May 27, 2026
Chairperson Greer Stone
Vice Chairperson Lisa Gauthier
Members of the Board
San Francisquito Creek Joint Powers Authority
Submitted by email
RE: 05/28/26 Agenda Item 5, Consider and Approve a Resolution Certifying the FEIR of the SAFER Bay Project and Related Actions
Dear Chairperson Stone and Members of the Board:
Citizens Committee to Complete the Refuge is submitting this joint letter on behalf of ourselves, the Sierra Club Loma Prieta Chapter’s Bay Alive Campaign, and Green Foothills. We respectfully submit these comments regarding responses to our January 23, 2026 comments to the Draft Environmental Impact Report (DEIR) for the Strategy to Advance Flood protection, Ecosystems and Recreation (SAFER) Project (Project). In FEIR responses, our joint letter comments were coded “CCCR” but represented the work and concerns of all our groups.
We wish to extend our sincere thanks to SFCJPA staff for the substantial attention given to our lengthy and detailed DEIR comment letter and for the significant responsive revisions incorporated into the FEIR that is now before the Board.
We want to specifically voice our support for the Board's approval of "the Modified Footprint Alternative (Figure RTC-1) of the FEIR Response to Comments Document", as outlined in letter L of the Board's Resolution Certifying the Final EIR. The approval of the Modified Footprint Alternative, as specified in the Final EIR, will reduce permanent impacts to the marsh and slough east of the Meta Headquarters. It will also provide a beautiful new addition to the Bay Trail with a 600-foot bridge for pedestrians and bicyclists.
Before taking action on certification of the FEIR, we ask the Board to consider the following remaining concerns:
The program-level trail width standard; and
Predator Management Funding; and
Implementation requirements related to contamination, groundwater, and construction-phase hazards.
Trail Width and Levee Footprint
We appreciate the detailed response provided regarding trail width standards(FEIR p. 3-160, response to CCCR-92). However, we remain concerned that establishing a program-level 20-foot trail width standard across the entire Project unnecessarily limits flexibility in reach locations constrained by space or sensitive habitats.
In the Bay Conservation and Development Commission’s (BCDC) Sharing Spaces, Public Access Design Guidelines for San Francisco Bay, a 20’ width is uncommon and use-specific.
“Provide trail widths ranging from five feet to sixteen feet, depending on the anticipated level and type of use (multi-use, bicycle-only, nature trail). In dense urban areas, an even wider promenade may be needed.” ( p. 26)“Urban” is a word used differently by BCDC (San Francisco Bay only) and by USACE (national), agencies cited in the FEIR response. The BCDC Guideline quoted above reflects the difference. Within the Project Area, the only proposed “promenade” is in the North of Bay Road reach per the Ravenswood Business District Specific Plan Update. The SAFER Bay siting specification should be location sensitive. No population growth is anticipated to transform shoreline trail use density over all reaches.
Responsibility to protect Bay wildlife and wetlands. Virtually the entire project fronts Bay sensitive wetlands. In BCDC’s Sharing Spaces Objective No. 7 is to “Ensure that Public Access is Compatible with Wildlife through siting, design and management strategies” (p. 15). The introduction notes: “However, in some cases, public access may have adverse effects on wildlife (including flushing, increased stress, interrupted foraging or nest abandonment), and may result in adverse long-term population and species effects. The type and severity of effects, if any, on wildlife depend on many factors, including site planning, the type and number of species present and the intensity and nature of the human activity.”
The document lists ways the objective can be achieved including: “Employ appropriate siting, design and management strategies (such as buffers or use restrictions) to reduce or prevent adverse human and wildlife interactions.” And “Retaining existing marsh and tidal flats and restoring or enhancing wildlife habitat, wherever possible.”
These BCDC criteria are considered during Design Review and Permitting. We suggest adopting the flexibility of the BCDC standards discussed above.
Predator Management Funding
We request that language be added to Mitigation Measure BIO-14: General Wildlife Impact Minimization Measures, to specifically require that a Predator Management Plan be developed and approved by the appropriate regulatory, resource agencies and the Don Edwards San Francisco Bay National Wildlife Refuge prior to the implementation of any project elements in the Ravenswood Ponds. The Predator Management Plan must identify a permanent funding mechanism to ensure the plan will be implemented, identify the party responsible for monitoring the efficacy of the Predator Management Plan, and provide reports as required to the USFWS, NMFS, and CDFW.
Hazardous Materials and Construction-Phase Implementation
The FEIR relies heavily on MM HAZ-1, MM HAZ-2, and MM HYD-1b to support less-than-significant conclusions for contamination, groundwater, and construction-related hazards. However, those measures still defer several implementation details and performance standards to future agency coordination and construction-phase planning. Because the Project traverses multiple historically contaminated shoreline areas adjacent to sensitive wetlands, residences, and a school, we remain concerned that clear guardrails for future contaminant-response and environmental protection requirements have not yet been fully defined.
We respectfully request that the Board direct staff to strengthen implementation requirements associated with MM HAZ-1, MM HAZ-2, and MM HYD-1b by ensuring that reach-specific construction-phase monitoring, contaminant-response triggers, contingency protocols, and agency-approved management plans are clearly defined prior to implementation in contaminated reaches.
While the FEIR references future plans and regulatory oversight, it does not clearly identify what contaminant concentrations, monitoring results, groundwater conditions, or construction discoveries would trigger modified construction methods, work stoppages, remediation, or expanded protections for nearby wetlands, schools, residents, or remediation systems. Providing greater clarity now would improve accountability, reduce uncertainty, and strengthen confidence that future site-specific decisions will remain protective of public health and Bay ecosystems.
Given the Project’s long implementation horizon, proximity to sensitive receptors, and reliance on future construction-phase decision-making, establishing these expectations now is both reasonable and prudent.
We thank you for your consideration of the above issues and congratulate the SFCJPA for reaching this decision point after so many years of work behind it.
Sincerely,
Eileen McLaughlin, Board Member
Citizens Committee to Complete the Refuge
Jennifer Chang Hetterly, Bay Alive Campaign Coordinator
Sierra Club Loma Prieta Chapter
Alexandra Mendoza, Environmental Associate
Green Foothills
CC: Susan DeJardin, Bay Alive Campaign, SCLP
Carin High, Co-Chair CCCR
Gail Raabe, Co-Chair CCCR
Chris MacIntosh, Conservation Chair, SMC Bird Alliance