake fault traces.

In her order, Judge Miller asked for expert testimony as to whether the two structures were "structurally independent".

By asking for testimony on that specific issue, Judge Miller appears to be rejecting plaintiffs' argument that she should rely upon a literal reading of the words in the AP law that says any alterations or additions to a structure on a fault constitute an upgrade that is subject to the law's limits. Instead, she appeared to have settled on a more fundamental issue: whether the buildings are structurally independent.

This criteria seems stronger than words like "alterations" that could apply to even the most minor changes; if two buildings are structurally independent, then one can hardly be claimed to be an upgrade to the other.

Testimony was due February 22nd, one month after the judge ruled against a plaintiffs' request that this expert testimony not be allowed into court. Plaintiffs did not want this testimony admitted.

Friday the plaintiffs submitted the testimony of Fariborz Barzegar, the founding principal of Habitat Engineering and Forensics, a consulting firm based in Oakland and Fremont that does structural engineering analysis. The firm's web site link to its "people" lists only Barzegar, and among other services lists his availability as an expert witness.

In his testimony Barzegar said that the new center, located (largely) underground just a few feet west of the stadium, would provide retaining-wall support to the soil under the stadium, and that therefore the two structures were interdependent.

He further said that since earthquake damage to either of the two structures might endanger the health and safety of people using the other, the two structures were interdependent.

He also supported plaintiffs' claim that structural independence was not the issue the judge should even be considering, asserting again that the "plain-word-meaning of AP" was the correct standard to use.

This is thin gruel on an issue that is of such fundamental importance to a major project.

[Author's note: Testimony from three additional experts for plaintiffs was put online by the court after this article was written. A supplemental article will discuss their testimony.]

In notable contrast, the University submitted the testimony of 6 experts, including David Friedman, Board President of Forell/Elsesser Engineers (E/F), Edward J Denton (the University's Campus Architect and Chief Building Official), Anthony Yuen (the Lead Designated Campus Fire Marshall), Joseph Diesko (a Licensed Architect and Vice President of HTNB Architecture, Inc.), and Jeffery A Maddox (a principal of The Fire Consultants Inc. who advise on and peer-review fire and building code compliance for campus projects).

Friedman's firm (E/F) has 40 years experience in structural and earthquake engineering that includes lengthy involvement with Memorial Stadium projects. They have over the years led engineering work for projects as diverse as city hall projects in Berkeley, Oakland, and San Francisco, the Asian Art Museum in San Francisco, and the main library seismic upgrade in San Francisco.

In his testimony, Friedman said that the design mandate from UC was to design a "stand-alone" building, "structurally separate and independent from California's Memorial Stadium (CMS)". He added that if the buildings were to be integrated, substantial structural changes to the CMS itself would have been required.

His testimony explains that seismic safety for the athletic center required that it be able to move independently of the CMS during an earthquake - and that achieving that required complete structural independence.

Friedman described the physical separation between the structures in some detail, with frequent references to drawings already in the court record. Using those, he illustrated both the vertical and horizontal separations between the buildings, and explained how even in an intense earthquake the structural components of the two buildings would never touch or endanger each other. "This four foot distance is more than adequate to guarantee that the two buildings will not touch each other during an earthquake," he said in one instance.

He emphasized that the designed separation was specifically included so as to comply with the intent of AP law. He added that the "structural separation between the athletic center and the stadium was the unequivocal design intent" of their work.

He later declared, "There is absolutely no structural connection between any part of the (athletic center) and the CMS."

This was apparently a long-standing design criterion. Said Friedman, "… we and the experts with whom we were associated knew since at least the winter of 2005/06 that we were not designing an addition or alteration to CMS; we were instructed to design and have designed a new fully independent building, structurally and otherwise.

Note the key words, "not designing an addition or alteration to CMS". That phrase clearly was intended to directly contradict the key argument made by plaintiffs in the case.

Friedman's testimony contained some interesting comments on UC's documents that are already in the court records.

In one instance, he admitted that a few design features that had made their way into documents in UC's EIR had "violated the intent to make the athletic center and CMS separate structures." These features were used by plaintiffs in court to assert that the buildings were integrated structures, but Friedman notes now that "we (later) caused that design to revert to the simple discipline of a separate structure."

Friedman's testimony also directly attempted to rebut plaintiffs' claims that "additions or alterations" to the stadium constituted upgrades to it. He cited a California Building Code (CBC) section that says that the words apply only to two buildings that are structurally dependent, and that since the athletic center and the CMS are not - the argument does not apply.

"There is simply no structural connection or dependency between the (athletic center) and CMS. We consciously and purposefully designed the (athletic center) to be this way," he testified.

Much has been made by the plaintiffs about a "grade beam" that will be placed under the west wall of CMS because of the athletic center project. They have claimed that the beam proves that "additions and alterations" to the stadium result from the new project.

Friedman explained that the grade beam (an underground concrete reinforcement) was a routine precautionary measure intended to protect the existing structure when excavations down hill might affect its structural integrity.

Said Friedman, "The new grade beam is not structurally attached or connected in any way, shape, or form to the (athletic center)."

He also addressed a statement in project documents that imply the athletic center in some way "buttresses" the foundation of the west wall of the stadium. He spoke to the point because plaintiffs have used that statement to assert the structural interdependence of the two buildings.

"The (athletic center) is not a buttress to the CMS is the sense of a buttress being a structural component, because the structures of the two buildings are not connected in any way."

In the final paragraph of Friedman's testimony he asserted that, "the complete structural separation between the CMS and the athletic center guarantees that the Center will not be subject to the hazard of earthquake fault rupture and, in so doing, also guarantees the (athletic center) honors the central purpose of AP law." Because the language of AP does not define "alterations", "additions", or "upgrades", much of the controversy in this case has been about the meaning of the law. Thus Friedman's use of the words "honor the central purpose of AP" is another effort at defining its meaning.

Edward Denton, in his testimony, describes the staff of 650 people who report to him, of whom 140 are architects, planners, engineers, inspectors, and contract administrators, among other professions. One of his "reports" is the Seismic Review Committee that advises him on structural design of campus facilities with particular regard to seismic performance.

Denton is directly responsible to ensure that all campus buildings comply with the California Building Code and Alquist Priolo (and all other laws and regulations).

Campus projects are not subject to review by county or municipal building officials, but must instead be approved by both Denton and the Campus Fire Marshall Anthony Yuen whose job it is to ensure compliance with all codes related to fire and life safety.

In his testimony Denton drew some parallels to private property owners and their building projects. He explained that Cal's Athletic Department is like the private property owner who wants to build, and that his role is like the local building code inspector. He presents projects he has approved to UC's Board of Regents that serve in a manner not unlike a local planning board that keeps watch over the community's broader plans and goals.

Denton recounts how from inception the athletic center was conceived and designed to be a separate structure, adjacent to but separate from the stadium. That separation arose from two key factors: the first was the goal to provide as soon as possible a seismically safe structure for the current occupants of the stadium. He acknowledges that insufficient funds were available to construct the center and retrofit the stadium at the same time, so the decision was made to build the center first. Second, were the two building not separate, substantial changes to the stadium would also have to be made in order for the new athletic center to be safe. Avoiding structural connections between the two buildings thus reduced project costs and completion schedules substantially.

AP law has already had a substantial bearing on the decision process employed by Denton's office. In his testimony, Denton described the process used to determine that the new center did not overlay any active fault traces. Peripherally he noted that if the new center were indeed an upgrade to the stadium, no excavations to find fault traces would have been needed - because they already knew the stadium sits on the Hayward fault. It is only because the center is a new separate construction that they had to verify there were no fault traces under it.

Denton made one almost parenthetical remark about the grade beam near the end of his testimony, commenting that its cost ($250,000) was insignificant in relation to the stadium's value that he pegged at $593 million dollars. Superficially he appears to be saying merely that this undeniable alteration to the stadium is insignificant, but he may also be trying to build the record as to the value of the stadium, a value that has been much questioned by plaintiffs. Still, if the athletic center is NOT an upgrade to the stadium, then the value of the stadium need not be determined for purposes of computing AP limits on upgrades to a structure on an active fault.

Plaintiffs have raised numerous questions about drawings in UC's EIR where they claim to see structural connections between the two buildings.

Denton testified that some of the drawings used in the EIR are now obsolete, that they have been replaced or modified in later work. He explained how design and construction drawings go through many versions and are created by a variety of teams working on different aspects of the project.

"I know from first hand experience … that it is common for there to be discrepancies among different types of drawings … and it is often difficult to … coordinate perfectly the drawings from all sources," he testified.

Denton explained how discrepancies in drawings are resolved over time as a project design moves to completion; he also described how some more fundamental drawings "trump" others that address less central matters. For example, a building structural drawing, he said, would trump an "interior architectural rendering" if the two happened to differently describe the same element.

Using this background, Denton asserted in a point-by-point analysis that plaintiffs had either "misread or misinterpreted the drawings", or "cited a drawing that is not the authority for the point they are trying to make", or "cited a drawing that had been later changed or corrected".

He added that even though the Regents have approved the design of the athletic center, "Construction cannot begin until my office deems the final construction drawings for the project to be complete and in compliance with all applicable provisions of the CBC and AP." He added, "Construction of the (athletic center) will not begin unless and until the final construction drawings depict the (athletic center) as a stand-alone structure that is neither an addition nor alteration to CMS."

This makes clear a key problem faced by plaintiffs in preparing their claims on the AP issues: they did not have final construction drawings upon which to base their claims - and even today those have not yet been finally approved.

But this also makes clear a difficulty the University faced in assembling their EIR: they also did not have final drawings to put in it, so the document inherently could not be a final and accurate description of the project. Plaintiffs can be expected to complain about that vociferously.

It is therefore possible that Denton's testimony will substantially help clear the AP concerns before the court, but it may make EIR concerns more problematic.

Campus Fire Marshall Anthony Yuen is designated by the State of California to be the Lead Designated Campus Fire Marshall and to act on behalf of the state to enforce regulations and building standards relating to "fire and panic safety" in the CBC for all campus owned and occupied buildings.

Thus he too acts like a building code inspector whose approval is necessary for all campus construction projects to proceed.

Yuen joined Denton in asserting that the two structures are independent, and that the new center does not include alterations or additions to the stadium. He adds the unique perspective of a fire marshall, however, when he testifies, "There are no piping, electrical, or mechanical ventilation or openings between the CMS and the (new center)," matters that are critical to fire suppression and containment.

According to his testimony, the two buildings have dedicated and separate fire alarm systems, and that the automated fire sprinkler systems and water supply systems are totally independent. He notes that were the two buildings integrated, the fire systems would have to be integrated too, and they are not. Even evacuation routes are totally independent; the exiting paths from the two do not interfere with one another.

He completes his testimony with a professional opinion that the proposed construction of the new center will not pose any additional fire hazards to the stadium, and notes (once again) that, "Our office has not given final approval to the (center's) construction documents as they are still under development."

Tomorrow: comments from Diesko and Maddox.

Objections to the expert testimony submitted by the two sides must be field with the court this Friday, February 29th. On March 7th, each side will have the opportunity to support its position in oral argument before the court. That will be the last hearing in this matter; a ruling is expected within 30 days thereafter.


©Copyright 2008, BearInsider.com and Scout.com. All rights reserved.

If you haven't done so already, subscribe to The Bear Insider so you can participate in this active online Cal community and get access to the members-only content from the nation-wide Scout.com network.

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The issue is central to claims made by the City of Berkeley, the Panoramic Hills Homeowners Association, and the California Oak Foundation that the new athletic center is an upgrade to the stadium and therefore subject to a California seismic safety law, titled \"Alquist-Priolo\" (AP) that limits upgrades to structures like Memorial Stadium that sit astride active earthquake fault traces.

In her order, Judge Miller asked for expert testimony as to whether the two structures were \"structurally independent\".

By asking for testimony on that specific issue, Judge Miller appears to be rejecting plaintiffs' argument that she should rely upon a literal reading of the words in the AP law that says any alterations or additions to a structure on a fault constitute an upgrade that is subject to the law's limits. Instead, she appeared to have settled on a more fundamental issue: whether the buildings are structurally independent.

This criteria seems stronger than words like \"alterations\" that could apply to even the most minor changes; if two buildings are structurally independent, then one can hardly be claimed to be an upgrade to the other.

Testimony was due February 22nd, one month after the judge ruled against a plaintiffs' request that this expert testimony not be allowed into court. Plaintiffs did not want this testimony admitted.

Friday the plaintiffs submitted the testimony of Fariborz Barzegar, the founding principal of Habitat Engineering and Forensics, a consulting firm based in Oakland and Fremont that does structural engineering analysis. The firm's web site link to its \"people\" lists only Barzegar, and among other services lists his availability as an expert witness.

In his testimony Barzegar said that the new center, located (largely) underground just a few feet west of the stadium, would provide retaining-wall support to the soil under the stadium, and that therefore the two structures were interdependent.

He further said that since earthquake damage to either of the two structures might endanger the health and safety of people using the other, the two structures were interdependent.

He also supported plaintiffs' claim that structural independence was not the issue the judge should even be considering, asserting again that the \"plain-word-meaning of AP\" was the correct standard to use.

This is thin gruel on an issue that is of such fundamental importance to a major project.

[Author's note: Testimony from three additional experts for plaintiffs was put online by the court after this article was written. A supplemental article will discuss their testimony.]

In notable contrast, the University submitted the testimony of 6 experts, including David Friedman, Board President of Forell/Elsesser Engineers (E/F), Edward J Denton (the University's Campus Architect and Chief Building Official), Anthony Yuen (the Lead Designated Campus Fire Marshall), Joseph Diesko (a Licensed Architect and Vice President of HTNB Architecture, Inc.), and Jeffery A Maddox (a principal of The Fire Consultants Inc. who advise on and peer-review fire and building code compliance for campus projects).

Friedman's firm (E/F) has 40 years experience in structural and earthquake engineering that includes lengthy involvement with Memorial Stadium projects. They have over the years led engineering work for projects as diverse as city hall projects in Berkeley, Oakland, and San Francisco, the Asian Art Museum in San Francisco, and the main library seismic upgrade in San Francisco.

In his testimony, Friedman said that the design mandate from UC was to design a \"stand-alone\" building, \"structurally separate and independent from California's Memorial Stadium (CMS)\". He added that if the buildings were to be integrated, substantial structural changes to the CMS itself would have been required.

His testimony explains that seismic safety for the athletic center required that it be able to move independently of the CMS during an earthquake - and that achieving that required complete structural independence.

Friedman described the physical separation between the structures in some detail, with frequent references to drawings already in the court record. Using those, he illustrated both the vertical and horizontal separations between the buildings, and explained how even in an intense earthquake the structural components of the two buildings would never touch or endanger each other. \"This four foot distance is more than adequate to guarantee that the two buildings will not touch each other during an earthquake,\" he said in one instance.

He emphasized that the designed separation was specifically included so as to comply with the intent of AP law. He added that the \"structural separation between the athletic center and the stadium was the unequivocal design intent\" of their work.

He later declared, \"There is absolutely no structural connection between any part of the (athletic center) and the CMS.\"

This was apparently a long-standing design criterion. Said Friedman, \"… we and the experts with whom we were associated knew since at least the winter of 2005/06 that we were not designing an addition or alteration to CMS; we were instructed to design and have designed a new fully independent building, structurally and otherwise.

Note the key words, \"not designing an addition or alteration to CMS\". That phrase clearly was intended to directly contradict the key argument made by plaintiffs in the case.

Friedman's testimony contained some interesting comments on UC's documents that are already in the court records.

In one instance, he admitted that a few design features that had made their way into documents in UC's EIR had \"violated the intent to make the athletic center and CMS separate structures.\" These features were used by plaintiffs in court to assert that the buildings were integrated structures, but Friedman notes now that \"we (later) caused that design to revert to the simple discipline of a separate structure."

Friedman's testimony also directly attempted to rebut plaintiffs' claims that \"additions or alterations\" to the stadium constituted upgrades to it. He cited a California Building Code (CBC) section that says that the words apply only to two buildings that are structurally dependent, and that since the athletic center and the CMS are not - the argument does not apply.

\"There is simply no structural connection or dependency between the (athletic center) and CMS. We consciously and purposefully designed the (athletic center) to be this way,\" he testified.

Much has been made by the plaintiffs about a \"grade beam\" that will be placed under the west wall of CMS because of the athletic center project. They have claimed that the beam proves that \"additions and alterations\" to the stadium result from the new project.

Friedman explained that the grade beam (an underground concrete reinforcement) was a routine precautionary measure intended to protect the existing structure when excavations down hill might affect its structural integrity.

Said Friedman, \"The new grade beam is not structurally attached or connected in any way, shape, or form to the (athletic center).\"

He also addressed a statement in project documents that imply the athletic center in some way \"buttresses\" the foundation of the west wall of the stadium. He spoke to the point because plaintiffs have used that statement to assert the structural interdependence of the two buildings.

\"The (athletic center) is not a buttress to the CMS is the sense of a buttress being a structural component, because the structures of the two buildings are not connected in any way.\"

In the final paragraph of Friedman's testimony he asserted that, \"the complete structural separation between the CMS and the athletic center guarantees that the Center will not be subject to the hazard of earthquake fault rupture and, in so doing, also guarantees the (athletic center) honors the central purpose of AP law.\" Because the language of AP does not define \"alterations\", \"additions\", or \"upgrades\", much of the controversy in this case has been about the meaning of the law. Thus Friedman's use of the words \"honor the central purpose of AP\" is another effort at defining its meaning.

Edward Denton, in his testimony, describes the staff of 650 people who report to him, of whom 140 are architects, planners, engineers, inspectors, and contract administrators, among other professions. One of his \"reports\" is the Seismic Review Committee that advises him on structural design of campus facilities with particular regard to seismic performance.

Denton is directly responsible to ensure that all campus buildings comply with the California Building Code and Alquist Priolo (and all other laws and regulations).

Campus projects are not subject to review by county or municipal building officials, but must instead be approved by both Denton and the Campus Fire Marshall Anthony Yuen whose job it is to ensure compliance with all codes related to fire and life safety.

In his testimony Denton drew some parallels to private property owners and their building projects. He explained that Cal's Athletic Department is like the private property owner who wants to build, and that his role is like the local building code inspector. He presents projects he has approved to UC's Board of Regents that serve in a manner not unlike a local planning board that keeps watch over the community's broader plans and goals.

Denton recounts how from inception the athletic center was conceived and designed to be a separate structure, adjacent to but separate from the stadium. That separation arose from two key factors: the first was the goal to provide as soon as possible a seismically safe structure for the current occupants of the stadium. He acknowledges that insufficient funds were available to construct the center and retrofit the stadium at the same time, so the decision was made to build the center first. Second, were the two building not separate, substantial changes to the stadium would also have to be made in order for the new athletic center to be safe. Avoiding structural connections between the two buildings thus reduced project costs and completion schedules substantially.

AP law has already had a substantial bearing on the decision process employed by Denton's office. In his testimony, Denton described the process used to determine that the new center did not overlay any active fault traces. Peripherally he noted that if the new center were indeed an upgrade to the stadium, no excavations to find fault traces would have been needed - because they already knew the stadium sits on the Hayward fault. It is only because the center is a new separate construction that they had to verify there were no fault traces under it.

Denton made one almost parenthetical remark about the grade beam near the end of his testimony, commenting that its cost ($250,000) was insignificant in relation to the stadium's value that he pegged at $593 million dollars. Superficially he appears to be saying merely that this undeniable alteration to the stadium is insignificant, but he may also be trying to build the record as to the value of the stadium, a value that has been much questioned by plaintiffs. Still, if the athletic center is NOT an upgrade to the stadium, then the value of the stadium need not be determined for purposes of computing AP limits on upgrades to a structure on an active fault.

Plaintiffs have raised numerous questions about drawings in UC's EIR where they claim to see structural connections between the two buildings.

Denton testified that some of the drawings used in the EIR are now obsolete, that they have been replaced or modified in later work. He explained how design and construction drawings go through many versions and are created by a variety of teams working on different aspects of the project.

\"I know from first hand experience … that it is common for there to be discrepancies among different types of drawings … and it is often difficult to … coordinate perfectly the drawings from all sources,\" he testified.

Denton explained how discrepancies in drawings are resolved over time as a project design moves to completion; he also described how some more fundamental drawings \"trump\" others that address less central matters. For example, a building structural drawing, he said, would trump an \"interior architectural rendering\" if the two happened to differently describe the same element.

Using this background, Denton asserted in a point-by-point analysis that plaintiffs had either \"misread or misinterpreted the drawings\", or \"cited a drawing that is not the authority for the point they are trying to make\", or \"cited a drawing that had been later changed or corrected\".

He added that even though the Regents have approved the design of the athletic center, \"Construction cannot begin until my office deems the final construction drawings for the project to be complete and in compliance with all applicable provisions of the CBC and AP.\" He added, \"Construction of the (athletic center) will not begin unless and until the final construction drawings depict the (athletic center) as a stand-alone structure that is neither an addition nor alteration to CMS.\"

This makes clear a key problem faced by plaintiffs in preparing their claims on the AP issues: they did not have final construction drawings upon which to base their claims - and even today those have not yet been finally approved.

But this also makes clear a difficulty the University faced in assembling their EIR: they also did not have final drawings to put in it, so the document inherently could not be a final and accurate description of the project. Plaintiffs can be expected to complain about that vociferously.

It is therefore possible that Denton's testimony will substantially help clear the AP concerns before the court, but it may make EIR concerns more problematic.

Campus Fire Marshall Anthony Yuen is designated by the State of California to be the Lead Designated Campus Fire Marshall and to act on behalf of the state to enforce regulations and building standards relating to \"fire and panic safety\" in the CBC for all campus owned and occupied buildings.

Thus he too acts like a building code inspector whose approval is necessary for all campus construction projects to proceed.

Yuen joined Denton in asserting that the two structures are independent, and that the new center does not include alterations or additions to the stadium. He adds the unique perspective of a fire marshall, however, when he testifies, \"There are no piping, electrical, or mechanical ventilation or openings between the CMS and the (new center),\" matters that are critical to fire suppression and containment.

According to his testimony, the two buildings have dedicated and separate fire alarm systems, and that the automated fire sprinkler systems and water supply systems are totally independent. He notes that were the two buildings integrated, the fire systems would have to be integrated too, and they are not. Even evacuation routes are totally independent; the exiting paths from the two do not interfere with one another.

He completes his testimony with a professional opinion that the proposed construction of the new center will not pose any additional fire hazards to the stadium, and notes (once again) that, \"Our office has not given final approval to the (center's) construction documents as they are still under development.\"

Tomorrow: comments from Diesko and Maddox.

Objections to the expert testimony submitted by the two sides must be field with the court this Friday, February 29th. On March 7th, each side will have the opportunity to support its position in oral argument before the court. That will be the last hearing in this matter; a ruling is expected within 30 days thereafter.


©Copyright 2008, BearInsider.com and Scout.com. All rights reserved.

If you haven't done so already, subscribe to The Bear Insider so you can participate in this active online Cal community and get access to the members-only content from the nation-wide Scout.com network.

Bear Insider staff writers visit the Insider discussion board regularly, and are available to discuss questions you may have about this article and Cal Athletics.

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