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Cypress Point Housing Project to Burden Environment, Infrastructure &

Public Safety 

Proposal in Process

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“There could hardly be a much worse location…”
   - The Sierra Club Loma Prieta chapter
“Five 'significant and unavoidable' traffic impacts”
   - Kittelson Traffic Impact Analysis for MidPen Housing

History

Since 2016, MidPen Housing has been in the process of purchasing an 11 acre undeveloped property on the border of Moss Beach and Montara, across Highway 1 from Point Montara Lighthouse, proposing to build a 71-unit housing project. We recognize the need for affordable housing in San Mateo County, but this isolated location is inappropriate, and the project is too big and will create environmental safety issues. This project will significantly and adversely impact Highway 1 traffic, road safety, the environment, and an already failing sewer system.

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The 11 acre parcel is located at a dangerous blind curve on HWY 1, across from the historic Point Montara Lighthouse on the border of Moss Beach and Montara.

The property is ill-suited for a large cluster of housing units. It is located at a dangerous blind curve on Highway 1, isolated from any community-oriented services, lacking infrastructure, adequate transit and walkability. As a former World War II top secret Naval training base, concerns regarding potential hazardous contamination have not been adequately evaluated. The County and MidPen continue to rely on an outdated Environmental Impact Evaluation done in 1985, before key toxic hazards, such as PCB’s and Asbestos, were known. These as well as lead are commonly found in Formerly Used Defense sites with similar history. 

 

After many drafts, discussions, meetings, letters and public reviews, the community remains steadfast in its opposition to the overwhelming scale of the project and its significant impacts on the environment. There has been no satisfactory response regarding the public safety concerns about toxic contamination for current residents, new family residents of the housing project, or the ever-increasing visitors to the San Mateo coast.

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Unaddressed Key Concerns of the Project
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  • The Cypress Point Housing Project is too big and too concentrated for the existing public works infrastructure, particularly regarding road deficiencies and an already stressed sewer system

  • Traffic impacts are significant and remain unmitigated

  • The County’s Connect the Coastside traffic management plan does not provide any commitment on CalTrans or SamTrans collaboration, feasibility or timing of major safety improvements, funding, or even what improvements must be in place to allow this or any major project to go forward

  • Peer Reviews of MidPen's Traffic Report, Hazards and Hydrology, Biological Resources Assessment, Wastewater Impact Analysis, and Vegetation Assessment raise significant issues about the environment and public safety that have not been addressed

  • There is no commitment to perform an EIR to assure public safety

  • Reasonably foreseeable cumulative impacts have not been adequately assessed

  • Coastal evacuation and hazard mitigation including wildfire and water resources have not been evaluated 

  • The location is inappropriate, isolated and potentially toxic

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Unaddressed Key Concerns: more detail


The Project is too big for the infrastructure

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Adding 71 units with up to 359 new residents in one location will be a major burden on the infrastructure. The basis for this project is a 1986 zoning and PUD approval that remains in the Land Use Map and LCP. Since then, the Lantos Tunnel (opened 2013) through Devil’s Slide was built instead of a multi-lane bypass, and from 2001 to 2003 POST acquired and conserved over 4,200 acres of Midcoast land previously slotted for dense development. These key events restrained the infrastructure development on the coast.

 

The zoning for this 11 acre parcel does not reflect today’s reality. Highway 1 and our Midcoast sewer and water infrastructure are already overburdened and at risk from rising seas. The Coastal Commission Staff early on recommended that MidPen evaluate a project size based on what's sustainable, guided by a true assessment of today’s challenges with infrastructure and traffic. The Midcoast community has reiterated this request to include consideration to the significant costs to coastside residents for project-specific upgrades.

 

Who will fund infrastructure upgrades?

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Traffic Impacts are significant and remain unmitigated

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MidPen Housing's application estimates 500 daily new vehicle trips will be generated from its proposed project. MidPen’s traffic consultants project five significant and unavoidable impacts to Highway 1 intersections in Moss Beach. The current options being presented to mitigate traffic are intertwined with the County’s Connect the Coastside and are inadequately assessed on feasibility. It is unlikely that these traffic issues can be mitigated without significant cost or in time for MidPen’s projected schedule. With the County’s help, MidPen appears to be backing away from responsibility for project specific impacts. Who will pay for traffic mitigations and will they be implemented in coordination with the project occupancy?

Connect the Coastside - Major concerns remain

The final version of Connect the Coastside (CTC), San Mateo County’s Comprehensive Transportation Management Plan for this Midcoast area was adopted by the Board of Supervisors on July 26, 2022. Although begun in 2014, Connect the Coastside was pushed to completion with MidPen’s Cypress Point housing project in mind.

 

However, CTC does not specifically propose mitigations for any foreseeable significant impacts from any development. With focus on Highway 1, it provides a framework of alternatives subject to CalTrans evaluation and approval, and SamTrans regarding transit as well as other public agencies as appropriate, expecting a lengthy process and projecting implementation schedules beyond 15 years for major improvements. It serves as a basis for seeking adequate funding, and will require feasibility studies, project-by-project environmental review and appropriate implementation approvals. The County is now sponsoring a new traffic study for 2023 to evaluate alternatives for the Moss Beach corridor along the Highway from Cypress Ave to 16th Street.  

  

The proposed traffic improvement alternatives include ballpark cost estimates which are eye-popping and clearly underestimated, with no committed funding and no clarity on who will pay. Further, the traffic data is outdated as it was gathered in 2014. The Covid-19 pandemic beginning in 2020 is likely to result in significant and long-lasting changes in traffic, transit and the economy.

 

Connect the Coastside includes some questionable assumptions. Traffic patterns and climate patterns may be changing in dramatic ways. Since the pandemic, the coast has been even more flooded with visitors seeking outdoor activity. Yet Connect the Coastside assumes visitor traffic will diminish, contrary to the assumption by the City of Half Moon Bay that visitor traffic will only continue to increase.

 

Major concerns remain. The Cypress Point housing project submitted a Coastal Development Permit application in July 2022, remarkably ahead of any insight to possible transportation improvements. The County is participating in this development.

Peer Reviews have not been considered

Five significant peer reviews of MidPen's environmental and public works studies were submitted by Midcoast ECO to the County in 2020 but are not referenced in the County’s staff report for the zoning change nor in the Coastal Commission’s staff report.

 

  • TRAFFIC - Pang Engineers, Inc produced a 14-page report reviewing MidPen's traffic study in the application, Caltrans response letters, SM County's Civil engineer traffic comments, and the Connect the Coastside Executive Summary. It revealed "potentially significant deficiencies, omissions and inaccuracies" and called for additional clarifications regarding mitigations. Click here to read Pang's peer review of MidPen's Traffic report.

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  • HAZARDS & HYDROLOGY -  SWAPE's Matthew Hagemann, a CA-licensed hydrogeologist and former Senior Science Policy Advisor with the US EPA peer reviewed MidPen's application regarding hazards, hazardous materials, and hydrology. He raises serious concerns about lead contamination, and MidPen's failure to adequately evaluate the proposed Moss Beach project's impacts. Click here to read SWAPE's peer review of hazards, hazardous materials, and hydrology.
     

  • WASTEWATER IMPACTS - Civil Engineer Robert W. Emerick, Ph.D., P.E. reviewed MidPen’s Wastewater Impact Analysis for the proposed MidPen Cypress Point project. He reviewed numerous documents to provide his detailed assessment, raising significant issues that MidPen’s analysis failed to identify. Click here to read Emerick's peer review of Wastewater Impacts.
     

  • BIOLOGICAL RESOURCES - BioMaAS Inc.’s Biologist, Steve Powell, reviewed MidPen’s Biological Resources Assessment (BRA). His review finds the BRA to be inadequate in describing the project as well as all actions associated with it. In addition, the BRA fails to analyze if the project will potentially violate the federal Endangered Species Act and Clean Water Act along with various other regulations. Its omissions result in an inadequate discussion of mitigation measures. Click here to read Powell's Peer Review of biological resources.
     

  • VEGETATION ASSESSMENT - Local professional forager, naturalist and plant identification expert, Bryan Jessop reviewed the Vegetation section of MidPen’s Biological Resources Assessment. He documents his own findings in the area and concludes that the Vegetation Assessment is clearly incomplete and unreliable. Click here to read Jessop's peer review of Vegetation Assessment.

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Commitment to perform an Environmental Impact Report Pending

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This property was a World War II top-secret military site that has never been officially assessed or cleaned up. The County and MidPen Housing have downplayed the potential of hazards in preliminary investigations, even though MidPen’s own reports on hazards found lead contamination. To date, they have resisted investigating concerns about asbestos. Any activities that disrupt the soil will likely create exposure pathways to residual contaminants if present. MidPen proposes to haul 875 truckloads of material as disclosed in their plans. https://www.smcgov.org/planning/cypress-point-affordable-housing-community-project-2019-lcp-amendment (see Chapter 11: Air Quality and Green house Gas, Appendices, Construction TAC Emissions, Section 3.0, Trips and VMT)

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A historical overview of the military site including maps identifying buildings and usage-type are available. Prior to any development on this location, a new and thorough environmental assessment of this land should be done that takes into account its history as a Formerly Used Defense (FUD) site that may be contaminated.

• Click here to read confirmation letter of asbestos on property

• Click here to read more about the history and environment of this World War II site

• Click here to read more on inadequate testing performed on site

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In October 2022, the Board of Supervisors approved an agreement with SWCA Environmental Consultants to prepare an EIR in relation to MidPen’s application for a Coastal Development Permit. The agreement term ends on September 30, 2023, and is for the amount of $244,263. On December 9, 2022, the County issued a Notice of Preparation seeking public input by January 9 for scoping the EIR. In accordance to the memo, “once the DEIR  has been completed, a 45-day public comment period will begin.” The issue of "Hazards and hazardous materials” is one of about 20 potential environmental effects of the project that should be evaluated to assure the public safety for all including the natural environment has been considered. 

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Cumulative impacts are worsened

MidPen Housing estimates 500 daily new trips will be generated from its proposed project. This is in addition to approximately 1,500 daily trips that will be generated by Big Wave (already approved for Moss Beach) and various other local development projects are in the works. In addition to residents who need to commute to work and school, we must also consider 3 million annual visitors to the SM Coastside according to the 2020 Half Moon Bay LCP estimate.

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A threat to coastal evacuation

Highway 1 is the only road in, through, and out of the Midcoast, with no alternate routes and no road expansions on the horizon. Extreme and elevated wildfire risk is a new reality for the coast. A Hazard Mitigation Plan effort was recently launched to include a focus on wildfire concerns, however, for now the assessment is that evacuation in case of a major wildfire will not be feasible.

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In 2019 the California Public Utilities Commission released updated fire threat maps for the unincorporated Midcoast that classify surrounding areas of Moss Beach and Montara as extreme high fire risk - the highest possible fire risk rating. MidPen’s 2019 application does not evaluate this risk nor does the County’s January 2021 Connect the Coastside draft of a Comprehensive Transportation Management Plan (CTMP).

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Beginning in late 2019, PG&E imposed several lengthy power outages locally which brought traffic to a standstill along the San Mateo County coast. Today power outages continue to be implemented to reduce fire risk as well as to manage usage during periods of power grid stress. With the beginning of the Covid-19 pandemic in early 2020, visitor traffic to the coast dramatically increased as people seek outdoor relief. These complicating factors are likely here to stay. This proposed project would increase risk for drivers on narrow neighborhood streets and Highway 1, with hundreds of cars added to an already perilous safety situation.

Inappropriate / Isolated Location
Potentially Endangering Public Safety

Moss Beach is a small bedroom community with few jobs and services. It is isolated, located five to seven miles in either direction from the nearest town centers of Pacifica and Half Moon Bay. Inadequate public transportation and a lack of walkability to access groceries, doctors, jobs, schools, pharmacies, and community-oriented services further indicate that this project is too large for this location. Both the Level of Service (LOS) and the Vehicle Miles Traveled (VMT) calculations would be significant. This car-dependent location will result in a financial burden for affordable housing residents and an increase in greenhouse gas pollution contrary to the goals of affordable housing.

 

Regarding presence of hazardous materials, MidPen’s own subsurface soil investigation, while limited and inadequate, found concentration of lead exceeding 9 times the Environmental Screening Level. While it was common practice to use asbestos in building materials and there is evidence that asbestos is likely present, MidPen has not screened for asbestos or other known toxins such as PCB’s.

 

We understand the need for affordable housing. It is a noble cause and we support the efforts to find sustainable solutions to the housing crisis. But is this site safe for families? What have we learned from recent history about toxins on former military sites? From Paradise under wildfire evacuation? From the Lightning Complex fires?

 

The pressure to build housing does not justify putting public safety at risk, especially in an already questionable location.

 Midpen Cypress Point Housing Project - Our Position

 

​MidPen Housing and the County relied on the 1986 approved zoning and PUD of the property to contend that it already passed the LCP policy compliance review. We dispute this position and provide case precedents establishing that a project must compare to what is the “existing” state and not the “approved” state in evaluating impacts.

 

  • 2020 Peer Reviews of MidPen's environmental and public work studies provided by Midcoast ECO must be considered in evaluating appropriate zoning of this land.
     

  • MidPen Housing must evaluate a project size based on what's sustainable, guided by a true assessment of today’s challenges with infrastructure, traffic and climate change evidence.
     

  • A full Environmental Impact Report must be performed to assess this former top-secret World War II military site and potential contamination.
     

  • A full assessment of cumulative impacts must be performed of both approved and proposed large-scale developments for the expanse of Highway 1 from Half Moon Bay to Pacifica.
     

  • The County should hold MidPen Housing responsible for full costs of mitigations for adverse impacts on the natural environment as well as public access to beaches, traffic, sewer / water and other infrastructure that their project will impose.
     

  • Traffic management plans must answer the unaddressed issues and financial costs pertaining to large-scale projects like this.
     

  • There must be a comprehensive, coordinated Disaster Preparedness and Evacuation Plan for the San Mateo County Coast.
     

  • In conformance with the goals of affordable housing, this location chosen by MidPen Housing and the County is not an appropriate location for a large-scale housing project, as it will not reduce VMT and is not near adequate public transportation, family-priced groceries, doctors, jobs, schools, pharmacies or community-oriented services.
     

 

Alternatives to Consider:

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  • Smaller Scope
    A significantly smaller housing project, and one that will generate less traffic such as housing for seniors or developmentally disabled, might be less stressful on the infrastructure and environment. A fact-based assessment must be performed to determine sustainability.
     

  • Community Center for the Midcoast
    The Midcoast is sorely missing a meeting community center with services. A community center could provide internet access, library and other information and social services to locals.
     

  • A Community Park
    This land has been enjoyed as open space by the community for decades and has significant wildlife activity and coastal habitat that could be enhanced. It is noted as “potential open space” on the land use maps. It suffers from neglect that could be easily remedied to avoid dumping and other destructive activities. A community park would be very much in keeping with the coastal character and valued by the Coastal Act.

Agency Comment Letters
Project Process & Timeline

MidPen Housing with San Mateo County Planning is pursuing this housing project in two phases. Phase 1 was processed as an LCP Amendment to rezone and replace the 1986 PUD, approved by the SMC Board of Supervisors and certified by the CCC in March 2021. This change is being challenged by Midcoast ECO’s lawsuit as described below. Phase 2 is in process as an application for a Coastal Development Permit (CDP), an Environmental Impact Report (EIR), a Design Review permit, and a grading permit.

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Midcoast ECO’s Lawsuit Challenges Approval of Phase 1 LCP Amendment and Rezoning - In Process

 

June 14, 2023

Midcoast ECO files Notice of Appeal

 

April 21, 2023

Honorable Samuel J. Feng ruled to deny Midcoast ECO petition against California Coastal Commission, San Mateo County & San Mateo County Board of Supervisors 

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January 9, 2023

Midcoast ECO filed Reply Brief. Unless the Court requests further information, the Court will proceed with its evaluation based on submittals to date. 

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Click here to read 1/9/23 Midcoast ECO Reply Brief

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December 5, 2022

California Coastal Commission and County of San Mateo each file Opposition Memorandums to counter Midcoast ECO’s Opening Brief. 

 

Click here to read 12/5/22 CCC Opposition to Midcoast ECO Petition

 

Click here to read 12/5/22 County of San Mateo Opposition to Midcoast ECO Petition

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October 31, 2022 - Midcoast ECO vs CA Coastal Commission: Opening Brief Submitted

Midcoast ECO submitted a detailed opening brief on the legal merits of our lawsuit petition, in which we allege that the California Coastal Commission failed to evaluate the reasonably foreseeable impacts of the specific plan and that the Local Coastal Program amendment violates Coastal Act policies.

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Click here to read 10/31/2022 Midcoast ECO's Opening Brief

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April 21, 2021 - Midcoast ECO Sues CA Coastal Commission regarding Insufficient Environmental Review of Cypress Point LCP Amendment, etc.

Midcoast ECO filed suit on April 21, 2021 in San Francisco Superior Court challenging the California Coastal Commission’s (CCC) certification of San Mateo County’s Local Coastal Program (LCP) Amendment LCP-2-SMC-20-0054-l, consisting of a Land Use Plan and Implementation Plan Amendment for the proposed Cypress Point Planned Unit Development (PUD) in Moss Beach.

 

The complaint alleges that environmental review of potentially significant adverse impacts has not been sufficient to approve San Mateo County’s LCP amendment LCP-2-SMC-20-0054-1 and that the CCC has violated the California Environmental Quality Act (CEQA) and the CA Coastal Act of 1976 in approving the amendment. 

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• Click here to read summary notice 

• Click here to read 4/21/21 Complaint

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Phase 2 - Status for EIR, Design Review and CDP

December 2022

Notice of Preparation (NOP) of a draft Environmental Impact Report was issued on December 9. A public scoping meeting for the Cypress Point Housing Project was held at the Planning Commission meeting on December 14 in accordance to the memo on EIR Procedure. “Once the DEIR has been completed, a 45-day public comment period will begin. Notice of availability of the DEIR for comment will be sent to any agencies, groups or individuals who request notification. The DEIR will be placed on the Planning Department’s web site for ease of access. During the public comment period on the DEIR, the County will hold a public meeting to present the DEIR to the Planning Commission for their input and to provide an additional opportunity for public input. Public comments received during this 45-day period will be considered in the preparation of the Final EIR (FEIR).”

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Oct 18, 2022

Board of Supervisors approved agreement with SWCA Environmental Consultants, for term 10/24/22 - 8/30/23, in the amount of $244,263, to prepare the EIR (staff report).

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July 6, 2022 - CDP Submission

An application for a Coastal Development Permit was submitted by MidPen Housing July 6, 2022 although it is still missing an EIR and other documents. The CDP is missing mitigation measures for environmental and infrastructure concerns as identified by the community and Midcoast ECO, as specified in our pending lawsuit. Click here for the 2022 CDP Application

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Phase 1 - Approvals completed - Pending Midcoast ECO’s Lawsuit

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Zoning Change, revised PUD and LCP Amendments
MidPen Housing, with the support of San Mateo County, proposed changes and amendments to the County's Zoning Regulations and Local Coastal Program (LCP). The Zoning change reduces the density from Medium High Density Residential to Medium Density Residential and replaces the Planned Unit Development (PUD) associated with the zoning change to accommodate MidPen’s project. The new PUD includes various changes to the implementation plan beyond the reduction of housing units. These changes necessitate amendments to the Local Coastal Program Implementation Plan and require the California Coastal Commission’s (CCC) certification of compliance with the Coastal Act. The approvals were completed and challenged as noted above.

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Coastal Commission Certification - March 12, 2021

During a virtual public meeting, the California Coastal Commission approved the amendments of the Land Use Plan and the Implementation Plan as submitted by San Mateo County and per the CCC Staff recommendation, with no questions or modifications. Many comments in opposition were submitted including comments from the Law Office of Brian Gaffney, representing Midcoast ECO. We remain concerned about the inadequacy of reviews on the impact to existing environmental conditions and public safety. No commitment to conduct a new Environmental Impact Report (EIR) was specified.

 

Click the links below to read the documents related to this Coastal Commission Meeting:

• Summary of CCC Staff Recommendation (2/26/2021)

• Exhibits for CCC Staff Recommendation

• Addendum to CCC Staff Recommendation (3/11/2021)

• Midcoast ECO's Comments Letter to CCC (3/5/2021)

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San Mateo County Approval - July 2020

The zoning changes and LCP amendments were approved by the Board of Supervisors and are the basis for proposed amendments to the LCP of the Unincorporated Areas of San Mateo County which also require CCC certification. These changes impact the County’s land use map and general plan as well as the Midcoast’s LCP. 

 

Note: San Mateo County has provided $5.5 million to MidPen Housing for pre-development costs. 

May 2019: $600K (HOME)
Oct 2018: $3M (Affordable Housing Fund)
May 2018: $400K (HOME) 
Oct 2017: $1M (Affordable Housing Fund)
Oct 2016: $500K (Affordable Housing Fund)

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