3. Although no landsliding occurred this past winter in some locations between Central and Oakland Avenues (see heavily vegetated areas on bluff face on Plate 1), the bedrock is primed to topple at those locations due to being notched at the base.
Most of the marine terrace deposits in this area are over steepened and will likely lay back to an average angle of about 38 degrees. This may come about in one to three rainy seasons. A conservative analysis would assume that we will have back-to-back wet seasons for the next several years, which may lay back the marine terrace deposits to the angle of repose. A more liberal analysis would assume that we will enter a drought period of three to five years, followed by wet year. Using those ranges implies that the top of the bluff may retreat significantly within one to six years.
A review of the most recent El Nino status by NOAA (which can be accessed here:
https://www.cpc.ncep.noaa.gov/products/analysis_monitoring/lanina/enso_evolution-statusfcsts-web.pdf ) stipulates that “La Niña conditions are present and favored to persist through December 2025 -February 2026, with a transition to ENSO-neutral likely in January-March 2026 (55% chance).*” Although La Nina climatic conditions typically results in lower than average precipitation and relatively smaller storm waves, there is always a chance that large coastal storm waves might impact central California even during a La Nina climatic cycle.
We have used two methods of projecting the future top of bluff retreat for this study. The first method is a simple long range bluff retreat method generated by measuring the difference in time and position of the bluff between the set of stereopair aerial photographs and the current bluff position. The only set of high resolution historical stereopair aerial photos we could procure on short notice were the 1956 set. We measured a variable retreat rate of 0.33 feet per year to 0.66 feet per year for the study area between 1956 and 2025.
We used these retreat rates to calculate and plot the projected bluff top position 10 years from now (represented by the purple line on Plate 1).
We also drew transects at select locations in the area of interest and plotted the projected top of bluff assuming the Marine Terrace Deposits will lay back to the angle of repose of about 38 degrees (Represented by the pink line on both the transects and map; see Plate 1) in response to rainfall and earthquakes. Using just this analysis pushes the top of the bluff back between 12 ½ to 22 feet from the current position. In our opinion this line represents the retreat that could happen in one to six years, taking future storms into consideration.
We have not factored in the collapse of the undercut portion of the bluff bedrock or the landsliding and subsequent retreat that would occur in the event of a large magnitude earthquake. If either of those processes are factored in and occur within that time period of one to six years, the amount of bluff retreat may be even greater.
It is of interest to note that the two methods result in a consistent difference in projected bluff top retreat configuration. The aerial photo method plotting the predicted position of the bluff ten years from now is consistently less than the pure physical model method of using the 545
Item 9 B.
City of Capitola –Bluff Retreat Along Grand Avenue footpath between Central and Oakland Aves. Project No. 2381.2 14 October 2025
angle of repose of the Marine Terrace Deposits with a stipulated life of one to six years. The shorter-lived angle of repose line actually lies consistently inland of the historical aerial photograph derived line. The angle of repose method might be overly conservative and the aerial photo analysis might be overly liberal, which may mean that reality lies between the two extremes. We have created a plate that depicts the area that lies between the two retreat lines and have labeled that area as a “Zone Of Short Term (1-10 Years) Blufftop Retreat” (red stippled polygon on Plate 3).
DISCUSSION OF FUTURE FOOTPATH CONFIGURATION
The objective of this study was to provide the City with an overview of the feasibility of mitigating the risk to the footpath with respect to the hazard of short-term bluff retreat. In discussions with City staff, we learned that the narrowest the path could be is four feet with a two-foot seaward buffer, resulting in an overall width of six feet.
Turning to Plate 1, it should be noted that the existing footpath is impinged upon at several locations by both of the bluff top retreat method lines, with the angle of repose method line even impinging upon a property line at one location.
Given that observation we have plotted a hypothetical six-foot-wide relocated footpath right up against the current seaward property lines along Grand Avenue in the study area (see Plate 1). This reflects the most extreme landward position that the footpath can be located without being pushed onto private property. As can be noted from the map, this hypothetical repositioning will result in a short-term life of mostly one to ten years, depending upon which retreat method line is used.
There is one issue toward the downcoast end of the study area, near the intersection of Oakland and Grand Avenues. At that location the angle of repose method retreat line impinges upon the hypothetical repositioning of the footpath. This implies that even if the footpath is pushed landward and snugged up against the property at that corner, it may be undermined and threatened in less than decade.
The author of this letter has discussed at length in the past, as well as participated in a past City designated committee, about exploring the possibility of armoring the entire bluff face with seawalls, retaining walls, rock bolts or even constructing jetties or groins in an attempt to arrest the ongoing retreat of the entire bluff. Such an armoring or protection effort is likely to cost a great amount of money (in excess of tens of millions of dollars) and will take years to design, permit and construct. Protecting the entire bluff is therefore not feasible for a short-term solution.
There are also different methods of erosion control that might slow down the retreat of the blanket of Marine Terrace Deposits, such as planting woody vegetation or vines that will combat rain drop impact, runoff and provide some evapotranspiration at the saturated contact between the Marine Terrace Deposits soil and the Purisima Formation bedrock. 546
Item 9 B.
City of Capitola –Bluff Retreat Along Grand Avenue footpath between Central and Oakland Aves. Project No. 2381.2 14 October 2025
This will retard the rate at which the Marine Terrace Deposits lay back to the angle of repose but ultimately will be subsumed by the bottom-up process of bluff retreat as the bedrock bluff face fails.
FINDINGS
1. An effective life of a decade or less can likely be achieved via reconfiguring and repositioning the footpath into a four-foot-wide path with a two-foot buffer and then placing that configuration adjacent to the seaward property line of the residences along Grand Avenue (see Plate 1 for the hypothetical layout).
2. Placing erosion control on the portion of the bluff face where the Marine Terrace Deposits are exposed may attenuate the retreat of just the Marine Terrace Deposits.
Ultimately though, any erosion control placed on the upper bluff face will be subsumed by the bottom-up process of bluff retreat as the bedrock bluff face fails.
3. Freezing the bluff face in its current position could be achieved through armoring the entire bluff with seawalls, retaining walls, or rock bolts. Constructing jetties or groins at the base of the bluff could capture sand and slow the overall rate of retreat too. Such an effort is likely to cost a great amount of money (in excess of tens of millions of dollars) and will take years to design, permit and construct. Protecting the entire bluff is therefore not feasible for a short-term solution.
RECOMMENDATIONS
1. If the longest lifetime of a relocated footpath is desired, the City should relocate the footpath as far inland as possible, with the inland side of the path abutting the property lines of the residences (see Plate 1 for this hypothetical layout).
2. An engineered grading and drainage plan should be prepared as part of the proposed footpath location. Care should be taken to avoid ponding water near the top of the bluff to avoid triggering large landslides and no collected storm water should be allowed to flow over the top of the bluff.
3. The effective life of the footpath should be considered when contemplating short term and long-term expenditures for keeping the footpath open. Long-term solutions, such as protecting the entire bluff from erosion will be very expensive and will require extensive studies, design work and may entail a difficult permitting process. 547
Item 9 B.
City of Capitola –Bluff Retreat Along Grand Avenue footpath between Central and Oakland Aves. Project No. 2381.2 14 October 2025
This concludes our geological letter regarding the impacts of landsliding and bluff top retreat for the Grand Avenue footpath between the intersections of Central and Oakland Avenues.
Please do not hesitate to contact us if you have any questions about this letter or our work or need further assistance.
Sincerely,
PACIFIC CREST ENGINEERING INC.
Erik N. Zinn
Principal Geologist
P.G. #6854, C.E.G. #2139
Attachments:Plate 1 – Site Plan & Geologic Transects
Plate 2 – Site Plan Without Aerial Photo & Geologic Transects Plate 3 – Site Plan Showing Zone of Short Term Blufftop Retreat
CERTIFIED ENGINEERING GEOLOGIST
STATE OF CALIFORNIA
ERIK N. ZINN
No. 2139
PROFESSIONAL GEOLOGIST
STATE OF CALIFORNIA
ERIK N. ZINN
No. 6854
548
Item 9 B.
1956 APPROXIMATE TOP OF BLUFF
2025 APPROXIMATE TOP OF BLUFF
HYPOTHETICAL 4-FOOT WIDE PATH WITH 2-FOOT BUFFER RELOCATION
PREDICTED BLUFFTOP LOCATION USING AERIAL PHOTO METHOD
ESTIMATED BLUFFTOP POSITION BASED ON HISTORICAL RETREAT RATES (PROJECTED ~10 YEAR POSITION FROM ANALYSIS OF 1956 AERIAL PHOTOS) ESTIMATED BLUFFTOP POSITION IF UPPER SOILS ERODE TO THEIR NATURAL 38 D ESTIMATED BLUFFTOP POSITION IF UPPER SOILS ERODE TO THEIR NATURAL 38 DEGREE SLOPE (POTENTIAL RETREAT WITHIN ~1-6 YEARS) TR1
TR2
TR3
TR4
TR5
TR6
SITE PLAN EXPLANATION
SYMBOLS
Estimated blufftop position if upper soils (Marine Terrace Deposits) erode to their natural 38 degree slope (potential retreat within ~1-6 years)
Estimated blufftop position based on historical retreat rates (projected ~10 year position from analysis of 1956 aerial photos) Transect line and location
Hypothetical footpath relcoation placed directly adjacent to residential properties (includes 2-foot buffer from seaward edge of path)
TR6
Base Map: Bowman & Williams; Topographic Map of a Portion of the Capitola Grand Avenue Pathway, Sheets TP-2 and TP-3; dated 10-06-2025; original scale: 1"=10'; Imagery provided by Pacific Crest Engineering for 9/25/2025 drone flight
Date: 10 October 2025 Revised: 14 October 2025
Job #2381.2
Scale: 1"=20’
Drawn by: MP/ENZ/mp Plate 1
Site Plan & Geologic Transects
Grand Avenue Footpath Bluff Retreat Hazard
& Risk Assessment
Capitola, California
0 20 40
Scale: 1"=20'
RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 SE SE RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 SE
SE
1" = 20'; h=v
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF WALKWAY/
CENTRAL
AVE.
1" = 20'; h=v
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
100 CENTRAL
AVE
PL
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
304 GRAND AVE
PL
x
x
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
101 SAXON AVE
HEDGE
PL
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
WALKWAY/ TOP OF BLUFF
SAXON
AVE.
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
WALKWAY/ TOP OF BLUFF
OAKLAND
AVE.
FOSSIL WAVE-CUT PLATFORM FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM PICKET FENCE PICKET FENCE
PICKET FENCE
PICKET FENCE
PICKET FENCE
PICKET
FENCE
1" = 20'; h=v 1" = 20'; h=v SE
1" = 20'; h=v
SE
1" = 20'; h=v
TRANSECT 1 TRANSECT 2 TRANSECT 3 TRANSECT 4
TRANSECT 5 TRANSECT 6
Transect Note: Elevations and distances were measured using a hybrid of: Bowman & Williams; Topographic Map of a Portion of the Capitola Grand Avenue Pathway, Sheets TP-2 and TP-3; dated 10-06-2025; original scale: 1"=10'; & 3-D reconstruction of a 2-D photogrammetry drone flight using DJI Terra and ArcGIS Pro.
TRANSECT EXPLANATION
EARTH MATERIALS
Marine Terrace Deposits
Purisima Formation Bedrock
SYMBOLS
Existing footpath
Hypothetical footpath relcoation placed directly adjacent to residential properties (includes 2-foot buffer from seaward edge of path)
Earth materials contact - dashed where approximate
Qmt
Tp
CERTIFIED ENGINEERING GEOLOGIST
STATE OF CALIFORNIA
ERIK N. ZINN
No. 2139
PROFESSIONAL GEOLOGIST
STATE OF CALIFORNIA
ERIK N. ZINN
No. 6854
549
Item 9 B.
Existing
Pavement
(shaded
gray)
Existing
Wood
Fence
1956 APPROXIMATE TOP OF BLUFF
2025 APPROXIMATE TOP OF BLUFF
HYPOTHETICAL 4-FOOT WIDE PATH WITH 2-FOOT BUFFER RELOCATION ESTIMATED BLUFFTOP POSITION BASED ON HISTORICAL RETREAT RATES (PROJECTED ~10 YEAR POSITION FROM ANALYSIS OF 1956 AERIAL PHOTOS) ESTIMATED BLUFFTOP POSITION IF UPPER SOILS ERODE TO THEIR NATURAL 38 DEGREE SLOPE (POTENTIAL RETREAT WITHIN ~1-6 YEARS) TR1
TR2
TR3
TR4
TR5
TR6
SITE PLAN EXPLANATION
SYMBOLS
Intersection of 38-degree angle of repose Marine
Terrace Deposits line with ground surface - see
see transects on this plate for derivation of the line
Projected top of bluff in 10 years using long term bluff retreat calculations derived from analysis of 1956 stereopair aerial photographs
Transect line and location
Hypothetical footpath relcoation placed directly adjacent to residential properties (includes 2-foot buffer from seaward edge of path)
TR6
Base Map: Bowman & Williams; Topographic Map of a Portion of the Capitola Grand Avenue Pathway, Sheets TP-2 and TP-3; dated 10-06-2025; original scale: 1"=10'
Date: 14 October 2025 Revised:
Job #2381.2
Scale: 1"=20’
Drawn by: MP/ENZ/mp Plate 2
Site Plan Without Aerial Photo
& Geologic Transects
Grand Avenue Footpath Bluff Retreat Hazard
& Risk Assessment
Capitola, California
0 20 40
Scale: 1"=20'
RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 SE SE RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 SE
SE
1" = 20'; h=v
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF WALKWAY/
CENTRAL
AVE.
1" = 20'; h=v
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
100 CENTRAL
AVE
PL
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
304 GRAND AVE
PL
x
x
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
101 SAXON AVE
HEDGE
PL
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
WALKWAY/ TOP OF BLUFF
SAXON
AVE.
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
WALKWAY/ TOP OF BLUFF
OAKLAND
AVE.
FOSSIL WAVE-CUT PLATFORM FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM PICKET FENCE PICKET FENCE
PICKET FENCE
PICKET FENCE
PICKET FENCE
PICKET
FENCE
1" = 20'; h=v 1" = 20'; h=v SE
1" = 20'; h=v
SE
1" = 20'; h=v
TRANSECT 1 TRANSECT 2 TRANSECT 3 TRANSECT 4
TRANSECT 5 TRANSECT 6
Transect Note: Elevations and distances were measured using a hybrid of: Bowman & Williams; Topographic Map of a Portion of the Capitola Grand Avenue Pathway, Sheets TP-2 and TP-3; dated 10-06-2025; original scale: 1"=10'; & 3-D reconstruction of a 2-D photogrammetry drone flight using DJI Terra and ArcGIS Pro.
TRANSECT EXPLANATION
EARTH MATERIALS
Marine Terrace Deposits
Purisima Formation Bedrock
SYMBOLS
Existing footpath
Hypothetical footpath relcoation placed directly adjacent to residential properties (includes 2-foot buffer from seaward edge of path)
Earth materials contact - dashed where approximate
Qmt
Tp
CERTIFIED ENGINEERING GEOLOGIST
STATE OF CALIFORNIA
ERIK N. ZINN
No. 2139
PROFESSIONAL GEOLOGIST
STATE OF CALIFORNIA
ERIK N. ZINN
No. 6854
550
Item 9 B.
Existing
Pavement
(shaded
gray)
Existing
Wood
Fence
2025 APPROXIMATE TOP OF BLUFF
HYPOTHETICAL 4-FOOT WIDE PATH WITH 2-FOOT BUFFER RELOCATION TR1
TR2
TR3
TR4
TR5
TR6
SITE PLAN EXPLANATION
SYMBOLS
Zone of short term (1-10 years) blufftop retreat
Transect line and location
Hypothetical footpath relcoation placed directly adjacent to residential properties (includes 2-foot buffer from seaward edge of path)
TR6
ZONE OF SHORT TERM
(1-10 YEARS) BLUFFTOP RETREAT
(red stippling)
Base Map: Bowman & Williams; Topographic Map of a Portion of the Capitola Grand Avenue Pathway, Sheets TP-2 and TP-3; dated 10-06-2025; original scale: 1"=10'
Date: 14 October 2025 Revised:
Job #2381.2
Scale: 1"=20’
Drawn by: MP/ENZ/mp Plate 3
Site Plan Showing Zone Of
Short Term Blufftop Retreat
Grand Avenue Footpath Bluff Retreat Hazard
& Risk Assessment
Capitola, California
0 20 40
Scale: 1"=20'
RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 SE SE RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 RELATIVE ELEVATION (NAVD 88)
80 40
60 SE
SE
1" = 20'; h=v
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
38° TERRACE LAYBACK
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF WALKWAY/
CENTRAL
AVE.
1" = 20'; h=v
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
100 CENTRAL
AVE
PL
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
304 GRAND AVE
PL
x
x
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
TOP OF BLUFF
101 SAXON AVE
HEDGE
PL
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
WALKWAY/ TOP OF BLUFF
SAXON
AVE.
x
x
TOP OF BLUFF
IN 10 YEARS CURRENT
WALKWAY/ TOP OF BLUFF
OAKLAND
AVE.
FOSSIL WAVE-CUT PLATFORM FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM
FOSSIL WAVE-CUT PLATFORM PICKET FENCE PICKET FENCE
PICKET FENCE
PICKET FENCE
PICKET FENCE
PICKET
FENCE
1" = 20'; h=v 1" = 20'; h=v SE
1" = 20'; h=v
SE
1" = 20'; h=v
TRANSECT 1 TRANSECT 2 TRANSECT 3 TRANSECT 4
TRANSECT 5 TRANSECT 6
Transect Note: Elevations and distances were measured using a hybrid of: Bowman & Williams; Topographic Map of a Portion of the Capitola Grand Avenue Pathway, Sheets TP-2 and TP-3; dated 10-06-2025; original scale: 1"=10'; & 3-D reconstruction of a 2-D photogrammetry drone flight using DJI Terra and ArcGIS Pro.
TRANSECT EXPLANATION
EARTH MATERIALS
Marine Terrace Deposits
Purisima Formation Bedrock
SYMBOLS
Existing footpath
Hypothetical footpath relcoation placed directly adjacent to residential properties (includes 2-foot buffer from seaward edge of path)
Earth materials contact - dashed where approximate
Qmt
Tp
CERTIFIED ENGINEERING GEOLOGIST
STATE OF CALIFORNIA
ERIK N. ZINN
No. 2139
PROFESSIONAL GEOLOGIST
STATE OF CALIFORNIA
ERIK N. ZINN
No. 6854
551
Item 9 B.
Grand Avenue Pathway
Conceptual Design
City Council
April 9, 2026
1972
552
Item 9 B.
• Vehicle access
closed in 1980s;
pedestrian
pathway retained
• Repeated
closures and
repairs due to
ongoing bluff
retreat
• 2017–2025: Bluff
failures and
storm damage led
to multiple
relocations
• Analysis
confirms
continued
retreat
• Council
direction
10/2025:
Long-Term Development
Process Background
Grand Avenue Pathway Concept
Design
Gone
553
Item 9 B.
Long-Term Development
Process Background
Grand Avenue Pathway Concept
Design
554
Item 9 B.
• Maintain ADA pedestrian access along
Grand Avenue
• Improve safety in near-term
• Provide a feasible interim solution
Project Goal
• Bluff instability is the controlling
factor
• Limited space due to setback
• Construction constraints near bluff (hand
work, access limits)
• Long-term stability cannot be assured
Key Constraints
Long-Term Development
Process
Project Goals and
Constraints
Grand Avenue Pathway Concept
Design
555
Item 9 B.
Long-Term Development
Process Proposed Approach
Grand Avenue Pathway Concept
Design
Shift pathway inland where feasible (~15
ft setback)
Asphalt pathway with curb and gutter
Drainage improvements (Phase 2)
Vegetation and encroachment removal
Soil/cement stabilization in select areas
Hand construction near bluff to reduce
risk
556
Item 9 B.
Long-Term Development
Process
East (Central Avenue to
Saxon Avenue)
Grand Avenue Pathway Concept
Design
More stable
Greater setback
557
Item 9 B.
Long-Term Development
Process
East (Central Avenue to
Saxon Avenue)
Grand Avenue Pathway Concept
Design
558
Item 9 B.
Long-Term Development
Process
West (Saxon Avenue to
Oakland Avenue)
Grand Avenue Pathway Concept
Design
More active erosion
Higher risk
559
Item 9 B.
Long-Term Development
Process
West (Saxon Avenue to
Oakland Avenue)
Grand Avenue Pathway Concept
Design
560
Item 9 B.
Long-Term Development
Process Costs and Constraints
Grand Avenue Pathway Concept
Design
Construction Cost: ~$223,000
(excludes design and permitting/CEQA)
Design: ~$32,000
Coastal permit required
Limited grant eligibility → likely
local funding
Higher risk on west segment
561
Item 9 B.
Long-Term Development
Process
Summary and Council
Direction
Grand Avenue Pathway Concept
Design
• Feasible interim pathway solution
• Approximately $250k-$275k all in costs
• Lifespan is limited due to erosion
• Risk varies by segment
Key Takeaways
• Proceed with design & permitting
• Modify scope or alignment
• Consider closure
• Funding approach
Council Direction Needed
562
Item 9 B.