2024

December 12, 2024
Three Fall Alternatives (2024) for the Millbrae and Burlingame Shoreline Resilience Project
To: San Mateo County Flood and Sea Level Rise Resiliency District
"The Millbrae-Burlingame Shoreline Resilience Project is timely in that BCDC has just released its Regional Shoreline Adaptation Plan (RSAP), which requires all Shoreline Adaptation Plans to meet BCDC’s RSAP guidelines. The RSAP’s One Bay Vision brings the whole region together to promote collaboration, protect shared assets and achieve common goals. These guidelines ensure a strategic, and forward-looking regional response to sea level rise that accommodates local variations and protects both vulnerable communities and a broad spectrum of public “assets,” including the societal and economic benefits provided by our Bay and its habitats as we plan for the realities with which sea level rise is confronting us. The RSAP emphasises that the health of the Bay habitats is as much at risk from sea level rise as the communities and infrastructure along the shoreline. For this reason, we are extremely concerned about planning efforts that could lead to potential harms to the Bay ecosystems such as encroachment, with fill, onto habitat in the Bay and we wish to express our deep concern over the proposed alternatives."

November 13, 2024
Joint Statement to BCDC Urging Support for Robust RSAP
To: San Francisco Bay Conservation and Development Commission
We are deeply concerned about recent calls to weaken the RSAP’s required Adaptation Strategy Standards (Standards) in order to allow greater flexibility, and even create new incentives, to enable more shoreline development. This would undermine efforts to preserve and expand natural and nature-based solutions for resilience to long term sea level rise. Shoreline ecosystems—wetlands, tidal marshes, and other vital habitats—are irreplaceable, offering unique and critical benefits to local communities that cannot be relocated, unlike housing and other development, which can be sited away from vulnerable shorelines. Bay ecosystems have specific ecological needs that only the Bay can provide.

Comments on Public Draft of the Regional Shoreline Adaptation Plan
To: San Francisco Bay Conservation and Development Commission
The Regional Shoreline Adaptation Plan (RSAP) makes important strides by integrating equity assessments at every stage of planning and setting some strong Adaptation Strategy Standards (Standards) related to Baylands ecosystems. However, there are critical gaps in the Standards regarding contamination risks and habitat goals, an insufficient emphasis on natural and nature-based solutions (NNBS) across plan elements, and a disconnect between the Standards and the rest of the RSAP. Addressing these issues is vital to avoid confusion, ensure compliance, and realize the RSAP’s One Bay Vision.

September 10, 2024
Draft Subsequent Environmental Impact Report for the Draft Ravenswood Business District/Four Corners Specific Plan Update
To: City of East Palo Alto
"We recognize the critical role that the Ravenswood Business District/4 Corners Specific Plan Update will play in shaping the future of East Palo Alto and its natural resources along the San Francisco Bay. We have participated in community meetings, engaged with local residents, community groups and City staff/consultants, and commented to the Planning Commission and City Council throughout the planning process. In this letter, we will first address a few overarching points that apply to the overall DSEIR, followed by noting a few errors/omissions in the document that should be corrected in the final report. Then we will address our concerns regarding individual CEQA-related environmental factors."

September 2, 2024
Treasure Island Marina Replacement and Expansion Project
To: NOAA Fisheries
"NOAA’s consultation on this project with the U.S. Army Corps of Engineers (USCAE) and other government agencies should call for hydrodynamic analysis to investigate and assess the potential impact of this project on eelgrass, in line with NOAA’s California Eelgrass Mitigation Policy and Implementing Guidelines, particularly as hydrodynamic analysis was not conducted for the 2005 EIR evaluation of eelgrass impact concerns. NOAA should not concur with the proposed permit for this project if hydrodynamic analysis is not performed. Per NOAA’s California Eelgrass Mitigation Policy and Implementing Guidelines, the adverse impacts of this project are most appropriately addressed by avoidance. Unless hydrodynamic analysis can confidently affirm limited impacts, the project as designed should not be permitted."

July 24, 2024
Ravenswood Business District/4 Corners Specific Plan Update
To: City of East Palo Alto
"We commend the diligent efforts of the City Council, City staff, and the consultant team in developing a thoughtful plan for the future development of the RBD/4 Corners area. We are particularly pleased that the DSPU reflects a strong commitment to conserving tidal marshes, tidal flats, and their vital habitats. The proposed inland levee alignment and shoreline transition zones preserve important opportunities for long-term resilience. We also applaud the DSPU’s innovative community benefits framework, which ties development entitlements directly to specific, community-identified priorities, increases financial transparency, and enables the City to comparatively evaluate proposed community benefits. We remain concerned that Scenario 2, including more than 3.3 million square feet of new office/R&D space, will overwhelm East Palo Alto with impacts that irreversibly alter the character and resilience of the community. Nevertheless, we offer comments below to strengthen the efficacy of the Plan across all scenarios."

July 16, 2024
301 Shoreway Environmental Impact Report Scoping
To: City of Belmont Planning Commission
"...the Sierra Club requests that the EIR include a detailed analysis of the potential impacts of this proposed biotech development as it relates to both public health impacts as well as environmental impacts. Sierra Club is very supportive of the Life Sciences industry and the benefits that it brings to our communities. To educate and raise awareness of the complexities of biohazards and public safety, we have compiled materials for reference of public officials, available at this link: Planning for Life Sciences Development in Bay Area Communities."

May 29, 2024
NOP for an EIR for Ferry Terminal at the Port of Redwood City
To: Port of Redwood City
"Our review of the proposed ferry terminal and mixed-use development at Redwood Creek raises substantial environmental and infrastructural concerns. OneShoreline is currently studying possible sea level rise (SLR) infrastructure solutions for this shoreline. If the mouth of Redwood Creek is to provide ferry access to the proposed terminal, it is imperative that the shoreline design around the 9-acre site reduce boat wakes that reverberate toward sensitive wetlands such as Bair and Greco Islands."

March 31, 2024
Draft Final Report on the Priority Conservation Area (PCA) Refresh
To: Bay Area Metro Center
"The comments expressed within this letter reflect a narrowed focus on the San Francisco Bay and shoreline, and arise from an awareness that the combined impacts of our pattern of building to the edges of the Bay, decreasing sediment supplies to the Bay, continued development along our shorelines, and rising sea levels, will result in significant adverse impacts to the health of the Bay ecosystem and the resilience of our shoreline communities if we fail to take appropriate action now. [...] We continue to urge that the nomination process be extended beyond cities, counties and open space districts. Local community based organization (CBO’s) and environmental groups are oftentimes more attuned to the issues, needs and desires of the community than local agencies. Local environmental groups are usually the source of information regarding important local biological resources that should be conserved, or lands that could provide migration space for habitats and resilience for the community."

February 20, 2024
Draft Environmental Impact Statement/Environmental Impact Report for the Beneficial Reuse of Excavated Material in Tidal Marsh Restoration Project
To: Santa Clara Valley Transportation Authority Environmental Programs Office
"We support the project concept as a multi-benefit, innovative approach to address sediment needs for wetland restoration and sea level rise resilience, and particularly its value for sustaining wildlife habitat on the Don Edwards National Wildlife Refuge. However, we are concerned that the soil acceptance criteria in the Quality Assurance Project Plan (QAPP) may not be ecologically appropriate for the proposed use of sediment in this setting. We offer the comments below in the spirit of collaboration to strengthen the environmental review and assure long term project efficacy and sustainable benefits for Bay shoreline communities and ecosystems."

February 14, 2024
Support and concerns regarding February 15 Study Issues and Budget Proposals Workshop
To: Sunnyvale Mayor and City Council
"The Sierra Club Loma Prieta Chapter and the Santa Clara Valley Audubon Society support the following items. CDD 24-02: Explore the Creation of a Dark Sky Ordinance for all Private Property [...] LRS 24-01: Examine the Permanent Closure of the Interior Levees Surrounding Sunnyvale’s Wastewater Treatment Ponds [...] ESD 24-01 Evaluate the Use of Artificial Turf Versus Living Groundcover [...] We are concerned about the following items. We are concerned about item DPW 24‐04 “Evaluate Late Night Lights at Public Parks” and item DPW 20-13 “Lighting of Current and Future City Owned Dog Parks”. Both of these items could increase light pollution in Sunnyvale in parkland habitat."

January 29, 2024
Comment on 2024-1-18 DRAFT One Bay Vision
To: Bay Conservation and Development Commission
"We are encouraged to note that BCDC is making progress on the Regional Shoreline Adaptation Plan (RSAP). We hope to see a final One Bay Vision that implements Bay Adapt’s six guiding principles, and makes clear to local governments and planners what it means to “Put Nature First Whenever Possible” and “Support Socially Vulnerable Communities” and explains clearly how they can do so. With that in mind, we hope you will strengthen the draft One Bay Vision to..."

January 16, 2024
Alarm and Concerns Regarding the Class VI Application for the Montezuma NorCal Carbon Hub/Montezuma Carbon LLC project
To: U.S. Environmental Protection Agency, Region 9
"The undersigned 87 organizations write to express their alarm and concerns regarding the Class VI application for the Montezuma NorCal Carbon Hub/Montezuma Carbon LLC project (hereinafter, “Montezuma Carbon Hub” or “the project”). We also invite officials from EPA Region 9 to meet with community members to hear more about these concerns and to answer questions. Information on how to set up that meeting is at the end of this letter. In summary, our concerns include the following..."

2023

November 30, 2023
Notice of Preparation of an Environmental Impact Report for the Millbrae and Burlingame Shoreline Area Enhancement Project
To: OneShoreline
"Our comments here summarize some of the serious concerns and known issues with the preferred project OneShoreline has selected, the Offshore Barrier and Lagoon, which call into question the feasibility of this unprecedented and controversial flood control project within Bay waters. Additionally, there has been a lack of transparency and outreach to agencies, key stakeholders and the public with respect to the process for identifying the Preferred Project Alternative that has been selected for further detailed studies in the EIR. For these reasons, we strongly urge you to rescind the current NOP and reissue it only after ensuring regulatory and resource agencies, key stakeholders and the community have the opportunity to provide critical input, informing the decision on alternatives that should be considered and the selection of the Preferred Project Alternative for further CEQA analysis."

November 29, 2023
Notice of Preparation: Millbrae and Burlingame Shoreline Area Protection and Enhancement Project EIR
To: OneShoreline
"We diligently reviewed OneShoreline’s supporting documents to improve our understanding of the Project. Unfortunately, we encountered inconsistencies in the documentation, with numbered alternatives not aligning across various reports. Similarly, the feasibility report drew from analyses in prior reports that did not consistently address the same Project concept or feature. Although we acknowledge the evolving nature of the Project, the lack of a definitive Project description forced us to make assumptions about the intended alternatives and hindered our ability to provide precise scoping comments regarding specific features or locations."

November 6, 2023
Requesting a submission extension for written comments to the NOP for the Millbrae and Burlingame Shoreline Area Protection and Enhancement Project EIR 
To: OneShoreline Board of Supervisors
"We would like to provide useful comments on this project. To do so we need sufficient time to review and understand this newly-available information. Therefore, we respectfully request that the deadline for the submission of written scoping comments be extended by an additional two weeks."

October 30, 2023
Sea Level Rise Guidance for Cleanup Activities
To: Department of Toxic Substances Control
"We were pleased to see the California Department of Toxic Substances Control (DTSC) issue draft Guidance for their Project Managers on how to incorporate future sea level rise (SLR) into hazardous waste site remediation planning and implementation. Importantly, the Guidance applies not only to sites currently undergoing remediation planning and implementation, but also to sites that have already completed all required remediation but leave hazardous wastes still in place. Nonetheless, we believe the Guidance lacks the necessary specificity to ensure consistent interpretation and application of the Guidance, as well as public clarity about the criteria for certain determinations and mechanisms for accountability."

July 24, 2023
Supporting city-led community engagement process
To: Mayor Gee and Members of the City Council
"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."

July 18, 2023
Recent revisions to the Ravenswood Business District Specific Plan Update framework
To: Community Development Director, City of East Palo Alto
"We commend the diligent work of City staff and its team of consultants to develop a thoughtful plan for the future of the RBD/Four Corners area and the City. We are particularly pleased to see that the RBDSP updates include protection of the public and private wetlands at the north east edge of the plan area. Reduced floor area ratios and the inclusion of stepped-back building heights and transition zones next to residential and shoreline areas are steps in the right direction, but do not allay all of our concerns. Please see our comments below regarding the recent plan updates as well as some continuing concerns regarding chemical hazards and community outreach."

July 7, 2023
Moffett Park Specific Plan and Final Environmental Impact Report
To: Mayor Klein and City Councilmembers
"We commend the diligent work of the City Council, City staff and its team of consultants to put forth a comprehensive and thoughtful plan for the future of Moffett Park. We acknowledge and appreciate the extensive research, refinement and public process that underlie the MPSP. Nevertheless, the Final Environmental Impact Report (EIR) and associated updates to the MPSP did not allay some significant concerns. We strongly disagree with the EIR’s conclusion that increased use by 42,000 new residents and 60,000 new employees in the Moffett Park area will not have a significant impact on wildlife and habitat in existing park and open space adjacent to Moffett Park. We also disagree with the EIR’s comment responses asserting that the threat of bird collisions above 60 feet is minimal."

June 23, 2023
Prematurity of the New Redwood Life Precise Plan and EIR
To: Mayor Gee and Redwood City Council
"We believe that it is premature to start a new Precise Plan for the Life Sciences industry and especially the associated EIR because there are several items that are not yet adequately addressed."