February 12, 2025
MTC Public Information
Attn: Veronica Cummings,
375 Beale Street, Suite 800
San Francisco, CA, 94105
RE: Scoping Comments for Environmental Impact Report for Plan Bay Area 2050+
We are appreciative that PBA 2050+ is now recognizing the need to address environmental issues by proposing a new “Plan Bay Area 2050 + Environment Element” (EN1) into its Blueprint Strategies. However, this Strategy fails to address and incorporate into the Blueprint the San Francisco Bay Conservation and Development Commission’s (BCDC) recent adoption (December 2024) and incorporation into the Bay Plan of its Regional Shoreline Adaptation Plan (RSAP) as required by the passage of SB 272 (Laird). This action included the RSAP’s Subregional Shoreline Adaptation Plan (SSAP) Guidelines that every local shoreline government (and county) jurisdiction must use to develop its own Subregional Shoreline Adaptation Plan and then submit it to BCDC for approval by 2034.
The RSAP and SSAP Guidelines provide directives for all shoreline jurisdictions on how to adapt to rising sea level (SLR). Thus, EN1 should identify the RSAP/SSAPs as establishing the standards by which jurisdictions should address SLR. The EIR should evaluate the possible impacts to Bay habitats and to associated shoreline jurisdictions if the RSAP/SSAP Guidelines are not cited in PBA 2050+ and Blueprint because significant environmental community impacts, both direct and indirect may result due to potential discrepancies between what kinds of development and adaptation strategies local jurisdictions may approve based on an approved SSAP and what may be approved using only local planning zoning regulations and other local ordinances that were developed prior to SB 272 and were designed only to meet PBA 2050 requirements such as developing new PDAs or utilizing existing PDAs.
For example, many local jurisdictions have proposed or approved Priority Development Areas (PDAs) on the shoreline. How will the PDA’s zoning designations and ordinances correlate with the new need to develop SSAPs for the same areas (since as PDAs they are not yet fully developed or possibly development has not even started). It is likely that the PDA’s local zoning and other ordinance requirements will differ from the SSAP Guidelines. The potential differences between such zoning and an SSAP could result in the destruction of adjacent shallow water habitats such as tidal marshes, mudflats, beaches and submerged aquatic vegetation such as eelgrass. As is becoming well known, hard shoreline edges, such as seawalls, deflect tidal wave energy and this can lead to the erosion of outboard shallow water aquatic habitats. Equally, such deflections are also lateral and one protected shoreline can mean a highly vulnerable shoreline in an adjacent community will be subjected to intensive erosive energies. The EIR must analyze the potential for these impacts if the need for an approved SSAP is not incorporated into PBA 2050+ and Blueprint.
If this inclusion does not occur then, for example, if a PDA is not yet built up but is planned for development right to the shoreline while an approved SSAP recommends setting back the development from the shoreline, a local government would have to decide which to follow, the PDA or the SSAP. The EIR should make clear the potential impacts of this decision-making and suggest feasible mitigations.
The EIR should discuss the potential impacts to the Bay habitats if the PDA scenario was followed by some communities rather than the SSAP. After all, shoreline PDAs were not developed for the most part with SLR in mind and certainly not with the clear attention to environmental needs found in the RSAP/SSAP. For example, a recent study* found that hard edged seawalls can redirect wave energy not only onto adjacent shorelines but even distant Bay shorelines. Consequently, the potential impacts may be not only local but regional and even more significant.
The EIR should analyze whether PDAs are required to apply SSAP standards to all future planning, and if so, whether the impacts described above would be reduced or eliminated. The EIR would need to propose mitigations for these impacts, many of which may not be mitigatable.
Similarly, the new revisions to Priority Conservation Areas (PCAs) should be recognized in the Blueprint strategies and the consequences of failing to do so should be identified and analyzed within the EIR. It is our understanding that PCAs will now be allowed within shoreline PDAs and that regional PCAs will be identified, although local jurisdictions will not be required to utilize them. The EIR should analyze how the failure to incorporate PCA’s into the Blueprint (especially EN1) may result in significant impacts to shoreline habitats as well as local communities. PCAs can provide the opportunity to avoid shoreline development that will soon be either experiencing significant flooding or even inundation.
Similarly, many Strategies in the 2050+ Blueprint should recognize the RSAP/SSAP requirements as should the PDA program. Any failure to do so will almost certainly result in significant impacts to shoreline shallow water habitats. The EIR should analyze these potential impacts and suggest mitigation measures including avoidance.
For example, under the Transportation Element:
Both T6, Modernize Freeways and Interchanges, and T7, Expand Freeways and Mitigate Impacts provide opportunities for adapting to sea level rise at all locations that are predicted to face inundation due to SLR. Any failure to implement the SSAP Guidelines in the design process will likely result in impacts to shoreline habitats. Failure to follow the SSAPs could lead to decisions to implement mitigations that do not address the SLR adaptation issue in a manner consistent with the SSAPs, for example by ignoring the potential regional impacts of the project. The RSAP process is, of course, based on a regional, as well as local, approach in identifying impacts and adaptations. The EIR should analyze the potential for significant impacts resulting from this.
Both T11, Enhance Transit Frequency, Capacity and Reliability, and T12, Expand Transit Services throughout the Region similarly provide opportunities to adapt to SLR if the SSAP Guidelines are utilized in the planning process. Absent that, significant impacts to shoreline habitats are likely to occur as noted above and this should, again be analyzed in the EIR.
Under the Housing Element:
H4 Build Adequate Affordable Housing to Ensure Homes for All encourages new housing. Failure to incorporate SSAP Guidance into the planning for this housing may result in housing subject to flooding and/or inundation due to SLR in areas that existing mapping may already identify as being vulnerable to sea level and groundwater rise under the proposed 4.9’ of sea level rise, as well as significant impacts to shoreline habitats, perhaps with local and regional effects as well. The EIR should analyze these potential impacts, both direct and indirect.
Under this program MTC/ABAG has identified Growth Geographies and established a PDA program. Both programs should recognize the RSAP/SSAP and modify each program so as to ensure compliance with the RSAP/SSAP. Absent that, both programs may encourage local jurisdictions to ignore or put off implementing SSAPs while continuing to use current zoning to develop new housing projects under the Growth Geographies and PDA mechanisms. The EIR should analyze how any failure to incorporate the RSAP/SSAP program into Growth Geographies and PDA programs may result in significant impacts to both jurisdictions and shoreline habitats.
Under the Economy Element:
The Growth Geographies and PDA issues again require an RSAP/SSAP acknowledgement in order to avoid the flooding and inundation of local and county jurisdictions and damage to shoreline habitat (drowning of shallow water habitats, erosion of habitats, etc.) that may result from SLR and the failure to follow the SSAP Guidelines so as to avoid those impacts. The following Economic elements all entail potential new shoreline development or the expansion of existing shoreline development that may lead to the impacts described above. The EIR must analyze the potential for such impacts as a result of the failure to recognize and plan consistent with the SSAP Guidelines.
EC4 Allow a Greater Mix of Land Uses and Densities in Growth Geographies
EC5 Provide Incentives to Employers to Locate in Low-VMT Areas
EC6 Provide Incentives to Employers to Locate in Low-VMT Areas
Under the Environment Element:
EN1 Adapt to Sea Level Rise, fails to recognize the adoption of the RSAP/SSAP as part of the BCDC Bay Plan (thus becoming a legal requirement). While much of the descriptive text in EN1 is good, that omission renders EN1 inadequate for avoiding local and regional SLR impacts to shoreline habitats and to the local jurisdictions, since EN1 has no regional perspective (again, hard shorelines in one location may impact the immediate adjacent shoreline jurisdictions as well as distant shoreline jurisdictions. The EIR should address this issue and determine potential impacts that would result from the failure to incorporate the RSAP/SSAP program into the PBA 2050+ Blueprint and PBA 2050+.
To conclude, all elements of Plan Bay Area 2050+ Blueprint and the full PBA 2050+ should require any proposed new development upon the shoreline to wait until the local jurisdictions can both develop and obtain BCDC approval for their RSAP/SSAP proposals. Failure to do so threatens the legislatively mandated regional approach to SLR. In turn, inadequate or variable planning perspectives may have significant impacts locally and regionally to other jurisdictions and to the Bay itself. The EIR must analyze the potential impacts of such situations.
Sincerely yours,
Arthur Feinstein, chair
Sierra Club, Bay Alive Campaign
*JGR OCEANS Research Article
Assessing the Influence of Shoreline Adaptation on Tidal Hydrodynamics: The Role of Shoreline Typologies
Michelle A. Hummel Mark T. Stacey First published: 29 December 2020