September 13, 2024
Re: Item 3 on the 9/16 Agenda: Update and Receive Council Input on Airport Long-Range Plan
Dear Mayor Stone and Palo Alto City Council Members,
The Sierra Club Loma Prieta Chapter Bay Alive Campaign, Palo Alto Student Climate Coalition, Santa Clara Valley Bird Alliance (Formerly Santa Clara Valley Audubon Society), Green Foothills, Acterra, Citizens Committee to Complete the Refuge, Concerned Residents of Palo Alto, Youth United For Community Action, Climate Resilient Communities, 350 Silicon Valley Palo Alto Climate Action, 350 Silicon Valley, 350 Bay Area, and the California Native Plant Society Santa Clara Valley Chapter join the Honorable Enid Pearson and Honorable Emily Renzel in deep concern over the proposed alternatives for the Airport Long-Range Plan. Our organizations include thousands of members in Palo Alto and neighboring communities who care deeply about Palo Alto’s Baylands Nature Preserve and the benefits it bestows on community members and our native plants, birds and wildlife. Our members also care about the health, livability and peace of mind of residents in Palo Alto as well as in neighboring communities. For these reasons, our members are extremely apprehensive about any planning efforts that could lead to the airport’s expansion in footprint or in operations.
Our organizations therefore oppose planning elements that would allow the airport to expand in space or air traffic (including eVTOL) or even move the runways north, as this would increase conflicts with birds and other wildlife in the adjacent wetlands. Palo Alto should not un-dedicate parkland, fill wetlands, increase the risk to birds or the need to deter them from using the adjacent wetlands, exacerbate noise, or perpetuate lead deposition and greenhouse gas emissions. We are supportive of adding solar panels over existing asphalt areas, and of creating a path to reduce the footprint, both physical and operational, of the airport in the future.
Protection of Palo Alto’s Baylands is the most popular option with the public
Responses to the online survey as noted in the staff report1 show clear preference for the No Action Alternative (Alternative 1). Many responses chose not to choose an alternative, instead expressing a “strong preference for preserving the Baylands and Duck Pond” and a “strong preference for closing the airport.” When Alternative 1 and the No Answer votes were combined, more than 58% of votes in the survey expressed a strong preference for preserving the Baylands and opposing airport expansion. Furthermore, of several “Focus Areas” presented for consideration, “Maintaining Harmony with the Baylands” received the most votes with 51.4% of the votes.
It is surprising therefore that the words “Baylands Nature Preserve” (and within it the word “nature”) appear only once in the staff report. Identified Key Issues and Needs include, “Integrate facilities with the adjacent Baylands Golf Links and Baylands Nature Preserve, both of which are also city-owned.” The word “Park” also appears only once. It seems that preservation and protection of parkland and the nature preserve are not recognized as a Key Issue or Need despite the overwhelming concern expressed by the community in the Airport survey, in letters to the City Council over the past few months, and in grassroots petitions2 and outreach efforts. In all these communications the community expressed strong opposition to airport expansion.
Due to the potentially significant impacts of encroaching into the Baylands and of increasing airport operations on wildlife and Bayland ecosystems, the impacts on neighboring communities, and the strong preference of community members to not expand the airport, our organizations recommend that City Council direct staff to proceed with alternative 1 (no-action/no-build). Airport operations should not encroach upon the Baylands directly or indirectly, and parkland should not be paved to accommodate the airport.
Please consider the following points in your direction to staff.
- Please do not allow the airport to expand into dedicated parkland3. It is surprising to us that the outreach conducted by the airport has not disclosed to the public that all the expansion alternatives (2,3,4,5) would require the un-dedication of parkland and therefore require a vote of the people. Alternatives 2, 4 and 5 would fill wetlands in the Baylands Nature Preserve, and Alternative 3 would encroach into the Golf Course.
- Please do not encroach on wetlands at the Baylands Nature Preserve (Alternatives 2,3,4,5).
Palo Alto’s Baylands are critical wildlife habitat for migratory birds. Two hundred eighty bird species have been recorded in the Palo Alto Baylands Preserve, which is the longest checklist for any birding hot spot in the country. Some of these species depend on the combination of habitats that is available at the lagoon, including imperiled rail species, the lovely Common Yellowthroat, and the Alameda Song Sparrow. Encroaching into this habitat by filling the wetlands and/or by moving airport activity and operations closer to their habitat (Alternatives 2, 3, 4, and 5) would harm these species and the many others who rely for their survival on Palo Alto’s preservation of the Baylands.
Palo Alto’s 2030 Comprehensive Plan calls for the City to act in accordance with the 2008 Baylands Master Plan (BMP), protecting open spaces as vital sources of public health, natural beauty, and enjoyment. The plan emphasizes the importance of preserving and protecting the Bay, marshlands, sloughs, creeks, and other wetlands as functioning habitats and elements of an interconnected wildlife corridor.
The 2008 BMP expressly forbids intensified airport use or significant intrusion into open space, including the Duck Pond and lagoon. As noted by the Honorable Emily Renzel (letter to City Council dated August 8, 2024), loss of wetlands not only contradicts this plan but also undermines the City's long standing mitigation requirement for historical fill of wetlands by the City of Palo Alto: (BMP on page 67-68).
In 1976, the Army Corps of Engineers (ACOE) granted permission to continue operations and expand the footprint of the landfill. That permission included mitigation measures that are described in the Environmental Impact Report for the Palo Alto Refuse Disposal Area. The lagoon that envelopes the Duck Pond (and where fill is proposed) is an important mitigation area4, intended to serve in perpetuity to mitigate unpermitted fill of wetlands at Byxbee Park decades ago. It currently provides open water and mudflats and supports a native plant community that supports migratory birds and locally endangered species.
The Palo Alto Airport, like all airports, must adhere to a Wildlife Hazard Management Plan (WHMP) mandated by the FAA, which allows for the removal of birds and wildlife from the airfield using lethal methods if necessary. Currently, a 320-ft buffer separates the runway from the lagoon and wetlands, enabling birds to use the nearby duck pond and lagoon while still allowing public enjoyment from the San Francisquito Creek Trail. However, WHMPs also prohibit enhancing habitats that could attract birds to the runways. Shifting the runway, as proposed in Alternatives 2, 3, 4, and 5, would necessitate a new WHMP, likely leading to increased efforts to deter birds from the Palo Alto Baylands, which would be detrimental to birds and other local wildlife. To avoid worsening conflicts between aircraft and wildlife, and to preserve the natural habitat, we strongly oppose relocating airport infrastructure towards the Baylands Nature Preserve.
- We support the placement of solar panels on existing paved areas.
Adding solar panels over existing paved areas will not expand the footprint or operational capacity of the airport while providing a sustainability benefit.
- Please do not expand the operational capacity or increase the air traffic of the airport.
Expanding airport operations could exacerbate existing impacts of the airport on nearby ecosystems and communities. Increased air traffic could lead to increased noise pollution, air pollution, and greenhouse gas emissions. We are concerned about the impacts of airport operations on communities such as those in East Palo Alto and Menlo Park’s Belle Haven Neighborhoods. We also have concerns with eVTOL aircraft, as the frequent use of this aircraft could lead to increased disturbances for local birds and other wildlife, as the majority of eVTOL operations will occur at lower altitudes where bird strikes are more common.
We believe that Palo Alto must start moving infrastructure away from the Bay. Land near the Bay, including the airport, should transition over time and serve to protect the community from the impacts of sea level rise, and to provide upland habitat to allow migration habitat for native species of plants and animals.
- Palo Alto should expedite a ban on the sale of leaded AVGAS in anticipation of the State and Federal Government legislative process.
The sale of leaded aviation fuel may be banned in California beginning in 2031 under a bill approved by the legislature and headed to Gov. Gavin Newsom. A federal ban could come as soon as 2030. The Palo Alto Airport should ready itself for a regulatory environment in which leaded aviation fuel is illegal. The negative human and environmental health impacts of leaded aircraft fuel are well known,5 and Palo Alto has the opportunity to be a global trailblazer in pollution standards by expediting a leaded AVGAS ban and by promoting aviation fuel alternatives.
Respectfully,
Hon. Enid Pearson
Palo Alto Councilmember 1965-75
Former Palo Alto Vice Mayor
Hon. Emily Renzel
Palo Alto Councilmember 1979-91
Baylands Conservation Committee
Matthew Dodder
Executive Director
Santa Clara Valley Bird Alliance
Susan DesJardin
Chair, Bay Alive Campaign
Sierra Club Loma Prieta Chapter
Avroh Shah
Head of Outreach
Palo Alto Student Climate Coalition
Darlene Yaplee
Co-founder
Concerned Residents of Palo Alto
Filiberto Zaragoza
Environmental Justice Campaign Organizer
Youth United for Community Action
Violet Wulf-Saena
Founder and Executive Director
Climate Resilient Communities
Lauren Weston
Executive Director
Acterra: Action for a Healthy Planet
Alice Kaufman
Policy and Advocacy Director
Green Foothills
Mia Berkele
Co-Lead, Nature Based Solutions Team
Silicon Valley Youth Climate Action
Eileen McLaughlin
Board Member
Citizens Committee to Complete the Refuge
Judy Fenerty
Conservation Chair
CNPS Santa Clara Valley Chapter
Cheryl Weiden
350 Silicon Valley Steering Committee
Andrea Gara
Co-leader
350SV Palo Alto Climate Action
Hilary Glann
Co-leader
350SV Palo Alto Climate Action
Zoe Jonick
Lead Organizer
350 Bay Area
1 Staff Report for Agenda Item 3: https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=0f6f33be-6159-42d0-980f-a62dfcea2bac
2 Diane McCoy collected 300 signatures from visitors to the baylands on a petition asking the City not to expand. Over 1500 people signed the Palo Alto Student Climate Coalition’s petition https://www.change.org/p/save-the-palo-alto-baylands-from-airport-expansion?utm_medium=custom_url&utm_source=share_petition&recruited_by_id=0c77e730-a48d-11ea-9049-bf7deb9d000a
3 In 1965, Palo Alto dedicated the Baylands as conservation parkland. Article VIII of the Palo Alto city charter stipulates that dedicated parkland cannot be sold, disposed of, or its use abandoned or discontinued without a majority vote of the electorate. It further states,"No substantial building, construction, reconstruction or development upon or with respect to any lands so dedicated shall be made except pursuant to ordinance subject to referendum.”
4 The “Lagoon Mitigation Project” was a required mitigation for the fill of wetlands. It installed two culverts underneath Embarcadero Road to allow tidal flow into the lagoon in order to sustain its ecological function and to restore wetlands impacted by previous developments. This mitigation is mentioned multiple times in City records. For example, on page 28 of the City Council Minutes of Oct 21, 1974, in reference to the Solid Waste Disposal.