Major Housing Project to Burden Neighborhood Roads & Infrastructure
Proposal in Process
- The Sierra Club Loma Prieta chapter
- Kittelson Traffic Impact Analysis
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 multi-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 overwhelm the small surrounding neighborhood. This project will significantly and adversely impact Highway 1 traffic, road safety, the environment, and an already failing sewer system.
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 evaluated. This development could increase the population of Moss Beach East of HWY 1 by 26% and worsen traffic problems, road safety, and environmental conditions.
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.
Unaddressed Key Concerns of the Project
This 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
Connect the Coastside traffic management plan is incomplete
Peer Reviews of MidPen's Traffic Report, Hazards and Hydrology, Biological Resources Assessment, and Wastewater Impact Analysis raise significant issues that have not been addressed
There is no commitment to perform an EIR
Cumulative impacts are worsened
The threat to coastal evacuation and water resources
The location is inappropriate and isolated
Watch our video to get a visual explanation as to why Moss Beach does not have the road infrastructure to support a large-scale housing project.
Unaddressed Key Concerns: more detail
The Project is too big for the infrastructure
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 old 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.
Traffic Impacts are significant and remain unmitigated
MidPen Housing's application estimates 500 daily new trips will be generated from its proposed project. Their traffic consultants project five significant and unavoidable impacts to Highway 1 intersections in Moss Beach. The current suggestions being presented to mitigate traffic are intertwined with the County’s Connect the Coastside and are inadequately assessed. It is unlikely that these traffic issues can be mitigated without significant cost. 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?
MidPen Housing has so far avoided addressing the five "Significant and Unavoidable" issues on Highway 1 as uncovered by their own Kittleson Traffic analysis. There are recommended "improvements" presented in the August 2020 MidPen staff report to divert traffic to neighborhood streets to support the project. These are grossly impractical, offering little relief and no benefit to the neighborhood community. In fact, some recommendations will actually create dangerous conditions: The bike sharrows proposed for Sierra and California streets do not consider the very steep inclines of both roads. Also, the recommendation to close Carlos at Highway 1 would funnel all 500+ projected daily car trips through neighborhood roads - this and the fact that the County's own Department of Public Works (DPW) is on record that closing Carlos is unacceptable - Click here to read the DPW letter. These recommendations in the August Staff Report presented to the San Mateo County Planning Commission and Board of Supervisors are inconsistent with the plans in Connect the Coastside addressing flow on Carlos Street for both vehicles and bicycle/pedestrian traffic. Neither the Midpen project proposal nor the Connect the Coastside January 2020 draft recommendations present plausible solutions in the near term to the Highway 1 significant impacts resulting from this multi-unit housing proposal.
Connect the Coastside is incomplete
An incomplete "Connect the Coastside" Comprehensive Transportation Management Plan is being presented by the County in conjunction with MidPen's Cypress Point project. Connect the Coastside will impact coastside development and accessibility for decades to come. After a four-year hiatus, why is the Connect the Coastside process being rushed at a time when public participation is limited? It still lacks policies and fails to cover the full scope intended. Due to the COVID-19 pandemic, the community and the MCC have called for a postponement of major projects until public participation can be assured and true sources of funds are known. But the County has ignored these requests.
The January 2020 draft of Connect the Coastside includes alternatives for addressing some of these traffic issues - although the impacts will still be substantial. It also includes incomplete cost estimates which are eye-popping, with no committed funding. Further, the traffic data is outdated as it was gathered in 2014. Traffic has significantly increased on the coast since the Lantos Tunnel was opened in 2013 and the high-tech job market boomed in the Bay Area.
The 2020 Covid-19 pandemic may also result in significant and long-lasting changes in the economy. Funding prospects for infrastructure and public transit improvements are likely to be significantly worse since Connect the Coastside was drafted. Traffic patterns may also be changing in dramatic ways. Since the pandemic risks of exposure have unfurled, the coast has been even more flooded with visitors seeking outdoor activity.
Peer Reviews are not being considered
Four significant peer reviews of MidPen's environmental and public works studies were submitted to the County in 2020 but are not referenced in the County’s staff report for the zoning change.
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.
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.
No commitment to perform a full Environmental Impact Report (EIR)
This property was a World War II top-secret military site that has never been officially assessed or cleaned up. Neither the County nor MidPen Housing has committed to perform an EIR even though MidPen’s own reports on hazards found lead contamination and failed to investigate concerns about asbestos. Any activities that disrupt the soil will likely create exposure pathways to residual contaminants if present. MidPen proposes to remove 600 truckloads of dirt as disclosed in their plans.
A historical overview of the military site including maps identifying buildings and usage-type are available, but MidPen has not pursued a full investigation nor has the County as they prepare to change the zoning and General Plan. 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.
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.
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.
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 2020 Connect the Coastside draft of a Comprehensive Transportation Management Plan (CTMP).
Beginning in late 2019, PG&E imposed several lengthy power outages locally which brought traffic to a standstill along the San Mateo County coast. In 2020, 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 March of 2020, visitor traffic to the coast has dramatically increased as people seek outdoor relief. These complicating factors are likely to continue for years to come. 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
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.
Midpen Housing Moss Beach Project - Our Position
MidPen Housing and the County rely on the 1986 approved zoning and PUD of the property to contend that it has 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. Read our attorney's letter to the County regarding inconsistencies of this project with the LCP and its failure to address current circumstances.
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.
Connect the Coastside traffic management plan 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 considered in Connect the Coastside.
In conformance with the goals of affordable housing, MidPen Housing and the County should consider a more appropriate location for a large-scale housing project that will reduce VMT and is near public transportation, family-priced groceries, doctors, jobs, schools, pharmacies, and community-oriented services.
Affordable housing projects must give preference to those who are already working in the community.
Alternatives to Consider:
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.
Project Process & Timeline 2020 - 2021
MidPen Housing with San Mateo County Planning is pursuing this housing project in two phases. The first phase is in process as described below and must be completed before the second phase, an application for a Coastal Development Permit, can begin.
Note: As of September 1, 2020, the County has provided $5.5 million to MidPen Housing for its pre-development costs of this project.
Zoning Change, revised PUD and LCP Amendments
MidPen Housing, with the support of San Mateo County, is proposing changes and amendments to the County's Zoning Regulations and Local Coastal Program (LCP). The Zoning change will reduce the density from Medium High Density Residential to Medium Density Residential and will replace 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 necesitate amendments to the Local Coastal Program Implementation Plan and require the California Coastal Commission’s (CCC) certification of compliance with the Coastal Act.
San Mateo County Approval
The changes and amendments were approved by the Board of Supervisors in July 2020 and are the basis for proposed amendments to the LCP of the Unincorporated Areas of San Mateo County. These changes impact the County’s land use map and general plan as well as the Midcoast’s LCP.
Coastal Commission Certification
California Coastal Commission certification is required for changes to be effective. San Mateo County Planning submitted a formal application to the CCC on September 8, 2020, consisting of a cover letter, resolution, ordinance, preliminary circulation improvement plan and supporting documents. The CCC staff responded on September 29 to notify the County that more information was needed. Once complete, the CCC staff posts the submission to the public and has 90 business days (18+ weeks) to review for Coastal Act and LCP compliance. Once reviewed, they will provide a Staff Report to the Coastal Commission with their recommendations on how to make the project consistent with the Coastal Act and LCP. The Coastal Commission will consider the LCP amendments at a public hearing to determine whether to certify, deny or certify with modifications. Notice will be posted 3 to 4 weeks before the public hearing, with public comments accepted up to Friday the week before the public hearing. Hearing is likely to be virtual due to pandemic protocols continuing well into 2021.
Click the links below to read the County’s September 8, 2020 application to the CCC and the CCC response:
Application for Development Permit (coming 2021)
More Info - Moss Beach Multi-Unit Housing Project
MidPen Application - Comment Letters
• MCC Letter to County 9/2018
Take Action! Send your Comments:
County Project Planner, Mike Schaller: email@example.com
MCC Members: firstname.lastname@example.org
CA Coastal Commission District Manager, Stephanie Rexing: email@example.com
CA Coastal Commission Planner, Erik Martinez: firstname.lastname@example.org
Supervisor Don Horsley, San Mateo County District 3: DHorsley@smcgov.org
Carole Groom, San Mateo County Supervisor (also on CA Coastal Commission): email@example.com
Warren Slocum, San Mateo County Supervisor: firstname.lastname@example.org
Dave Pine, San Mateo County Supervisor: email@example.com
Dave Canepa, San Mateo County Supervisor: firstname.lastname@example.org
Andrew Bielak, MidPen Housing Corporation: MossBeach@midpen-housing.org