February 21, 2025
Valley Water Board of Directors
Re: Feb 25 Board Meeting Agenda Item 3.4
The Sierra Club Loma Prieta Chapter and our Bay Alive Campaign along with the Santa Clara Valley Bird Alliance represent tens of thousands of members and supporters committed to advancing the health and resilience of the San Francisco Bay, its wildlife, and its shoreline communities. We are particularly concerned about the scope and timeline of sea level rise protection efforts in Santa Clara and San Mateo Counties.
The U.S. Army Corps of Engineers (USACE) decision to indefinitely postpone action in the Phase II area of Project E7 heightens the urgency of pursuing alternative strategies to protect critical shoreline assets. However, the proposed modifications to Project E7 and the previously agendized reallocation of Phase II funds risk excluding Environmental Impact Areas (EIAs) 1-4 from the benefits promised under this voter-approved local tax. Valley Water must ensure that the Safe, Clean Water and Natural Flood Protection Program continues to direct substantial investments toward flood resilience projects in EIAs 1-4, as originally intended.
We respectfully request the Board to do the following.
Preserve Safe, Clean Water and Natural Flood Protection Project E7 funding for EIAs 1-4 rather than reallocating it to other geographical areas.
Retain the stated benefits of Project E7, including restoring 400 acres of tidal marsh and related habitats in EIAs 1-4 and protecting critical structures, such as the Regional Water Quality Control Plant.
Maintain the ability to use Project funds for design and construction to support resilience efforts in these areas.
Revise the Control Process Update to ensure robust outreach and engagement well in advance of required public hearings.
With the indefinite postponement of USACE’s Phase II levee project, program investments for EIAs 1-4 should support the additional goals of the parcel tax, particularly the restoration and enhancement of tidal marshes and natural habitats. For Palo Alto and Mountain View, the Baylands’ natural flood resilience properties will be the primary remaining defense against sea level rise. The Bay Conservation and Development Commission’s recently adopted Regional Shoreline Adaptation Plan (RSAP) underscores the urgency of protecting and expanding healthy Baylands as a critical element of regional resilience.
Rather than reallocating funds originally designated for a Phase II levee to cover cost overruns elsewhere, Valley Water should instead reinvest them in nature-based solutions within the same shoreline area, aligning with the RSAP’s priorities. Palo Alto and Mountain View taxpayers should not be doubly burdened, first by the loss of federal investments in levee protections, and then by the diversion of their parcel tax contributions to other communities.
Maintaining the current benefits of Project E7 and ensuring that Safe, Clean Water and Flood Protection Project funds remain available for planning, design, and construction would provide needed assurance that these communities’ resilience needs will not be overlooked. There are projects in Palo Alto and Mountain View, some already identified and others requiring additional study, that could be undertaken if they had funding, including the essential protection of the Regional Water Quality Control Plant in Palo Alto that serves multiple jurisdictions. Now is not the time to exclude EIA 1-4 localities from this critical funding source.
Additionally, we remain deeply concerned about the inadequate level of outreach to Palo Alto and Mountain View residents and officials. At Valley Water’s February 11 hearing, it was evident that city officials in both cities were caught off guard by the scheduled vote. If city officials were unaware, it is reasonable to assume that the broader public was as well, indicating that Valley Water’s outreach efforts were wholly insufficient. Valley Water must fully engage with city governments, businesses, and community groups before eliminating funding for local projects that affect them. Mere notification is not enough; effective engagement is essential to public oversight, particularly now that Valley Water no longer needs to return to voters for program changes. We urge you to revise the Control Process Update to require more substantial outreach and engagement before significant funding decisions are made.
While we appreciate the postponement of the February 11 vote, a two-week delay is insufficient to properly address these concerns with municipalities and the public. We urge you to refrain from voting on the proposed modifications until extensive outreach has been conducted.
Thank you for considering these comments.
Sincerely,
Jen Hetterly
Bay Alive Campaign Coordinator
Sierra Club Loma Prieta Chapter
Shani Kleinhaus
Environmental Advocate
Santa Clara Valley Bird Alliance
CC:
Palo Alto City Manager
Mountain View City Manager