February 13, 2026
Mayor Saballos and Members of the City Council
City Hall, Redwood City
1017 Middlefield Road
Redwood City, CA 94063
Via email: <council@redwoodcity.org>
and
Paige Saber, Engineering Department, Redwood City, <psaber@redwoodcity.org>
Re: Redwood Shores Flood Protection Project
Design and Community Engagement Recommendations
Dear Mayor Saballos, Redwood City Councilmembers and Ms. Saber,
Thank you for the opportunity to comment on the Redwood Shores Flood Protection Project. We offer these comments in the spirit of strengthening the planning process, improving community understanding, and supporting a durable, resilient outcome, consistent with BCDC’s Regional Shoreline Adaptation Plan (RSAP).1
FEMA+1 Alternative
We support the Council’s and Staff decision to pursue the FEMA+1 adaptive pathways approach with an intermediate 35-year phase. A phased strategy is superior to the one-and-done FEMA+3.5 option, not simply as a cost- and time-saving measure, but as a core implementation strategy consistent with BCDC’s Regional Shoreline Adaptation Plan (RSAP). Constructing hardened infrastructure to its ultimate height long before it is needed can impose avoidable environmental, visual, and financial impacts. Regulatory requirements will also keep changing in adaptation to evolving science and climate conditions. A well-designed adaptive pathway can extend the lifespan of shoreline ecosystems while aligning investments with evolving sea level rise conditions, habitat changes and for preserving flexibility.
Preserving Flexibility depends on how Phase One is designed
Incorporating greatest possible setbacks in Phase One should be a foundational design principle wherever feasible. That approach is strongly supported by OneShoreline’s 2023 Shoreline Policy Planning Guidance2 and BCDC’s Regional Shoreline Adaptation Plan guidelines3. Setbacks can reduce immediate habitat impacts by preserving transition space, to minimize the negative impacts of hardened shoreline immediately alongside marsh and habitat, and allowing shoreline habitats to migrate upland through time as sea levels rise. They also expand future opportunities for ecotone slopes and horizontal levees, as well as for raising levee heights or levee widening, thereby strengthening long-term ecological resilience.
During community meetings, it was stated that approximately 40% of the levee alignment would require a floodwall constructed atop the levee, even under Phase 1 conditions. However, no documentation identifies the specific reaches where floodwalls would be installed, nor the proposed wall heights. This lack of detail limits meaningful evaluation of visual, environmental, and design impacts. Moreover, if Phase Two includes higher flood protection standards, it is reasonable to assume that Phase One floodwalls would require additional vertical height. Given the community’s consistent preference for a more naturalistic levee design without vertical wall elements wherever feasible, the location, extent, and height of proposed floodwalls are critical design parameters that must be clearly disclosed for analysis and consideration.
Additionally, other Phase One design choices may effectively pre-determine what becomes possible in Phase Two. However, the Phase Two concepts showed two distinct pathways for achieving additional height in the future:
constructing a wider-base levee in Phase One so additional elevation can later be added without further widening, or
adding flood walls atop the Phase One structure, referred to as the hybrid approach.
Because the first option requires committing to a wider footprint now, decisions about base width, alignment, and setback distances in Phase One will largely shape which Phase Two strategies remain viable. Future community dialogue should clearly indicate which Phase Two model is anticipated for each shoreline reach, describe the trade-offs considered, and explain why that approach is preferred.
Nature-based Adaptation Solutions to Sea Level Rise (SLR)
We also encourage the City to more clearly demonstrate how nature-based solutions (NBS) are being prioritized in designing SLR protection systems consistent with the RSAP. While NBS were referenced in the presentations, it was not always clear which strategies would be included or where or how they would function as an integral part of the sea level rise protection. The RSAP prioritizes Nature-based adaptation to SLR to be incorporated wherever possible in order to preserve Bay ecological functions that we all depend upon.
To support this discussion constructively, we attach a memorandum prepared by the San Francisco Estuary Institute (SFEI), which includes an analysis of the entire shoreline of Redwood Shores and identifies site-specific nature-based adaptation concepts along multiple segments of the Redwood Shores shoreline. The memo demonstrates that levee setbacks, marsh and shoreline restoration, ecotone slopes, and horizontal levees are viable in several locations. Many of these opportunities depend on preserving sufficient transition space in the Phase One alignments.
The RSAP also, importantly, notes that each city’s sea level rise plan must take regional needs into consideration so that opportunity areas for marsh migration, such as the KGO-Radio Tower basin, are identified in the project as potential marsh migration space and incorporated into the adaptation plan, possibly in Phase Two, for regional resilience needs.
The Need for Educational Outreach for Community Involvement
The RSAP requires involvement via dialogue with the community. Many community residents are clearly unfamiliar with the RSAP, the science of the flood attenuation, and habitat benefits and functions of nature-based systems, or how levee design can extend or reduce the life of shoreline ecosystems. Additional educational outreach is needed, potentially in partnership with science communicator experts such as SFEI, to help the community engage more constructively in the design tradeoffs ahead.
We were encouraged to hear at the February 9 study session that outreach feedback and survey results will be shared publicly. Ongoing transparency is essential. Clearly summarizing community input and demonstrating how it informs recommendations will build trust, maintain public enthusiasm, and improve the quality of participation.
Trail Amenities
We remain concerned about several trail amenities that were presented. The public meetings included features such as boardwalks to observation platforms which will encroach into the marsh, and trail shade structures reportedly in response to the online survey. Some of these elements may be ecologically problematic in this setting. Elevated structures in the water and the marshes increase human intrusion into sensitive marsh habitat so should be discouraged, and shade structures can easily create predator perches along the shoreline adjacent to habitat.
Similarly, light standards should not be used on the trail as they too provide predator perches, and lighting along levees or near sloughs should only be provided if and when necessary, using low bollards, low light levels and in very judicious amounts, in keeping with Dark Sky Principles.
Rather than waiting for formal environmental review to surface these issues, the Project team should proactively explain potential unintended habitat impacts and present amenities designed to avoid them. In isolation, a resident may favor a shade structure, but when informed of ecological consequences, that preference may change. Informed feedback leads to better decisions and better outcomes.
In Summary
We support advancing a thoughtful adaptive pathway design. To do so successfully, we respectfully request that
Community feedback at meetings and through online surveys be clearly summarized and reported to the community in a timely fashion. This is essential for successful community involvement, dialogue and buy-in.
RSAP, ecological benefits and tradeoffs be more transparently explained, potentially in an educational meeting such as with SFEI or other respected communicator, and all the information posted in a public area such as the Redwood Shores Library where it can be physically viewed and discussed with friends and neighbors, and
Sufficient time be provided, with a reasonable deadline, for informed public response before future design decisions are made.
These adjustments will strengthen the project, improve public trust, and increase the likelihood of durable community support, which will result in a much better solution.
Adaptive infrastructure requires equally adaptive governance that is transparent, iterative, and responsive. We look forward to partnering with the City to ensure this project advances flood protection in a way that protects residents, respects ecological function and preserves future options.
Thank you for your leadership and consideration.
Sincerely,
Jennifer Hetterly, Campaign Coordinator
Bay Alive Campaign
Sierra Club Loma Prieta Chapter
Gita Dev, Chair
Sustainable Land Use Committee
Sierra Club Loma Prieta Chapter
CC. Terence Kyaw, Dir. of Public Works, Redwood City <TKyaw@redwoodcity.org>
ATTACHMENT : SFEI Memorandum “Adaptation Concepts for the Redwood Shores Shoreline”
1 RSAP- Regional Shoreline Adaptation Plan as required by the Bay Conservation and Development Commission (BCDC) and by SB 272
2 OneShoreline Policy Planning Guidance to Protect and Enhance Bay Shoreline Areas of San Mateo County, June 2023, pp. 27-47. https://oneshoreline.org/wp-content/uploads/2023/09/OneShoreline-Planning-Policy-Guidance-Final-June-21-2023-For-Web.pdf
3 Bay Conservation and Development Commission Regional Shoreline Adaptation Plan, December 2024, Adaptation Strategy Standards 2-6, 8, 16, pp. 156-159, 163. https://www.bcdc.ca.gov/wp-content/uploads/sites/354/2024/12/regional-shoreline-adaptation-plan.pdf