The Hidden Impact of the Cypress Point – MidPen Housing Project

Growth has hidden costs, especially in an area where the infrastructure is already stressed. Water supply is one example, where we appear to be conserving so others can profit by building. The controversial MidPen “Affordable Housing”^[1] project at Cypress Point in Moss Beach is a major upcoming example here Coastside. The Planning Commission held a hearing Wednesday 12/14 to solicit community input on factors the upcoming Environmental Impact Report (EIR) for the Project^[2] should consider.  I spoke at that hearing, then sent an email, which is included below with some alterations for clarity, images, and footnotes for presentation here.  I encourage you to inform the Planning Commission of your opinions, at the emails listed below.

Note that I did NOT include several concerns raised by others, such as the toxic materials on the former WWII top secret anti-aircraft training center^[3], the Project’s impact on wildlife, nor the alleged illegality of the entire decision and approval process, which is the subject of a lawsuit by MidCoastEco.  My focus was on infrastructure, and the hidden costs thereof – which should not be passed on to existing residents.

Subject: Questions and Comments on EIR for MidPen Housing Corporation, File Number: PLN2022-00220

From: Gregg Dieguez                                                                                                                                           Wed, Dec 14, 2022 at 10:25 AM
To: [email protected], [email protected]

Below are some concerns regarding the potential impact of the proposed MidPen/Cypress Point development (the Project) on the area, which I am requesting be evaluated by the EIR study:

1. Stormwater & flooding in Moss Beach and Montara downhill from the development are already excessive and block use of the roads. [photos above and below] Both Carlos St. in Moss Beach and streets in Montara, as well as Hwy 1, have been flooded and impassable in recent storms, creating inconvenience, property damage, and public safety issues. Additional impermeable surfaces from this development will continue a trend of the County failing to plan for and create stormwater capacity. First Flush measures of beach pollution have been increasing; at one point Fitzgerald Marine Reserve was the most polluted beach in the state.  Carlos St. currently has no stormwater drainage facilities.   The County’s continued permitting of  additional new buildings has had the Cumulative Impact of exacerbating the stormwater and drainage problems as more impermeable surfaces have covered soil which could absorb water and delay the release thereof over time.  How will the County and the development create and fund the necessary stormwater handling capacity to avoid property damage, road closures, and pollution of sensitive habitats?

2. Sewer Capacity cannot handle this large development. In part due to infiltration of water from the stormwater issue, the entire SAM sewer system is at a tipping point, and will fail and cause more spills unless this Project creates additional capacity. On Oct. 25th, 2022 a storm filled the recently expanded Wet Weather Storage (WWS) in the Burnham Strip in SAM’s Intertie Pipeline System (IPS) to within 6″ of overflowing.^[4] In addition, the Dec. 13th, 2021 storm caused an overflow at the plant, which nearly shorted out the entire electrical building and shut down the entire plant, which would have triggered sewage spills of millions of gallons. How will the County and the development create and fund the necessary additional sewer system capacity required for this project? [Update: less than 3 weeks after this article was written, the New Year’s Day storm of 2023 caused overflows at the SAM plant and the IPS in Moss Beach burst, resulting in a spill of 3-4 million gallons]
3. Fire Prevention: Fire hydrant water pressure in the Moss Beach neighborhood is already inadequate – per the MWSD 2017 master plan (page 106) 39% of hydrants in Moss Beach were below standard and deemed inadequate . While those hydrants are in the legal pressure range (though below MWSD standard) for detached single family homes, they are likely inadequate for the more dense housing in the proposed project, which includes multi-unit dwelling buildings with less defensible space. Further, the increased housing density and fire-fighting burden of this project will require more fire fighting water storage than MWSD maintains at present. Finally, both the Carlos St. entrance and the ‘back door’ access to the project via Lincoln could impede fire equipment access through narrow streets with sharp turns. How will the County and this development create and fund the necessary firefighting and fire prevention accommodations for this project?

4. Disaster Evacuation coastside, both on Hwy 1 / Lantos Tunnel and in the neighborhood, has already been cited as one of the worst in the state. Montara, Half Moon Bay, and Pacifica have been ranked the 13th, 20th, and 22nd worst emergency evacuation sites in the state, among 675 U.S. communities at risk.  An updated interactive map of evacuation risks is available here.  The wildfire risk in our area is extremely high. How will the County and this development perpetually provide for the safety of existing and new residents and the massively increased visitors during wildfires and other disasters, and avoid making a dangerous situation even worse?
5. Parking and Transportation Safety: the transportation study provided by the developer uses 9 year old transportation metrics for an apartment classification that is no longer in the manual.  As a result it underestimates both the traffic and parking burdens created by the Project.  The new dwelling classification used for traffic estimates must include the rural nature of this area, and the increased volume and lengths of trips residents will require to obtain services. Further, the study used an edition of the transportation manual that is 2 versions and at least 9 years out of date, in spite of the current version being available a year before the consultant’s report. I confirmed with a veteran traffic engineer that the consulting study was flawed; my source knows the author and could not explain how such a basic error was allowed. However, my source will not testify in public, as he still receives contract work from that firm. MidPen has a history of underestimating parking requirements. At the MidPen Moonridge development, I found an overflow of over 250 cars parked on the access street at 11:30am on a recent Wed morning, so I suspect parking and travel requirements are here, once again, woefully underestimated, which compounds both evacuation and traffic concerns. Fortunately the access road at Moonridge is large enough for both traffic and overflow parking on both sides of the street. However, Carlos St. is barely large enough for a fire truck. How will the County and this development create and perpetually fund the necessary parking and road capacity for this project?
6. Water supply: the 2017 MWSD master plan showed adequate water supply, however since that time their report from Balance Hydrologics showed that in the 3rd year of the drought, the age of water drawn from their main mountain well went from 24 years to thousands of years old (Table 4 page 47/241 of attached report). MWSD thus had to reduce production from that well, until it recharged in wet years. Another water source, the airport wells owned by MWSD, have suffered nitrate infiltration, presumably from nearby farms, and have required half a million $ of filtering equipment and supplies. The addition of 71 more dwellings will further increase the stress on MWSD water supplies, and/or raise the cost of water to existing residents, who will receive no benefit from the added population. One solution is for the County to allow MWSD to acquire the Caltrans Martini Creek Bypass land and expand their watershed, a purchase the County has previously blocked. That property is also a source of wildfire risk to Moss Beach, which might be mitigated and managed by MWSD, if given funding. How will the County and this development ensure that this project does not undermine the water security and/or increase the water costs for existing residents?
7. In addition to the sustainability concerns mentioned above, there is the issue of Fiscal Sustainability. The assets required to safely serve the proposed extra population put the community over a “tipping point” in water, sewer, storm-water, fire protection, and transportation, and those extra new assets must be perpetual, which means those assets will have an infinite cost of operation, maintenance and asset replenishment. What is the County’s and developer’s plan to perpetually fund and provide the infrastructure required for the population expansion it is seeking, so that existing residents are not harmed – physically or financially?

I look forward to understanding how the County will resolve these issues, and to the lasting audits and guarantees of performance which will ensure the solutions are available in advance of the project’s harmful impacts and are perpetually viable for the additional burdens created by the project.

Gregg A. Dieguez
Midcoast Community Council Vice Chair (writing as an individual)
Founder: MIT Club of Northern Calif. Energy & Environment Program
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P.O. Box 370404
Montara, CA 94037

FOOTNOTES:

[1] Terminology
I put that phrase in quotes because it should really be called “Expensive Rentals”, as nothing is cheap here, and “Housing” masks the lack of equity participation which renters don’t get. If we’re fixing ‘equity’ in our society, a large factor in the success of the middle class in the 20th century was Home Ownership, and the growth of wealth from home equity appreciation they received. It would be a lot easier to get on board with projects where the residents had OWNERSHIP of the dwelling. Think of that in contrast: the U.S. gives a 9% Real Estate Tax Credit to the wealthy investors behind ‘Affordable Housing’. The success of that tax credit/social program over the last 50 years is yet another reason for the growth in wealth disparity in the U.S. – rents and tax credits become part of the profit stream that enhances investor profits.

[2] Planning Commission Project Information:
Formal project title is: File Number: PLN2022-00220, should you care to add your comments. Here is the County website: https://www.smcgov.org/planning/cypress-point-affordable-housing-community-project. Here are more extensive MCC web materials on the project, including historical comments: http://midcoastcommunitycouncil.org/cypress-point

[3] Some of the Top Secrets:
This Moss Beach installation was a top secret anti-aircraft training center. They kept many secrets there, mainly weapons and targeting systems. The most significant of these was the radio-controlled proximity fuse, which when placed in the projectile of a 3 inch or 5 inch naval cannon, could automatically detect when it reached its target and detonate next to it. This, in combination with radar, allowed ships to effectively target and bring down aircraft that were more than 20 miles away, before they could even see them. This was a major advantage that our enemies did not have. Further, drones were used for target practice to replace pilot-towed targets toward the end of the war. So we were using drones in war almost 80 years ago!

[4] Sewer Wet Weather Storage
Wet Weather Storage (WWS) in a sewer collection system retains excess flows for a period of time, smoothing the flow to the treatment plant, and avoiding overloading the facility. It also provides benefits in allowing maintenance and construction to occur downstream from the storage. SAM increased the Wet Weather Storage (WWS) by 200,000 gallons in 2021, just in time to avert another spill from the storms of that fall and winter. It would have been 400,000 gallons of WWS as I and others recommended at SAM meetings, but Half Moon Bay – who has been suing its partners to avoid paying for the Intertie Pipeline System (IPS) – agreed to approve only the minimum WWS amount proposed by the engineering study, and did that approval only under protest subject to the results of their lawsuit. Years prior, in the face of HMB refusing to approve maintenance or WWS on the IPS, MWSD and GCSD funded – on their own – the first 200,000 gallons of WWS on the Burnham Strip of land provided by GCSD. Installing another 200,000 gallons of WWS will now cost multiples of what it would have cost, had HMB not prevented it in 2021.