Redwood City Saltworks
Photo courtesy of Matt Leddy
Since 2006, multinational Cargill Incorporated, the second largest privately held company in the U.S., and Arizona-based developer DMB Associates have been aggressively pursuing a campaign to rezone Cargill's Redwood City salt pond site to permit large-scale development.
Despite widespread opposition to Bay development, Redwood City, moved forward with the environmental review process for a massive bay fill development plan that would have placed 12,000 housing units, five schools, 1 million sq. ft. of office buildings and retail on 1,000 acres of salt ponds south of Seaport Blvd. The first Notice of Preparation for the Saltworks Project EIR was issued in October 2010. An unprecedented number, 900 hundred, of written scoping comments were submitted to the City in March.
Since that time, Cargill/DMB have withdrawn their original straw man project off the table, and is now focused on working behind the scenes to influence decisions of whether Clean Water Act jurisdiction exists on the site, despite the fact that jurisdiction has historically been exerted over this site, and despite the fact that jurisdiction was asserted over an analogous site in Napa, CA. We are aware that Cargill/DMB have had closed door discussions with U.S. Army Corps of Engineers (Corps) staff and Environmental Protection Agency (EPA) staff in Washington D.C. regarding whether these ponds should be subject to Clean Water Act jurisdiction. These ponds were created in the bay by building levees over tidal wetlands. Tidal slough channels can still be viewed in aerial photos.
Cargill's developer DMB has told the City and the press that a new development plan for the Saltworks site will be submitted after the federal agency jurisdictional question is resolved.
Photo courtesy of Matt Leddy, Pond 10, November 27, 2010
What's At Stake:
The 1433 acres of crystallizers and salt ponds in Redwood City were included in the 1990 Congressionally approved Refuge expansion boundary. The ponds are adjacent toGreco Island, already part of the Refuge, and restoration could expand the critical wildlife corridor between Bair island and Ravenswood Point in Menlo Park.These lands are of significant value in preserving and restoring habitat diversity within the south and central bay ecosystem, and for mitigating the impacts of sea level rise.
Developer DMB's project documents and public outreach materials attempt to portray the Redwood City salt ponds as an industrial wasteland or brownfield. Fortunately, the existing wildlife value of these salt ponds has been well documented.
Point Reyes Bird Observatory has data showing that tens of thousands of shorebirds were using the Redwood City salt ponds in the 1990's. A study in the1980's by the US Fish and Wildlife Service also documents thousands of birds in all ponds and crystallizers. Even the San Francisco Bay Regional Water Quality Control Board has commented on the existing value of this site calling the Redwood City Salt ponds an "important biological resource".
Beginning in December 2009, Matt Leddy with Friends of Redwood City counted and photographed hundreds of shorebirds feeding and roosting in ponds that are slated for development. On a day in February 2011, he observed over 5,900 shorebirds in Pond 10, including willets, black-necked stilts, marbled godwits, dowitchers, avocets and sandpipers. On a visit to the site in November 2010, he counted 2,100 birds on Crystallizer Pond 1 near Seaport Blvd. including western and least sandpipers and semipalmated plovers. Matt Leddy's complete report, Waterbird Counts in Select Redwood City Saltworks Ponds, can be viewed at the following link:
Cargill informed the City that it would continue to make salt if the project isn't approved. If a CEQA process moves forward for a new development plan, it's critical that the EIR for the Saltworks project accurately documents theexisting environment for this site, reflecting the important wildlife habitat associated with these salt ponds.
Project Impacts to Consider
The first of two scoping letters that CCCR and FORC submitted to Redwood City on March 31, 2011 provides extensive comments on the current environmental conditions at the Saltworks Project site, the existing habitat values and the importance of the site to regional Bay ecosystem goals.
Under the heading of "Unique Restoration Opportunities" for the Redwood City segment of the bay, the Goals Project stated, "The Redwood City crystallizers and associated salt ponds offer the opportunity to maintain and enhance shorebird and waterfowl habitat in close proximity to large tidal flats that are so important for foraging shorebirds. Creating salt pan habitat would provide nesting habitat for the snowy plover."
Our second scoping letter focused on the numerous other "potentially significant impacts" identified by the City in the Notice of Preparation and Initial Study for the Saltworks Project. As you would expect, a development plan that would place 30,000 new Redwood City residents on an isolated bayfill site could have serious impacts in all 18 environmental issue areas analyzed under CEQA including:
Traffic: Up to 70,000 new daily vehicle trips would create gridlock on Highway 101 and major City transportation corridors that are already operating at capacity. Funding for the Project's proposed transit solution doesn't exist beyond the site borders.
Water Supply: Redwood City has no water for the project, so DMB proposed a water transfer scheme using Kern County water rights that expire in 2070, and redirects agricultural water from the Delta to urban development.
Land Use and Planning: Any development on the salt ponds is inconsistent with the City's current General Plan land use designation of "Open Space" and with current "Tidal Plain" zoning. Residential development is incompatible with the adjacent Port and other industrial uses and a Saltworks project could affect the successful implementation of Redwood City's Downtown Plan for transit-oriented housing.
Geological and Flooding Hazards: Building at this location would place housing and structures on a site susceptible to liquefaction and "strong to violent" seismic shaking which could lead to lateral spreading and sloughing of the 13-foot tall perimeter flood levee. Residents would be living within a 100-year flood zone, at risk not only from a levee failure during an earthquake, but from sea level rise as well.
Water Quality: The site is surrounded by sensitive aquatic and tidal marsh habitats that could be adversely affected by numerous pollutants from construction activities and stormwater runoff.
Air Quality/GHG Emissions: Any large development project, once built, could have significant air quality impacts from increased ozone, particulate matter and greenhouse gas emissions associated with cars, buses and trucks. But also significant are the impacts from a 20-30 year build-out. Grading, construction equipment, and the transport of millions of cubic yards of fill will all contribute to degraded air quality.
Noise: Noise and vibration from construction, including use of pile drivers, could continue for 20-30 years, creating potentially serious impacts on wildlife, residents in the 1,000 adjacent mobile homes and workers in nearby businesses.