Mayor Saballos and City Council members
City of Redwood City
Via email: council@redwoodcity.org
Re: Redwood Life Project, Consent Item 6.E on April 14, 2025 City Council meeting agenda
Dear Mayor Saballos and Redwood City Council Members,
On behalf of the Sierra Club Loma Prieta Chapter’s Sustainable Land Use Committee and Bay Alive Campaign, which advocates for the ecological health of San Francisco Bay and for community resilience to sea level rise, we respectfully submit the following comments regarding initiation of CEQA review for the Redwood Life project. We have actively engaged on the Redwood Life project on behalf of thousands of members in and around Redwood Shores and have participated in all related public meetings since the process began.
We appreciate that the proposed Alternative 2 takes some initial steps toward reducing the impacts of this large scale development on this fragile, housing-adjacent dump site. However, substantial concerns remain regarding the project’s impacts on the local environment, community well-being, and public safety.
Given the constraints of the site and its location alongside the sensitive habitat of the Redwood Shores Ecological Reserve, our strong preference remains to avoid large scale construction impacts and retain the original Westport Specific Plan. Nonetheless, we supported the City Council’s prior direction to develop a “Community Alternative” through a robust, city-led community engagement process prior to the possible repeal of the existing Westport Specific Plan.
Unfortunately, that inclusive process came to a premature end. In the rush to initiate the CEQA review process, community discussion was cut short after Alternative 2 was revealed and inclusive participation was abandoned, calling into question the credibility of private data used to suggest support for Alternative 2 at the Joint Session on March 4, 2025. This artificial curtailment of the process to create a community-developed alternative is deeply troubling. We strongly urge you to complete the community process to arrive at an alternative that is more aligned with community concerns and responsive to the impacts identified in the City’s Sensitivity Analysis before advancing into an EIR.
We respectfully request that the City Council take the following actions:
Delay the scheduled vote on initiating the EIR for the Redwood Life proposal and the Alternative. This will allow time to refine a true “Community Alternative,” that addresses feedback gathered during the February 12 community workshop, and which Alternative 2 fails to reflect.
Strengthen Alternative 2 in collaboration with the community to produce a plan that addresses more of the community’s concerns, including environmental and safety issues raised in the very recently completed (January 30, 2025) Sensitivity Analysis. This would build upon community input already provided and strive for a solution that truly meets both community needs and the City's strategic long-range planning, economic and sea level rise goals.
Alternative 2, misleadingly represented as “a 20 percent reduction of the project,” is in fact only a 13.77% reduction of the project size; see calculation below.1 Councilmember Gee’s question, on March 4, about whether an additional, smaller alternative could undergo full environmental review suggests an acknowledgement that the size of both the original proposal and Alternative 2 remains a real concern. As a council member who attended the public workshop, he understands the community sentiment that Alternative 2, while it does address some of the immediate neighbors’ concerns, remains inadequate to address concerns about the project's overall scale and impacts.
Prior to initiating the CEQA process, the City has an opportunity to strike a better balance, alleviate persistent, legitimate community concerns, and avoid the potential need to try to mitigate or override findings of significant environmental impact.
In a similar case, for East Palo Alto’s recent “Ravenswood Business District Specific Plan", the City Council adopted a 26 percent reduction in size from the original developers’ proposals, in order to address community concerns2.Clarify Council direction regarding the scope of analysis for landfill contamination risks, including those associated with construction impacts, groundwater rise, and sea level rise. Multiple Councilmembers at the Joint Session asked for, and received, assurances that the upcoming environmental review would analyze sea level rise, groundwater rise, and contamination risks associated with building on the former dump. However, it is important to clarify a key limitation of CEQA; while CEQA requires analysis of how a project may impact the environment, it does not require analysis of or mitigation for how the environment might impact a project.
As a result, a typical EIR might examine whether construction activities, like piercing the landfill cap, could release contaminants under current conditions, but it would likely not analyze how 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.
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
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.
A SMALLER PROJECT COULD SIGNIFICANTLY REDUCE MANY IMPACTS
This is a fragile site on a subsiding, capped and unlined dump, surrounded on three sides by the rich ecosystems of a wildlife refuge, and on the fourth side by existing residential neighborhoods. Further reduction of the project’s overall size could have the following beneficial effects.
Reducing destructive penetrations of the landfill cap and the landfill from pile driving and limiting potential migration of toxics into the adjacent refuge habitat
Reducing the need for 7 to 14 feet of weight of added fill on the fragile landfill cap, by reducing below-grade parking
Reducing the number of tall buildings, which would allow these to be set back farther from the shoreline, minimizing shadows on the refuge and night lighting that disturbs night-foraging wildlife
Reducing nuisance of construction noise and dust for residential neighbors
Increasing potential for a wider shoreline buffer zone for sea level rise resilience flexibility over the next 75 years
Reducing the number of employees, which would help reduce traffic impacts on local roads
Reducing the number of parking spaces required, which in turn would result in fewer or smaller parking structures
Reducing the number of development phases, and potentially shortening the overall 25-year construction timeline.
SHORTENING THE 25-YEAR PHASED BUILDOUT COULD REDUCE THE NEED FOR EXPENSIVE INTERIM FLOOD PROTECTION MEASURES WHILE ALSO REDUCING CONSTRUCTION IMPACTS.
In the 75-year life of the proposed development, given a 25-year planning window plus the 50-year average building life, the sea level is projected to rise by 3 feet or more, according to the official estimates of the California Ocean Protection Council.8 Delaying full buildout until 2050 dramatically increases the risk that the site could face inundation and the buildings become stranded liabilities for the City before the end of their useful life. Protecting these buildings through the end of the century will likely require significant, ongoing taxpayer investment in additional defensive measures.
A DETAILED ANALYSIS AND UPDATED SURVEY OF THE LANDFILL IS ESSENTIAL.
The proposed development is located on a deteriorating former dump site adjacent to the sensitive Redwood Shores Ecological Reserve. A Phase I Environmental Site Assessment done in 2018 by Ramboll US Corporation found that
“The historical use of the site as a landfill, coupled with the existing groundwater and leachate contamination, methane and other potential vapor intrusion concerns, and the continued subsidence issues resulting in necessary upgrades to the LFG 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.
We thank you for your time and service, and urge you to take these critical steps to ensure a healthier, more resilient future for Redwood City and its residents.
Sincerely,
Gita Dev
Chair, Sustainable Land Use and Conservation Committees
Sierra Club Loma Prieta Chapter
Jennifer Chang Hetterly
Bay Alive Campaign Coordinator
Sierra Club Loma Prieta Chapter
cc:
James Eggers, Chapter Director
Mike Ferreira, Chapter Chair
Susan DesJardin, Bay Alive Campaign Chair
1 Original project size is 3,316,970 sf and Alternative 2 is 2,860,000 sf . That is clearly only a 13.77% reduction of the overall project size.
2 Four Years of Hard Work Paid Off in East Palo Alto, December 19, 2024 “After four years of hard work, East Palo Alto’s City Council approved a scaled-back expansion plan for the shoreline Ravenswood Business District (RBD) on December 17th. While the plan remains substantial in size and impact, it now includes a majority of our policy recommendations to protect Baylands ecosystems, enhance sea level rise resilience, and minimize harm to the community....”
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,
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.
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)
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.”
7 High-Tide Refuge Islands for the San Francisco Estuary, California Coastal Conservancy Pilot projects include some in Redwood Shores Ecological Reserve
8 California Ocean Protection Council State of California Sea Level Rise Guidance: 2024
9 Phase 1 Environmental Site Assessment, Bayshore Technology Park, Redwood City, California. 2018
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.