ReWild Coalition Letter to City of San Diego Environment Committee

As we have seen when thousands were flooded out of their homes and businesses during a February rainstorm, and twice in January when the ocean sent thousands of pounds of beach sand surging into our coastal communities, the City of San Diego is under direct onslaught from extreme weather events.

These events will continue to grow in frequency and severity. In addition to storm surges and bigger rainstorms, our sea levels are rising. The Pacific Institute has predicted 3.3 to 4.6 feet of sea level rise by 2100, and the state Ocean Protection Council’s draft 2024 guidance recommends planning for a minimum of 3.1 feet of sea level rise.

Members of the San Diego City Council Environment Committee are in the most powerful seats in the city to address these issues, and have the responsibility and capacity to act, adapt to, and manage these imminent threats to our coastline and bays.

ReWild Mission Bay, and by extension the 86 community organization members of the ReWild Coalition, have provided the city with feasibility studies, new research, engineering results and community leadership to restore these areas of environmental concern destroyed in our recent history. Since the completion of the ReWild Mission Bay Feasibility Study, our coalition has created and highlighted the economic value of the existing marsh habitat, the value of carbon sequestration the marsh provides every day, and the ability of our public parks to reconnect us to our shared shorelines, especially for Native American communities who, over time, saw their connection to the coast severed.

The ReWild Coalition has consistently advocated for the Wildest alternative to be acted upon for the wetland restoration component of the land use plan update in the northeast corner of Mission Bay Regional Park. The Wildest plan demonstrates that 315 acres of restored habitat — including 227 acres of restored tidal wetland — are entirely feasible. The 30-year old Mission Bay Park Master Plan calls for wetland restoration, requires water quality improvement be the “foremost consideration” of land uses, and enables the city to responsibly plan for sea level rise as required by the Supplemental Environmental Project (SEP) analysis funded through the Regional Water Quality Control Board settlement in 2020.

With SEP funding, the City of San Diego was able to include the Wetlands Optimized alternative, which comes the closest to Wildest in restored acreage, and is the clear, environmentally-superior alternative in the De Anza Natural EIR. Prioritizing contiguous restored habitat, water quality improvement, new recreational opportunities, and additional carbon sequestration should lead councilmembers to call for Wildest acreage and the Wetlands Optimized alternative.

Implementation of either of these alternatives brings the city closer to its own Climate Action Plan (CAP) commitment to new tidal wetlands than the city’s De Anza Natural alternative does. In fact, the city just settled a lawsuit related to its implementation of the CAP. Wildest acreage is the fastest path to restoring 350 acres of salt marsh and other associated tidal wetlands by 2030, and 700 acres by 2035. Prioritizing wetland restoration is also supported by the city’s Climate Resilient S.D. policy that prioritizes habitat restoration as a nature-based solution, and the goals of the Parks Master Plan for wetland restoration and access to culturally-important habitats for Native American communities.

While the De Anza Natural Plan is much improved from the city’s initial 2018 Notice of Preparation (NOP), it falls short of the benefits described above in several critical ways. By addressing these changes below in the proposed Mission Bay Park Master Plan amendment, the city’s path toward a resilient shoreline and greater opportunities for access become more clear. The proposed amendment must:

1.    Be more resilient to the future impacts of sea level rise. The current proposal before the committee could result in environmental hazards, safety concerns and wasted money from putting costly infrastructure in the way of foreseeable impacts.

Solution: Commit in this amendment to transitional infrastructure on the proposed “island” west of De Anza Cove. This can be done by taking the following steps:

• Remove existing infrastructure.
• Contour the elevations so marsh migration will occur and state that “this plan anticipates and plans for the island becoming wetland in the coming decades.”
• Design new infrastructure to facilitate future removal.
• Require only nature-based solutions and shallow grades along the shoreline.
• Designate the island as primitive and/or low-impact low-cost guest accommodation.

2.    Keep existing open water or restore it to wetland. Filling open water to create non-wetland habitat will not be approved by regulatory agencies down the line, and is an unrealistic, damaging proposal to begin with.

Solution: Pull the regional parkland, upland, beach and boat facility back to the existing upland boundary, and create four additional acres of high marsh/transitional habitat in those areas.

3.    Improve the existing habitat and water quality with a 100-foot minimum buffer, as the city’s own biological guidelines for wetland buffers in the Coastal Overlay Zone require. The buffer creation should be phased so that existing sports fields are not displaced until there are new fields and/or facilities.

Solution: Change “100-foot average” to “100-foot minimum buffer along wetlands and the entire Rose Creek frontage,” and add “on the water side of public access paths within the 100-ft minimum buffer, use landscaping to better protect the area from intrusion by domesticated animals and people.”

4.    Address the habitat impacts of poorly designed and wasteful night lighting.

Solution: Add night habitat protections to the plan by taking the following steps:

• No night lighting will be permitted within the buffer except a greater than four foot-high bollard-style lighting.
• Ensure that night lighting will be directed away from and shielded so as not to illuminate native habitat and habitat buffers.

5.    Require that the proposed channel between Rose Creek and De Anza Cove be functioning habitat to improve water quality and increase the freshwater input needed for proper functioning of the restored eastern tidal wetlands. A smaller and shallower cove could benefit from the creek flow.

Solution: Remove “or other water conveyance” from the description of the channel and ensure this area is included in the wetland management plan. Also replace the sentence “If future hydrology analyses…could be reconsidered” with “The channel should be designed to improve water quality in De Anza Cove and support wetland restoration to the east of Rose Creek.”

6.    Add a timeline and benchmarks—a problem recently identified and addressed in the city’s Climate Action Plan settlement agreement.

Solution: Add “Commit to creating the wetland management plan, including an implementation component, and completing wetland restoration by 2030, consistent with the existing Climate Action Plan and other relevant plans.”

7.    Include wildlife agency review and concurrence, demonstrating a commitment to input from the community. Future general development plans, project-level designs and management and access plans should commit to this since this amendment and Programmatic EIR do not include enough project design details.

Solution: Revise the Recommendations subsection of the De Anza Natural section with “Wildlife agency (e.g., U.S. Fish and Wildlife Service and California Department of Fish and Wildlife) review and concurrence will be required prior to City approval of future General Development Plans or project level designs,” and add under Wetland Location “Wildlife Agency (e.g., U.S. Fish and Wildlife Service and California Department of Fish and Wildlife) and community groups will be partners in creating and implementing the wetland management plan.”

8.    Protect recreationists and wetland habitat by staying non-motorized in De Anza Cove, as proposed. A non-motorized cove and tidal habitat complex will offer novel and economically-valuable recreation for Mission Bay Regional Park, while being safer for swimmers and easier to enforce and patrol for Mission Bay Park Ranger staff and lifeguards.

Solution: Retain the use of the cove as non-motorized.

9.    Put camping on the same footing as recreational vehicles. The master plan is biased towards recreational vehicles as the way to provide low-cost guest accommodation.

Solution: In Key Recommendations, part iii Tourist Attractions, revise the “Overnight facilities for recreational vehicles” sentence to add “and other types of camping or low-cost visitor accommodations.”

10.    Show the city’s commitment to maximizing public access where it doesn’t conflict with wildlife and water quality improvement goals. Access to the public shoreline is not clearly identified as a goal.

Solution: In Key Recommendations vii Access and Circulation, should add “in compliance with the buffer land use and requirements in the City’s Biological Guidelines.”

This amendment is long overdue, and has had numerous false starts in previous decades. We commend the current leadership of the Planning Department for revising the De Anza Natural Amendment to the Mission Bay Park Master Plan and making it align more closely with the principles of climate action and resilience the City of San Diego has adopted elsewhere.

The ReWild Coalition particularly supports the inclusion of the clause recognizing the cultural connection of the Tipai-Ipai to this place and the need to add interpretation to the park that respects and restores that connection. This must be strengthened and enacted.

ReWild has identified several areas where De Anza Natural must be improved to ensure this plan is the most protective of critical habitat, aligned with best practices and current climate science, and still allows for a balanced approach to use types that meet visitor needs and regulatory requirements.

The ReWild Coalition has been a productive partner with the city and wants to see critical waterfront habitats restored for future generations as quickly as possible, and remains happy to discuss requests further.