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mitigation systems is interpreted to be a REC (Recognized Environmental Condition).”9 The unlined dump site sits directly atop Bay mud in an area highly susceptible to seismic liquefaction and settlement. The proposal to demolish all twenty existing 2-story buildings and replace them with structures as tall as 120 feet, combined with the addition of 7 to 17 feet of earthen fill, would place unprecedented pressures on this unstable site and its clay cap. This could increase the risk of toxic gas release and groundwater contamination, posing hazards to both nearby communities and sensitive ecosystems. The current plan involves piercing the protective clay cap and waste mass more than 1,000 times for 90’ long driven piles.10 This could not only disturb the integrity of the landfill, but could also cause damage to the toxic leachate collection system. Moreover, over the life of the proposed development, rising groundwater levels driven by sea level rise might submerge the landfill’s toxic leachate collection system of perforated pipes, rendering this vital protection system ineffective. A detailed analysis and updated survey of the landfill, an unlined dump, capped in order to remain dry and that did not anticipate sea levels rising into it, is essential. This should assess both the construction-related and long-term environmental risks, under maximum projections for sea level and groundwater rise, through the development’s expected lifespan. Specific areas of concern include: ● The current integrity of the clay cap, ● Water infiltration and structural problems from internal settlement voids, ● Cracking of perimeter wall and cap from differential settlement, ● Risks to leachate collection system and dump integrity from rising water levels ● Damage from existing tree roots, ● Additional risks posed by construction-related fracturing of the cap. Without this analysis, the City may not fully understand or anticipate the long-term consequences and liabilities of building on this vulnerable site. In Summary, we firmly believe that rushing to initiate the CEQA process without an alternative that adequately addresses these critical issues will not yield needed information for sound decision-making nor serve the best long-term interests of the City and the community's health and safety. We urge you to complete the remaining step to develop a Community Alternative that reflects feedback received at the last community workshop. For a development of this magnitude, especially on a vulnerable shoreline, you appropriately initiated an extensive public engagement process. Please stay the course and complete the process before initiating CEQA review. 10 Redwood Life Planning Application Update 11-04-2022. We note that the current 2-story buildings were more careful to minimize penetrations into the landfill. 9 Phase 1 Environmental Site Assessment, Bayshore Technology Park, Redwood City, California. 2018 sierraclub.org/loma-prieta ~ 3921 East Bayshore Road, Suite 204, Palo Alto, CA 94303 6