Summary
October 18, 2024
San Francisco Bay Conservation and Development Commission
Metro Center
375 Beale Street, Board Room
San Francisco, CA
RE: Public Comment on the Bay Plan Amendment No. 1-24 to Adopt a Regional Shoreline Adaptation Plan and Establish Guidelines for the Preparation of Sea Level Rise Plans Pursuant to SB 272 (Laird 2023)
Dear Bay Conservation and Development Commission,
The County of Marin is submitting public comment for the Bay Plan Amendment No. 1-24 to Adopt a Regional Shoreline Adaptation Plan and Establish Guidelines for the Preparation of Sea Level Rise Plans Pursuant to SB 272 (Laird 2023). The County of Marin agrees that collaborative action is needed to respond to sea level rise. In addition to the $519,000 dollars allocated to Marin County’s Sea Level Rise Governance Project, Marin’s BayWAVE Initiative has invested approximately $1 Million to identify multi-jurisdictional solutions to support Marin’s response. The County’s overall response has been substantive, with an estimated $38M secured since 2009 to plan, design and construct flood and sea level rise protection projects and another $77M in future investments planned.
After reviewing the Draft Regional Shoreline Adaptation Plan, Staff Report and Preliminary Recommendation, we respectfully ask the Bay Conservation and Development Commission (BCDC) to consider the following points:
We request that all previous work for sea level rise, including but not limited to vulnerability assessments, climate adaptation plans or assessments, hazard mitigation plans, etc., be counted towards the requirements. The current draft guidelines state that previous work may be used, however they do not provide clear guidance on how existing plans will be evaluated, placing the burden on jurisdictions to ensure that they comply. We request that BCDC provide clear guidance and technical assistance to individual jurisdictions regarding which elements of the guidelines are not met by existing plans.
We request that BCDC create a draft, all-inclusive Scope of Work with an estimated cost associated for local governments to use to understand the true magnitude of staff time and funding needed. A Scope of Work will help Local governments that have already adopted plans or have plans underway to amend their current plans to fulfill guideline requirements. The estimated cost will help determine if identified funding sources are sufficient.
The draft guidelines state that local governments must work with other regional transit and utility agencies, however, we have concerns about agency capacity to coordinate with all jurisdictions under the 2034 deadline.
We have concerns about staff time required to fulfill these new planning requirements, while also moving forward urgent implementation projects to protect our community that have already been identified through previous planning efforts.
If you have any questions or would like to discuss any of the points outlined in this letter, please contact Ariel Espiritu Santo, Assistant County Executive at nevry.rfcvevghfnagb@znevapbhagl.tbi or 415.473.2408.
Respectfully submitted,
Derek Johnson
County Executive
CC: Ariel Espiritu Santo, Assistant County Executive
Marin County Board of Supervisors
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