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those same driven pile impacts could exacerbate contamination risks in the future, as environmental factors change and sea and groundwater levels rise. Since rising waters are considered part of the environment, CEQA doesn’t require their future interaction with the project to be assessed unless the project itself contributes to a broader environmental impact, such as disruption of groundwater flows. Without explicit City Council direction to evaluate how the proposed development could increase the site’s long-term vulnerability to future hazards, especially related to landfill contamination, these critical issues likely would not be addressed in the EIR. This could result in a serious information gap regarding how the project might worsen future community and ecological impacts from inevitable sea level rise, including: ● Increased disturbance of contaminated landfill material from construction ● Accelerated deterioration of the landfill cap from cap-piercing piles and soil surcharge ● Greater exposure to groundwater intrusion and mobilization of soil-borne toxins Other cities have addressed similar CEQA shortcomings by requiring or commissioning supplemental studies to fill these gaps.3 We urge you to do the same, so that you receive the full scope of analysis needed to make a safe, informed decision. 4. Align the Community Alternative with new regional requirements to include Nature Based Sea Level Rise Adaptation along the Shoreline. The City’s public workshop on sea level rise indicated that traditional engineered levees are still currently the City’s principle strategy for sea level rise adaptation in this project area. However, the Bay Conservation and Development Commission’s Regional Shoreline Adaptation Plan (RSAP), adopted in 2024 pursuant to SB272, requires shoreline jurisdictions to comply with several sea level rise adaptation strategy standards, including the use of natural and nature based solutions “to the greatest extent feasible.”4 4 Bay Conservation and Development Commission, Regional Shoreline Adaptation Plan, December 2024, pdf pages 166-177 ● Adaptation Strategy Standard 2: Prioritize uses that require a location along the shoreline. (This standard further calls for prioritizing, preserving and enhancing land uses that require a shoreline location or those that can only be carried out on, in, or adjacent to water.) ● Adaptation Strategy Standard 3: Protect, restore, enhance, and adapt Baylands habitats, ensure complete and connected ecosystems, and facilitate their long-term survival. (In areas along the Bay shoreline with existing Baylands habitats, this standard calls for protection, restoration, and/or enhancement of those habitats to the greatest extent feasible in order to meet regional habitat goals.) ● Adaptation Strategy Standard 4: Prioritize natural and nature-based adaptation where feasible. (In the expanded text of this standard, it is emphasized that if NNBA approaches are deemed infeasible, strategies should incorporate habitat enhancements.) ● Adaptation Strategy Standard 5: Preserve natural and undeveloped lands for shoreline resilience. In areas along the Bay shoreline with natural and undeveloped lands vulnerable to flooding and containing existing Baylands habitats and/or species that are especially suitable for ecosystem enhancement, preserve these areas to provide shoreline resilience. 3 As part of its Moffett Park Specific Plan Update, the City of Sunnyvale commissioned two technical studies- a study to assess existing flood risk and flood risk based on future sea-level rise projections as well as a technical study of the localized impacts of sea level rise on shallow groundwater. City of Sunnyvale, Moffett Park Specific Plan Draft Environmental Impact Report Appendix G: ESA and San Francisco Estuary Institute, “Sunnyvale Sea Level Rise Adaptation Strategy - Background,” 2020; pdf page 788 ESA, San Francisco Estuary Institute, Pathways Climate Institute, “Sea-level rise impacts on shallow groundwater in Moffett Park. A technical addendum to the Moffett Park Specific Plan”, November 2022, pdf page 729, sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303 3