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Given site conditions in the project area and proximity to the Redwood Shores Ecological Reserve, the City has a rare opportunity to get ahead of the game in complying with these new regional standards. For example, by widening setbacks along the low-lying shoreline, the City can preserve undeveloped lands for shoreline resilience (RSAP Adaptation Standard 5) and make space for shallow-sloped, vegetated levees (ecotone levees) that support marsh migration and provide refugia for wildlife in high tide and storm events (RSAP Adaptation Standards 2, 3, and 4) while also reducing flood and storm surge impacts5 and maintaining vital ecosystem services.6 In line with the new adaptation standards, the City can also avoid potentially dire unintended consequences by ensuring fuller analysis and transparency of the future contamination risks to ecosystems associated with the adjoining landfill’s exposure to sea level and groundwater rise (RSAP Adaptation Standard 12). It is important to note that pilot sea level rise adaptation work, by agencies, is already underway in this important wildlife refuge.7 We bring to your attention that improvements to the Bay Trail have been the only aspect of the proposed development that consistently received positive community response. Widening the shoreline band will also allow for an improved Bay Trail amenity, extending the durability of public access. It also provides the potential to include some stretches of linear park that would provide a desirable public benefit for local residents who currently stand to experience all the negative impacts of development but few of the developer ’s offered “Community Benefits.” Taking the above actions could address several significant concerns and build greater alignment among community stakeholders. We also offer the following details to inform further refinement of Alternative 2. 7 High-Tide Refuge Islands for the San Francisco Estuary, California Coastal Conservancy Pilot projects include some in Redwood Shores Ecological Reserve 6 Ibid., pdf page 47. Baylands habitats “provide enormous economic benefits to the region through their ecosystem services, including sustaining the 70 percent of California’s commercial fisheries that are dependent on wetlands habitat, making San Francisco Bay habitats a major economic contributor to the state. They also support essential services such as recycling nutrients, improving water quality, and storing and sequestering carbon that draws greenhouse gases out of the atmosphere.” 5 Bay Conservation and Development Commission, Regional Shoreline Adaptation Plan, December 2024, pdf page 48 https://www.bcdc.ca.gov/wp-content/uploads/sites/354/2024/12/regional-shoreline-adaptation-plan.pdf. “Improving Baylands not only supports habitats and ecosystem services, but it can also reduce coastal flood risk and impacts. Baylands can reduce wave energy and wave heights during storms, minimize erosion along the shoreline, and absorb and store excess floodwater that reduces catastrophic flooding.” ● Adaptation Strategy Standard 12: Reduce contamination risks across communities and Bayland ecosystems. (This standard calls for transparency regarding the impact of flooding, specifically calling out groundwater rise, on "contaminated sites that have been locally prioritized") ● Adaptation Strategy Standard 18: Develop and maintain cross-jurisdictional flood risk reduction. (In relation to discussion regarding the usage of OLUs, the RSAP requires cross-jurisdictional collaboration for areas of high hydraulic connectivity, which includes Redwood Shores) sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303 4