To: The Long Beach City CouncilFrom: Los Cerritos Wetlands Task Force, Sierra ClubRe: Public Hearing regarding approval of the City of Long Beach Climate Action and Adaptation Plan/CAAPPEIR and determining that it is consistent with the City’s Certified Local Coastal Program. City CouncilMeeting, August 9, 2022, Agenda Item 8, File # 22-00918, # 22-00919. “Climate change is ultimately a planning problem:there is no entity other than the state that can electrifythe country, expand the grid, build prodigious amounts of mass transit and wind down coal, oil and gasproduction in time to keep warming short of catastrophic levels.” Kate Aronoff, The Guardian, August 9,2022 The Los Cerritos Wetland Task Force, Sierra Club, offers this critique of CAAP’s AdaptationObjectives and Actions to point out some of the shortcomings of a plan that is inadequate toaddress the harsh realities of the climate crisis. CAAP fails to address species extinction, economicand racial disparities, and the dispossession of tribal lands and rights exacerbated by a localeconomy addicted to fossil fuels. CAAP sacrifices environmental and social sustainability in orderto accommodate existing and expanding coastal development and infrastructure focused primarilyon industrial, commercial, and real estate interests.The LCWTF did not participate inshaping thisdocument, HOWEVER, our comments will be familiar to those who did, and to the Council Membersas well. We have submitted them multiple times in other contexts related to policies, permits,practices, and developments that harm our City, including damage to and erasure of natural areasand tribal sacred sites.
CAAP’s Glaring Omissions:● No plan to reduce/end local fossil fuel extraction, production, export/import.● No plan to shut down SERRF, end burning of plastic and other toxic trash.● No plan to regulate/end local plastic production/sales, address plastic pollution.● No timetable or financial plan to safely shut down wells that do or will leak methane andother toxins.● Does not take into account climate change impacts on/from major local projects that areproposed/approved but not yet built.● Does not guarantee safe drinking water for all residents or prioritize water quality use forpreservation of nature.
● Does not advocate for community swimming pools and neighborhood parks as “coolingcenters” in marginalized communities.● No planned retreat. No plan to limit/end construction in coastal areas subject to SLR, stormsurges, flooding due to climate change.● No commitment to preserve sacred sites/natural open spaces or inclusion of traditionaltribal land management practices.● No plan to reduce hardscape by incentivizing the removal of structures and paved areas,and restoring natural creeks and other waterways.● Does not critique/alter City policies, practices, and permitted activities that contribute toclimate change and harm public health and the ecosystem.
NOTE: CAAP text inBLACK, LCWTF comments inRED
ADAPTATION OBJECTIVES AND ACTIONSActions are organized into four climate impacts: EH - Extreme Heat, AQ - Air Quality, DRT - Drought,SLR - FLD - Sea Level Rise and Flooding
1. EH - Extreme heat - set up to ensure and improve public health and safety in the face of extremeheat events. All residents have access to services and programs to withstand extreme heat events EH-3Expand and enhance urban forest cover and vegetationto mitigate urban heat island conditions.Do not build artificial turf sports fields.Do not replace natural areas in public parks or on public beaches with paved areas or buildings.Enforce permit regulations (CDPs and City) regarding the trimming and removal/replacement ofpublic trees by private parties.Do not permit development on lands suitable for use as carbon storage and water retentionReshape lands, enhance soil quality to increase water retention.Reduce/remove hardscape as part of the public planning process, incentivise the removal ofhardscape and de-incentivise expanding hardscape by private entities (tax-incentives, etc.To restore ecosystems, establish open space areas/wildlife preserves with limited or no publicaccess.EH-3.1: Update the Urban Forest Management Plan witha focus on prioritizing reduction of urbanheat island conditions through both increased urban forest and enhanced vegetation.Restore, create ecosystems of CA Native trees and plants in public spaces. Plant trees thatprovide nesting/roosting sites for birds. Reduce trimming of city trees. Do not trim public treesduring nesting season/in summer months when shade is needed. For their own health, treesshould be trimmed in the winter months.
EH-3.2: Identify tree planting opportunities in subwatershed areas with the lowest urban forest coverto minimize stormwater runoff and help protect the area from flooding during intense storm events.Do not remove public trees, including parkway trees, unless they are a threat to public safety.Require 2 to 1 replacement of any public tree with mature trees that provide an equal orgreater public benefit: shade, bird habitat, etc. Include existing trees/plant trees as part ofdrought-tolerant planting policies and public landscaping projects. Do not build/expand onopen spaces subject to sea-level rise. Identify and preserve areas to serve as SLR/floodcontrol buffers, carbon sinks, retention of groundwater.EH-3.3: Identify and prioritize the planting of drought-tolerant or California native trees to enhanceand expand urban forest cover and vegetation.Plant and maintain trees to support nesting/roosting birds and other wildlife, including nativeinsects. Protect active nesting and roosting sites from human activities. Do not useherbicides, reduce lawns/expand meadowlands in parks, reduce mowing, edging, eliminateleaf blowing by maintenance crews, expand mulching to regulate growth.EH-3.4: Identify and involve community stakeholdersin the planning process to inform urban forestcover needs and priorities.Take direction from tribal culture keepers and tribal ethnobiologists. Listen to the Los CerritosWetlands Task Force, Sierra Club. Do not engage in wholesale removal of any species of tree,notify public and allow for public comment/appeal when public trees are to betrimmed/removed.EH-3.5: Evaluate the cost of water and other infrastructureto provide ongoing maintenance for trees,and seek ways to meet those costs through the City’s budget process, Capital Improvement Program,grants and other funding or financing opportunities.Prioritize use of recycled water for maintenance of public parks and parkways, reduce use ofwater for street sweeping, and other cleaning of hardscapes, eliminate use ofpotable water,including recycled water by THUMS or any other oil/gas extraction operationEH-4: Install Additional Water Fountains andTakeOther Actions to Increase Public Access to Water.Equity Strategy: Prioritize public water access in areas most impacted by extreme heat, with a focus onopportunities to serve children, seniors, core transit riders, and low-income communities.BUILD COMMUNITY POOLS!EH-6: Enhance and expand the accessibility of coolingcenters.Community pools are cooling centers! Parks with shade trees are cooling centers. Do not limitdefinition of cooling centers to air conditioned buildings!EH-6.1: Evaluate the existing cooling center networkand identify various means to expand access,prioritizing neighborhoods and households most vulnerable to extreme heat. ExpandEquity StrategyPrioritize increasing access tocooling centers for those most at-risk ofheat-related injury, illness and death, such as people experiencing homelessness, seniors, young children and infants, pregnant women, people with chronic illnesses, transit riders, and outdoorworkers.BUILD COMMUNITY POOLS IN LOW INCOME INLAND NEIGHBORHOODS WITH A HISTORY OFMARGINALIZATION DUE TO RACISM AND CLASSISM. PROVIDE FREE SWIMMING LESSONSTO RESIDENTS TO MAKE COMMUNITY WATER SAFE WHEN AT BEACHESEH-8: Improve Beach and Coastal Transit Access DuringExtreme Heat Events. During extreme heatevents, coastal temperatures are often significantly lower than those farther inland. For those residents whodo not have access to a car or are unable to drive, public transit that accesses the coast and beach offers areprieve from high temperatures and provides additional recreational opportunities.Provide free public transit. Provide shaded bus stops. Ensure that community members are watersafe/can swim so that they can safely engage in wading, swimming, and other water recreation atpublic beaches. Address pollution of ocean waters and beaches by port traffic and tenants, localindustry, storm runoff.
2. AQ - Air Quality, Goal: All Long Beach communities have clean air and improved public healthMonitor air quality violations throughout the City. Provide air quality monitors to residents when asource of air pollution is determined to be intentional/part of the regular operation of a business, oran “accidental release” that reoccurs multiple times. Prohibit fireworks displays/shows by publicand private entities within City limits. Prohibit events like the Grand Prix which contributesignificant GHG emissions. Shut down SERRF.AQ-2 (AQ 2.1 -2.4): Encourage urban agriculture practicesthat reduce air quality pollution. Include allkinds/areas of land management, not just agriculture.Formulate additional planting/soil enhancement strategies that contribute to air quality inlandscaping, fire prevention measures, for public and private open spaces. Ex: encourage restoringCa native plant meadows in private and public spaces (small and large).AQ 2.4:Develop educational and training opportunitiesfor drought-tolerant urban agriculture.Training in permaculture and other sustainable land mgt practices, training in tribal ecologicalpractices, take direction from traditional tribal ecologists, grow CA native plants for food,medicine, and to support/restore ecosystem and wildlife.AQ-6: Implement the San Pedro Bay Ports Clean Air Action PlanBan Coke. End production/storage/transportation of coke within city limits, including export fromPort of Long Beach.AQ-7Increase Monitoring and Regulation of Oil Extractionand Refining Process,Establish airmonitors outside of active wells that are within the Long Beach city limits. Conduct an audit survey of allmethane emissions to check possible emissions coming from either active or abandoned oil wells.Air quality impacts from local oil and gas operations are minimized. Increase monitoring and regulation ofoil extraction and refining process.Also: Building and Energy ActionsBE-8, Implement short-term measuresto reduce emissions related to oil and gas extraction. Reduce emissions from local oil and gas extraction.
Monitor emissions from oil and gas refinery/storage sites. Calculate projected emissions fromapproved but not yet operational projects/activities into predictions of GHG emissions. Settimetable, create plan to reduce/shut down oil (and gas) extraction, storage, and refining within citylimits. Fund shut down of abandoned wells and city owned wells (prioritize in Tidelands Areafunding). Address climate/health impacts of plastic production as a by-product of fossil fuelextraction.
3. DRT - Drought, Goal: Long Beach has a more sustainable and diverse water supply that reducesdependence on imported water and improves long-term water securityDo not use potable groundwater water in oil/gas drilling and/or refining operations. Phase out, donot expand, water injection drilling operations. Prioritize use of recycled water for maintenance ofpublic parks and parkways. Reduce use of water for street sweeping and other cleaning ofhardscapes. Eliminate use of potable water, including recycled water, by THUMS and other oil/gasextraction operations. Ensure that a minimum amount of water is provided to all residential users,including tenants, regardless of ability to pay. Provide water to maintain city trees. Waterdepartment should not bill other City departments for water used to maintain public green spaces,city trees or to maintain public facilities such as bathrooms/drinking fountains, public pools. Toprotect groundwater and public health, end, ban use of pesticides and herbicides on lands/inwaters within city limits.DRT–3: Expand Usage Of Green Infrastructure And GreenStreets. Incorporate green infrastructure andgreen streets to diversify water supply, increase natural and stormwater capture, prevent urban runoff,reduce the demand on existing infrastructure, reduce the heat island effect, and increase sustainability andresiliency.DRT-3.1:Study and identify locations that are bestsuited for green infrastructure, such as areas thatare prone to frequent flooding during heavy rainfall events.Do not permit new development in “areas that are prone to frequent flooding during heavyrainfall events.” Do not permit development in wetlands or on lands that support wetlandsecosystems. Conserve open space to provide natural habitat, absorb storm runoff, buildgroundwater capacity, prevent drought conditions, reduce use of imported water, and delaysalt water intrusion. Require solar panels on every new building and on all existing publicbuildings and parking lots.DRT-4: Expand Usage of Recycled Water and Greywaterfor Non-Potable Use. Increase and incentivizerecycled water and greywater use to establish a more diverse water supply portfolio.Do not use potable or recycled water in oil and gas operations.DRT-5: Incorporate Increased Rainfall Capture andOther Actions to Maximize Local Water Supplies andOffset Imported Water. Increase and incentivize rainfall capture and other actions to establish a morediverse water supply portfolio and maximize local water supplies from stormwater capture, recycled water,and groundwater.
Reconfigure/restore soils in open spaces to allow for retention of water, including absorption ofrainfall and storm runoff. Remove hardscapes to rediscover, restore local springs and streams,incorporate streambeds into landscaping.
4. FLD - Sea Level Rise and Flooding, Goal: Long Beach understands and is prepared for its futureflood riskNo acknowledgement of the contribution of local fossil fuel extraction/production, storage, andtransportation to local SLR/flooding. No plan to reduce/eliminate local fossil fuel extraction orassessment of the environmental and economic impacts of intentional/accidental releases of GHG,oil, and other toxins into local air and waters.Short-Term Actions (to 2030) City plans and policiesare forward-looking and ensure projects andinvestments account for projected sea level and flooding impactsFLD-1: Update and Augment Floodplain Regulations asNecessary. Update and augment floodplainregulations as necessary to limit, elevate, or provide floodproofing standards for development in areasdesignated as vulnerable to flooding in order to minimize physical damage to development…Longer-termupdates may consider managed retreat if projections and observed local impacts warrant it.“Current projections and observed local impacts” demand that managed retreat be implementedimmediately, not just considered/investigated in the long term. Prohibiting development andmanaging the retreat of current development are the most viable and economically/environmentallysustainable solutions to the inevitability of SLR/flooding in coastal and low lying areas and mustnot be postponed.FLD-2: Incorporate sea level rise language into citywideplans, policies, and regulations.Do not build on the beach! No Belmont Beach and Aquatic Center/BBAC. Do not build structures onsoils subject to SLR, storm events, liquefaction, tsunamis.FLD-6: Conduct Citywide Beach Stabilization Study.Trucking in sand is harmful to air quality and shoreline ecosystems, is becoming more than aseasonal or temporary measure, and provides no long term benefits. Limit coastal development onbeaches and at sea level. Prioritize managed retreat instead.FLD-7: Review and Conduct Studies of Combine Riverine/Coastal Flooding and Increased Severityof Rainfall Events on Watershed Flooding.Do not degrade/reduce wetlands/parklands/beaches in order to provide SLR/storm event buffers orconvert them to storm water basins at the expense of existing ecosystems.FLD-8: Enhance Dunes - Convert seasonal storm bermsto year-round dunes through active dunerestoration as part of an adaptive management strategy. Discontinue beach grooming and plant nativedune species to allow natural vegetation to stabilize dunes and hold sand.Plant trees that support coastal birds adjacent to dunes.FLD-8.5: Consider combinations of options to provideflood/erosion protection in Belmont Shore andthe southeast tip of Alamitos Peninsula.
Do not permit new shoreline structures that will require beach nourishment and/or must bedemolished within their serviceable lifetime due to projected SLR/storm events. BelmontShore and the Peninsula are coastal areas with high income residential and commercialproperties.Environmental justice requires prioritizinglow income communities. Do notallocate Tidelands or other public monies for new/expanded public development such as theBBAC. Limit flood erosion and protection to existing structures in Belmont Shore and on thePeninsula.Medium-Term Actions (2030-2050) Vulnerable infrastructureis elevated or relocatedFLD- 10:Relocate/elevate critical infrastructure.Develop plans/funding sources to relocate/elevate additional structures, including privateresidential properties (especially those in disadvantaged areas). Prioritize relocation in Tidelandsbudget, provide additional funding in Port and City budgets and in grant applications. Do notinclude oil/gas operations as “critical infrastructure.”Long-Term Actions (2050-2100), Long-term physical adaptation strategies are selected and implementedbased on additional research and community adaptation priorities, and prioritize natural solutions wheneverpossible.FLD-11: Elevate Riverine Levees.Do not add levees that will compromise existing wetlands/riverine ecosystems. Do not add leveesto maintain/expand fossil fuel operations, including drilling operations on or offshore, pipelines andtransportation corridors across or impacting wetlands/waterways/shoreline in coastal zone.FLD-12:Expand Beach Nourishment.Do not expand beach nourishment to address SLR. Do not permit expansion of existing structuresor construction of new structures that will require beach nourishment to address SLR or floodingdue to storm surges, within their lifetime.FLD- 4/15:Elevate street hardscapes, streets, pathways.Reduce number and size of transportation corridors threatened by SLR/flooding.FLD-17: Retreat/realign parking lots.Do not relocate parking lots to existing beaches, parks, wetlands or build new parking lots in theseplaces.FLD-19: Investigate Feasibility of managed retreat.Managed retreat must be implemented, not just investigated, immediately. This is the only viablesolution to the inevitability of SLR/flooding and cannot be postponed.FLD-20: Evaluate storm surge barrier at Alamitos Bay.Protection of a wealthy, advantaged coastal area with high income residential and commercialpropertiesshould not be prioritized.