Support of City-Led Community Engagement Process

July 24, 2023

Mayor Gee and Members of the City Council
City of Redwood City
Via email: council@redwoodcity.org

Subject: Agenda item 9A of July 24, 2023. Redwood Life project in Redwood Shores

Dear Mayor Gee and Council Members of Redwood City,

The Sierra Club Loma Prieta Chapter’s Sustainable Land Use Committee advocates for land use issues, and the Bay Alive Campaign advocates for the ecological health of San Francisco Bay and for community resilience to sea level rise. While we support staying with the original Westport Specific Plan, we support the staff recommendation that a city-led community engagement process should be used to update the Westport Specific Plan, if the Council is considering the possible repeal of the existing Westport Specific Plan.

To emphasize the necessity of meaningful community engagement, we further acknowledge the Planning Commission’s recent unanimous recommendation that the City Council direct the applicant to engage in additional community outreach.1

We additionally support Alternative 1 in the Staff Report, specifying the following: “Direct staff and/or the applicant to provide additional information prior to consideration of initiation proceedings.” Additionally, Alternative 1 fulfills staff’s expressed need to pinpoint a “stable project description” prior to initiating the CEQA process.

The City, in collaboration with the community, rather than private developer, should determine what changes, if any, are appropriate in a Specific Plan in order to achieve overall City strategic objectives while addressing resident concerns, sustainability goals, habitat and ecosystem vitality, and public safety priorities.

A meaningful and robust city-led Community Engagement process could review the existing Specific Plan and determine what changes could be made that

  • Continue to protect the community and safeguard neighbors with building height restrictions and setbacks,
  • Recognize that this is a fragile site, on an unlined city dump, sitting on bay mud, and that is of concern for Bay ecology and to the Regional Water Quality Control Board 2,
  • Protect the “Redwood Shores Ecological Reserve,” a California State wildlife habitat area, which is home to species of special concern,
  • Develop appropriate setback requirements and shoreline protection guidelines to provide lasting sea level rise resilience and landfill protection and incorporate OneShoreline Planning Policy Guidance 3,
  • Recognize that biosafety and bio risk management are fundamental public health concerns for this evolving industry and that biosafety levels BSL-3 and BSL-4 labs should not be allowed in or near residential settings and sensitive receptor locations,
  • Recognize that sustainability goals need to be clearly articulated given the heavy consumption demands of the biotech industry and
  • Address the jobs/housing fit and jobs/housing balance.

The City will be required to do an environmental impact report (EIR) for a changed Specific Plan when it is completed.

Contrary to city planning requirements, the developer requests the initiation, now, of an EIR on their proposed incomplete submittal despite its numerous deficiencies.

To date, as noted in Planning Department responses to the developer, the project application remains substantially incomplete. At the April 24, 2023 City Council Study Session, staff confirmed that the application remains incomplete and cannot proceed until the city receives “a stable project description.” Planning staff further emphasized the following specific procedures and necessary steps prior to initiating the CEQA process

“It’s important that we finally pin down the project before we do the CEQA process just so we’re not hitting a moving target [emphasis added]. We want to know from the feedback tonight whether the developer and staff need to get together and figure out...are there changes we need to do that would affect the environmental review of the project. Once we have what we call a stable project description, it will be the point where you could start the environmental review [emphasis added].”
 

In addition, impacts of sea level rise, flooding, the high likelihood of a seismic event of magnitude 7.2 or greater, with attendant ground liquefaction and soil stability concerns, and future shallow groundwater rise exposing legacy pollutants, are all important issues that have been raised but cannot be addressed using the CEQA process as an EIR can ONLY study the impact of a project on the environment; it does not study the impact of the environment on a project. These issues can, however, be addressed by the City in a Specific Plan.

To date, Redwood Life developer Longfellow Real Estate Partners has not demonstrated much capability or willingness to engage the community, neighboring residents and environmental stakeholders in order to discuss and respond to concerns, though Sierra Club has written several letters of concern in response to the development proposal. We attach our letter dated April 20, 2023.

In summary we support a city-led community engagement process and City Council’s implementation of Alternative 1 in the July 24, 2023 Staff Report, which includes the option of deciding to stay with the original Westport Specific Plan.

The Regional Water Quality Control Board has required an assessment of the sea level rise strategy for the unlined landfill and granted Longfellow an extension until September 1, 2023. Given the fragility of the landfill site, we urge the city to wait until the Water Board receives, reviews and approves the mandatory report on this critical issue.

We further urge the City to go beyond the minimum CEQA requirements and include robust environmental analysis and mitigation of likely area impacts related to sea level rise and shallow groundwater rise, including anticipated effects on future soil stability and contamination conditions as well as the public safety concerns.
 

Respectfully submitted,

Gita Dev, Co-Chair, Sustainable Land Use Committee, Sierra Club Loma Prieta Chapter
Gladwyn d’Souza, Chair, Conservation Committee, Sierra Club Loma Prieta Chapter
Jennifer Chang Hetterly, Campaign Coordinator, Bay Alive, Sierra Club Loma Prieta Chapter

Cc: James Eggers, Executive Director, Sierra Club Loma Prieta Chapter
        Dave Pine, Chair, Board Of Supervisors, San Mateo County <dpine@smcgov.org>
        Ray Mueller, Board of Supervisors District 3, San Mateo County <rmueller@smcgov.org>
        Len Materman, OneShoreline, San Mateo County <Len@oneshoreline.org>

Attachment: Sierra Club letter dated April 20, 2023

1 Staff report for item 9A, dated July 24, 2023

2 State of California Regional Water Quality Control Board, San Francisco Bay Region. Order No.. R2- 2022-0031, Amending Waste Discharge Requirements for Bayfront Landfills Listed in Table 1 Amendment to Waste Discharge Requirements for Long-Term Flood Protection Considerations at Closed and Operating Municipal Solid Waste Bayfront Landfills. n.d. : “These Bayfront landfills are inherently vulnerable to sea level rise (SLR), extreme storm events, king tides, and groundwater rise which can occur when higher sea levels cause shallow water tables to rise.”

3 One Shoreline Planning Policy Guidance One Shoreline's Planning Policy Guidance is intended to be a standardized, yet evolving, resource for cities and the County to account for anticipated increases in sea level rise.