Tell BCDC's Commissioners to Prioritize Ecosystem Health, Natural Resilience, and Contamination Safety in the RSAP

Strengthening the RSAP for a Resilient Bay Area

Dear BCDC Commission, The Regional Shoreline Adaptation Plan (RSAP) will shape the future of our region, my community, for years to come. Our Bay waters, shoreline habitats, and communities depend on getting this right. Commendable Progress, But More Is Needed\nThe RSAP makes important strides by integrating equity assessments at every stage of planning and setting some strong Adaptation Strategy Standards (Standards) related to Baylands ecosystems.  However, there are critical gaps in the Standards, an insufficient emphasis on natural and nature-based solutions (NNBS) across plan elements, and a disconnect between the Standards and the rest of the RSAP. Addressing these issues is vital to avoid confusion, ensure compliance, and realize the RSAP’s One Bay Vision. Key Areas for Improvement\nTo sustainably and cost-effectively protect the Bay Area, please consider the following: 1. Prioritize ecosystem health and NNBS at every step\nNNBS offer a cost-effective, win-win approach to SLR. Baylands ecosystems—essential to our communities, our economy, and global biodiversity—are on the front lines of the crisis, both facing risk and offering opportunity. These natural ecosystems provide vital services like flood control, pollution filtration, and climate regulation that our communities depend upon. Yet, SLR threatens their survival just when their resilience tools are most needed.  * The RSAP should prioritize Baylands health by making NNBS and habitat ecosystems core considerations for every aspect of SLR plan development. As an example, mapping of opportunities for NNBS, including habitat migration, should be included in the checklists for each Strategic Regional Priority. 2. Clarify requirements and emphasize ecosystem health standards\nInconsistent reference to requirements between and among the Vision Statements, the “required assets and actions” in Section 2, and the Standards in Section 3 may create confusion and hinder progress. Much like the equity assessment, Ecosystem health Standards should be explicitly required in each RSAP element and checklist, ensuring clarity, compliance, and successful implementation. 3. Strengthen Groundwater and Contamination Standards\nSLR poses significant contamination risks from toxic sites and landfills along the shoreline. While the RSAP includes a narrow standard for reducing contamination risks due to flooding in socially vulnerable, environmental justice (EJ) communities, it fails to address non-emergent groundwater rise and soil disruption related to adaptation projects themselves. The RSAP currently also lacks any contamination Standard for non-EJ communities.   * Expand Contamination Standards\nBroaden the EJ standard to include contamination risks from non-emergent groundwater rise, not just flooding, and add a contamination Standard for non-EJ communities. 4. Define Metrics for Habitat Goals The RSAP includes a Standard that requires protection, restoration, and/or enhancement of Baylands habitats to “meet habitat goals,” but these goals are neither defined or quantified.  * The RSAP should establish clear, measurable habitat goals and require each local plan to specify how it will contribute to them, and BCDC should monitor and report on progress toward these targets to ensure accountability and success. This is an unprecedented opportunity to safeguard the long-term health and resilience of the San Francisco Bay and its communities. The RSAP has the potential to protect vulnerable populations and ecosystems, but only if it includes stronger, clearer, and more specific guidelines that prioritize natural and sustainable solutions. Please strengthen the RSAP in these key areas to ensure the One Bay Vision becomes reality and secure a resilient future for all. Thank you for your consideration.