Santa Cruz City Council
June 9, 2026

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8 h. Blufftop and Alternative Access/Mitigation. SAMPs shall identify potential alternative public shoreline access and mitigation for any loss of sandy beach and other recreational access.

Such options may include, but are not limited to, vertical access to rocky shorelines or directly to the water (such as surf access), lateral access (e.g., trails or pathways) along blufftops or as part of shared vertical seawalls, viewing platforms, and parks. SAMPs will consider preferred locations for such features and potential tools for promoting construction of such features (e.g., public projects, design requirements for any shoreline armoring, conditions on private development, acquisition of easements, or removal of structures). Planning efforts should also consider how such features should be adapted and modified over time as sea levels rise to ensure access is maintained over time.
i. Environmental Justice. SAMPs shall include an assessment of environmental justice, including the potential distribution of coastal resource benefits and impacts to disadvantaged and other members of the community; and strategies to address any disparate or inequitable impacts. j. Monitoring, Evaluation, and Updating. Each SAMP shall address monitoring of plan implementation and periodic updating.

BB-7. Public Projects along West Cliff. In addition to other policies in this section that may be applicable in any particular case (e.g., related to development in the Shoreline Hazard Evaluation Area, shoreline armoring, etc.), the following provisions also apply to projects in the vicinity of West Cliff Drive in an interim manner until certification of a West Cliff Shoreline Adaptation Management Plan pursuant to Policy BB-6, which shall provide a more detailed set of policies. a. Avoid the use of shoreline armoring to the maximum extent feasible. Where unavoidable, minimize the scope, extent, and impacts associated with shoreline armoring to the maximum extent feasible. As part of any Coastal Development Permit (CDP) evaluation for proposed armoring (including modifications/expansions of any extant armoring, replacement armoring, and altogether new armoring), the City shall evaluate the feasibility of either relocating the structure that needs protection away from such hazards to avoid needed armoring (e.g., relocating portions of West Cliff Drive inland of or through portions of Lighthouse Field State Beach), or eliminating the structure, provided public recreational access will not be significantly adversely impacted. Limit any allowed/required armoring to areas where critical infrastructure (e.g., public roads, sidewalks, and public utilities) meets the requirements of Policy BB-12. Any allowed/required armoring shall be sited and designed to avoid covering natural landforms and to mimic natural landforms to the maximum extent feasible. b. Mitigate all coastal resource impacts associated with allowed/required armoring, including pursuing a hybrid strategy that could include accommodating natural bluff/shoreline retreat through moving at risk infrastructure inland. Coordinate with partners like the California Coastal Commission, State Parks, and the community to consider adaptive strategies that could include realignment of infrastructure, including in terms of potential impacts to public recreational trails, parking facilities, and other infrastructure, as well as more broadly in terms of specific areas (e.g., Lighthouse Point, and Lighthouse Field and Natural Bridges State Beaches).

Exhibit 3
LCP-3-STC-25-0073-3-Part B

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9 c. Where armoring is allowed/required, explore and prioritize nature-based/living shoreline solutions and consider engineered natural feature restoration management strategies consistent with other LCP policies. Natural feature restoration is defined as man-made features constructed and engineered to replicate previously present natural features that may have eroded or been lost over time to mimic natural conditions. d. Maintain blufftop space seaward and landward of infrastructure (e.g., recreational trail, water/sewer lines, etc.) in a natural state to the maximum extent feasible to maximize options for adaptation over time. Apply appropriate drainage and native landscaping measures to help protect such areas against increased erosion.
e. Monitor armoring in terms of its ongoing impacts on coastal resources, including on public recreational resources, including surfing, and implement measures to offset such impacts (e.g., removal of rock on beaches that is displaced from revetments, incorporation of new access features (such as public benches, overlooks, and/or interpretive elements) into infrastructure/armoring structures, exploration of upgrades to vertical access, etc.). f. Explore separated pedestrian and bicycle access when making decisions regarding public recreational access management along West Cliff. Explore future West Cliff Drive alignment options to allow for continued support of enhanced multimodal coastal access. g. Support through access for recreational users and emergency responders through trail realignment inland, where feasible, which may involve permanent removal of parking and reconfiguration of roadway.

BB-8. Private Development in the Shoreline Hazard Evaluation Area. The Shoreline Hazard Evaluation Area is land located within a coastal hazard zone mapped in Shoreline Hazard Evaluation Area figure. Except as may be authorized by a Shoreline Area Management Plan (SAMP) developed pursuant to Policy BB-6, development within the Shoreline Hazard Evaluation Area must be designed and sited to be safe from erosion, bluff failure, wave run-up, flooding, and other longterm coastal hazards for its anticipated lifetime without relying on existing shoreline protection or new or enhanced shoreline protection of any kind, including seawalls, revetments, upper bluff retaining walls, deep caisson foundations, groins, offshore reefs, or other such artificial bluff erosion interventions (exclusive of development along the San Lorenzo River and protected by levees). All such development within the defined Shoreline Hazard Evaluation Area shall also comply with the following:
a. Shoreline Hazards Analysis. Require a site-specific coastal hazards analysis to evaluate shoreline hazard risks over the anticipated life of the proposed development. Analyses shall be conducted by a qualified professional with expertise in coastal processes and shall establish the development requirements and setback from the beach or blufftop edge based on the anticipated life of the structure (minimum 75 years for residential development), best available science including high sea level rise projections (as may be identified by the Ocean Protection Council or equivalent) and a 100-year storm event, and in addition for blufftop development, a demonstrated factor of safety greater than or equal to 1.5 for static conditions and greater than or equal to 1.1 for seismic conditions, or an equivalent best available scientific analysis.

Exhibit 3
LCP-3-STC-25-0073-3-Part B

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10 b. Shoreline Hazards Risk Disclosure and Assumption of Risk. As a condition of approval for all coastal development permits, require a deed restriction to ensure that property owners understand and assume the risks and mitigate the coastal resource impacts of development in a hazardous area. Recorded assumptions of risk shall include a waiver of claim of damage or liability against the permitting authority, waiver of rights to future shoreline armoring, acknowledgement that the development may need to be removed and the site restored in response to future hazard conditions or inland migration of the public trust, and any other acknowledgements and mitigation measures necessary to internalize risk decisions. If development is threatened by shoreline erosion or other hazards and needs to be removed or relocated, the owner shall bear full responsibility for all costs and must work with the City to implement the mitigation in a timely manner.
c. Infrastructure Limitations. Require property owners to acknowledge, in a recorded deed restriction, that public funds may not be available, and coastal erosion conditions may limit the ability to repair, maintain and/or continue to provide infrastructure and related services to the property (e.g., roadways and utilities) in the future and that the occupancy of structures may be prohibited if such services are no longer able to be provided including sewer and water systems that may be rendered inoperable.
d. Maintenance of Public Access Rights. Require the property owner to acknowledge that coastal development approval (i.e., CDP) does not constitute a waiver of any public rights that may exist on the property, and that a CDP approval may not be used as evidence of a waiver of any public rights that may exist on the affected property now or in the future. e. Landscaping and Drainage. Require removal of non-native and invasive plants and replacement with native bluff plants as well as upgrades to drainage infrastructure sited and designed to protect coastal resources for the area of impact of any development in areas subject to coastal hazards as a condition of approval for that development. Development in coastal hazard areas shall collect and direct drainage flow, including water from landscaping and irrigation to inland drainage systems so drainage does not contribute to coastal bluff or other shoreline erosion. All drainage elements shall be camouflaged to be hidden from public view.
f. Future Armoring Restrictions. Shoreline armoring shall not be constructed to protect the development, including if the development is threatened with damage or destruction from coastal hazards in the future. As part of any CDP for development not otherwise exempt or excluded from CDP requirements, the City shall require the property owners to record a deed restriction waiving, on behalf of themselves and any successors and assigns, any rights to construct armoring that may exist under applicable law. Any shoreline armoring shall be limited to that which is authorized by a CDP and is deemed necessary to protect other structures, development, or public beaches permitted to obtain armoring. g. Future Coastal Hazards Adaptation. Require property owners to acknowledge that development on affected properties, and any shoreline protective devices on- or off-site protecting such property, may need to be modified in the future to address coastal hazards, including as may be anticipated by a shoreline area management plan developed pursuant to Policy BB-6. This could include removal or relocation (in whole or in part) consistent with future LCP policies or applicable future shoreline management plans, and that the development may be required to be relocated/removed and the site restored in response to certain defined adaptation strategies, such as when the development is deemed unsafe, Exhibit 3
LCP-3-STC-25-0073-3-Part B

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11 comes to be located on public trust lands, when no longer served by necessary utilities/infrastructure, when coastal hazards would necessitate shoreline armoring, and/or as part of armoring repair/maintenance if not entitled to armoring.

BB-9. Minor Public Development in the Shoreline Hazard Evaluation Areas. New minor public facilities or improvement of public facilities (e.g., restroom buildings, beach access staircases, signage and wayfinding materials, wharf maintenance, and other facilities that enhance public access and safety) shown within the Shoreline Hazard Evaluation Area figure may be considered and approved when they support coastal dependent uses, enhance coastal access, or provide necessary amenities for public recreational access. Allowable minor public development shall be sited and designed to protect and enhance coastal resources over the course of its anticipated life.

BB-10. Efficacy of Shoreline Protection. Require an applicant for development, including redevelopment of an existing structure, to assess the continued efficacy of any onsite shoreline protective devices to protect the development or structure, including evaluation of future conditions such as projected sea level rise. This includes evaluation of the condition of the devices, and whether devices can be removed or modified to allow affected areas to be returned to more natural conditions and/or to minimize the armoring’s footprint and coastal resource impacts. If such assessment does show shoreline protective devices can be removed or modified, and affected areas returned to more natural conditions, include such actions in the conditions of approval for authorized development. Where necessary, require a removal and restoration plan, including financial bonding, for large projects to address potential shoreline protection or project failure at some future date.

BB-11. Nature-based Shoreline Protection. Non-structural nature-based adaptation strategies (e.g., relocation, drainage control, and landscaping, etc.) shall be prioritized over and used in tandem with any hybrid nature-based shoreline protection (e.g., projects that introduce structural elements, sediment/hydrological manipulation, etc.). Nature-based shoreline protection shall be prioritized over non-nature-based shoreline protection (e.g., seawalls) to the maximum extent feasible. Any hard armoring features used in combination with nature-based adaptation strategies or similar hybrid approaches shall be consistent with Policy BB-11 below. Nature-based shoreline protection will be prioritized even if a SAMP for that area has not been adopted yet. It is assumed that the process for adoption of a SAMP will hone nature-based solution decisionmaking.

BB-12. Shoreline Protective Devices. Shoreline protective devices shall only be allowed if they meet all the following criteria:
a. Allowable Shoreline Protective Devices. The shoreline protective device is required to: (1) serve a coastal-dependent use; or (2) protect a public beach; or (3) protect an existing principal structure that was legally constructed on or before January 1, 1977 (and that has not been changed in a way that constitutes redevelopment), and the use, beach, or structure is Exhibit 3
LCP-3-STC-25-0073-3-Part B

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12 in danger from erosion (e.g., a structure would be unsafe to use or occupy within two storm seasons as deemed by the Building Official based on geotechnical analysis). b. Least Damaging Alternative. The shoreline protective device is the least environmentally damaging feasible alternative. Hard armoring (such as seawalls, etc.) shall only be allowed if nature-based adaptation strategies (such as relocation; nature-based adaptation strategies like dune/reef enhancement projects, beach nourishment, vegetative planting, drainage control and landscape improvements; and hybrid strategies, etc.) cannot meet the above least environmentally damaging feasible alternative criteria, and if limited to avoid coastal resource impacts to the maximum extent feasible. Consideration of new shoreline protection shall require review of any already-existing protective devices to assess the need for their removal or minimization, or for restoration of those sites, to be required as a condition of approval of any new shoreline protective device.
c. Design Standards. All shoreline protective devices shall be sited and designed to both avoid coastal resource impacts and enhance coastal resources to the maximum extent feasible, including by reducing the footprint of the structure, designing for sea level rise conditions expected over the life of the protected development while recognizing the potential for phased adaptation approaches, enhancing visually blighted conditions, increasing beach width, and restoring/enhancing habitat value, and integrating new access features/opportunities.
d. Mitigation. All shoreline protective devices shall be accompanied by proportional mitigation for all unavoidable coastal resource impacts, including with respect to impacts on shoreline sand supply, sandy beaches, public recreational access, including surfing and other waterbased recreation, landscaping, public views, natural landforms, and water quality for the anticipated life of the development. Proportional “in lieu” fees may be used as a tool for impact mitigation if in-kind options (e.g., developing new public access facilities commensurate to offset the access impacts identified) are infeasible, and if such fees are deposited into an interest-bearing account managed by the City and used for coastal adaptation projects and programs, including public coastal recreational access improvements. e. Monitoring. Shoreline protective devices shall be regularly monitored (at least once every 3 years and after any significant storms) by a civil engineer and/or engineering geologist familiar and experienced with shoreline protective devices and processes, and monitoring reports reflecting such evaluation shall be completed every five years and shall at a minimum cover all aspects of the armoring reevaluation and repair and maintenance provisions specified below.
f. Armoring Reevaluation. For shoreline protective devices that are proposed to be reconstructed, expanded, and/or replaced (where, at a minimum, 50% or more replacement constitutes replacement of the entire structure), and in addition to the other requirements of this policy, the CDP application shall include a reassessment of the need for the device, the need for any repair or maintenance of the device, and the potential for removal based on changed conditions and circumstances, including whether the shoreline protective device meets the criteria of this policy. The CDP application shall at a minimum include an evaluation of the age and condition of the principal structure being protected (or evaluation of the coastal-dependent use being served or public beach being protected, if applicable); changed geologic site conditions including but not limited to changes relative to erosion and sea level rise; and impacts to coastal resources.

Exhibit 3
LCP-3-STC-25-0073-3-Part B

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13 g. Repair and Maintenance. The shoreline protective device shall be repaired and maintained as necessary to ensure that it continues to exist in its approved and/or required state (including CDP requirements pertaining thereto), particularly in relation to ensuring the continued utility and function of the design standard requirements above. Repair and maintenance of a shoreline protective device that is not protecting an existing structure (or any structure that is ineligible for armoring under this Chapter) shall be limited to the minimum amount of maintenance needed to maintain the functionality of the device, but in no case shall include its expansion or extend its useful life.
h. Armoring Duration. The shoreline protective device shall only be authorized until the time when the existing principal structure that is protected by such a device: (1) is no longer present; (2) no longer requires armoring; or (3) is redeveloped, or in the case of approved/required public recreational access areas and features, those areas and features remain in good condition and available for public use. Permittees shall be required to submit a CDP application to remove the shoreline protective device within six months of a determination by the City or the Coastal Commission’s Executive Director that the shoreline protective device is no longer authorized to protect the structure it was designed to protect because the structure is no longer present or no longer requires armoring. In the case of coastal redevelopment, removal of the authorized shoreline protective device and restoration of the affected area shall be required as part of construction of the redeveloped structure. i. Emergency Authorization. In cases of emergency, a shoreline protective device may be approved on a temporary basis, and only under the condition that the device is required to be removed unless a regular CDP is approved for retention of the structure. In such cases, a complete CDP application shall be required to be submitted within 60 days following construction of the temporary emergency shoreline protective device, unless an alternate deadline is authorized by the City of Santa Cruz Planning Director for good cause, including continued good faith efforts toward submittal of such application. Any such emergency shoreline protective device shall be sited and designed to be the minimum necessary to abate the identified emergency, and to be consistent with all LCP shoreline protective device standards to the maximum extent feasible, including requirements to avoid coastal resource impacts. Mitigation for impacts will be required through the regular CDP process, including mitigation commensurate with the duration of impacts caused by the emergency device. The City shall notify the Executive Director upon receipt of a request for an emergency shoreline protective device within the City’s CDP jurisdiction.
j. Proposed Development Protected by Existing Armoring. If proposed development is currently protected by armoring, then it shall only be approved if allowable pursuant to subsections a and i above and the armoring is modified to reduce its coastal resource impacts (e.g., restacking/removing riprap/rock revetments so as to open up additional beach space, contouring seawalls to improve public views, etc.) to the maximum extent feasible.

BB-13. Materials for Beach Replenishment. When considering implementation of a sand nourishment or management program (e.g., possible augmentation of West Cliff pocket beaches), consider the possible future materials dredged from the San Lorenzo River or the Santa Cruz Small Craft Harbor (in consultation with the Santa Cruz Port District), or other materials compatible with those in the Monterey Bay area. Scientific sand accretion studies and biological resource assessments shall be Exhibit 3
LCP-3-STC-25-0073-3-Part B

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14 required as part of consideration of any sand management program, among other factors, to address the feasibility and potential ecological impacts of any beach replenishment strategy.

BB-14. Alignment of Adaptation Policies. Align coastal climate change adaptation policies during development of and future updates of any coastal hazard adaptation plan, or other coastal adaptation policies (or corresponding Implementation Plan sections) to reflect progress in the City’s adaptation and shoreline management planning to remain consistent throughout all City climate change and hazard risk documents.

BB-15. Beach Outfalls. Seek and pursue opportunities to consolidate and/or eliminate reliance on storm water outfalls that convey stormwater toward and/or directly onto the beach and/or into Monterey Bay or the Pacific Ocean in areas impacted by development or maintenance/upgrade of public infrastructure, to minimize impacts from coastal hazards as well as to avoid impacts to water quality, public access, and scenic and visual resources. Ongoing coastal bluffs erosion has required and will likely require modifications to public infrastructure, including roadway and culvert grading and alignment, necessitating reassessment of stormwater flows and possible adjustment of outfall locations. Siting of new or realignment of existing storm water outfalls should result in no net increase in outfall volumes, shall consider and minimize erosion, water quality and visual impacts, and for bluff outfalls, any non-native and invasive plants in the project area shall be removed and replaced with native bluff plants. Outfalls that are or are likely to be below sea level with sea level rise and/or high storm seas should be designed to prevent the entry of sea water and sand to an extent practical and be regularly monitored and maintained. Outfalls should be sited and designed to minimize public view impacts including as seen from the beach and other shoreline public viewing areas, including through potential use of screening and camouflaging materials, and use of natural storm and energy dissipaters to reduce erosion and improve visual appearance. Finally, new and/or substantially upgraded drainage infrastructure shall be sited and designed to filter and treat runoff prior to outfall.

BB-16. Plans by Neighboring Jurisdictions and Authorities. Review and integrate City plans with plans and policies of adjacent jurisdictions and authorities to the extent feasible. Specifically, the City should consult with Santa Cruz County, the City of Capitola, and the Santa Cruz Port District wherever possible to create partnerships to implement beach management planning and maintain continued seamless, safe public access and healthy beach ecosystems.

BB-17. California Department of Parks and Recreation. Coordinate coastal adaptation planning along West Cliff and other portions of the City’s coastline with State Parks, as State Parks manages Natural Bridges State Beach, Lighthouse Field State Beach, portions of West Cliff near Lighthouse Field State Beach, and Seabright (Twin Lakes) State Beach within the City. In addition to this coordination, consider an update to the guidance and potential projects included in the State’s beach-specific general plans for both Seabright, Natural Bridges, and Lighthouse Field beaches.

Policies that provide coastal resource management guidance for these State beach areas should be developed in partnership with State Parks and reflect the priorities within any relevant State beach general or management plans, consistent with the California Coastal Act.

Exhibit 3
LCP-3-STC-25-0073-3-Part B

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15 BB-18. Protection of Private Property in Hazardous Areas. Where full adherence with all LCP policies, including for setbacks and other Beaches and Bluffs Hazards Adaptation policies and avoidance measures, would preclude a reasonable economic use of the property to the extent that it would likely constitute a taking of private property, the City may allow the minimum economic use and/or development of the property necessary to avoid an unconstitutional taking of private property under the California or U.S. Constitutions. If development is allowed pursuant to this policy, it must be consistent with all LCP policies to the maximum extent feasible.

Exhibit 3
LCP-3-STC-25-0073-3-Part B

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Coastal Hazards Coastal hazards include but are not limited to episodic and long-term shoreline retreat and coastal erosion, high seas, ocean waves, runup and overtopping, storms,
tsunami, coastal flooding, landslides, bluff and geologic instability, seismic events, liquefaction, their interaction, and all as may be impacted by sea level rise.

Existing Structure A structure in existence prior to the effective date of the Coastal Act (i.e., development legally authorized and
built prior to January 1, 1977) and that has not been
redeveloped since.

Development As used in these policies, “development”, “new development,” and qualifying redevelopment are
synonymous, and defined per Coastal Act Section 30106.

Nature-Based Adaptation
Strategy
A coastal adaptation and/or erosion control method that comprised natural elements, which contributes to the
persistence and enhancement of coastal processes and
ecological benefits while also offering protection
services to inshore areas. Nature-Based Adaptation
strategies include both “soft solutions”, which avoid
fixing the shoreline with hard structures and instead rely on the use of dynamic systems to attenuate coastal
hazards, such as dune or wetland restoration, or sand
replenishment and “hybrid armoring”, which fixes the
shoreline, such as with a buried revetment or other
shoreline protective device and includes a nature-based feature to provide ecological and other benefits.

Beaches and Bluff Chapter Supplemental Glossary
Exhibit 3
LCP-3-STC-25-0073-3-Part B

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Redevelopment Redevelopment of a structure consists of: (1) Interior and/or exterior remodeling and renovations or demolition or partial demolition, or other alterations that change 50% or more of any one major structural component
(including exterior walls, floor and roof structures, and foundations) of the structure in question; or (2) additions and alterations to the structure that lead to more than a 50% increase in floor area of the development. Changes
to floor area and individual major structural components are measured cumulatively over time from January 1,
1977. A structure that is redeveloped shall no longer be considered an existing structure for purposes of other
LCP policies.

Shoreline Protective
Devices
Shoreline protective devices are synonymous with
“armoring,” “shoreline armoring,” and “coastal armoring,” and include structures along the ocean-land interface
that are used to protect development from coastal
hazards, including but not limited to seawalls, riprap/rock revetments, gunite/shotcrete, sheet piles, breakwaters, groins, bluff retention devices, retaining walls,
pier/caisson foundation (or other form of atypical deep foundation) and/or wall systems.

Natural Feature
Restoration
Human made features constructed and engineered to
replicate natural features and mimic natural conditions, including formerly present features that may have eroded or been lost over time.

Exhibit 3
LCP-3-STC-25-0073-3-Part B

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Exhibit 3
LCP-3-STC-25-0073-3-Part B

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,_
' SANTACRUZ
Local Coastal Program Update
Shoreline Hazard Evaluation Area
0 0.5
CJ
-CJ
1 Miles
Legend
Coastal Zone
West Cliff Dr Zones
100' Setback Top of Bluff
CoSMoS 6.6ft Erosion
Exhibit 3
LCP-3-STC-25-0073-3-Part B

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Exhibit 3
LCP-3-STC-25-0073-3-Part B

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Exhibit 3
LCP-3-STC-25-0073-3-Part B

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0 450
West Cliff Dr Zone 2
Legend
c::::J Coastal Zone
c::::J West Cliff Dr Zone 2
t-___________ .._ ____________________________ .....j - 100' Setback Top of Bluff CoSMoS 6.6ft Erosion
Exhibit 3
LCP-3-STC-25-0073-3-Part B

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Exhibit 3
LCP-3-STC-25-0073-3-Part B

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Exhibit 3
LCP-3-STC-25-0073-3-Part B

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Exhibit 3
LCP-3-STC-25-0073-3-Part B

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STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION CENTRAL COAST DISTRICT
725 FRONT STREET, SUITE 300
SANTA CRUZ, CA 95060
PHONE: (831) 427-4863
WEB: WWW.COASTAL.CA.GOV
Th12c
Prepared April 13, 2026 for April 16, 2026 Hearing
To: Commissioners and Interested Persons
From: Kevin Kahn, Central Coast District Manager
Rainey Graeven, District Supervisor
Subject: Additional hearing materials for Th12c
LCP Amendment Number LCP-3-STC-25-0073-3 (Beaches and Bluff Hazard Adaptation)
This package includes additional materials related to the above-referenced hearing item as follows:

Correspondence received in the time since the staff report was distributed

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April 10, 2026
Delivered via email
To: Meagan Harmon, Chair, California Coastal Commission CC: Kate Huckelbridge, Executive Director, California Coastal Commission, Karl Schwing, Deputy District Director, San Diego Coast District Re: Th12a City of Santa Cruz LCP Amendment No. LCP-3-STC-25-0073-3-Part B (Beaches and Bluffs Hazard Adaptation)
Dear Chair Harmon, Commissioners, and Central Coast Staff, Thank you for the opportunity to provide public comments on the City of Santa Cruz’s Beaches and Bluffs Hazard Adaptation LCP Amendment. Surfrider commends both the City and Commission staff for integrating a strong protective framework for Santa Cruz’s irreplaceable beaches, bluffs, and coastal amenities. The LUP language provides an excellent launch point for the City’s comprehensive LCP Update, and overall we are supportive of its approval. That said, we offer the following suggestions to further strengthen the LUP’s coastal protections during these challenging times of climate change and rising sea levels.

Policy BB-12. Shoreline Protective Devices
Surfrider Foundation applauds the comprehensive armoring standards established throughout Policy BB-12, which represent a meaningful and enforceable framework for limiting shoreline protective devices consistent with Coastal Act Section 30235 and the Casa Mira decision. We write specifically to flag two vulnerabilities in the emergency authorization provision, BB-12(i), that could potentially undermine the protective intent of the broader policy framework if left unaddressed.

First, BB-12(i) authorizes emergency armoring without defining what conditions constitute an "emergency,” thus leaving the determination entirely to the City Planning Director's discretion.

The Commission's own regulations at 14 CCR §13009 define emergency as "a sudden, unexpected occurrence demanding immediate action to prevent or mitigate loss or damage to life, health, property or essential public services." No equivalent standard appears in BB-12(i), or anywhere in the LUP. Therefore, we recommend – at minimum – that the LUP be amended to mirror the Commission's regulatory standard, ensuring the City applies the same threshold the Commission would apply were the project in an area of Commission original jurisdiction.

Leaving “emergency” undefined in the LUP risks a situation wherein the City applies a less P.O. Box 73550, San Clemente, CA 92673 | [email protected] | 949.492.8170 | surfrider.org

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restrictive standard – wittingly or unwittingly – for emergency CDPs than the Coastal Act; LUPs must be consistent with the Act.

Second, the 60-day deadline for filing a follow-up regular CDP application can be extended indefinitely at the Planning Director's sole discretion “for good cause, including continued good faith efforts toward submittal of such application.” This language is fairly elastic, and therefore exploitable. Experience across California's coast has shown that once emergency armoring is in place, it can remain for years – even decades – before being retroactively permitted. Property owners with emergency CDPs have an incentive to avoid permitting, because permitting typically requires mitigation. We encourage the City and Commission to consider whether the current extension language provides sufficient constraint against delay, and whether additional guardrails on the duration of emergency authorizations would better protect the coastal resources that the broader BB-12 framework is designed to preserve.

We respectfully ask the Commission to address both of these vulnerabilities through suggested modifications to the LUP prior to certification, and encourage the City to work with Commission staff to incorporate the appropriate language into BB-12(i) before the amendment is finalized.

Policy BB-13. Material for Beach Replenishment
Surfrider recognizes the urgent erosion challenges facing West Cliff Drive and supports the City's consideration for feasible beach replenishment options. We do, however, wish to flag an important sediment dynamics consideration regarding BB-13's identification of Santa Cruz Harbor dredge material as potential sources for West Cliff replenishment. Sand along the Santa Cruz shoreline moves predominately from west to east. Harbor construction caused a two- to three-fold increase in the rate of downcoast cliff retreat, with seasonally or permanently depleted downcoast beaches. Diverting dredge spoils away from the established eastward bypass program risks compounding that deficit.

We therefore ask that BB-13 be amended to require that any sand management program utilizing dredge material from the Santa Cruz Harbor explicitly analyze and demonstrate that proposed placement activities will not reduce sediment supply to beaches downcoast of the harbor. This would preserve the City's flexibility to explore creative replenishment solutions for West Cliff from compatible sources while ensuring that neighboring beaches are not further disadvantaged in the process.

Thank you for the opportunity to comment on the City of Santa Cruz’s LCP Amendment. We appreciate your consideration of our proposed modifications. Our hope is that the final approved version of the City’s LUP chapter on Beaches and Bluffs Hazards Adaptation will serve as an example for other developed coastal cities to emulate.

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For our Ocean, Waves, and Beaches,
Mitch Silverstein
California Policy Senior Coordinator
Surfrider Foundation
[email protected]
619.736.7757

31.129
California Coastal Commission
455 Market Street, Suite 300
San Francisco, CA 94105
April 9, 2026
RE: Agenda Items TH12c, City of Santa Cruz LCP Amendment Number LCP-3-STC-25-0073-3- Part B (Beaches and Bluffs Hazard Adaptation)
Hearing Date: April 16, 2026
Position: APPROVE WITH MODIFICATION
Dear Chair Harmon and Commissioners,
The Sierra Club urges that your Commission only approve this document with amendment as discussed herein. The Sierra Club appreciates the amount of work done in support of this LCP Amendment, and recognizes the challenges that coastal jurisdictions face dealing with coastal hazards, including coastal erosion, which will be exacerbated by sea level rise. Unfortunately, the City of Santa Cruz LCP update includes a provision which should be deleted.

Cooperation between adjacent jurisdictions is critically important, especially with regard to sand and sediment flow. The County of Santa Cruz has addressed this through their LCP, and it has been discussed in the County of Santa Cruz Sea Level Rise Plan Working Group. Disruption of the littoral drift, of sand flow along the coast, has significant ramifications of furthering coastal erosion, and of impacting recreational beach opportunities. The City of Santa Cruz LCP Amendment proposes to take (steal) sand from the littoral drift, right at their downcurrent City/County boundary, and to move it up out of the Bay to address issues in another area. The proposal, at Policy BB-13, to take sand from the dredging of the Santa Cruz Small Craft Harbor, should be removed from the LCP.

Sand flow past the Harbor gets caught in the harbor mouth and is dredged out to maintain the harbor opening. The best practice is to take this sand and dispose of it immediately downcurrent, in the water, so that it can continue on in its normal flow, populating mid-County beaches with sand and providing buffer against erosion during winter storms. There have long been tensions in the community about how the harbor takes too much of that sand and builds up an unnaturally large, tall, beach at Twin Lakes beach, resulting in less sand flow in the directly adjacent mid-County area. The proposal now to take sand from that dredge of the harbor mouth, which should be immediately returned to the drift, and instead to transport it far away runs counter to everything that we know about this area. The reference to a sand nourishment program for upcoast areas with materials dredged from the Santa Cruz Small Craft Harbor should be removed.

31.130
Although some areas of the California coastline may be able to withstand some unnatural taking of sand, this is one area that cannot. The County has done significant work in its Sea Level Rise Plan Working Group assessing future conditions and risks in light of sea level rise and the proposed removal of sand from the drift may undercut the Group’s assessments and predictions.

Also, the City is proposing taking sand from the drift at their downcurrent boundary with the County, so that the effects of that removal will be felt outside of their jurisdiction. The concerns that the City of Santa Cruz is facing in their West Cliff area, up out of the Bay, are certainly serious, but taking sand from an area under sand starvation stress is not the answer, and should not be entertained in this document.

We note that Policy BB-16 does mention cooperation between jurisdictions. Discussion between and cooperation between jurisdictions is important, but some ideas are so bad that they simply must be stopped. The removal of sand from the littoral drift at the harbor mouth area, as proposed in Policy BB13, is such a case.

The Sierra Club requests that Policy BB-13 be amended as follows:

BB-13. Materials for Beach Replenishment. When considering implementation of a sand nourishment or management program (e.g., possible augmentation of West Cliff pocket beaches), consider the possible future materials dredged from the San Lorenzo River or the Santa Cruz Small Craft Harbor (in consultation with the Santa Cruz Port District), or other materials compatible with those in the Monterey Bay area. Scientific sand accretion studies and biological resource assessments shall be required as part of consideration of any sand management program, among other factors, to address the feasibility and potential ecological impacts of any beach replenishment strategy.

The Sierra Club understands the Santa Cruz Port District dredging permit (10 year) is up for renewal in 2028. The issue of maintenance of the littoral drift and of continuity of sand flow, and of harbor dredging spoils disposal protocols, must also be addressed as the Port District dredging permit is reviewed.

Thank you for your consideration of these comments.

Sincerely,
Nancy Okada Michael Guth
Co-Chair, Coastal Committee Chair, Santa Cruz Group
Sierra Club California Ventana Chapter

31.131
STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION

CENTRAL COAST DISTRICT
725 FRONT STREET, SUITE 300
SANTA CRUZ, CA 95060
PHONE: (831) 427-4863
WEB: WWW.COASTAL.CA.GOV
April 21, 2026
Sent Electronically
Clara Stanger, Senior Planner
Community Development Department
809 Center Street, Rm. 101
Santa Cruz, CA 95060
[email protected]
Subject: Coastal Commission Action on City of Santa Cruz Local Coastal Program (LCP) Amendment No. LCP-3-STC-25-0073-3-Part B (Beaches & Bluffs Hazards Adaptation)
Dear Ms. Stanger:

At its meeting on April 16, 2026, the Coastal Commission took action on the City of Santa Cruz LCP Amendment No. LCP-3-STC-25-0073-3-Part B (Beaches & Bluffs Hazard Adaptation). The Commission approved the proposed amendments to the Land Use Plan, if modified as suggested. A copy of the adopted findings and suggested modifications are included as attachments.

This letter formally transmits to you the Commission’s resolution of certification and adopted findings pursuant to Section 13544 of Title 14 of the California Code of Regulations. Pursuant to Section 13544, effective certification of LCP Amendment No.

LCP-3-STC-25-0073-3-Part B whereby the County may begin issuing coastal development permits subject to this amendment, will occur after:

1. The City, by action of the City Council: (a) acknowledges receipt of this resolution of certification, including the suggested modifications; and (b) accepts and agrees to the modifications and takes whatever formal action is required to satisfy the modifications (e.g., implementation of ordinances).

2. The Commission’s Executive Director reports to the Commission her determination that the City’s actions are legally adequate, and the Commission does not object to the Executive Director’s determination.

3. Notice of the certification of the LCP amendment is filed with the Secretary of the Resources Agency.

Coastal Commission staff will take care of items #2 and #3 above, following completion of item #1 by the City. Note that the Commission’s regulations provide that the Commission’s action of certification with the suggested modifications shall expire six months from the date of the Commission’s action, or on October 16, 2026.

31.132
Clara Stanger, City of Santa Cruz
LCP-3-STC-25-0073-3-Part B (Beaches & Bluffs Hazard Adaptation)

Please let me know if I can assist you in any way in completing action on this LCP amendment, or if you have any questions. We appreciate the City’s close coordination and collaboration on this LCP amendment.

Sincerely,
Rainey Graeven
District Supervisor
Central Coast District Office
Enclosure (Via Email): Adopted Staff Report with Suggested Modifications

31.133
City Council

AGENDA REPORT
DATE: 05/21/2026
AGENDA OF: 06/09/2026
DEPARTMENT: Water
SUBJECT: Public Hearing on 2025 Urban Water Management Plan (WT) LOCATION: Water Service Area
RECOMMENDATION: Receive input and discuss the 2025 Urban Water Management Plan and Water Shortage Contingency Plan.

BACKGROUND: The Urban Water Management Planning Act, enacted through Assembly Bill 797 in 1983 and incorporated into the California Water Code, requires that every urban water supplier providing water for municipal purposes to more than 3,000 customers or supplying more than 3,000 acre-feet of water annually (~1 billion gallons per year) prepare and adopt an Urban Water Management Plan, and update it every five years. The purpose, required contents, and procedural steps for preparing and adopting Urban Water Management Plans are specified in Water Code sections 10608 and 10610 – 10657. Additional guidance for development of the 2025 Urban Water Management Plan is provided in the California Department of Water Resources’ 2025 Urban Water Management Plan Guidebook.

Urban Water Management Plans establish a framework for water suppliers throughout the state to carry out their long-term planning responsibilities and for reporting their strategies to meet future water challenges to both the state government and the communities they serve. Each 5- year plan covers a 20-year planning horizon, with some analyses extending to an optional 25- year horizon. The City of Santa Cruz has prepared and adopted Urban Water Management Plans for 1985, 1990, 1995, 2000, 2005, 2010, 2015, and 2020. The plan addresses a wide range of topics, including the City’s water service area; current and projected population; existing and planned water supplies; historical, current, and projected water demands; water service reliability assessments; water use efficiency measures; and the Water Shortage Contingency Plan.

The Water Shortage Contingency Plan is a required component of the Urban Water Management Plan and describes how the City will manage its water system during drought-related shortages.

It also outlines procedures for conducting a water supply and demand assessment, compliance and enforcement strategies, and actions to be undertaken in response to a catastrophic interruption of water supplies, including a regional power outage, earthquake or other emergency. Although the Water Shortage Contingency Plan is a component of the Urban Water Management Plan, it must be considered and adopted independently.

32.1 The City of Santa Cruz Water Commission reviewed key components of the 2025 Urban Water Management Plan, including Water Shortage Contingency Plan, at several public meetings including:
 October 6, 2025: 2025 UWMP Overview
 December 1, 2025: 2025 Update to the Long-Range Demand Forecast  February 2, 2026: UWMP – Climate Change Planning Scenario Review Process  March 2, 2026: UWMP – Drought Risk and Water Service Reliability Assessments  April 6, 2026: Preliminary Draft 2025 Urban Water Management Plan The draft 2025 Urban Water Management Plan, including the Water Shortage Contingency Plan was circulated on May 8, 2026, along with notice of the time and place of this public hearing, to all outside jurisdictions receiving water service from the City of Santa Cruz: the County of Santa Cruz and the City of Capitola. Notification letters included the location where the draft 2025 Urban Water Management Plan, including the Water Shortage Contingency Plan, could be viewed, the hearing schedule, and contact information of the preparer for the City.

DISCUSSION: The 2025 Urban Water Management Plan (https://www.santacruzca.gov/uwmp) follows the same basic format as the 2020 Urban Water Management Plan, adopted in November 2021. The key findings of the 2025 Urban Water Management are summarized below.

Key Finding – System Water Use and Demand:

For many decades, water use in Santa Cruz increased along with population and new water service accounts, except during two major drought periods in the late 1970s and the early 1990s.

Around 2000, this pattern changed: demand began to flatten, likely due to price changes, drought, economic downturn, and other factors. In 2015, after two years of drought and water rationing, annual water use fell to a level of about 2.5 billion gallons, similar to the use during the 1970s drought. In 2025, demand remains at a similar level, around 2.6 billion gallons. While demand did rebound to prior levels following droughts in the 1970s and 1980s, demand has not rebounded to pre-drought conditions following 2015, contrary to previous projections. Looking ahead, water demand is expected to grow slowly and reach approximately 2.9 billion gallons per year by 2045 and 2050.

Key Finding – Conservation Target Compliance:

California’s Water Conservation Act of 2009, also known as Senate Bill X7-7, required water suppliers to reduce per person water use by 20 percent by 2020. Santa Cruz met and exceeded this requirement: the City’s 2020 target was 110 gallons per person per day, but actual use was only 74 gallons per person per day. Santa Cruz met the state conservation standards and continues to maintain compliance.

Key Finding – Existing System Water Supply:

Santa Cruz relies almost entirely on local water sources that depend on rainfall. Most supply comes from surface water, including North Coast streams (Liddell Spring, Laguna Creek, and Majors Creek), the San Lorenzo River, and Loch Lomond Reservoir, with a smaller share provided by groundwater from the Beltz Well system. Over the past decade, surface water from the San Lorenzo River supplied about 60 percent of the total, North Coast sources about 20 percent, Loch Lomond about 15 percent, and groundwater about 5 percent.

32.2 The City does not currently operate its own recycled water system, but the Pasatiempo Golf Course, a customer of the Water Department, uses recycled water supplied by the City of Scotts Valley and treated onsite. This reduces demand for potable water from the Santa Cruz system.

Key Finding – Future Water Projects:

Although Santa Cruz has a very low system-wide water demand, it still faces ongoing water supply reliability challenges. The amount of water available from the City’s flowing water sources can change dramatically from year to year, resulting in inconsistent water supply.

Climate change is expected to make the City’s water supplies even more variable, and the City has limited storage capacity to weather multi-year droughts. The City is also committed to improving fish habitat by diverting less water from its flowing sources at certain times. To address these reliability issues, the City is advancing a set of water system projects designed to improve long-term reliability.

Policy and Planning Framework
In 2014-2015, the City worked with a community-led Water Supply Advisory Committee to develop a Water Supply Augmentation Strategy. This strategy identifies four main elements which are being pursued together:
 Element 0: Demand Management – Expanding conservation programs to further reduce water use.
 Element 1: Transfers and Exchanges – Partnering with neighboring water districts (Soquel Creek Water District and/or the Scotts Valley Water District) to rest groundwater wells and replenish regional groundwater basins.
 Element 2: Aquifer Storage and Recovery – Actively storing surface water in groundwater basins for later use.
 Element 3: Recycled Water or Desalination – Developing a new potable supply if groundwater storage and transfers are not feasible or sufficient.

Since 2015, the City has carried out extensive technical studies to provide more details about potential projects including their costs, amount of water that could be produced, and time to implement. This planning work resulted in two key documents:
 Securing Our Water Future Policy (2022): Establishes principles such as public health, equity, affordability, public acceptance, and regional collaboration, and sets goals of adding 500 million gallons of supply by 2027 and closing the water supply gap by 2032.

The full policy is included as Urban Water Management Plan- Appendix K.  Water Supply Augmentation Implementation Plan (2025): Provides a detailed, phased roadmap for advancing aquifer storage and recovery, transfers, recycled water, and if needed, potable reuse or desalination. The plan identifies a preferred supply portfolio centered on aquifer storage and recovery and regional partnerships, along with adaptive decision points. The full plan is included as Urban Water Management Plan- Appendix I.

Projects
Since 2015, the City’s water system has been undergoing significant modernization through its Capital Investment Program, referred to as the Santa Cruz Water Program. Key supply related projects include:
 Aquifer Storage and Recovery Program: Aquifer storage and recovery allows the City to store treated surface water into the Mid-County Groundwater Basin during wetter periods and extract it during droughts. The program is being built out through the conversion of existing Beltz wells, upgrades to the Beltz Water Treatment Plant, and development of

32.3 new aquifer storage and recovery wells, with multiple sites already in pilot testing, design, or construction. Full implementation is expected by 2031 and would provide up to 3.7 million gallons per day (MGD) of extraction capacity.  Transfers with Scotts Valley Water District: A new pipeline connection between the City and Scotts Valley Water District (Intertie 1), expected to be operational in 2026, will enable up to 1 MGD of water to move between the two systems. Santa Cruz would seasonally send surplus surface water to Scotts Valley, allowing them to rest their groundwater wells, and would receive groundwater back during dry periods. This “in lieu” or “passive” recharge approach would help improve conditions in the Santa Margarita Groundwater Basin and builds regional drought resilience.  Transfers with Soquel Creek Water District: Existing interties between the City and Soquel Creek Water District allow up to 1.4 MGD to move between the systems, with minor upgrades potentially needed to improve efficiency. Future transfers from Soquel Creek Water District could be facilitated by the Pure Water Soquel project, which is a key component for groundwater sustainability in the Santa Cruz Mid-County Groundwater Basin. During dry periods when surface water sources may be constrained, Soquel Creek Water District could pump groundwater and send it to the City. It is anticipated that transfers from Soquel Creek Water District could provide up to 1.4 MGD or more with infrastructure improvements.
 Graham Hill Water Treatment Plant Projects: The City is launching a major modernization of the Graham Hill Water Treatment Plant beginning in 2027, replacing the existing conventional pretreatment process with a high-rate clarification process, adding a new ozone contact process and building, converting the existing filters to biological filtration, and constructing two new tanks to replace the existing wash water storage tank. Additional upgrades include chemical storage, operations and maintenance buildings, and improved stormwater and sewer systems. Once completed, the plant’s capacity will increase to 18 MGD, enabling the City to fully utilize its surface water rights to meet supply reliability goals.
 Tait Diversion and Coast Pump Station Improvements: The City plans to upgrade the Tait Diversion to increase capacity from 12 cubic feet per second (cfs) to 28 cfs and to improve fish screening and overall operational flexibility. These improvements will allow the City to use its modified water rights more effectively and reduce reliance on the Felton Diversion inflatable dam. Construction is expected to begin in 2031 and last about two years. The project enhances both environmental protection and supply flexibility.

Key Finding – Water Service Reliability Assessments:

The UWMP includes two statewide-required assessments:
 Drought Risk Assessment (DRA) – evaluates the next five years (2026–2030).  Water Service Reliability Assessment (WSRA) – evaluates reliability through 2050 under normal, dry, and extended drought conditions.

Both the DRA and WSRA incorporated the City’s planned water supply augmentation program.

Although the planned water supply augmentation projects are not yet complete, the projects are advancing. Therefore, the projects are included in the forecasts of future water supplies. In line with the 2015 recommendations of the Water Supply Advisory Committee, the 2022 Securing Our Water Future Policy, the City’s 2025 Capital Investment Program, and the water supply alternatives recommended in the final Water Supply Augmentation Implementation Plan, the DRA and WSRA assume the following planned projects will be implemented.

32.4  By 2026, the City will have completed construction of Intertie 1 and will be implementing transfers with the Scotts Valley Water District at up to 0.7 MGD.  By 2027, the City will have completed conversion of the Beltz 12 well facility to permanent ASR operations.
 By 2028, the City will have completed conversion of the Beltz 8 well facility to permanent ASR operations and will be implementing transfers from the Soquel Creek Water District at up to 1.0 MGD.
 By 2029, the City will have completed conversion of the Beltz 9 well facility to permanent ASR operations.
 By 2030, the City will be implementing transfers with the Scotts Valley Water District at up to 1.0 MGD and transfers from the Soquel Creek Water District at up to 1.4 MGD.  By 2035, the City will have completed conversion of the Beltz 10 well facility to permanent ASR operations, upgraded the Beltz Water Treatment Plant, and developed two new ASR wells in the Santa Cruz Mid-County Groundwater Basin. The City will also have completed the Facility Improvements Project at the Graham Hill Water Treatment Plant which will increase water treatment capacity to 18 MGD and improvements to the Tait Diversion and Coast Pump Station to increase its capacity to 18 MGD.

The City conducted both the DRA and the WSRA using a historic rain and streamflow pattern (hydrology) and a projected climate change hydrology.

The WSRA under historic hydrology found that water supply would meet projected demand under all conditions. The WSRA under the selected climate change condition found that water supply would meet projected demand under normal/average year and single-dry year conditions in all years through 2050. Under the selected climate change condition in the five-consecutiveyear drought condition, in 2030 a small shortage (four percent) could occur in the fifth year of the drought sequence, but after 2035, implementation of planned projects would provide adequate supply to meet projected demand through 2050.

The short-term DRA and longer-term WSRA show that while the City remains vulnerable to extreme drought, particularly in the near term, the planned projects that the City is actively pursuing are expected to provide adequate supply to reliably meet projected demand through 2050. In the event that supplies fall short of demand resulting in a water shortage emergency, the Water Shortage Contingency Plan would be implemented.

Key Finding – Water Shortage Contingency Plan:

The City of Santa Cruz faces ongoing challenges in reliably providing enough water now and in the future, which is why continued work on water supply augmentation projects is essential. The main issue is that climate change is resulting in the variations in the amount and timing of precipitation, the primary source of water supply. This is especially impactful during multiyear droughts and under expected climate change conditions. Other constraints include limited storage capacity, requirements to protect fish species and comply with water rights, and changing water quality.

This UWMP includes a Water Shortage Contingency Plan (WSCP), as required by the California Water Code. The plan explains how the City of Santa Cruz manages the water system during drought-related shortages and outlines the steps the City would take in a water shortage emergency. It also describes how the City assesses water supply and demand, enforces water use

32.5 rules, and responds to major disruptions—such as a regional power outage, earthquake, or other emergencies. The approach, components, and structure of the Water Shortage Contingency Plan are not changed from the 2021 Water Shortage Contingency Plan. Only minor procedural changes and clarifications have been made.

The WSCP includes six standard water shortage levels and actions that would be taken to reduce demand at each level. Shortage stages in this WSCP are based on peak season demand and correspond to the six standard shortage levels defined in Water Code of up to ten, twenty, thirty, forty, fifty and greater than fifty percent shortage, as summarized in Table 1.

Table 1: Water Shortage Contingency Plan Levels
Shortage
Level
Percent
Shortage
Range
Shortage Response Actions
1 Up to
10%
Water Shortage Warning. Stage 1 applies to relatively minor water shortage that requires up to a 10% level of demand reduction. The allocation system applies to all stages. At Stage 1, allocations are provided to customers, but excess use penalties are not yet implemented.
2 Up to
20%
Water Shortage Alarm. Stage 2 applies to moderate water shortages with a demand reduction requirement of up to 20%. This condition requires more vigorous public information and outreach. The primary demand reduction measure that will be implemented at this stage and all stages going forward is the use of excess use penalties for water use above customer allocations.
3 Up to
30%
Water Shortage Emergency. Stage 3 applies to a serious water shortage with a demand reduction requirement of up to 30%. This condition is a serious situation that will require significant reductions by each customer class. Allocations will be reduced to Stage 3 levels.
4 Up to
40%
Severe Water Shortage. Stage 4 applies to a serious water shortage with a demand reduction requirement of up to 40%. This condition is a serious situation that will require significant reductions by each customer class. Allocations will be reduced to Stage 4 levels. Under this scenario, virtually all available water must be reserved either for health and safety purposes or to sustain local business. 5 Up to
50%
Critical Water Shortage. Stage 5 represents an imminent and extraordinary crisis threatening health, safety, and security of the entire community. Under this dire situation, extreme measures are necessary to cut back water use by up to half the normal amount. Not enough water would exist even to meet the community’s full health and safety needs, the top priority. All water should be reserved for human consumption, sanitation, and fire protection purposes and any remaining amount allocated to minimize economic harm. A shortage of this severity could be expected to generate stress and confusion, much the same as any major emergency and at some point, could transform into a full-blown natural disaster that can no longer be governed by local ordinance and may need to be managed by the basic principles and command structures of the state Standardized Emergency Management System. The City has experienced water shortages in the past but never one of such large proportion.
6 >50%
Catastrophic Water Shortage. For Stage 6, Santa Cruz takes the position that this level of shortage would most likely only occur due to a major disaster that caused significant damage to our water treatment and/or distribution infrastructure. In such a disaster, such as a large earthquake, the Santa Cruz response would not come from this WSCP, but rather from the Santa Cruz Water Department’s Emergency Response Plan.

32.6 Changes since the Circulation of the Draft Urban Water Management Plan:

No comments on the draft Urban Water Management Plan were received in advance of preparation of this staff report. Minor updates incorporated to the plans since the draft Urban Water Management Plan, including Water Shortage Contingency Plan, were circulated for public review and are summarized in Urban Water Management Plan- Appendix U. Additionally, official meeting minutes from this City Council meeting and copies of the final adopted resolutions will be added to Appendix U to document the City’s actions.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) DETERMINATION: The item currently before the Council is not a CEQA project because it is solely an informational item. Furthermore, the preparation and adoption of UWMPs is statutorily exempt from CEQA per California Water Code Section 10652.

HEALTH IN ALL POLICIES (HiAP): The three pillars of Health in All Policies, sustainability, equity, and public health, are integral to multiple elements of the 2025 Urban Water Management Plan, including Water Shortage Contingency Plan. Through discussion of the City’s ongoing demand management (conservation) programs, the 2025 Urban Water Management Plan aligns with the pillar of sustainability. The analysis of the social, economic, and demographic factors within our service area help support the pillar of equity in the provision of water. And finally, the pillar of public health aligns with the plan in the description of the Water Department’s efforts to preserve and secure reliable and resilient water supplies.

FISCAL IMPACT:

1. The recommendation in this report impacts the General Fund: No

2. This recommendation requires a budget adjustment: No

3. The recommendation creates an on-going expenditure commitment: No FISCAL IMPACT DESCRIPTION: There is no fiscal impact associated with this item because it is an informational item.

Prepared By:

Sarah Easley Perez
Principal Planner
Submitted By:

Heidi Luckenbach
Water Director
Approved By:

Matt Huffaker
City Manager
ATTACHMENTS:

None.

32.7 SANTA CRUZ WATERDEPARTMENT
Presentation to
Santa Cruz City Council
June 9, 2026
2025 URBAN WATER

MANAGEMENT
PLAN (UWMP) and

WATER SHORTAGE

CONTINGENCY PLAN
(WSCP)

32.8 Presentation Summary
2 UWMP OverviewWater Shortage Contingency PlanOutreach & Schedule

32.9 UWMP

OVERVIEW &

CONTENT
3 32.10
• UWMP and WSCP updated every 5 years
(CA Water Code 10610–10656, 10608)
• Adoption and submittal to DWR of both
UWMP and WSCP by July 1, 2026
• Non-compliance may affect eligibility for
state grants and loans
Purpose of UWMP
Support long-term water supply planningInform local, regional, and statewide water management State Requirements
4 32.11
Supplier Background & Conditions
The UWMP includes key information about Santa Cruzwater system ◦ Area Served◦ Climate◦ Demographics◦ Water Sources◦ Department Organization The plan also documents existing and historic conditions ◦ Water Supply◦ Population Served◦ Water Demand◦ Efficiency Targets 5 32.12
Existing and Historic Conditions
6 32.13
25-Year Demand Forecast
7 2025 Long-Range Demand Forecast Update by M.CubedUses development projections from all served jurisdictionsEach jurisdiction considered Regional Housing Needs Allocations (RHNA)• City (including UCSC)• County of Santa Cruz• City of Capitola Forecasted demand levels
are similar to historic use
patterns from the 1960s
7 32.14
System Supplies
The UWMP is required to describe:
◦ Groundwater and Groundwater
Management
◦ Surface Water and Water Rights◦ Stormwater◦ Wastewater and Recycled Water◦ Desalinated Opportunities◦ Transfers and Exchanges◦ Current and Future Water Supply Projects
8 32.15
2014
Water Supply Advisory
Committee (WSAC) formed
2015
WSAC’s Final Report on
Agreements and
Recommendations issued,
detailing the Water Supply
Augmentation Strategy
(WSAS)
2016
WSAS Implementation
begins
2022
Securing Our Water Future
(SOWF) policy adopted by
City Council
2025
Water Supply Augmentation
Implementation Plan
(WSAIP) finalized
Major Water Supply Planning Milestones
9 32.16
Water Supply Projects
10 2026 Transfers with SVWD at 0.7 MGD
2027 Beltz 12 ASR Conversion Complete2028 Beltz 8 ASR Conversion Complete Transfers from SqCWD at 1.0 MGD2029 Beltz 9 ASR Conversion Complete 2030 Transfers with SVWD at 1.0 MGD Transfers from SqCWD at 1.4 MGD2035 Beltz 10 ASR Conversion Complete Beltz WTP Upgraded 2 New ASR Wells GHWTP Treatment at 18 MGD Tait and CPS Capacity at 18 MGD Planned Water Supply Augmentation and Infrastructure Improvements to be implemented incrementally:• Consistent with WSAIP and CIP• Incremental implementation to allow adaptive management
• Potential future expansion of
Pure Water Soquel by 2040 (subject to ongoing groundwater modeling)

32.17 UWMP Reliability Assessments
11 Water Service Reliability Assessment
(WSRA)
Drought Risk Assessment
(DRA)
Timeframe 2026 - 2030 2030 - 2050
Timestep Annual 5-year
Rolled out Projects with Expected Completion
2026 - 2050
Rolled out Projects with Expected
Completion 2026 - 2030 Projects
Since Normal Year, Single Dry Year, and
Consecutive 5-year Dry Period Consecutive 5-year Dry Period Conditions Projected Hydrology Historic and Climate Change Scenarios Historic and Climate Change Scenarios

32.18 Drought Risk Assessment
Looks ahead at next 5 years from 2025 considering multi-year-year drought 12 Historic hydrology: no shortages

32.19 Climate change hydrology: minor shortage in 2030 (49 MG, ~2%) Drought Risk Assessment
Looks ahead at next 5 years from 2025 considering multi-year-year drought 13 32.20
14 Water Service Reliability Assessment (WSRA)
Historic hydrology: no shortages
Looks ahead in 5-year increments considering normal, dry, and multi-year-year drought conditions

32.21 15
Water Service Reliability Assessment (WSRA)
Climate change hydrology: Minor shortage in 2030 (92 MG, ~4%), no shortages after 2035 Looks ahead in 5-year increments considering normal, dry, and multi-year-year drought conditions

32.22 DRA and WSRA Summary
Near Term (2026 – 2030)
Minor shortage (2 - 4%) only
in year 5 of the 5-year dry
period under climate change
conditions Long Term (2035 – 2050)
Supply reliability under all
modeled conditions with
planned augmentation
projects
16 32.23
Water Shortage
Contingency Plan
17 32.24
Water Shortage Contingency Plan (WSCP)
18 WSCP Overview
• Included as Chapter 8 of the
UWMP: proposed for parallel adoption
• Last updated in 2020 UWMP• Defines the City’s response to water shortages
• Includes:
• Six standard shortage levels• Implementation and enforcement framework
• Annual supply reliability
evaluation process

32.25 WSCP Approach
19 No major changes to the 2020 WSCP proposed
• Volumetric customer allocations rather than restrictions on specific uses • Customers choose how to manage their allocation
• Outreach and enforcement increase with shortage severity Stage 1 Shortage
(up to 10%)
Allocations implemented,
no penalties
Stages 2-5 Shortage
(20% through >50%)
Allocations with excess
use penalties
Stage 1 implemented in 2021 (business customers excluded)

32.26 New WSCP Allocation Tables
20 Appendix P provides new detailed allocation examples• Based on the 2021 WSCP methodology• Clarifies allocation methods for each customer class

32.27 Outreach &
Schedule
21 32.28
Outreach & Public Participation
Public Presentations to the Santa Cruz Water Commission:
◦ October 2025 – Kick-off of the 2025 UWMP ◦ December 2025 – 2025 Long-Range Demand Forecast ◦ February 2026 – Climate Scenario Review◦ March 2026 – Drought Risk and Water System Reliability Assessment
◦ April 6 – Preliminary Draft UWMP and WSCP
Notice of Draft UWMP and WSCP Availability included:
• Association of Monterey Bay Area Governments (AMBAG)• Santa Cruz Local Agency Formation Commission (LAFCO)• University of California, Santa Cruz• County of Santa Cruz• City of Capitola• Local Water Agencies • Soquel Creek Water District• San Lorenzo Valley Water District• Scotts Valley Water District• Central Water District• City of Watsonville • Local Groundwater Sustainability Agencies (GSAs)• Resource Conservation District of Santa Cruz County• Local elected officials 22 Formal 60-Day Notification to Jurisdictions Served:• City of Capitola• County of Santa CruzFormal Notice of Hearing and Proposed Adoption• City of Capitola• County of Santa Cruz• Santa Cruz Sentinel on May 18 and 25

32.29 Accessibility
• UWMP, including WSCP and
appendices, fully meets WCAG 2.1 ADA accessibility requirements 23 32.30
Schedule Highlights
Public Release of Draft 2025 UWMP and WSCPMay 8
Public hearing and City Council consideration of adoption of the 2025 UWMP and WSCPJune 9 If adopted, submittal of 2025 UWMP and WSCP to DWR and State LibraryJune 16 2025 UWMP and WSCP made available for public review and distributionJune 30 24 32.31
Water Year 2025
Initial Water Supply Outlook
Santa Cruz Water Department
Santa Cruz Water Commission February 3, 2025

THANK YOU
25 32.32
City Council

AGENDA REPORT
DATE: 06/04/2026
AGENDA OF: 06/09/2026
DEPARTMENT:

SUBJECT:

City Manager’s Office/Community Development/City Council Amendments to Municipal Code Title 24, Zoning, Related to Protections Against On-Shore Facilities Supporting Off-Shore Oil and Gas Drilling and Deep-Sea Mining and Exploration, and Corresponding Changes to the City’s Local Coastal Program Implementation Plan (CM/CD/CN) LOCATION: Citywide
RECOMMENDATION: Motion to:
1) Introduce for publication an ordinance adding Section 24.06.093 to Chapter 24.06 – Zoning Map and Text Amendments and amending Sections 24.06.090 and 24.10.1620 of the Santa Cruz Municipal Code (SCMC) related to adding protections against on-shore facilities supporting off-shore oil & gas drilling and deep-sea mining and exploration; and 2) Introduce for publication an ordinance amending the Local Coastal Program Implementation Plan (LCP IP) and amending Section 24.10.1525 of the SCMC to add protections against onshore facilities supporting deep-sea mining and exploration; and 3) Find that the proposed amendments are categorically exempt from California Environmental Quality Act (CEQA) review, pursuant to: Class 7 Exemption (14 CCR § 15307); Class 8 Exemption (14 CCR § 15308); and the Common Sense Exemption (14 CCR § 15061(b)(3)).

BACKGROUND: The City of Santa Cruz (City) is a global leader in environmental protection and sustainability initiatives. For decades, the City has led regional initiatives to prevent extractive, polluting activities off California’s Central Coast that pose significant risk to coastal communities like Santa Cruz.

In the wake of the 1969 Santa Barbara oil spill, local jurisdictions and activists united to prevent oil and gas drilling along the coast of California. These efforts helped create the Local Government Outer Continental Shelf (OCS) Coordination Program in 1980, which succeeded in creating a “Blue Wall” in opposition to the U.S. Department of the Interior’s proposed lease sale of 15 areas in the OCS for oil and gas drilling.

33.1 In 1985, the voters of Santa Cruz passed Measure A, codified in the SCMC as Ordinance 85-70, expressing local opposition to off-shore oil and gas drilling and preventing zoning changes to accommodate facilities that would support off-shore oil and gas drilling without a vote of the people. Forty years later, in early 2025, U.S. Department of Interior’s Five-Year OCS Oil and Gas Leasing Program, administered by the Bureau of Ocean Energy Management (BOEM), indicated their intent to offer new areas off the California Coast as proposed lease sites for oil and gas drilling, including areas within the boundaries of National Marine Sanctuaries. Further federal actions have indicated intent to open federal waters for commercial deep-sea mining, a nascent industry that poses unknown risk to ocean ecosystems and coastal communities.

Continuing the City’s leadership in this area, on September 30, 2025, Mayor Keeley, Vice Mayor Kalantari-Johnson, and Councilmember Renee Golder, brought forward an initiative to further strengthen Opposition to Offshore Oil Drilling. At that meeting the City Council committed to supporting local efforts to oppose off-shore drilling and deep-sea mining in our region and directed staff to work in collaboration with the County and engage in coordinated opposition of current efforts by the federal administration to overturn protections of our local marine environment. This work included reinvigorating the Local Government OCS Coordination Program and contracting with Save Our Shores, the marine conservation organization instrumental in creating the “Blue Wall” in the 1980s, to help lead policy efforts to strengthen local protections against the federal OCS leasing proposal and other changes that threaten the environmental and economic resiliency of coastal Santa Cruz.

Council submitted various rounds of comment and letters of opposition to the federal administration's proposed 11th National Outer Continental Shelf Oil and Gas Leasing program between December 2025 and March 2026. Vice Mayor Kalantari-Johnson also serves on the League of Cities, Coastal Cities Leadership Committee, to further amplify the importance of coordinated local and regional opposition to proposed marine protection rollbacks.

DISCUSSION: The proposed ordinances update the City’s municipal code and LCP IP to modernize the language relating to off-shore drilling, add language specifically addressing deepsea mining, and address recent developments related to these industries by leveraging local landuse authority to directly oppose unwanted activities in the waters off-shore of Santa Cruz. In addition, the proposed ordinances add science-backed findings related to the ecological, public health, economic, and climate impacts related to oil and gas drilling and deep-sea mining and exploration. Additional information supporting these findings is included in the Supporting Documents attachment.

The proposed amendments will make the following changes to the SCMC:
 Add definitions of related terms for clarity and specificity within the municipal code;  Update the existing requirement that any zoning change to accommodate on-shore support facilities for off-shore oil and gas drilling be subject to a vote of the people to also require that any zoning change to accommodate on-shore support facilities for deepsea mining and exploration be subject to a vote of the people; and  Add prohibitions against on-shore support facilities for deep-sea mining, in addition to the existing prohibitions against on-shore support facilities for off-shore oil and gas drilling to the City’s General Industrial and General Industrial/Performance Districts.

33.2 In sum, the proposed amendments strengthen and modernize the City’s commitment to opposing harmful, extractive activities off the coast of Santa Cruz with an approach that is within the City’s police powers, is legally defensible, and is consistent with the California Coastal Act as well as other state and federal laws governing coastal policy. The proposed amendments are consistent with the City’s General Plan and Local Coastal Program, as described in detail in the attached May 7, 2026 Planning Commission Agenda Report.

Through adopting the proposed amendments, the City would once again set a precedent and provide a model for other coastal jurisdictions in the fight against off-shore oil and gas drilling and deep-sea mining.

Planning Commission Review
Amendments to the Zoning Ordinance are required to be presented at a meeting of the Planning Commission, which then makes a recommendation on the amendments to the City Council. The Planning Commission reviewed the proposed changes at the May 7, 2026 meeting and voted unanimously to recommend approval of the proposed amendments (6-0, Commissioner Kelley absent). The Planning Commission expressed support and appreciation for the City’s efforts to stand against off-shore oil and gas drilling and deep-sea mining and exploration in the face of new threats to coastal communities and ecosystems. Additionally, the Planning Commission inquired about the actions of other local jurisdictions regarding the adoption of similar protections and was pleased to learn that Santa Cruz is the first jurisdiction in California to act toward implementing such measures, thereby setting a precedent for others to follow.

Staff members from Save Our Shores were present to provide public comments in favor of the proposed amendments and answer questions from commissioners related to the efficacy of the proposed approach, similar initiatives in other coastal jurisdictions, and scientific research on the impacts of deep-sea mining. The Planning Commission did not receive comments from other members of the public during the meeting but received several written comments in support of the proposed ordinances ahead of the hearing.

California Coastal Commission Preliminary Review
Any portion of an adopted ordinance that amends the City’s LCP IP requires California Coastal Commission (CCC) approval. Staff submitted the proposed amendments to the CCC for coordination in April 2026. CCC Staff provided preliminary feedback and comments that were considered in the development of the proposed amendments.

Public Outreach
On November 21, 2025, the City entered into an agreement with Save Our Shores to engage local entities and community stakeholders, as well as develop outreach materials and an education campaign on the importance of the proposed ordinances. To date, Save Our Shores has worked closely with other jurisdictions to develop similar ordinances and conducted outreach across various media platforms.

Vice Mayor Kalantari-Johnson and Councilmembers Newsome and Golder authored an article titled “Now is the time to protect the Monterey Bay”, published in the Sentinel on April 25, 2026. In the piece, the councilmembers expressed their support for the proposed ordinances and drew attention to the May 7, 2026 Planning Commission hearing, inviting public comment. The City’s opposition efforts were also featured in a Western City article on June 2, highlighting several jurisdictions opposing the federal offshore drilling proposal.

33.3 On April 26, at the Save the Bay event, hosted by the Romero Institute, Vice Mayor KalantariJohnson spoke about the work the City is doing to oppose federal efforts including the amendments to local City ordinances to strengthen protections against offshore oil drilling and potential onshore facilities to support oil drilling.

As part of community outreach and public noticing for the Planning Commission meeting held on May 7, 2026, the following noticing was completed: The proposed ordinances were advertised in the Sentinel on April 20, 2026, postcards were sent to the City’s LCP Mailing List on April 16, and email notifications were sent to the City’s LCP Email List on April 23, 2026.

The proposed ordinances and agenda report for the May 7, 2026 Planning Commission meeting were posted on the City’s Planning Commission webpage on May 1, 2026. Email notifications regarding the published agenda were sent to the City’s Community Development Updates, LCP, Planning Commission Meetings and Zoning Administrator Meetings interest lists on May 4, 2026.

Next Steps
Should the first reading of the ordinances be approved by the City Council, a second reading would follow on June 23, 2026. Approved amendments that are not amendments to the LCP IP will take effect thirty days after final action by the City Council, while those that are subject to CCC jurisdiction will be submitted to the CCC for review and will take effect following approval by that body.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) DETERMINATION:

The proposed amendments are categorically exempt from CEQA review pursuant to the Class 7 Exemption (14 CCR § 15307) – Actions by Regulatory Agencies for Protection of Natural Resources and the Class 8 Exemption (14 CCR § 15308) – Actions by Regulatory Agencies for Protection of the Environment, as the proposed ordinances are intended to ensure the maintenance of natural resources and the protection of the environment through protection against potential oil or trailing spills, leaks, and other harmful impacts from on-shore support facilities for off-shore oil and gas drilling and deep-sea mining and exploration that could disrupt the biological productivity of coastal waters and conditions required to sustain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes. None of the exceptions to the categorical exemptions (14 CCR § 15300.2) apply since there is no expected cumulative impact from prohibiting new onshore facilities as the action would simply maintain the status quo, there are no unusual circumstances related to prohibiting on-shore facilities that would create a significant effect on the environment, prohibiting new on-shore facilities would not impact any scenic highway, the prohibition of on-shore facilities would not affect hazardous waste sites, and the prohibition would not cause a substantial adverse change in any historical resource. The amendments are also exempt under the Common Sense Exemption (14 CCR § 15061(b)(3)) as it can be seen with certainty that prohibiting on-shore facilities related to off-shore oil and gas drilling and deep-sea mining and exploration will maintain the status quo, and there is no possibility of a significant negative effect on the environment.

HEALTH IN ALL POLICIES (HiAP): The proposed amendments support the sustainability pillar of HiAP by affirming the City’s commitment to greenhouse gas emissions mitigation by discouraging extractive activities along California’s Central Coast that pose significant environmental hazards to the surrounding ecosystems while also perpetuating a reliance on fossil

33.4 fuels and non-renewable resources. The proposed action also supports the public health pillar of HiAP. Allowing the development of on-shore facilities that support oil and gas drilling and DSM within the City could expose residents to harmful impacts of the mineral extraction processes, threaten the health of the Monterey Bay National Marine Sanctuary, and pose risks to coastal recreation opportunities along the City’s coastline. The proposed amendments also support the equity pillar of HiAP by adding protections that aim to preserve continued coastal recreation access for all community members.

FISCAL IMPACT:

1. The recommendation in this report impacts the General Fund: No

2. This recommendation requires a budget adjustment: No

3. The recommendation creates an on-going expenditure commitment: No FISCAL IMPACT DESCRIPTION: These amendments have no future impact on the General Fund, nor do they create an on-going expenditure commitment. The appropriation of funds to support the development, analysis, and coordination of regional efforts regarding the proposed ordinances was absorbed by the City Manager’s operating budget in Fiscal Year 2026. In that sense, the General Fund impact associated with the proposed ordinance has already been approved by City Council, and the item before Council today represents a return on that expenditure.

Prepared By:

William Kelley
Management Analyst
Akana Jayewardene
Senior Planner
Tiffany Wise-West, PE, PhD
Sustainability and
Resiliency Officer
Clara Stanger
Acting Principal Planner
Submitted By:

Shebreh
Kalantari-Johnson
Vice Mayor
Scott Newsome
Councilmember, District 4
Renee Golder
Councilmember, District 6
Approved By:

Matt Huffaker
City Manager
ATTACHMENTS:

1. ORDINANCE (LCP IP) – CLEAN.DOCX

2. ORDINANCE (LCP IP) – TRACK CHANGES.DOCX

3. ORDINANCE (NON-LCP) – CLEAN.DOCX

4. ORDINANCE (NON-LCP) – TRACK CHANGES.DOCX

5. PLANNING COMMISSION AGENDA REPORT OF MAY 7, 2026 MEETING.PDF

6. SUPPORTING DOCUMENTS.PDF

33.5 1
ORDINANCE NO. 2026-XX

AN ORDINANCE OF THE CITY OF SANTA CRUZ AMENDING SANTA CRUZ MUNICIPAL CODE SECTION 24.10.1525 – PROHIBITED USES, PROHIBITING THE

DEVELOPMENT OF ON-SHORE FACILITIES SUPPORTING DEEP-SEA MINING EXPLORATION & DEVELOPMENT WITHIN CERTAIN LAND USE DISTRICTS.

SECTION 24.10.1525 IS PART OF THE LOCAL COASTAL PROGRAM

IMPLEMENTATION PLAN (LCP IP) AND WILL REQUIRE APPROVAL BY THE

CALIFORNIA COASTAL COMMISSION PRIOR TO TAKING EFFECT INSIDE THE COASTAL ZONE. (CEQA: EXEMPT PURSUANT TO CLASS 7 EXEMPTION (14 CCR § 15307); CLASS 8 EXEMPTION (14 CCR § 15308); AND THE COMMON SENSE EXEMPTION (14 CCR § 15061(B)(3))).

WHEREAS, the four-mile portion of the California coastline within the boundaries of the City of Santa Cruz (the “City”) is a precious natural resource which is valuable to the People of the City, the State of California, and the Nation; and
WHEREAS, the City has authority under the U.S. Constitution, the California Constitution, and State law, through its City Council, to use its police powers to enact legislative measures regulating land use within the City’s geographical jurisdiction in the interest of public health, safety, environment, and general welfare; and
WHEREAS, the City bases its coastal management decisions on the policies and priorities in the California Coastal Act, and conflicts are resolved in a manner which on balance is the most protective of significant coastal resources; and
WHEREAS, there have been several times in the recent past wherein the waters off of the City’s coastline have been considered for off-shore development of oil and gas resources and deepsea mineral extraction; and WHEREAS, in the 1980s, the United States’ Department of the Interior launched a campaign to “unleash” American energy through the then USGS Conservation Division, opening wide areas off of America’s coast to leasing for oil and gas drilling; and WHEREAS, in 1985, and in an effort to create a “blue wall” of zoning prohibitions against these proposed area leases, a majority of the voters from the City approved Measure A, requiring voter approval before the City could make any zoning changes that would permit the construction of on-shore support facilities for off-shore oil and gas drilling efforts (“Measure A”); and WHEREAS, Measure A was codified into the City Code as Santa Cruz Municipal Code (SCMC) Section 24.06.090; and
WHEREAS, the City later passed ordinances prohibiting the refinery of petroleum products or other industrial activities in support of off-shore oil drilling in General Industrial Districts (SCMC 24.10.1525) and in General Industrial Districts/Performance Districts (SCMC

24.10.1620); and

33.6 2
WHEREAS, in 2025, the Bureau of Ocean Energy Management (“BOEM”) initiated an overhaul of the United States’ off-shore drilling policy as the “Unleashing American Energy” initiative, pursuant to the proposed 11th National Outer Continental Shelf (OCS) Oil and Gas Leasing Program (the “Program”); and
WHEREAS, in September 2022, the State of California enacted the California Seabed Mining Prevention Act, banning new oil and gas leasing and seabed mining in state waters due to unacceptably high risk of harm to the marine environment and the public interest; and WHEREAS, the health, safety, environment, economy, and general welfare of the City’s coastline and local communities, including but not limited to the County of Santa Cruz more broadly, could be threatened both directly and indirectly by proposals for on-shore support facilities, including those proposed by the Program, intended to support the off-shore development of oil and gas resources and deep-sea mineral extraction, including but not limited to:

1. On-shore support facilities for off-shore oil and gas development and deep-sea mining could substantially adversely affect the many significant coastal resources located within the City of Santa Cruz:
a. The City of Santa Cruz’s coastline is highly scenic and central to the coastal character of the town. The City has long protected the scenic and visual qualities of its coastal areas by siting development to be visually compatible with the character of surrounding areas and to minimize the alteration of natural land forms. For example, the City prohibited development of Lighthouse Field through the voterapproved Measure D (1974). And, in 1992, the City approved its first Local Coastal Plan prioritizing habitat protection, public access, and viewsheds as vital community resources. Siting an on-shore facility in the City’s coastal zone could disrupt the scenic and visual qualities the City has worked hard to protect. b. The City is home to numerous tourist destinations, including the Santa Cruz Beach Boardwalk, Wharf, world-renowned surf breaks, Monterey Bay National Marine Sanctuary Exploration Center, two City beaches (Main Beach and Cowell Beach), three State Beaches (Natural Bridges State Beach, Seabright State Beach, and Lighthouse Field State Beach), and the Santa Cruz Harbor. The City provides access to numerous public beaches, beach bluffs, and coastal trails. It relies on tourism, including over 1 million annual visitors to the Wharf alone, as a significant part of its economy. On-shore support facilities could detract from the tourist experience in the City, both visually and by limiting the available coastal areas for tourists to visit.
c. The construction and operation of on-shore support facilities in the City could impede public access to the coastline. Oil or tailings spills from on-shore support facilities could cut off public access to the beach and ocean for months. d. The California Coastal Act requires that valuable marine resources in the City be maintained and enhanced. These marine resources could be impaired by the

33.7 3
construction or operation of on-shore support facilities by increasing the risk of oil spills and leaks from facilities.
e. An on-shore facility and its risks of spills and leaks could disrupt the biological productivity of coastal waters and conditions required to sustain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes. Operations from on-shore facilities could also impair state marine protected areas, the Natural Bridges State Marine Reserve, and sections of the 6,094 square mile Monterey Bay National Marine Sanctuary - all in close proximity to the City.
f. The Monterey Bay region is home to over 500 fish species, 90 species of seabird, and 30 species of marine mammals. The City is home to resident and transitory populations of blue whale, humpback whale, southern sea otter, leatherback sea turtle, snowy plover, coho salmon, and steelhead trout, all of whom are threatened or endangered. A portion of these species’ habitats are found along the City’s coastline; oil spills and leaks from new on-shore facilities on the coast could destroy that habitat and threaten the existence of the species. g. Acres of environmentally sensitive habitat – including sandy beaches, coastal bluffs and marine terraces, kelp forests, estuaries, and coastal dunes and lagoons – are found along the City of Santa Cruz’s coastline. Building an on-shore facility could directly destroy the habitat, as well as indirectly affect its long-term health. h. The City has a vibrant and economically and culturally important commercial fishing sector: commercial fish catch from all California National Marine Sanctuaries (which includes Santa Cruz) generated over $69 million in annual revenue from 2010-2012 with Dungeness crab, squid, salmon, urchin, halibut, and groundfish playing important roles. The City has devoted significant space to serving those industries and has a strong interest in supporting the economic wellbeing of this ocean-dependent sector. On-shore facilities such as pipelines, tankers, and tailing ponds located within the coastal zone could take up valuable harbor space and substantially interfere with this industry. i. Significant harbor space exists at the Santa Cruz Harbor to serve boating industries, which houses 800 permanent vessel slips for commercial, recreational, and research users and serving as a hub for boating, fishing charters, and whale watching. Public launching facilities and additional berthing space in the Harbor encourage increased recreational boating use in adjacent coastal waters. The City prioritizes limiting non-water-dependent land uses – such as on-shore support facilities – that could congest access corridors and preclude boating support facilities. j. The City’s coast is internationally recognized for its surf culture, with 13 surf breaks along a 4-mile stretch from Natural Bridges State Beach to the Santa Cruz Harbor catering to all skill levels. Important surf breaks include Steamer Lane, Cowells, Indicators, and Middle Peak, among others. Nearly 800,000 annual surf

33.8 4
visits occur in Santa Cruz County, generating almost $200 million yearly for the greater Santa Cruz area. This vital ocean-oriented recreational activity cannot readily be provided at inland water areas. The City’s residents, as well as tourists who travel to participate, may be deprived of this activity if an on-shore support facility is built.
k. There are numerous significant archaeological or paleontological resources as identified by the State Historic Preservation Officer located on or near the City’s coast. Key resources include ancient Native American shell mounds, coastal terrace sites dating back thousands of years (such as the Sand Hill Bluff just north of City limits and extensive marine fossils associated with local manifestations of the Purisima Formation), Santa Cruz Mudstone, and Santa Margarita Sandstone.

These resources are culturally and historically valuable and could be irreparably harmed if on-shore support facilities were constructed in their vicinity. l. The City’s existing municipal infrastructure is inadequate to support on-shore facilities. For example, State Highway Route 1 services the City; the section at the Fishhook is narrow, winding, and heavily congested with traffic on an ongoing basis. Additionally, the City does not have oil spill containment technologies in the event of a pipeline leak; the nearby Santa Cruz Harbor cannot handle tankers and other large vessels; and local City streets are not amenable to the large trucks needed to service on-shore facilities to transport oil or mineral resources out of the City.

2. The City of Santa Cruz has unique characteristics that could make it particularly unsuitable for siting on-shore support facilities for off-shore oil and gas development and deep-sea mining:
a. The City of Santa Cruz experiences extreme winter storms, including atmospheric rivers that regularly result in local flooding, including of the San Lorenzo River and associated watershed, and destructive coastal wave events, including wave overtopping of West Cliff Drive, that may make on-shore operations hazardous and at risk of creating an oil spill or leak.
b. The City is a seismically hazardous area, located near the San Andreas and San Gregorio Faults and home to the massive 1989 Loma Prieta earthquake that destroyed or damaged 40 buildings and killed six people. Because the City is at a higher risk for earthquakes, this has the potential to rupture pipelines or disrupt other on-shore facilities.
c. The coastline of the City has suffered from high erosion rates. Substantial episodic and seasonal coastal erosion occurs along developed bluffs and sandy beaches along with slower long term erosion. Areas of particular concern include West Cliff Drive and Main Beach. Drivers of erosion include accelerating sea level rise, wave energy, and extreme winter storms exacerbated by climate change. This would put an on-shore facility located on the coast at great risk of an oil spill or leak.

33.9 5

3. The construction and operation of on-shore support facilities could create many hazards and risks threatening the public health, safety, environment, and general welfare of the City of Santa Cruz:
a. On-shore support facilities can create the risk of spills or leaks, such as the spill experienced on Refugio State Beach in 2015, in which 140,000 gallons of oil spilled and spread over 150 miles of the California coast. The spill led to the closure of miles of beaches and 130 square miles of fishing grounds and killed hundreds of birds, fish, and marine mammals. Oil spills can have numerous adverse effects, including: degradation of sensitive marine environments; contamination of beaches and other recreational areas; reduction in property values; decrease in tourism; long-term impairment of water-dependent industries, such as fishing; and acute human health effects, such as skin and eye irritation, breathing problems, nausea and vomiting, and others.
b. On-shore support facilities can emit and transport hazardous and toxic air pollutants, such as:
i. Benzene, toluene, ethylbenzene, and xylene. Short-term exposure to these chemicals can cause drowsiness, dizziness, nausea, depression, fatigue, and eye, skin, and respiratory tract irritation; long-term exposure can result in respiratory effects, damage to the central nervous system, kidneys, and liver, and developmental effects (such as birth defects). Benzene is also a known human carcinogen and has been linked to leukemia. ii. Particulate matter (PM). Exposure can result in heart attacks, irregular heartbeats, asthma, decreased lung function, increased respiratory symptoms, and premature death in people with heart or lung disease. PM can also stain and damage stone and other materials, including culturally or historically valuable objects such as statues and monuments, as well as harm sensitive ecosystems by contributing to acid rain and nutrient depletion. iii. Hydrogen sulfide (H2S). Short-term exposure can result in irritation of the eyes, nose, and throat, headache, dizziness, nausea, vomiting, coughing, difficulty breathing, and permanent damage to the central nervous system. iv. Carbon monoxide (CO). Short-term exposure can result in headache, dizziness, vomiting, nausea, unconsciousness, and death. v. Nitrogen oxides (NOx) and sulfur oxides (SOx). Short-term exposure can aggravate respiratory diseases, particularly asthma, leading to respiratory symptoms such as coughing, wheezing or difficulty breathing. Long-term exposure may contribute to the development of asthma and potentially increase susceptibility to respiratory infections. NOx and SOx also

33.10 6
contribute to acid rain, and NOx contributes to nutrient pollution in coastal waters.
c. On-shore support facilities for deep-sea minerals also raise significant concerns about radioactive waste and dust. Scientific studies have revealed that polymetallic nodules contain high concentrations of radioactive materials. During processing, as nodules are crushed, small particles may be distributed into the air, posing radiological hazards to human health. Furthermore, residual products from mining slurry—a mixture of seawater, sediment, and nodule fines—also pose significant risk if discharged back into the ocean. Radioactive particles may be ingested by marine organisms, introducing radiation into the food web that may be ingested by people. These public health risks are especially concerning given the limited regulatory frameworks and scientific understanding governing radioactive byproducts from deep-sea mining operations.
d. On-shore support facilities are also potential contributors to groundwater and surface water pollution. For example, some facilities use deep-injection wells to dispose of wastewater that may contain oil residuals, chemicals, and other hazardous wastes, which can contaminate aquifers and groundwater. e. Noisy helicopter and commercial street traffic and other nuisances like light pollution from 24-hour facilities could be significant irritants to the City’s residents.

4. The City of Santa Cruz has considered the national energy interest and found that it already significantly supports national energy needs:
a. The City of Santa Cruz has consistently committed to advancing renewable energy systems (especially distributed solar), green building standards, sourcing green energy, reducing fossil fuel demand, and protecting economically and environmentally critical coastal resources, all of which aligns with long-term national energy strategies moving away from reliance on fossil fuels and fossil fuel extraction.
b. The City of Santa Cruz has fully committed to California’s prioritization of a just decarbonization transition in a responsible way. The City of Santa Cruz’s strategy to rapidly achieve a just decarbonization transition is through its Climate Action Plan 2030, which includes building codes that incentivize electrification and require deep decarbonization, sourcing 97% of its electricity city-wide from Central Coast Community Energy (which will provide 100% renewable electricity by 2030), prioritizing electric vehicles, public transit and active transportation, and supporting community scale distributed renewable energy systems.

WHEREAS, the City wishes for the voters of the City of Santa Cruz to retain the final authority on whether to allow on-shore support facilities for all off-shore oil and gas development and deep-sea mining, and not just on-shore support facilities for off-shore oil and gas drilling as currently specified in the Santa Cruz Municipal Code Section 24.06.090; and

33.11 7
WHEREAS, at its May 7, 2026 meeting, the City Planning Commission reviewed the proposed amendments to Title 24 of the Santa Cruz Municipal Code and found that the public necessity, the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendments are in general conformance with the principles, policies, and land use designations set forth in the General Plan, Local Coastal Plan, and any adopted area or specific plan as proposed to be amended; and
WHEREAS, at its May 7, 2026 meeting, the Santa Cruz Planning Commission considered the modifications to the Santa Cruz Municipal Code as modifications to the Local Coastal Program and found that (1) the proposed amendments are deemed to be in the public interest; (2) the proposed General Plan and/or Local Coastal Program amendments are consistent and compatible with the rest of the General Plan and LCP and any implementation programs that may be affected; (3) the potential impacts of the proposed amendments have been assessed and have been determined not to be detrimental to the public health, safety, or welfare; and (4) the proposed amendments have been processed in accordance with the applicable provisions of the California Government Code and the California Environmental Quality Act (CEQA); and

WHEREAS, at its May 7, 2026 meeting, the City Planning Commission passed a motion that recommended the City Council approve the determination under the California Environmental Quality Act and approve the proposed amendments to Title 24 of the Santa Cruz Municipal Code.

BE IT ORDAINED by the City of Santa Cruz as follows:

SECTION 1. The City Council finds that the above recitals are true and correct and are adopted and incorporated herein by reference as findings.

SECTION 2. Section 24.10.1525 of the Santa Cruz Municipal Code is hereby amended to read as follows:

1. Any manufacturing use involving the primary production of products from new materials found to be incompatible with the neighborhood or the city as a whole based on noise, odor, air quality or other adverse environmental impact shall be prohibited.

2. No use which either produces or utilizes asbestos in any manufacturing process shall be permitted.

3. Refinery of petroleum products or other industrial activities in support of off-shore drilling or deep-sea mining, as defined in Section 24.06.093, shall not be permitted.

4. Repeal or amendment of subsection 3 shall be subject to the requirements of other applicable portions of the Santa Cruz Municipal Code, including but not limited to Sections

24.06.090 and 24.06.093.

SECTION 3. Intention and Interpretation of Ordinance

33.12 8

1. Sections 2 and 3 of this Ordinance are intended and shall be interpreted to be additive to and complement Santa Cruz Municipal Code section 24.06.090, which was enacted by a vote of the people on November 5, 1985 via Ordinance 85-70.

2. Nothing in this Ordinance shall apply to prohibit any person or entity from exercising a vested right, obtained pursuant to State or local law, as of the effective date of this Ordinance.

3. The provisions of this Ordinance shall not be applicable to the extent they violate the constitution or laws of the United States or the State of California.

4. If any section, sentence, clause, phrase, or part of this Ordinance is held unconstitutional or invalid, the remainder of this Ordinance shall be given full effect consistent with the intent and purpose of the Ordinance.

SECTION 4. The City Council finds and determines that the adoption of this ordinance is considered a “project” under California Code of Regulations, Title 14, section 15378(a)(1) of the California Environmental Quality Act (CEQA) Guidelines, typically subject to environmental review. The City Council finds that the project is categorically exempt from CEQA review, pursuant to: Class 7 Exemption (14 CCR § 15307) – Actions by Regulatory Agencies for Protection of Natural Resources, as the proposed ordinance intends to ensure the maintenance of a natural resource; Class 8 Exemption (14 CCR § 15308) – Actions by Regulatory Agencies for Protection of the Environment, as the proposed ordinance intends to ensure the protection of the environment; and the Common Sense Exemption (14 CCR § 15061(b)(3)) as it can be seen with certainty that prohibiting on-shore facilities related to off-shore oil and gas drilling and deep-sea mining and exploration will maintain the status quo, and there is no possibility of a significant negative effect on the environment.

SECTION 5. This Ordinance shall take effect and be in full force thirty (30) days after final adoption outside of the Coastal Zone. Within the Coastal Zone, this ordinance shall take effect and be in full force after approval by the California Coastal Commission, but no earlier than thirty (30) days after final adoption.

PASSED FOR PUBLICATION this 9th day of June, 2026, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor

33.13 9
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
PASSED FOR FINAL ADOPTION this 23rd day of June, 2026, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
This is to certify that the above and
foregoing document is the original
of Ordinance No. 202x-xx and that
it has been published or posted in
accordance with the Charter of the
City of Santa Cruz.
________________________________
Bonnie Bush, City Clerk Administrator

33.14 1
ORDINANCE NO. 2026-XX

AN ORDINANCE OF THE CITY OF SANTA CRUZ AMENDING SANTA CRUZ MUNICIPAL CODE SECTION 24.10.1525 – PROHIBITED USES, PROHIBITING THE

DEVELOPMENT OF ON-SHORE FACILITIES SUPPORTING DEEP-SEA MINING EXPLORATION & DEVELOPMENT WITHIN CERTAIN LAND USE DISTRICTS.

SECTION 24.10.1525 IS PART OF THE LOCAL COASTAL PROGRAM

IMPLEMENTATION PLAN (LCP IP) AND WILL REQUIRE APPROVAL BY THE

CALIFORNIA COASTAL COMMISSION PRIOR TO TAKING EFFECT INSIDE THE COASTAL ZONE. (CEQA: EXEMPT PURSUANT TO CLASS 7 EXEMPTION (14 CCR § 15307); CLASS 8 EXEMPTION (14 CCR § 15308); AND THE COMMON SENSE EXEMPTION (14 CCR § 15061(B)(3))).

WHEREAS, the four-mile portion of the California coastline within the boundaries of the City of Santa Cruz (the “City”) is a precious natural resource which is valuable to the People of the City, the State of California, and the Nation; and
WHEREAS, the City has authority under the U.S. Constitution, the California Constitution, and State law, through its City Council, to use its police powers to enact legislative measures regulating land use within the City’s geographical jurisdiction in the interest of public health, safety, environment, and general welfare; and
WHEREAS, the City bases its coastal management decisions on the policies and priorities in the California Coastal Act, and conflicts are resolved in a manner which on balance is the most protective of significant coastal resources; and
WHEREAS, there have been several times in the recent past wherein the waters off of the City’s coastline have been considered for off-shore development of oil and gas resources and deepsea mineral extraction; and WHEREAS, in the 1980s, the United States’ Department of the Interior launched a campaign to “unleash” American energy through the then USGS Conservation Division, opening wide areas off of America’s coast to leasing for oil and gas drilling; and WHEREAS, in 1985, and in an effort to create a “blue wall” of zoning prohibitions against these proposed area leases, a majority of the voters from the City approved Measure A, requiring voter approval before the City could make any zoning changes that would permit the construction of on-shore support facilities for off-shore oil and gas drilling efforts (“Measure A”); and WHEREAS, Measure A was codified into the City Code as Santa Cruz Municipal Code (SCMC) Section 24.06.090; and
WHEREAS, the City later passed ordinances prohibiting the refinery of petroleum products or other industrial activities in support of off-shore oil drilling in General Industrial

33.15 2
Districts (SCMC 24.10.1525) and in General Industrial Districts/Performance Districts (SCMC

24.10.1620); and
WHEREAS, in 2025, the Bureau of Ocean Energy Management (“BOEM”) initiated an overhaul of the United States’ off-shore drilling policy as the “Unleashing American Energy” initiative, pursuant to the proposed 11th National Outer Continental Shelf (OCS) Oil and Gas Leasing Program (the “Program”); and
WHEREAS, in September 2022, the State of California enacted the California Seabed Mining Prevention Act, banning new oil and gas leasing and seabed mining in state waters due to unacceptably high risk of harm to the marine environment and the public interest; and WHEREAS, the health, safety, environment, economy, and general welfare of the City’s coastline and local communities, including but not limited to the County of Santa Cruz more broadly, could be threatened both directly and indirectly by proposals for on-shore support facilities, including those proposed by the Program, intended to support the off-shore development of oil and gas resources and deep-sea mineral extraction, including but not limited to:

1. On-shore support facilities for off-shore oil and gas development and deep-sea mining could substantially adversely affect the many significant coastal resources located within the City of Santa Cruz:
a. The City of Santa Cruz’s coastline is highly scenic and central to the coastal character of the town. The City has long protected the scenic and visual qualities of its coastal areas by siting development to be visually compatible with the character of surrounding areas and to minimize the alteration of natural land forms. For example, the City prohibited development of Lighthouse Field through the voterapproved Measure D (1974). And, in 1992, the City approved its first Local Coastal Plan prioritizing habitat protection, public access, and viewsheds as vital community resources. Siting an on-shore facility in the City’s coastal zone could disrupt the scenic and visual qualities the City has worked hard to protect. b. The City is home to numerous tourist destinations, including the Santa Cruz Beach Boardwalk, Wharf, world-renowned surf breaks, Monterey Bay National Marine Sanctuary Exploration Center, two City beaches (Main Beach and Cowell Beach), three State Beaches (Natural Bridges State Beach, Seabright State Beach, and Lighthouse Field State Beach), and the Santa Cruz Harbor. The City provides access to numerous public beaches, beach bluffs, and coastal trails. It relies on tourism, including over 1 million annual visitors to the Wharf alone, as a significant part of its economy. On-shore support facilities could detract from the tourist experience in the City, both visually and by limiting the available coastal areas for tourists to visit.
c. The construction and operation of on-shore support facilities in the City could impede public access to the coastline. Oil or tailings spills from on-shore support facilities could cut off public access to the beach and ocean for months.

33.16 3
d. The California Coastal Act requires that valuable marine resources in the City be maintained and enhanced. These marine resources could be impaired by the construction or operation of on-shore support facilities by increasing the risk of oil spills and leaks from facilities.
e. An on-shore facility and its risks of spills and leaks could disrupt the biological productivity of coastal waters and conditions required to sustain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes. Operations from on-shore facilities could also impair state marine protected areas, the Natural Bridges State Marine Reserve, and sections of the 6,094 square mile Monterey Bay National Marine Sanctuary - all in close proximity to the City.
f. The Monterey Bay region is home to over 500 fish species, 90 species of seabird, and 30 species of marine mammals. The City is home to resident and transitory populations of blue whale, humpback whale, southern sea otter, leatherback sea turtle, snowy plover, coho salmon, and steelhead trout, all of whom are threatened or endangered. A portion of these species’ habitats are found along the City’s coastline; oil spills and leaks from new on-shore facilities on the coast could destroy that habitat and threaten the existence of the species. g. Acres of environmentally sensitive habitat – including sandy beaches, coastal bluffs and marine terraces, kelp forests, estuaries, and coastal dunes and lagoons – are found along the City of Santa Cruz’s coastline. Building an on-shore facility could directly destroy the habitat, as well as indirectly affect its long-term health. h. The City has a vibrant and economically and culturally important commercial fishing sector: commercial fish catch from all California National Marine Sanctuaries (which includes Santa Cruz) generated over $69 million in annual revenue from 2010-2012 with Dungeness crab, squid, salmon, urchin, halibut, and groundfish playing important roles. The City has devoted significant space to serving those industries and has a strong interest in supporting the economic wellbeing of this ocean-dependent sector. On-shore facilities such as pipelines, tankers, and tailing ponds located within the coastal zone could take up valuable harbor space and substantially interfere with this industry. i. Significant harbor space exists at the Santa Cruz Harbor to serve boating industries, which houses 800 permanent vessel slips for commercial, recreational, and research users and serving as a hub for boating, fishing charters, and whale watching. Public launching facilities and additional berthing space in the Harbor encourage increased recreational boating use in adjacent coastal waters. The City prioritizes limiting non-water-dependent land uses – such as on-shore support facilities – that could congest access corridors and preclude boating support facilities. j. The City’s coast is internationally recognized for its surf culture, with 13 surf breaks along a 4-mile stretch from Natural Bridges State Beach to the Santa Cruz

33.17 4
Harbor catering to all skill levels. Important surf breaks include Steamer Lane, Cowells, Indicators, and Middle Peak, among others. Nearly 800,000 annual surf visits occur in Santa Cruz County, generating almost $200 million yearly for the greater Santa Cruz area. This vital ocean-oriented recreational activity cannot readily be provided at inland water areas. The City’s residents, as well as tourists who travel to participate, may be deprived of this activity if an on-shore support facility is built.
k. There are numerous significant archaeological or paleontological resources as identified by the State Historic Preservation Officer located on or near the City’s coast. Key resources include ancient Native American shell mounds, coastal terrace sites dating back thousands of years (such as the Sand Hill Bluff just north of City limits and extensive marine fossils associated with local manifestations of the Purisima Formation), Santa Cruz Mudstone, and Santa Margarita Sandstone.

These resources are culturally and historically valuable and could be irreparably harmed if on-shore support facilities were constructed in their vicinity. l. The City’s existing municipal infrastructure is inadequate to support on-shore facilities. For example, State Highway Route 1 services the City; the section at the Fishhook is narrow, winding, and heavily congested with traffic on an ongoing basis. Additionally, the City does not have oil spill containment technologies in the event of a pipeline leak; the nearby Santa Cruz Harbor cannot handle tankers and other large vessels; and local City streets are not amenable to the large trucks needed to service on-shore facilities to transport oil or mineral resources out of the City.

2. The City of Santa Cruz has unique characteristics that could make it particularly unsuitable for siting on-shore support facilities for off-shore oil and gas development and deep-sea mining:
a. The City of Santa Cruz experiences extreme winter storms, including atmospheric rivers that regularly result in local flooding, including of the San Lorenzo River and associated watershed, and destructive coastal wave events, including wave overtopping of West Cliff Drive, that may make on-shore operations hazardous and at risk of creating an oil spill or leak.
b. The City is a seismically hazardous area, located near the San Andreas and San Gregorio Faults and home to the massive 1989 Loma Prieta earthquake that destroyed or damaged 40 buildings and killed six people. Because the City is at a higher risk for earthquakes, this has the potential to rupture pipelines or disrupt other on-shore facilities.
c. The coastline of the City has suffered from high erosion rates. Substantial episodic and seasonal coastal erosion occurs along developed bluffs and sandy beaches along with slower long term erosion. Areas of particular concern include West Cliff Drive and Main Beach. Drivers of erosion include accelerating sea level rise, wave

33.18 5
energy, and extreme winter storms exacerbated by climate change. This would put an on-shore facility located on the coast at great risk of an oil spill or leak.

3. The construction and operation of on-shore support facilities could create many hazards and risks threatening the public health, safety, environment, and general welfare of the City of Santa Cruz:
a. On-shore support facilities can create the risk of spills or leaks, such as the spill experienced on Refugio State Beach in 2015, in which 140,000 gallons of oil spilled and spread over 150 miles of the California coast. The spill led to the closure of miles of beaches and 130 square miles of fishing grounds and killed hundreds of birds, fish, and marine mammals. Oil spills can have numerous adverse effects, including: degradation of sensitive marine environments; contamination of beaches and other recreational areas; reduction in property values; decrease in tourism; long-term impairment of water-dependent industries, such as fishing; and acute human health effects, such as skin and eye irritation, breathing problems, nausea and vomiting, and others.
b. On-shore support facilities can emit and transport hazardous and toxic air pollutants, such as:
i. Benzene, toluene, ethylbenzene, and xylene. Short-term exposure to these chemicals can cause drowsiness, dizziness, nausea, depression, fatigue, and eye, skin, and respiratory tract irritation; long-term exposure can result in respiratory effects, damage to the central nervous system, kidneys, and liver, and developmental effects (such as birth defects). Benzene is also a known human carcinogen and has been linked to leukemia. ii. Particulate matter (PM). Exposure can result in heart attacks, irregular heartbeats, asthma, decreased lung function, increased respiratory symptoms, and premature death in people with heart or lung disease. PM can also stain and damage stone and other materials, including culturally or historically valuable objects such as statues and monuments, as well as harm sensitive ecosystems by contributing to acid rain and nutrient depletion. iii. Hydrogen sulfide (H2S). Short-term exposure can result in irritation of the eyes, nose, and throat, headache, dizziness, nausea, vomiting, coughing, difficulty breathing, and permanent damage to the central nervous system. iv. Carbon monoxide (CO). Short-term exposure can result in headache, dizziness, vomiting, nausea, unconsciousness, and death. v. Nitrogen oxides (NOx) and sulfur oxides (SOx). Short-term exposure can aggravate respiratory diseases, particularly asthma, leading to respiratory symptoms such as coughing, wheezing or difficulty breathing. Long-term exposure may contribute to the development of asthma and potentially

33.19 6
increase susceptibility to respiratory infections. NOx and SOx also contribute to acid rain, and NOx contributes to nutrient pollution in coastal waters.
c. On-shore support facilities for deep-sea minerals also raise significant concerns about radioactive waste and dust. Scientific studies have revealed that polymetallic nodules contain high concentrations of radioactive materials. During processing, as nodules are crushed, small particles may be distributed into the air, posing radiological hazards to human health. Furthermore, residual products from mining slurry—a mixture of seawater, sediment, and nodule fines—also pose significant risk if discharged back into the ocean. Radioactive particles may be ingested by marine organisms, introducing radiation into the food web that may be ingested by people. These public health risks are especially concerning given the limited regulatory frameworks and scientific understanding governing radioactive byproducts from deep-sea mining operations.
d. On-shore support facilities are also potential contributors to groundwater and surface water pollution. For example, some facilities use deep-injection wells to dispose of wastewater that may contain oil residuals, chemicals, and other hazardous wastes, which can contaminate aquifers and groundwater. e. Noisy helicopter and commercial street traffic and other nuisances like light pollution from 24-hour facilities could be significant irritants to the City’s residents.

4. The City of Santa Cruz has considered the national energy interest and found that it already significantly supports national energy needs:
a. The City of Santa Cruz has consistently committed to advancing renewable energy systems (especially distributed solar), green building standards, sourcing green energy, reducing fossil fuel demand, and protecting economically and environmentally critical coastal resources, all of which aligns with long-term national energy strategies moving away from reliance on fossil fuels and fossil fuel extraction.
b. The City of Santa Cruz has fully committed to California’s prioritization of a just decarbonization transition in a responsible way. The City of Santa Cruz’s strategy to rapidly achieve a just decarbonization transition is through its Climate Action Plan 2030, which includes building codes that incentivize electrification and require deep decarbonization, sourcing 97% of its electricity city-wide from Central Coast Community Energy (which will provide 100% renewable electricity by 2030), prioritizing electric vehicles, public transit and active transportation, and supporting community scale distributed renewable energy systems.

WHEREAS, the City wishes for the voters of the City of Santa Cruz to retain the final authority on whether to allow on-shore support facilities for all off-shore oil and gas development and deep-sea mining, and not just on-shore support facilities for off-shore oil and gas drilling as currently specified in the Santa Cruz Municipal Code Section 24.06.090; and

33.20 7
WHEREAS, at its May 7, 2026 meeting, the City Planning Commission reviewed the proposed amendments to Title 24 of the Santa Cruz Municipal Code and found that the public necessity, the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendments are in general conformance with the principles, policies, and land use designations set forth in the General Plan, Local Coastal Plan, and any adopted area or specific plan as proposed to be amended; and
WHEREAS, at its May 7, 2026 meeting, the Santa Cruz Planning Commission considered the modifications to the Santa Cruz Municipal Code as modifications to the Local Coastal Program and found that (1) the proposed amendments are deemed to be in the public interest; (2) the proposed General Plan and/or Local Coastal Program amendments are consistent and compatible with the rest of the General Plan and LCP and any implementation programs that may be affected; (3) the potential impacts of the proposed amendments have been assessed and have been determined not to be detrimental to the public health, safety, or welfare; and (4) the proposed amendments have been processed in accordance with the applicable provisions of the California Government Code and the California Environmental Quality Act (CEQA); and

WHEREAS, at its May 7, 2026 meeting, the City Planning Commission passed a motion that recommended the City Council approve the determination under the California Environmental Quality Act and approve the proposed amendments to Title 24 of the Santa Cruz Municipal Code.

BE IT ORDAINED by the City of Santa Cruz as follows:

SECTION 1. The City Council finds that the above recitals are true and correct and are adopted and incorporated herein by reference as findings.

SECTION 2. Section 24.10.1525 of the Santa Cruz Municipal Code is hereby amended to read as follows:

1. Any manufacturing use involving the primary production of products from new materials found to be incompatible with the neighborhood or the city as a whole based on noise, odor, air quality or other adverse environmental impact shall be prohibited.

2. No use which either produces or utilizes asbestos in any manufacturing process shall be permitted.

3. Refinery of petroleum products or other industrial activities in support of off-shore drilling or deep-sea mining, as defined in Section 24.06.093, shall not be permitted.

4. Repeal or amendment of subsection 3 shall be subject to the requirements of other applicable portions of the Santa Cruz Municipal Code, including but not limited to Sections

24.06.090 and 24.06.093.

SECTION 3. Intention and Interpretation of Ordinance

33.21 8

1. Sections 2 and 3 of this Ordinance are intended and shall be interpreted to be additive to and complement Santa Cruz Municipal Code section 24.06.090, which was enacted by a vote of the people on November 5, 1985 via Ordinance 85-70.

2. Nothing in this Ordinance shall apply to prohibit any person or entity from exercising a vested right, obtained pursuant to State or local law, as of the effective date of this Ordinance.

3. The provisions of this Ordinance shall not be applicable to the extent they violate the constitution or laws of the United States or the State of California.

4. If any section, sentence, clause, phrase, or part of this Ordinance is held unconstitutional or invalid, the remainder of this Ordinance shall be given full effect consistent with the intent and purpose of the Ordinance.

SECTION 4. The City Council finds and determines that the adoption of this ordinance is considered a “project” under California Code of Regulations, Title 14, section 15378(a)(1) of the California Environmental Quality Act (CEQA) Guidelines, typically subject to environmental review. The City Council finds that the project is categorically exempt from CEQA review, pursuant to: Class 7 Exemption (14 CCR § 15307) – Actions by Regulatory Agencies for Protection of Natural Resources, as the proposed ordinance intends to ensure the maintenance of a natural resource; Class 8 Exemption (14 CCR § 15308) – Actions by Regulatory Agencies for Protection of the Environment, as the proposed ordinance intends to ensure the protection of the environment; and the Common Sense Exemption (14 CCR § 15061(b)(3)) as it can be seen with certainty that prohibiting on-shore facilities related to off-shore oil and gas drilling and deep-sea mining and exploration will maintain the status quo, and there is no possibility of a significant negative effect on the environment.

SECTION 5. This Ordinance shall take effect and be in full force thirty (30) days after final adoption outside of the Coastal Zone. Within the Coastal Zone, this ordinance shall take effect and be in full force after approval by the California Coastal Commission, but no earlier than thirty (30) days after final adoption.

PASSED FOR PUBLICATION this 9th day of June, 2026, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor

33.22 9
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
PASSED FOR FINAL ADOPTION this 23rd day of June, 2026, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
This is to certify that the above and
foregoing document is the original
of Ordinance No. 202x-xx and that
it has been published or posted in
accordance with the Charter of the
City of Santa Cruz.
________________________________
Bonnie Bush, City Clerk Administrator

33.23 1
ORDINANCE NO. 2026-XX

AN ORDINANCE OF THE CITY OF SANTA CRUZ AMENDING SANTA CRUZ MUNICIPAL CODE CHAPTER 24.06 – ZONING MAP AND TEXT AMENDMENTS, SECTION 24.06.090 – SUPPORT FACILITIES FOR OFF-SHORE OIL AND GAS DRILLING – SUBMISSION TO THE ELECTORATE, AND SECTION 24.10.1620 – PROHIBITED

USES, REQUIRING VOTER APPROVAL FOR ON-SHORE FACILITIES SUPPORTING

OFF-SHORE OIL & GAS OR DEEP-SEA MINING EXPLORATION & DEVELOPMENT

AND FURTHER PROHIBITING THE DEVELOPMENT OF ON-SHORE FACILITIES

SUPPORTING DEEP-SEA MINING EXPLORATION & DEVELOPMENT WITHIN CERTAIN LAND USE DISTRICTS. (CEQA: EXEMPT PURSUANT TO CLASS 7 EXEMPTION (14 CCR § 15307); CLASS 8 EXEMPTION (14 CCR § 15308); AND THE COMMON SENSE EXEMPTION (14 CCR § 15061(B)(3))).

WHEREAS, the four-mile portion of the California coastline within the boundaries of the City of Santa Cruz (the “City”) is a precious natural resource which is valuable to the People of the City, the State of California, and the Nation; and
WHEREAS, the City has authority under the U.S. Constitution, the California Constitution, and State law, through its City Council, to use its police powers to enact legislative measures regulating land use within the City’s geographical jurisdiction in the interest of public health, safety, environment, and general welfare; and
WHEREAS, the City bases its coastal management decisions on the policies and priorities in the California Coastal Act, and conflicts are resolved in a manner which on balance is the most protective of significant coastal resources; and
WHEREAS, there have been several times in the recent past wherein the waters off of the City’s coastline have been considered for off-shore development of oil and gas resources and deepsea mineral extraction; and WHEREAS, in the 1980s, the United States’ Department of the Interior launched a campaign to “unleash” American energy through the then USGS Conservation Division, opening wide areas off of America’s coast to leasing for oil and gas drilling; and WHEREAS, in 1985, and in an effort to create a “blue wall” of zoning prohibitions against these proposed area leases, a majority of the voters from the City approved Measure A, requiring voter approval before the City could make any zoning changes that would permit the construction of on-shore support facilities for off-shore oil and gas drilling efforts (“Measure A”); and WHEREAS, Measure A was codified into the City Code as Santa Cruz Municipal Code Section (SCMC) 24.06.090; and
WHEREAS, the City later passed ordinances prohibiting the refinery of petroleum products or other industrial activities in support of off-shore oil drilling in General Industrial

33.24 2
Districts (SCMC 24.10.1525) and in General Industrial Districts/Performance Districts (SCMC

24.10.1620); and
WHEREAS, in 2025, the Bureau of Ocean Energy Management (“BOEM”) initiated an overhaul of the United States’ off-shore drilling policy as the “Unleashing American Energy” initiative, pursuant to the proposed 11th National Outer Continental Shelf (OCS) Oil and Gas Leasing Program (the “Program”); and
WHEREAS, in September 2022, the State of California enacted the California Seabed Mining Prevention Act, banning new oil and gas leasing and seabed mining in state waters due to unacceptably high risk of harm to the marine environment and the public interest; and WHEREAS, the health, safety, environment, economy, and general welfare of the City’s coastline and local communities, including but not limited to the County of Santa Cruz more broadly, could be threatened both directly and indirectly by proposals for on-shore support facilities, including those proposed by the Program, intended to support the off-shore development of oil and gas resources and deep-sea mineral extraction, including but not limited to:

1. On-shore support facilities for off-shore oil and gas development and deep-sea mining could substantially adversely affect the many significant coastal resources located within the City of Santa Cruz:
a. The City of Santa Cruz’s coastline is highly scenic and central to the coastal character of the town. The City has long protected the scenic and visual qualities of its coastal areas by siting development to be visually compatible with the character of surrounding areas and to minimize the alteration of natural land forms. For example, the City prohibited development of Lighthouse Field through the voterapproved Measure D (1974). And, in 1992, the City approved its first Local Coastal Plan prioritizing habitat protection, public access, and viewsheds as vital community resources. Siting an on-shore facility in the City’s coastal zone could disrupt the scenic and visual qualities the City has worked hard to protect. b. The City is home to numerous tourist destinations, including the Santa Cruz Beach Boardwalk, Wharf, world-renowned surf breaks, Monterey Bay National Marine Sanctuary Exploration Center, two City beaches (Main Beach and Cowell Beach), three State Beaches (Natural Bridges State Beach, Seabright State Beach, and Lighthouse Field State Beach), and the Santa Cruz Harbor. The City provides access to numerous public beaches, beach bluffs, and coastal trails. It relies on tourism, including over 1 million annual visitors to the Wharf alone, as a significant part of its economy. On-shore support facilities could detract from the tourist experience in the City, both visually and by limiting the available coastal areas for tourists to visit.
c. The construction and operation of on-shore support facilities in the City could impede public access to the coastline. Oil or tailings spills from on-shore support facilities could cut off public access to the beach and ocean for months.

33.25 3
d. The California Coastal Act requires that valuable marine resources in the City be maintained and enhanced. These marine resources could be impaired by the construction or operation of on-shore support facilities by increasing the risk of oil spills and leaks from facilities.
e. An on-shore facility and its risks of spills and leaks could disrupt the biological productivity of coastal waters and conditions required to sustain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes. Operations from on-shore facilities could also impair state marine protected areas, the Natural Bridges State Marine Reserve, and sections of the 6,094 square mile Monterey Bay National Marine Sanctuary - all in close proximity to the City.
f. The Monterey Bay region is home to over 500 fish species, 90 species of seabird, and 30 species of marine mammals. The City is home to resident and transitory populations of blue whale, humpback whale, southern sea otter, leatherback sea turtle, snowy plover, coho salmon, and steelhead trout, all of whom are threatened or endangered. A portion of these species’ habitats are found along the City’s coastline; oil spills and leaks from new on-shore facilities on the coast could destroy that habitat and threaten the existence of the species. g. Acres of environmentally sensitive habitat – including sandy beaches, coastal bluffs and marine terraces, kelp forests, estuaries, and coastal dunes and lagoons – are found along the City of Santa Cruz’s coastline. Building an on-shore facility could directly destroy the habitat, as well as indirectly affect its long-term health. h. The City has a vibrant and economically and culturally important commercial fishing sector: commercial fish catch from all California National Marine Sanctuaries (which includes Santa Cruz) generated over $69 million in annual revenue from 2010-2012 with Dungeness crab, squid, salmon, urchin, halibut, and groundfish playing important roles. The City has devoted significant space to serving those industries and has a strong interest in supporting the economic wellbeing of this ocean-dependent sector. On-shore facilities such as pipelines, tankers, and tailing ponds located within the coastal zone could take up valuable harbor space and substantially interfere with this industry. i. Significant harbor space exists at the Santa Cruz Harbor to serve boating industries, which houses 800 permanent vessel slips for commercial, recreational, and research users and serving as a hub for boating, fishing charters, and whale watching. Public launching facilities and additional berthing space in the Harbor encourage increased recreational boating use in adjacent coastal waters. The City prioritizes limiting non-water-dependent land uses – such as on-shore support facilities – that could congest access corridors and preclude boating support facilities. j. The City’s coast is internationally recognized for its surf culture, with 13 surf breaks along a 4-mile stretch from Natural Bridges State Beach to the Santa Cruz

33.26 4
Harbor catering to all skill levels. Important surf breaks include Steamer Lane, Cowells, Indicators, and Middle Peak, among others. Nearly 800,000 annual surf visits occur in Santa Cruz County, generating almost $200 million yearly for the greater Santa Cruz area. This vital ocean-oriented recreational activity cannot readily be provided at inland water areas. The City’s residents, as well as tourists who travel to participate, may be deprived of this activity if an on-shore support facility is built.
k. There are numerous significant archaeological or paleontological resources as identified by the State Historic Preservation Officer located on or near the City’s coast. Key resources include ancient Native American shell mounds, coastal terrace sites dating back thousands of years (such as the Sand Hill Bluff just north of City limits and extensive marine fossils associated with local manifestations of the Purisima Formation), Santa Cruz Mudstone, and Santa Margarita Sandstone.

These resources are culturally and historically valuable and could be irreparably harmed if on-shore support facilities were constructed in their vicinity. l. The City’s existing municipal infrastructure is inadequate to support on-shore facilities. For example, State Highway Route 1 services the City; the section at the Fishhook is narrow, winding, and heavily congested with traffic on an ongoing basis. Additionally, the City does not have oil spill containment technologies in the event of a pipeline leak; the nearby Santa Cruz Harbor cannot handle tankers and other large vessels; and local City streets are not amenable to the large trucks needed to service on-shore facilities to transport oil or mineral resources out of the City.

2. The City of Santa Cruz has unique characteristics that could make it particularly unsuitable for siting on-shore support facilities for off-shore oil and gas development and deep-sea mining:
a. The City of Santa Cruz experiences extreme winter storms, including atmospheric rivers that regularly result in local flooding, including of the San Lorenzo River and associated watershed, and destructive coastal wave events, including wave overtopping of West Cliff Drive, that may make on-shore operations hazardous and at risk of creating an oil spill or leak.
b. The City is a seismically hazardous area, located near the San Andreas and San Gregorio Faults and home to the massive 1989 Loma Prieta earthquake that destroyed or damaged 40 buildings and killed six people. Because the City is at a higher risk for earthquakes, this has the potential to rupture pipelines or disrupt other on-shore facilities.
c. The coastline of the City has suffered from high erosion rates. Substantial episodic and seasonal coastal erosion occurs along developed bluffs and sandy beaches along with slower long term erosion. Areas of particular concern include West Cliff Drive and Main Beach. Drivers of erosion include accelerating sea level rise, wave

33.27 5
energy, and extreme winter storms exacerbated by climate change. This would put an on-shore facility located on the coast at great risk of an oil spill or leak.

3. The construction and operation of on-shore support facilities could create many hazards and risks threatening the public health, safety, environment, and general welfare of the City of Santa Cruz:
a. On-shore support facilities can create the risk of spills or leaks, such as the spill experienced on Refugio State Beach in 2015, in which 140,000 gallons of oil spilled and spread over 150 miles of the California coast. The spill led to the closure of miles of beaches and 130 square miles of fishing grounds and killed hundreds of birds, fish, and marine mammals. Oil spills can have numerous adverse effects, including: degradation of sensitive marine environments; contamination of beaches and other recreational areas; reduction in property values; decrease in tourism; long-term impairment of water-dependent industries, such as fishing; and acute human health effects, such as skin and eye irritation, breathing problems, nausea and vomiting, and others.
b. On-shore support facilities can emit and transport hazardous and toxic air pollutants, such as:
i. Benzene, toluene, ethylbenzene, and xylene. Short-term exposure to these chemicals can cause drowsiness, dizziness, nausea, depression, fatigue, and eye, skin, and respiratory tract irritation; long-term exposure can result in respiratory effects, damage to the central nervous system, kidneys, and liver, and developmental effects (such as birth defects). Benzene is also a known human carcinogen and has been linked to leukemia. ii. Particulate matter (PM). Exposure can result in heart attacks, irregular heartbeats, asthma, decreased lung function, increased respiratory symptoms, and premature death in people with heart or lung disease. PM can also stain and damage stone and other materials, including culturally or historically valuable objects such as statues and monuments, as well as harm sensitive ecosystems by contributing to acid rain and nutrient depletion. iii. Hydrogen sulfide (H2S). Short-term exposure can result in irritation of the eyes, nose, and throat, headache, dizziness, nausea, vomiting, coughing, difficulty breathing, and permanent damage to the central nervous system. iv. Carbon monoxide (CO). Short-term exposure can result in headache, dizziness, vomiting, nausea, unconsciousness, and death. v. Nitrogen oxides (NOx) and sulfur oxides (SOx). Short-term exposure can aggravate respiratory diseases, particularly asthma, leading to respiratory symptoms such as coughing, wheezing or difficulty breathing. Long-term exposure may contribute to the development of asthma and potentially

33.28 6
increase susceptibility to respiratory infections. NOx and SOx also contribute to acid rain, and NOx contributes to nutrient pollution in coastal waters.
c. On-shore support facilities for deep-sea minerals also raise significant concerns about radioactive waste and dust. Scientific studies have revealed that polymetallic nodules contain high concentrations of radioactive materials. During processing, as nodules are crushed, small particles may be distributed into the air, posing radiological hazards to human health. Furthermore, residual products from mining slurry—a mixture of seawater, sediment, and nodule fines—also pose significant risk if discharged back into the ocean. Radioactive particles may be ingested by marine organisms, introducing radiation into the food web that may be ingested by people. These public health risks are especially concerning given the limited regulatory frameworks and scientific understanding governing radioactive byproducts from deep-sea mining operations.
d. On-shore support facilities are also potential contributors to groundwater and surface water pollution. For example, some facilities use deep-injection wells to dispose of wastewater that may contain oil residuals, chemicals, and other hazardous wastes, which can contaminate aquifers and groundwater. e. Noisy helicopter and commercial street traffic and other nuisances like light pollution from 24-hour facilities could be significant irritants to the City’s residents.

4. The City of Santa Cruz has considered the national energy interest and found that it already significantly supports national energy needs:
a. The City of Santa Cruz has consistently committed to advancing renewable energy systems (especially distributed solar), green building standards, sourcing green energy, reducing fossil fuel demand, and protecting economically and environmentally critical coastal resources, all of which aligns with long-term national energy strategies moving away from reliance on fossil fuels and fossil fuel extraction.
b. The City of Santa Cruz has fully committed to California’s prioritization of a just decarbonization transition in a responsible way. The City of Santa Cruz’s strategy to rapidly achieve a just decarbonization transition is through its Climate Action Plan 2030, which includes building codes that incentivize electrification and require deep decarbonization, sourcing 97% of its electricity city-wide from Central Coast Community Energy (which will provide 100% renewable electricity by 2030), prioritizing electric vehicles, public transit and active transportation, and supporting community scale distributed renewable energy systems.

WHEREAS, the City wishes for the voters of the City of Santa Cruz to retain the final authority on whether to allow on-shore support facilities for all off-shore oil and gas development and deep-sea mining, and not just on-shore support facilities for off-shore oil and gas drilling as currently specified in the Santa Cruz Municipal Code Section 24.06.090; and

33.29 7
WHEREAS, at its May 7, 2026 meeting, the City Planning Commission reviewed the proposed amendments to Title 24 of the Santa Cruz Municipal Code and found that the public necessity, the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendments are in general conformance with the principles, policies, and land use designations set forth in the General Plan, Local Coastal Plan, and any adopted area or specific plan as proposed to be amended; and

WHEREAS, at its May 7, 2026 meeting, the City Planning Commission passed a motion that recommended the City Council approve the determination under the California Environmental Quality Act and approve the proposed amendments to Title 24 of the Santa Cruz Municipal Code.

BE IT ORDAINED by the City of Santa Cruz as follows:

SECTION 1. The City Council finds that the above recitals are true and correct and are adopted and incorporated herein by reference as findings.

SECTION 2. Section 24.06.090 of the Santa Cruz Municipal Code is hereby amended to read as follows:

So long as Ordinance 85-70 (adopted by a vote of the people on November 5, 1985) remains in effect, no zoning changes to accommodate on-shore support facilities for off-shore oil and gas drilling shall be enacted without a vote of the people of the city of Santa Cruz.

Similarly, pursuant to Ordinance No. XX, no zoning changes to accommodate on-shore support facilities for deep-sea mining shall be enacted without a vote of the people of the City of Santa Cruz. The definitions contained in Santa Cruz Municipal Code Section 24.06.093 shall apply to this Section.

SECTION 3. Chapter 24.06 of the Santa Cruz Municipal Code (Zoning Map and Text Amendments) is hereby amended to add Section 24.06.093 to read as follows:

24.06.093 Support Facilities for Off-Shore Oil and Gas Drilling or Deep-Sea Mining – Submission to the Electorate.

The purpose of this section is to protect the City of Santa Cruz’s coastline, water, economy, local industries, including tourism, air quality, public access, recreation, biodiversity, and quality of life, and to further the City of Santa Cruz’s transition away from the direct and indirect effects of harmful extractive off-shore activities. As further specified in Ordinance No. XX’s findings, the general welfare of the City of Santa Cruz is both directly and indirectly tied to the health and resiliency of the Pacific Ocean. These provisions continue the City’s long-standing practice of protecting the Pacific Ocean and its coastline as valuable public resources by ensuring that any legislative approvals (including, but not limited to, a zoning amendment, General Plan amendment, Local Coastal Program amendment, Development Plan, Specific Plan, or other legislative action) that allow on-shore support facilities for off-shore oil and gas development or deep-sea mining

33.30 8
within the City only be allowed if they are approved by a simple majority (50% +1) of the voters in the City of Santa Cruz who cast ballots.

1. Definitions.
a. The term “on-shore support facility” means any new or expanded facilities within the City of Santa Cruz’s jurisdiction that support the exploration, development, production, storage, processing, or other activities related to off-shore fossil fuel, including oil and gas, energy resources development or deep-sea mining. “On-shore support facilities” include but are not limited to:
i. Transportation facilities: On-shore facilities and equipment for the purpose of transporting crude off-shore oil and gas or deep-sea minerals and slurry to and from processing and storage facilities, including pipelines, pipeline landfalls, pump stations, tankers, rail spurs, and trucking terminals. ii. Storage facilities: On-shore facilities and equipment for the purpose of storing crude off-shore oil and gas or deep-sea minerals, including tank farms and slurry ponds, or storing chemicals, drilling muds, cuttings, produced waters, and/or other materials used in the course of drilling offshore oil and gas wells, production, or in the processing of crude off-shore oil and gas.
iii. Processing facilities: On-shore facilities and equipment for the purpose of processing, distilling, converting, treating, blending, purifying, leaching, and/or refining crude off-shore oil and gas or deep-sea minerals, including refineries, gas plants, treatment tanks, tailing ponds, and distillation units. iv. Waste disposal facilities: On-shore facilities, including tailing ponds and landfills, and equipment for the purpose of disposing of chemicals, drilling muds, cuttings, produced waters, tailings, dried wastes, and other toxic materials generated in the course of drilling off-shore oil and gas wells, production, or in the processing of off-shore oil and gas or deep-sea mineral products.
b. Exceptions. The term “on-shore support facilities” does not refer to:
i. Transportation, storage, processing, or waste disposal facilities or equipment that are not being used to support off-shore oil and gas development or deep-sea mining.
ii. Existing facilities that support on-shore or off-shore oil and gas development.

33.31 9
iii. Gas stations or power plants used to support off-shore-oil and gas development and deep-sea mining.
c. The term “deep-sea mining” means the extraction of deep-sea mineral deposits, including, but not limited to, polymetallic nodules, ferromanganese crusts, and seafloor sulfides, from the ocean floor or seamounts at depths typically greater than 200 meters, including in areas within the U.S. Exclusive Economic Zone and beyond national jurisdiction.
d. The term “deep-sea minerals” means natural deposits of valuable minerals found in the ocean, including, but not limited to, metals and placer deposits of metals, nonmetallic minerals, gemstones, ores, gold, silver, copper, lead, iron, cobalt, nickel, manganese, silica, chrome, platinum, tungsten, zirconium, titanium, garnet, and phosphorous. e. Exceptions. The term “deep-sea minerals” does not refer to rock, gravel, sand, silt, oyster shells, or hydrocarbons.

2. Voter Approval for On-Shore Support Facilities.

Any legislative approvals (to include, but not be limited to, a zoning amendment, General Plan amendment, Local Coastal Program amendment, Development Plan, Specific Plan, or other legislative action), including those that comply with existing City zoning laws or require a zoning change, authorizing or allowing the development, construction, opening, installation, or expansion of any on-shore support facility within the City of Santa Cruz, shall not be effective unless such authorization is approved by a simple majority (50% +1) of the voters in the City who cast ballots.

SECTION 4. Section 24.10.1620 of the Santa Cruz Municipal Code is hereby amended to read as follows:

1. Any manufacturing use involving the primary production of products from new materials found to be incompatible with the neighborhood or the city as a whole based on noise, odor, air quality or other adverse environmental impact shall be prohibited.

2. No use which either produces or utilizes asbestos in any manufacturing process shall be permitted.

3. Refinery of petroleum products or other industrial activities in support of off-shore drilling or deep-sea mining, as defined in Section 24.06.093, shall not be permitted.

4. Repeal or amendment of subsection 3 shall be subject to the requirements of other applicable portions of the Santa Cruz Municipal Code, including but not limited to Sections

24.06.090 and 24.06.093.

SECTION 5. Intention and Interpretation of Ordinance

33.32 10

1. Sections 2 and 3 of this Ordinance are intended and shall be interpreted to be additive to and complement Santa Cruz Municipal Code section 24.06.090, which was enacted by a vote of the people on November 5, 1985 via Ordinance 85-70.

2. Nothing in this Ordinance shall apply to prohibit any person or entity from exercising a vested right, obtained pursuant to State or local law, as of the effective date of this Ordinance.

3. The provisions of this Ordinance shall not be applicable to the extent they violate the constitution or laws of the United States or the State of California.

4. If any section, sentence, clause, phrase, or part of this Ordinance is held unconstitutional or invalid, the remainder of this Ordinance shall be given full effect consistent with the intent and purpose of the Ordinance.

SECTION 6. The City Council finds and determines that the adoption of this ordinance is considered a “project” under California Code of Regulations, Title 14, section 15378(a)(1) of the California Environmental Quality Act (CEQA) Guidelines, typically subject to environmental review. The City Council finds that the project is categorically exempt from CEQA review, pursuant to: Class 7 Exemption (14 CCR § 15307) – Actions by Regulatory Agencies for Protection of Natural Resources, as the proposed ordinance intends to ensure the maintenance of a natural resource; Class 8 Exemption (14 CCR § 15308) – Actions by Regulatory Agencies for Protection of the Environment, as the proposed ordinance intends to ensure the protection of the environment; and the Common Sense Exemption (14 CCR § 15061(b)(3)) as it can be seen with certainty that prohibiting on-shore facilities related to off-shore oil and gas drilling and deep-sea mining and exploration will maintain the status quo, and there is no possibility of a significant negative effect on the environment.

SECTION 7. This Ordinance shall take effect and be in full force thirty (30) days after final adoption.

PASSED FOR PUBLICATION this 9th day of June, 2026, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator

33.33 11
PASSED FOR FINAL ADOPTION this 23rd day of June, 2026, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
This is to certify that the above and
foregoing document is the original
of Ordinance No. 202x-xx and that
it has been published or posted in
accordance with the Charter of the
City of Santa Cruz.
________________________________
Bonnie Bush, City Clerk Administrator

33.34 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 1 ORDINANCE NO. 2026-XX

AN ORDINANCE OF THE CITY OF SANTA CRUZ AMENDING SANTA CRUZ MUNICIPAL CODE CHAPTER 24.06 – ZONING MAP AND TEXT AMENDMENTS, SECTION 24.06.090 – SUPPORT FACILITIES FOR OFF-SHORE OIL AND GAS DRILLING – SUBMISSION TO THE ELECTORATE, AND SECTION 24.10.1620 – PROHIBITED

USES, REQUIRING VOTER APPROVAL FOR ON-SHORE FACILITIES SUPPORTING

OFF-SHORE OIL & GAS OR DEEP-SEA MINING EXPLORATION & DEVELOPMENT

AND FURTHER PROHIBITING THE DEVELOPMENT OF ON-SHORE FACILITIES

SUPPORTING DEEP-SEA MINING EXPLORATION & DEVELOPMENT WITHIN CERTAIN LAND USE DISTRICTS. (CEQA: EXEMPT PURSUANT TO CLASS 7 EXEMPTION (14 CCR § 15307); CLASS 8 EXEMPTION (14 CCR § 15308); AND THE COMMON SENSE EXEMPTION (14 CCR § 15061(B)(3))).

WHEREAS, the four-mile portion of the California coastline within the boundaries of the City of Santa Cruz (the “City”) is a precious natural resource which is valuable to the People of the City, the State of California, and the Nation; and
WHEREAS, the City has authority under the U.S. Constitution, the California Constitution, and State law, through its City Council, to use its police powers to enact legislative measures regulating land use within the City’s geographical jurisdiction in the interest of public health, safety, environment, and general welfare; and
WHEREAS, the City bases its coastal management decisions on the policies and priorities in the California Coastal Act, and conflicts are resolved in a manner which on balance is the most protective of significant coastal resources; and
WHEREAS, there have been several times in the recent past wherein the waters off of the City’s coastline have been considered for off-shore development of oil and gas resources and deepsea mineral extraction; and WHEREAS, in the 1980s, the United States’ Department of the Interior launched a campaign to “unleash” American energy through the then USGS Conservation Division, opening wide areas off of America’s coast to leasing for oil and gas drilling; and WHEREAS, in 1985, and in an effort to create a “blue wall” of zoning prohibitions against these proposed area leases, a majority of the voters from the City approved Measure A, requiring voter approval before the City could make any zoning changes that would permit the construction of on-shore support facilities for off-shore oil and gas drilling efforts (“Measure A”); and WHEREAS, Measure A was codified into the City Code as Santa Cruz Municipal Code Section (SCMC) 24.06.090; and
WHEREAS, the City later passed ordinances prohibiting the refinery of petroleum products or other industrial activities in support of off-shore oil drilling in General Industrial

33.35 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 2 Districts (SCMC 24.10.1525) and in General Industrial Districts/Performance Districts (SCMC

24.10.1620); and
WHEREAS, in 2025, the Bureau of Ocean Energy Management (“BOEM”) initiated an overhaul of the United States’ off-shore drilling policy as the “Unleashing American Energy” initiative, pursuant to the proposed 11th National Outer Continental Shelf (OCS) Oil and Gas Leasing Program (the “Program”); and
WHEREAS, in September 2022, the State of California enacted the California Seabed Mining Prevention Act, banning new oil and gas leasing and seabed mining in state waters due to unacceptably high risk of harm to the marine environment and the public interest; and WHEREAS, the health, safety, environment, economy, and general welfare of the City’s coastline and local communities, including but not limited to the County of Santa Cruz more broadly, could be threatened both directly and indirectly by proposals for on-shore support facilities, including those proposed by the Program, intended to support the off-shore development of oil and gas resources and deep-sea mineral extraction, including but not limited to:

1. On-shore support facilities for off-shore oil and gas development and deep-sea mining could substantially adversely affect the many significant coastal resources located within the City of Santa Cruz:
a. The City of Santa Cruz’s coastline is highly scenic and central to the coastal character of the town. The City has long protected the scenic and visual qualities of its coastal areas by siting development to be visually compatible with the character of surrounding areas and to minimize the alteration of natural land forms. For example, the City prohibited development of Lighthouse Field through the voterapproved Measure D (1974). And, in 1992, the City approved its first Local Coastal Plan prioritizing habitat protection, public access, and viewsheds as vital community resources. Siting an on-shore facility in the City’s coastal zone could disrupt the scenic and visual qualities the City has worked hard to protect. b. The City is home to numerous tourist destinations, including the Santa Cruz Beach Boardwalk, Wharf, world-renowned surf breaks, Monterey Bay National Marine Sanctuary Exploration Center, two City beaches (Main Beach and Cowell Beach), three State Beaches (Natural Bridges State Beach, Seabright State Beach, and Lighthouse Field State Beach), and the Santa Cruz Harbor. The City provides access to numerous public beaches, beach bluffs, and coastal trails. It relies on tourism, including over 1 million annual visitors to the Wharf alone, as a significant part of its economy. On-shore support facilities could detract from the tourist experience in the City, both visually and by limiting the available coastal areas for tourists to visit.
c. The construction and operation of on-shore support facilities in the City could impede public access to the coastline. Oil or tailings spills from on-shore support facilities could cut off public access to the beach and ocean for months.

33.36 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 3 d. The California Coastal Act requires that valuable marine resources in the City be maintained and enhanced. These marine resources could be impaired by the construction or operation of on-shore support facilities by increasing the risk of oil spills and leaks from facilities.
e. An on-shore facility and its risks of spills and leaks could disrupt the biological productivity of coastal waters and conditions required to sustain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes. Operations from on-shore facilities could also impair state marine protected areas, the Natural Bridges State Marine Reserve, and sections of the 6,094 square mile Monterey Bay National Marine Sanctuary - all in close proximity to the City.
f. The Monterey Bay region is home to over 500 fish species, 90 species of seabird, and 30 species of marine mammals. The City is home to resident and transitory populations of blue whale, humpback whale, southern sea otter, leatherback sea turtle, snowy plover, coho salmon, and steelhead trout, all of whom are threatened or endangered. A portion of these species’ habitats are found along the City’s coastline; oil spills and leaks from new on-shore facilities on the coast could destroy that habitat and threaten the existence of the species. g. Acres of environmentally sensitive habitat – including sandy beaches, coastal bluffs and marine terraces, kelp forests, estuaries, and coastal dunes and lagoons – are found along the City of Santa Cruz’s coastline. Building an on-shore facility could directly destroy the habitat, as well as indirectly affect its long-term health. h. The City has a vibrant and economically and culturally important commercial fishing sector: commercial fish catch from all California National Marine Sanctuaries (which includes Santa Cruz) generated over $69 million in annual revenue from 2010-2012 with Dungeness crab, squid, salmon, urchin, halibut, and groundfish playing important roles. The City has devoted significant space to serving those industries and has a strong interest in supporting the economic wellbeing of this ocean-dependent sector. On-shore facilities such as pipelines, tankers, and tailing ponds located within the coastal zone could take up valuable harbor space and substantially interfere with this industry. i. Significant harbor space exists at the Santa Cruz Harbor to serve boating industries, which houses 800 permanent vessel slips for commercial, recreational, and research users and serving as a hub for boating, fishing charters, and whale watching. Public launching facilities and additional berthing space in the Harbor encourage increased recreational boating use in adjacent coastal waters. The City prioritizes limiting non-water-dependent land uses – such as on-shore support facilities – that could congest access corridors and preclude boating support facilities. j. The City’s coast is internationally recognized for its surf culture, with 13 surf breaks along a 4-mile stretch from Natural Bridges State Beach to the Santa Cruz

33.37 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 4 Harbor catering to all skill levels. Important surf breaks include Steamer Lane, Cowells, Indicators, and Middle Peak, among others. Nearly 800,000 annual surf visits occur in Santa Cruz County, generating almost $200 million yearly for the greater Santa Cruz area. This vital ocean-oriented recreational activity cannot readily be provided at inland water areas. The City’s residents, as well as tourists who travel to participate, may be deprived of this activity if an on-shore support facility is built.
k. There are numerous significant archaeological or paleontological resources as identified by the State Historic Preservation Officer located on or near the City’s coast. Key resources include ancient Native American shell mounds, coastal terrace sites dating back thousands of years (such as the Sand Hill Bluff just north of City limits and extensive marine fossils associated with local manifestations of the Purisima Formation), Santa Cruz Mudstone, and Santa Margarita Sandstone.

These resources are culturally and historically valuable and could be irreparably harmed if on-shore support facilities were constructed in their vicinity. l. The City’s existing municipal infrastructure is inadequate to support on-shore facilities. For example, State Highway Route 1 services the City; the section at the Fishhook is narrow, winding, and heavily congested with traffic on an ongoing basis. Additionally, the City does not have oil spill containment technologies in the event of a pipeline leak; the nearby Santa Cruz Harbor cannot handle tankers and other large vessels; and local City streets are not amenable to the large trucks needed to service on-shore facilities to transport oil or mineral resources out of the City.

2. The City of Santa Cruz has unique characteristics that could make it particularly unsuitable for siting on-shore support facilities for off-shore oil and gas development and deep-sea mining:
a. The City of Santa Cruz experiences extreme winter storms, including atmospheric rivers that regularly result in local flooding, including of the San Lorenzo River and associated watershed, and destructive coastal wave events, including wave overtopping of West Cliff Drive, that may make on-shore operations hazardous and at risk of creating an oil spill or leak.
b. The City is a seismically hazardous area, located near the San Andreas and San Gregorio Faults and home to the massive 1989 Loma Prieta earthquake that destroyed or damaged 40 buildings and killed six people. Because the City is at a higher risk for earthquakes, this has the potential to rupture pipelines or disrupt other on-shore facilities.
c. The coastline of the City has suffered from high erosion rates. Substantial episodic and seasonal coastal erosion occurs along developed bluffs and sandy beaches along with slower long term erosion. Areas of particular concern include West Cliff Drive and Main Beach. Drivers of erosion include accelerating sea level rise, wave

33.38 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 5 energy, and extreme winter storms exacerbated by climate change. This would put an on-shore facility located on the coast at great risk of an oil spill or leak.

3. The construction and operation of on-shore support facilities could create many hazards and risks threatening the public health, safety, environment, and general welfare of the City of Santa Cruz:
a. On-shore support facilities can create the risk of spills or leaks, such as the spill experienced on Refugio State Beach in 2015, in which 140,000 gallons of oil spilled and spread over 150 miles of the California coast. The spill led to the closure of miles of beaches and 130 square miles of fishing grounds and killed hundreds of birds, fish, and marine mammals. Oil spills can have numerous adverse effects, including: degradation of sensitive marine environments; contamination of beaches and other recreational areas; reduction in property values; decrease in tourism; long-term impairment of water-dependent industries, such as fishing; and acute human health effects, such as skin and eye irritation, breathing problems, nausea and vomiting, and others.
b. On-shore support facilities can emit and transport hazardous and toxic air pollutants, such as:
i. Benzene, toluene, ethylbenzene, and xylene. Short-term exposure to these chemicals can cause drowsiness, dizziness, nausea, depression, fatigue, and eye, skin, and respiratory tract irritation; long-term exposure can result in respiratory effects, damage to the central nervous system, kidneys, and liver, and developmental effects (such as birth defects). Benzene is also a known human carcinogen and has been linked to leukemia. ii. Particulate matter (PM). Exposure can result in heart attacks, irregular heartbeats, asthma, decreased lung function, increased respiratory symptoms, and premature death in people with heart or lung disease. PM can also stain and damage stone and other materials, including culturally or historically valuable objects such as statues and monuments, as well as harm sensitive ecosystems by contributing to acid rain and nutrient depletion. iii. Hydrogen sulfide (H2S). Short-term exposure can result in irritation of the eyes, nose, and throat, headache, dizziness, nausea, vomiting, coughing, difficulty breathing, and permanent damage to the central nervous system. iv. Carbon monoxide (CO). Short-term exposure can result in headache, dizziness, vomiting, nausea, unconsciousness, and death. v. Nitrogen oxides (NOx) and sulfur oxides (SOx). Short-term exposure can aggravate respiratory diseases, particularly asthma, leading to respiratory symptoms such as coughing, wheezing or difficulty breathing. Long-term exposure may contribute to the development of asthma and potentially

33.39 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 6 increase susceptibility to respiratory infections. NOx and SOx also contribute to acid rain, and NOx contributes to nutrient pollution in coastal waters.
c. On-shore support facilities for deep-sea minerals also raise significant concerns about radioactive waste and dust. Scientific studies have revealed that polymetallic nodules contain high concentrations of radioactive materials. During processing, as nodules are crushed, small particles may be distributed into the air, posing radiological hazards to human health. Furthermore, residual products from mining slurry—a mixture of seawater, sediment, and nodule fines—also pose significant risk if discharged back into the ocean. Radioactive particles may be ingested by marine organisms, introducing radiation into the food web that may be ingested by people. These public health risks are especially concerning given the limited regulatory frameworks and scientific understanding governing radioactive byproducts from deep-sea mining operations.
d. On-shore support facilities are also potential contributors to groundwater and surface water pollution. For example, some facilities use deep-injection wells to dispose of wastewater that may contain oil residuals, chemicals, and other hazardous wastes, which can contaminate aquifers and groundwater. e. Noisy helicopter and commercial street traffic and other nuisances like light pollution from 24-hour facilities could be significant irritants to the City’s residents.

4. The City of Santa Cruz has considered the national energy interest and found that it already significantly supports national energy needs:
a. The City of Santa Cruz has consistently committed to advancing renewable energy systems (especially distributed solar), green building standards, sourcing green energy, reducing fossil fuel demand, and protecting economically and environmentally critical coastal resources, all of which aligns with long-term national energy strategies moving away from reliance on fossil fuels and fossil fuel extraction.
b. The City of Santa Cruz has fully committed to California’s prioritization of a just decarbonization transition in a responsible way. The City of Santa Cruz’s strategy to rapidly achieve a just decarbonization transition is through its Climate Action Plan 2030, which includes building codes that incentivize electrification and require deep decarbonization, sourcing 97% of its electricity city-wide from Central Coast Community Energy (which will provide 100% renewable electricity by 2030), prioritizing electric vehicles, public transit and active transportation, and supporting community scale distributed renewable energy systems.

WHEREAS, the City wishes for the voters of the City of Santa Cruz to retain the final authority on whether to allow on-shore support facilities for all off-shore oil and gas development and deep-sea mining, and not just on-shore support facilities for off-shore oil and gas drilling as currently specified in the Santa Cruz Municipal Code Section 24.06.090; and

33.40 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 7 WHEREAS, at its May 7, 2026 meeting, the City Planning Commission reviewed the proposed amendments to Title 24 of the Santa Cruz Municipal Code and found that the public necessity, the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendments are in general conformance with the principles, policies, and land use designations set forth in the General Plan, Local Coastal Plan, and any adopted area or specific plan as proposed to be amended; and

WHEREAS, at its May 7, 2026 meeting, the City Planning Commission passed a motion that recommended the City Council approve the determination under the California Environmental Quality Act and approve the proposed amendments to Title 24 of the Santa Cruz Municipal Code.

BE IT ORDAINED by the City of Santa Cruz as follows:

SECTION 1. The City Council finds that the above recitals are true and correct and are adopted and incorporated herein by reference as findings.

SECTION 2. Section 24.06.090 of the Santa Cruz Municipal Code is hereby amended to read as follows:

So long as Ordinance 85-70 (adopted by a vote of the people on November 5, 1985) remains in effect, no zoning changes to accommodate on-shore support facilities for off-shore oil and gas drilling shall be enacted without a vote of the people of the city of Santa Cruz.

Similarly, pursuant to Ordinance No. XX, no zoning changes to accommodate on-shore support facilities for deep-sea mining shall be enacted without a vote of the people of the City of Santa Cruz. The definitions contained in Santa Cruz Municipal Code Section 24.06.093 shall apply to this Section.

SECTION 3. Chapter 24.06 of the Santa Cruz Municipal Code (Zoning Map and Text Amendments) is hereby amended to add Section 24.06.093 to read as follows:

24.06.093 Support Facilities for Off-Shore Oil and Gas Drilling or Deep-Sea Mining – Submission to the Electorate.

The purpose of this section is to protect the City of Santa Cruz’s coastline, water, economy, local industries, including tourism, air quality, public access, recreation, biodiversity, and quality of life, and to further the City of Santa Cruz’s transition away from the direct and indirect effects of harmful extractive off-shore activities. As further specified in Ordinance No. XX’s findings, the general welfare of the City of Santa Cruz is both directly and indirectly tied to the health and resiliency of the Pacific Ocean. These provisions continue the City’s long-standing practice of protecting the Pacific Ocean and its coastline as valuable public resources by ensuring that any legislative approvals (including, but not limited to, a zoning amendment, General Plan amendment, Local Coastal Program amendment, Development Plan, Specific Plan, or other legislative action) zoning changes or other legislative acts that allow on-shore support facilities for off-shore oil and

33.41 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 8 gas development or deep-sea mining within the City only be allowed if they are approved by thea simple majority (50% +1) of the voters in the City of Santa Cruz in a general electionwho cast ballots.

1. Definitions.
a. The term “on-shore support facility” means any new or expanded facilities within the City of Santa Cruz’s jurisdiction that support the exploration, development, production, storage, processing, or other activities related to off-shore fossil fuel, including oil and gas, energy resources development or deep-sea mining. “On-shore support facilities” include but are not limited to:
i. Transportation facilities: On-shore facilities and equipment for the purpose of transporting crude off-shore oil and gas or deep-sea minerals and slurry to and from processing and storage facilities, including pipelines, pipeline landfalls, pump stations, tankers, rail spurs, and trucking terminals. ii. Storage facilities: On-shore facilities and equipment for the purpose of storing crude off-shore oil and gas or deep-sea minerals, including tank farms and slurry ponds, or storing chemicals, drilling muds, cuttings, produced waters, and/or other materials used in the course of drilling offshore oil and gas wells, production, or in the processing of crude off-shore oil and gas.
iii. Processing facilities: On-shore facilities and equipment for the purpose of processing, distilling, converting, treating, blending, purifying, leaching, and/or refining crude off-shore oil and gas or deep-sea minerals, including refineries, gas plants, treatment tanks, tailing ponds, and distillation units. iv. Waste disposal facilities: On-shore facilities, including tailing ponds and landfills, and equipment for the purpose of disposing of chemicals, drilling muds, cuttings, produced waters, tailings, dried wastes, and other toxic materials generated in the course of drilling off-shore oil and gas wells, production, or in the processing of off-shore oil and gas or deep-sea mineral products.
b. Exceptions. The term “on-shore support facilities” does not refer to:
i. Transportation, storage, processing, or waste disposal facilities or equipment that are not being used to support off-shore oil and gas development or deep-sea mining.
ii. Existing facilities that support on-shore or off-shore oil and gas development.

33.42 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 9 iii. Gas stations or power plants used to support off-shore-oil and gas development and deep-sea mining.
c. The term “deep-sea mining” means the extraction of deep-sea mineral deposits, including, but not limited to, polymetallic nodules, ferromanganese crusts, and seafloor sulfides, from the ocean floor or seamounts at depths typically greater than 200 meters, including in areas within the U.S. Exclusive Economic Zone and beyond national jurisdiction.
d. The term “deep-sea minerals” means natural deposits of valuable minerals found in the ocean, including, but not limited to, metals and placer deposits of metals, nonmetallic minerals, gemstones, ores, gold, silver, copper, lead, iron, cobalt, nickel, manganese, silica, chrome, platinum, tungsten, zirconium, titanium, garnet, and phosphorous. e. Exceptions. The term “deep-sea minerals” does not refer to rock, gravel, sand, silt, oyster shells, or hydrocarbons.

2. Voter Approval for On-Shore Support Facilities.

Any legislative approvals (to include, but not be limited to, a zoning amendment, General Plan amendment, Local Coastal Program amendment, Development Plan, Specific Plan, or other legislative action), including those that comply with existing City zoning laws or require a zoning change, authorizing or allowing the development, construction, opening, installation, or expansion of any on-shore support facility within the City of Santa Cruz, shall not be effective unless such authorization is approved by a simple majority (50% +1) of the voters in the City in a general electionwho cast ballots.

SECTION 4. Section 24.10.1620 of the Santa Cruz Municipal Code is hereby amended to read as follows:

1. Any manufacturing use involving the primary production of products from new materials found to be incompatible with the neighborhood or the city as a whole based on noise, odor, air quality or other adverse environmental impact shall be prohibited.

2. No use which either produces or utilizes asbestos in any manufacturing process shall be permitted.

3. Refinery of petroleum products or other industrial activities in support of off-shore drilling or deep-sea mining, as defined in Section 24.06.093, shall not be permitted.

4. Repeal or amendment of subsection 3 shall be subject to the requirements of other applicable portions of the Santa Cruz Municipal Code, including but not limited to Sections

24.06.090 and 24.06.093.

SECTION 5. Intention and Interpretation of Ordinance

33.43 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 10 1. Sections 2 and 3 of this Ordinance are intended and shall be interpreted to be additive to and complement Santa Cruz Municipal Code section 24.06.090, which was enacted by a vote of the people on November 5, 1985 via Ordinance 85-70.

2. Nothing in this Ordinance shall apply to prohibit any person or entity from exercising a vested right, obtained pursuant to State or local law, as of the effective date of this Ordinance.

3. The provisions of this Ordinance shall not be applicable to the extent they violate the constitution or laws of the United States or the State of California.

4. If any section, sentence, clause, phrase, or part of this Ordinance is held unconstitutional or invalid, the remainder of this Ordinance shall be given full effect consistent with the intent and purpose of the Ordinance.

SECTION 6. The City Council finds and determines that the adoption of this ordinance is considered a “project” under California Code of Regulations, Title 14, section 15378(a)(1) of the California Environmental Quality Act (CEQA) Guidelines, typically subject to environmental review. The City Council finds that the project is categorically exempt from CEQA review, pursuant to: Class 7 Exemption (14 CCR § 15307) – Actions by Regulatory Agencies for Protection of Natural Resources, as the proposed ordinance intends to ensure the maintenance of a natural resource; Class 8 Exemption (14 CCR § 15308) – Actions by Regulatory Agencies for Protection of the Environment, as the proposed ordinance intends to ensure the protection of the environment; and the Common Sense Exemption (14 CCR § 15061(b)(3)) as it can be seen with certainty that prohibiting on-shore facilities related to off-shore oil and gas drilling and deep-sea mining and exploration will maintain the status quo, and there is no possibility of a significant negative effect on the environment.

SECTION 7. This Ordinance shall take effect and be in full force thirty (30) days after final adoption.

PASSED FOR PUBLICATION this 9th day of June, 2026, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator

33.44 Highlighted text = changes made since May 7, 2026, Planning Commission meeting 11 PASSED FOR FINAL ADOPTION this 23rd day of June, 2026, by the following vote:

AYES:

NOES:

ABSENT:

DISQUALIFIED:

APPROVED: ______________________________
Fred Keeley, Mayor
ATTEST: _________________________________
Bonnie Bush, City Clerk Administrator
This is to certify that the above and
foregoing document is the original
of Ordinance No. 202x-xx and that
it has been published or posted in
accordance with the Charter of the
City of Santa Cruz.
________________________________
Bonnie Bush, City Clerk Administrator

33.45 Planning Commission

AGENDA REPORT
DATE: May 1, 2026
AGENDA OF: May 7, 2026
ITEM NO: FP26-0004: Proposal to Amend Municipal Code Title 24, Zoning, Related to Protections Against On-Shore Facilities Supporting Off-Shore Oil & Gas Drilling and Deep-Sea Mining and Exploration, and Corresponding Changes to the City’s Local Coastal Program Implementation Plan (CM/CD)
LOCATION: Citywide
RECOMMENDATION: Motion to:
1) Acknowledge that the required Planning Commission findings for recommending approval of Zoning Ordinance and Local Coastal Program amendments can be made, as detailed in the staff report, and;
2) Recommend that the City Council approve the proposed amendments to the City of Santa Cruz Municipal Code (SCMC) Title 24 – Zoning, including: adding Section 24.06.093 and amending Sections 24.06.090, 24.10.1525 and 24.10.1620, including recommending approval of the corresponding changes to the City’s Local Coastal Program Implementation Plan; and
3) Acknowledge the determination that the proposed amendments are categorically exempt from the California Environmental Quality Act (CEQA) review, pursuant to: Class 7 Exemption (14 CCR § 15307); Class 8 Exemption (14 CCR § 15308); and the Common Sense Exemption (14 CCR § 15061(b)(3)).

BACKGROUND: The City of Santa Cruz (City) is a global leader in environmental protection and sustainability initiatives. For decades, the City has led regional initiatives to prevent extractive, polluting activities off California’s Central Coast that pose significant risk to coastal communities like Santa Cruz.

In the wake of the 1969 Santa Barbara oil spill, local jurisdictions and activists united to prevent oil and gas drilling along our coast. These efforts helped create the Local Government Outer Continental Shelf (OCS) Coordination Program in 1980, which succeeded in creating a “Blue Wall” in opposition to the U.S. Department of the Interior’s proposed lease sale of 15 areas in the OCS for oil and gas drilling. Subsequently, the Monterey Bay National Marine Sanctuary was established in 1992 to protect and preserve the rich marine ecosystem along the Central Coast.

33.46 In January 1985, the City Council took initial steps towards outlining allowable coastal activities by defining the terms “off-shore” and “on-shore” in municipal code sections 24.22.578 and

24.22.582, respectively in Ordinance 85-05. The term “off-shore,” for purposes in the municipal code, refers to land below “mean higher high water” as defined by the United States Coast and Geodetic Survey (USCGS). “On-shore” refers to land above “mean higher high water” as defined by the USCGS. Five months later, in July of 1985, Council adopted Ordinance 85-47 amending SCMC Section 24.10.1525 Prohibited Uses to include prohibitions on petroleum refinery or other industrial activities that support off-shore oil drilling. Later that same year, on November 5, 1985, the residents of Santa Cruz voted to adopt Ordinance 85-70 to officially affirm the City’s opposition to oil or gas drilling off the coast of Central or Northern California, enumerate the adverse environmental and economic impacts of off-shore drilling and associated on-shore facilities, and enable the City Council to take strong and effective action to oppose such oil and gas drilling.

On March 11, 1986, Council acted on the aforementioned commitment by adopting Ordinance 86-09 to add Section 24.06.090 Support Facilities for Off-Shore Oil and Gas Drilling – Submission to Electorate (24.06) to the municipal code. This change ensured that no zoning changes would be made to allow on-shore support facilities for off-shore oil and gas drilling without a vote by the people of the City of Santa Cruz.

Other related ordinances include Ordinance 2007-13, which added the same Prohibited Uses found in Section 24.10.1525 of Chapter 14 Part 16: I-G: General Industrial District to Section

24.10.1620 regarding Prohibited Uses in the General Industrial District/Performance District.

Forty years after the City first codified its opposition to off-shore oil and gas drilling, the same threat that sparked Santa Cruz’s 1985 ordinance against oil and gas drilling has returned. In early 2025, the U.S. Department of Interior’s Five-Year OCS Oil and Gas Leasing Program, administered by the Bureau of Ocean Energy Management (BOEM), indicated their intent to offer new areas of the California Coast as proposed lease sites for oil and gas drilling, including areas within the boundaries of National Marine Sanctuaries.

In response to these actions, on September 30, 2025, the City Council committed to supporting local efforts to oppose off-shore drilling in our region. This included reinvigorating the Local Government OCS Coordination Program and contracting with Save Our Shores to help lead policy efforts to strengthen local protections against the federal OCS leasing proposal and other changes that threaten the environmental and economic resiliency of coastal Santa Cruz.

Since then, the Federal government has blitzed through standard regulatory practices to enable new and existing oil and gas production. The proposed Five-Year Oil and Gas Leasing Program has rapidly progressed through procedural rounds without regard for comments submitted in response to the proposal. Along the way, additional rules have been proposed to weaken the environmental review process and strip away insurance requirements for oil and gas lessees.

In addition to the threat of new oil and gas drilling off the coast of Central California, recent posturing by BOEM signals their intent to pursue opportunities for commercial deep-sea mining (DSM). On February 24, 2026, BOEM proposed Administrative Revisions to Regulations

33.47 Related to Outer Continental Shelf Minerals Other Than Oil, Gas, and Sulphur. Deep-sea mining poses environmental, economic, and public health risks, the extent of which is yet unknown. The existing prohibitions on petroleum refinement refer only to support facilities for off-shore oil drilling. The City does not currently have any explicit prohibition on activities related to DSM.

Without a prohibition, facilities that support DSM and associated activities could be permitted in the City’s General Industrial District and General Industrial District/Performance District. The proposed prohibitions would decrease the likelihood that DSM is conducted off-shore of the Santa Cruz coastline and limit local exposure to hazards associated with the transportation, processing, and refinement of materials from DSM.

Various actions at the Federal level have undermined existing laws and regulations which, under normal circumstances, protect against rapid, unilateral off-shore activities. On January 20, 2025, Executive Order 14154 Unleashing American Energy specifically called for energy development on the OCS and the production and processing of rare-earth minerals. It also revokes Executive Order 11991 Relating to Protection and Enhancement of Environmental Quality, enacted May 24, 1977. This action revokes the Council on Environmental Quality’s authority to adopt regulations implementing the National Environmental Policy Act and instead directs agencies to, “prioritize efficiency and certainty over any other objectives, including those of activist groups” in the regulatory and permitting process. Additional Federal actions, including Executive Order 14260 Protecting American Energy From State Overreach signed on April 8, 2025 and the Administration’s invocation of the 1950 Defense Production Act indicate an intention to preempt state and local laws to pursue oil and gas drilling and mineral extraction that would not typically be allowed off the coast of California. These actions add further cause for urgency in protecting local interests. The proposed ordinance addresses these developments by leveraging local landuse authority to directly oppose unwanted activities in the waters off-shore of Santa Cruz.

DISCUSSION: The proposed amendments are grounded in modern scientific justification, measurable public health impacts, and climate risks related to oil and gas drilling and DSM.

Each of these is an essential factor in local policymaking. While the threats this ordinance would address represent a regression to 1980s-era environmental and energy policy, the City’s response to them should reflect a modern understanding of ocean ecology, fossil fuel extraction, and greenhouse gas emissions, as well as decades of advancement in public health policy. For decades, institutions like the University of California, Santa Cruz; Moss Landing Marine Labs; Monterey Bay Aquarium Research Institute; and the Monterey Bay Aquarium have drawn globally recognized researchers to the area who have deepened the understanding of how coastal cities like Santa Cruz are impacted by events in coastal waters. Research conducted throughout the Monterey Bay National Marine Sanctuary and surrounding areas has established the importance of natural features like sandy beaches, coastal bluffs and marine terraces, kelp forests, estuaries, and coastal dunes and lagoons - all of which are found along the City’s coastline in maintaining a healthy, safe environment. In light of these findings and global developments in coastal policy, the California Coastal Commission lauds nature-based solutions to coastal resilience as offering myriad co-benefits, including improved water quality, increased species diversity, and improved public access.

In contrast, global activities in the fossil fuel sector have continuously demonstrated that offshore drilling is not compatible with healthy ecosystems or the safe recreational use of the coastline and adjacent waters. Even excluding oil spill incidents, the dangers of which were well33.48 known by the 1980s, off-shore drilling and mining activities require large industrial operations on nearby coastal land. These operations often prohibit public use of the coast or impede public access to otherwise accessible coastal areas, deposit hazardous waste materials into surrounding areas, or otherwise disrupt and damage sensitive coastal habitats.

Definitions
To ensure clarity throughout the amended areas of the municipal code, the ordinance proposes adding definitions of relevant terms to Section 24.06.093. The proposed addition defines the term “on-shore support facility” to mean facilities within the City of Santa Cruz’s jurisdiction that support off-shore fossil fuel development or deep-sea mining, and it provides examples of facilities that would be included in this category, as well as examples of exempted facilities. This definition does not impact the existing definitions of “off-shore” and “on-shore” incorporated into the municipal code in 1985 but rather builds on them to define facilities relative to the areas these terms refer to. Additional definitions would include “deep-sea mining,” and “deep-sea minerals.” These definitions will be used henceforth in this Agenda Report.

Prohibition of Support Facilities for Deep-Sea Mining
The ordinance would update the City’s municipal code to prohibit support facilities for DSM operations in the City’s industrial zones. This action would help modernize the municipal code; recent advancements in DSM technology and greater demand for rare-earth minerals increase its commercial viability compared to the 1980s. As noted above, DSM presents similar environmental, economic, and public health threats to the Santa Cruz community as oil and gas drilling. By adding protections against DSM, these changes would help align the municipal code with the intent of Ordinance 85-70. Specifically, the ordinance would add language to the Prohibited Uses Section 24.10.1525 I-G General Industrial District and Section 24.10.1620 IG/PER-2 General Industrial District/Performance District to include prohibitions on industrial activities in support of DSM.

Mandatory Voter Approval for Accommodating Oil & Gas Drilling and Deep-Sea Mining The proposed ordinance would ensure that the voters of Santa Cruz have a say in any future legislative changes that could support off-shore oil and gas drilling or DSM. The ordinance would update the municipal code to explicitly state that voter approval will be required to make any zoning changes that could accommodate on-shore support facilities. It would also update the municipal code to require that any legislative approval (including, but not limited to, a zoning amendment, General Plan amendment, Local Coastal Program amendment, Development Plan, Specific Plan, or other legislative action) for on-shore support facilities, even those that comply with existing City zoning laws, will require voter approval.

To codify these changes, the ordinance would update SCMC Section 24.06.090 Support Facilities for Off-Shore Oil and Gas Drilling — Submission to the Electorate, which currently requires voter approval for any zoning change to accommodate on-shore support facilities for off-shore oil and gas drilling, to also require voter approval for any zoning change that would accommodate on-shore support facilities for DSM. Staff further propose adding SCMC Section

24.06.093 to explicitly require a vote of the people to allow any legislative approval, including those that comply with existing City zoning laws, that would authorize or allow any on-shore support facility for oil and gas or DSM within the City of Santa Cruz.

33.49 Alignment with the City’s General Plan
The City of Santa Cruz adopted the General Plan 2030 in 2012 to guide the City’s future physical, social, economic, cultural, and environmental character. The amendments proposed by this ordinance support many components of the City’s General Plan 2030, including but not limited to the following goals and policies:
- Natural Resources and Conservation Element Policy 6.2: Support protection of the Monterey Bay National Marine Sanctuary and its environs. - Land Use Element Policy 2.3.1: Protect, maintain, and enhance publicly accessible coastal and open space areas.
- Parks, Recreation and Open Space Policy 3.3.1: Protect coastal bluffs and beaches from intrusion by non-recreational structures and incompatible uses. - Parks, Recreation and Open Space Policy 3.3.4: Maximize public access and enjoyment of recreation areas along the coastline.
- Natural Resources and Conservation Element Policy 2.2: Protect sensitive habitat areas and important vegetation communities and wildlife habitat, to include riparian, wetland (salt marsh and freshwater wetland), coastal prairie, coastal bird habitat, and habitat that support special status species, as well as, sensitive and edge habitats (“ecotones”). - Natural Resources and Conservation Element Policy 2.2.2: Protect coastal roosts and rookeries in the course of activities that could disturb or disrupt breeding or result in loss of habitat, such as construction activities, recreational activities, or special events.

The Climate Action Plan 2030 (CAP 2030) identifies the City’s carbon emission levels, identifies short and long-term emissions reduction targets and provides a roadmap for achieving those targets by 2030 and beyond. CAP 2030 is incorporated by reference into the General Plan 2030. The proposed amendments support the many of the measures and actions identified in the CAP 2030, including:
- Building Energy Measure BE-2: Electrify 31 percent of existing residential buildings by 2030 and 53% by 2035.
- Building Energy Measure BE-3: Electrify 26 percent of existing commercial buildings by 2030 and 45 percent by 2035.
- Building Energy Measure BE-5: Increase resiliency through equitable energy efficiency and local solar programs.
- Climate Restoration Measure CR-2: Explore new carbon sequestration and carbon capture opportunities.
- Municipal Government Measure M-2: Procure carbon free or 100 percent renewable electricity for municipal operations by 2030.
- Municipal Government Measure M-9: Support climate action planning.

The proposed ordinance aligns with the goals related to building electrification and renewable resources by backing the City’s commitment to move away from fossil fuel usage and towards carbon neutrality. The General Plan 2030 Natural Resources and Conservation 4.3.3 calls for adopting City renewable energy objectives as defined within the Climate Action Plan. New oil and gas drilling perpetuates a reliance on carbon-producing fossil fuels. The proposed ordinance supports measure CR-2 by preventing the unnecessary release of carbon currently store in the deep-sea. Disturbances to the seabed associated with DSM could potentially release huge amounts of carbon back into the atmosphere. Opposition to DSM supports the CAP 2030’s stated goal of limiting and mitigating such events.

33.50 Alignment with City’s Local Coastal Program
The City’s Local Coastal Program (LCP) is the tool used by the City and the California Coastal Commission to implement the Coastal Act and regulate development activities within the Coastal Zone. All amendments to the LCP are reviewed by the Coastal Commission, and City staff are working closely with their Central Coast District Office to consider the impacts and implications of proposed changes. The proposed ordinance includes two LCP Implementation Plan amendments. First, the proposed Section 24.06.093 of Chapter 24.06 – Zoning Map and Text Amendments would be added to the City’s LCP to create the voting requirements similar to those outlined in SCMC Section 24.06.090, which would also be amended to include reference to on-shore facilities for DSM. Second, Chapter 24.10 Land Use Districts, Part 16: I-G General Industrial District Section 24.10.1525 Prohibited Uses would be amended to include the prohibition of on-shore support facilities for DSM in the zoning district.

As further articulated in the “whereas” clauses in the ordinance, the proposed ordinance is consistent with the following programs and policies in the LCP:
- Environmental Quality Element Policy 4.1: Protect the natural ecosystem of the Monterey Bay Marine Sanctuary and the shoreline.
- Community Design Element Program 2.1.3: Protect the Monterey Bay National Marine Sanctuary and the shoreline and views to and along the ocean, recognizing their value as natural and recreational resources.
- Land Use Element Policy 3.7: Recognize and protect the Pacific Ocean and Monterey Bay as a valuable open space, natural resource, and National Marine Sanctuary. - Economic Development Element Program 1.6.6: Protect the Monterey Bay National Marine Sanctuary, recognizing that it is integral to the economic health of the County's tourism, recreation, fishing and aquaculture industries.

The proposed ordinance also supports the City’s LCP by bolstering the protections and expanding the foundation provided by Ordinance 85-70, which is part of the City’s LCP.

Additionally, Program 3.7.1 of the LCP’s Land Use Element Section D. Open Space Lands states:

Work with the County and other groups to take all actions possible to oppose exploration for and development of offshore oil off the California coast, oil tanker traffic along the coast of Monterey Bay, and on-shore support facilities, and to establish a permanent ocean sanctuary for all portions of the California coast in which drilling is not already proceeding.

Immediately following federal proposals to open the waters off California’s Central Coast for oil and gas drilling, the City joined with the County of Santa Cruz in a coordinated effort, led by Save Our Shores, to oppose these developments. The proposed Ordinance is a direct result of this effort and represents one action the City is taking to protect its coastline, as provided for in the LCP.

Next Steps
Following a recommendation by the Planning Commission, the proposed ordinance will proceed to City Council for a first reading on June 9, 2026. Should City Council approve the proposed ordinance, it would then proceed to a second reading before City Council on June 23, 2026.

33.51 Should the amendments be approved by the City Council, those changes that constitute amendments to the Local Coastal Program Implementation Plan (LCP IP) will be submitted to the California Coastal Commission. The final language of the ordinance is subject to modification in accordance with the Coastal Commission’s review. Portions of the package that are not amendments to the LCP IP would take effect thirty days after final action by the City Council. Portions that are subject to Coastal Commission jurisdiction would take effect immediately upon final action by that body. Staff anticipate submitting the proposed amendments to the Coastal Commission in June 2026.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) DETERMINATION: The proposed amendments are categorically exempt from CEQA review pursuant to: Class 7 Exemption (14 CCR § 15307) – Actions by Regulatory Agencies for Protection of Natural Resources, as the proposed ordinance aims to assure the maintenance of a natural resource; Class 8 Exemption (14 CCR § 15308) – Actions by Regulatory Agencies for Protection of the Environment, as the proposed ordinance aims to assure the protection of the environment; and the Common Sense Exemption (14 CCR § 15061(b)(3)) as it can be seen with certainty that prohibiting on-shore facilities related to off-shore oil and gas drilling and deep-sea mining will maintain the status quo, and there is no possibility of a significant negative effect on the environment.

HEALTH IN ALL POLICIES (HiAP): The proposed amendments support the sustainability pillar of HiAP by affirming the City’s commitment to Green House Gas emissions mitigation.

The goal of the amendment is to prevent extractive activities along California’s Central Coast that pose significant environmental hazards to the surrounding ecosystems while also perpetuating a reliance on fossil fuels and non-renewable resources. The proposed action also supports the public health pillar of HiAP. Allowing the development of on-shore facilities that support oil and gas drilling and DSM within the City could expose residents to harmful impacts of the mineral extraction processes, threaten the health of the Monterey Bay National Marine Sanctuary, and pose risks to coastal recreation opportunities along the City’s coastline.

FINDINGS: Zoning Ordinance Section 24.06.040 requires that prior to making a recommendation for approval of General Plan or Zoning Ordinance amendments to the City Council, the Planning Commission shall make findings that the public necessity, and the general community welfare, and good zoning practice shall be served and furthered; and that the proposed amendment is in general conformance with the principles, policies, and land use designations set forth in the General Plan, Local Coastal Program, and any adopted area or specific plan.

The proposed ordinance fulfills each finding described in Section 24.06.040. It serves and furthers public necessity and general community welfare by protecting local coastal resources against harmful resource extraction and guards Santa Cruz’s residents and natural features against dangerous environmental and public health hazards. It serves and furthers good zoning practice by codifying desires of City residents and advancing local interests in a manner compliant with California State laws and regulations, while preserving maximal power for the City’s voters to make future decisions regarding zoning changes that could accommodate oil, gas, and DSM infrastructure within the City.

33.52 Similar findings are also required in the Local Coastal Program for any amendments to the LCP.

These findings include: (1) the proposed amendment is deemed to be in the public interest; (2) the proposed General Plan and/or Local Coastal Program amendment is consistent and compatible with the rest of the General Plan and LCP and any implementation programs that may be affected; (3) the potential impacts of the proposed amendment have been assessed and have been determined not to be detrimental to the public health, safety, or welfare; and (4) the proposed amendment has been processed in accordance with the applicable provisions of the California Government Code and the California Environmental Quality Act (CEQA).

The proposed ordinance fulfills each additional finding required of an amendment to the LCP.

First, each amendment in the proposed ordinance is in the public interest. The amendments protect local natural and economic resources and ensure that future decision-making power regarding zoning changes that accommodate on-shore support facilities rests with the City’s voters. Second, the amendments to the LCP are consistent and compatible with the rest of the General Plan and LCP, as described above in this report. Third, the potential impacts of each proposed amendment have been assessed and been determined to promote and advance public health, safety, and welfare. As described in the “whereas” clauses of the proposed ordinance, the general welfare of the City of Santa Cruz is both directly and indirectly tied to the health and resiliency of the Pacific Ocean and its coastline. The proposed amendments would result in greater protections against activities that are known to be harmful to the Pacific Ocean and its coastline. And finally, the proposed amendments have been processed in accordance with the applicable provisions of CEQA, as demonstrated by the various exemptions listed above.

Submitted By:

William Kelley
Management Analyst
Akana Jayewardene
Senior Planner
Approved By:

Tiffany Wise-West
Sustainability and Resiliency Officer
Clara Stanger
Acting Principal Planner
Lee Butler
Director of Community Development
ATTACHMENTS:

1. ORDINANCE (LCP IP) – TRACK CHANGES.DOCX

2. ORDINANCE (NON-LCP) – TRACK CHANGES.DOCX

33.53 1
Supporting Documents
Table of Contents
Refugio Oil Spill: Public Guide to Natural Resource Damage Assessment Process................. 2 Health Effects Notebook for Hazardous Air Pollutants .............................................................. 28 Benzene..................................................................................................................................... 29 Toluene...................................................................................................................................... 35 Ethylbenzene............................................................................................................................. 40 Xylene........................................................................................................................................ 44 Particulate Matter (PM) Basics..................................................................................................... 49 Hydrogen Sulfide .......................................................................................................................... 51 Basic Information about Carbon Monoxide (CO) Outdoor Air Pollution .................................. 55 Basic Information about NO2...................................................................................................... 54 Sulfur Dioxide Basics....................................................................................................................56 References..................................................................................................................................... 58

33.54 2

REFUGIO OIL SPILL

PUBLIC GUIDE TO NATURAL RESOURCE DAMAGE ASSESSMENT PROCESS

33.55 3
Co-Author
Linda Krop
Chief Counsel
Environmental Defense Center
Co-Author
Matt Haden
Intern, Environmental Defense Center
University of California Santa Barbara
The Environmental Defense Center (“EDC”) is a public interest law firm that was founded in the aftermath of the 1969 Santa Barbara Oil Spill to protect and enhance the environment through education, advocacy and legal action. As the only non-profit public interest environmental law firm between Los Angeles and San Francisco, EDC has represented more than 115 clients since 1977. EDC’s current focus areas include protection of the Santa Barbara Channel, ensuring clean water, preserving open space and wildlife, and addressing climate and energy.

EDC has a long history of responding to oil and gas development threats along the California coast. In 1994, EDC helped craft and pass the California Coastal Sanctuary Act, which bans oil leasing in State waters. In 2001, EDC lead the legal fight to provide the State of California with a voice in the matter of federal oil leasing, which resulted in the termination of 40 undeveloped federal leases. EDC has represented several groups in successfully defeating oil and gas projects offshore Santa Barbara County, including ARCO’s Ellwood project, Mobil’s Clearview project, Torch’s Tranquillon Ridge project, Venoco’s Paredon project, and two proposed Liquefied Natural Gas projects. In addition, EDC helped stop the expansion of the Petrochem refinery in Ojai and secured the end to tankering of oil produced offshore California.

EDC’s expertise in oil issues was brought to bear on May 19, 2015, when an onshore pipeline carrying oil produced from offshore platforms in the Santa Barbara Channel ruptured, spilling more than 140,000 gallons of crude oil onto nearby beaches and into the Pacific Ocean. EDC responded immediately and has been working continuously since then to ensure full clean-up and restoration of the affected environment.

Thus far we have successfully reinstated the protections of the California Coastal Act, secured the passage of new laws improving regulations governing intrastate pipelines, submitted recommendations for improving federal regulations and recommissioning of the ruptured Plains All American Pipeline, and mobilized and educated the public aboutthe impacts ofthe spill and opportunities for engagement.

The Natural Resource Damage Assessment process is critical to achieving our long-term goal of requiring full restoration of harm caused to wildlife, habitats, and recreation by the Plains All American Pipeline Refugio oil spill. This guide was prepared to enable affected communities to engage in this important final phase ofthe oil spill response process.
906 Garden Street
© 2015 Environmental Defense Center
www.EnvironmentalDefenseCenter.org
805.963.1622
111 W. Topa Topa Street
Santa Barbara, CA 93101 Ojai, CA 93023
Cover photos left to right: Erin Feinblatt, Linda Krop, Linda Krop, Bruce Reitherman, Gail Osherenko, Gail Osherenko

33.56 4
his Guide is intended to help the public understand and participate in the federal Natural Resource Damage Assessment (“NRDA”) process that will be applied to the Refugio Oil Spill which took place in Santa Barbara County on May 19, 2015. On that date, more than 140,000 gallons of crude oil spilled from the Plains All American Pipeline, quickly damaging the sensitive environment of the coastline and the Santa Barbara Channel. The oil travelled a quarter mile to the ocean, and then spread approximately 150 miles along the California coast, reaching as far south as Crystal Cove State Park in Newport Beach. The spill caused the closure of two popular State Parks, many miles of public beaches, and over 130 square miles of fishing grounds. More than 300 marine mammals and birds were killed, and many more were injured. We will never know the full impact of the spill because most of the oil will never be recovered; nor will many dead and injured animals be found.

The oil spill occurred in one of the most environmentally important regions on the planet, in an area often referred to as the “Galapagos of North America.” The Santa Barbara Channel area is located in the transition zone between warm southern Pacific waters and cool northern waters, resulting in unparalleled biodiversity. Because of the importance of this region, the federal government established the Channel Islands National Marine Sanctuary and National Park in 1980, and the state and federal governments subsequently approved a network of marine protected areas around the Islands and along the mainland coast.This environmentally sensitive region was substantially harmed as a result ofthe Refugio Oil Spill.

Map showing oiled finger printing results after the Refugio Oil Spill. Map courtesy of NOAA-ERMA Unfortunately, the response to the spill was deferred because Plains apparently delayed in reporting the problem to the proper authorities. Even after the report was made, full deployment of cleanup and response personnel, vessels and equipment were delayed until the second day, resulting in a substantial amount of oil spilling from the pipeline and making it to the ocean. The tides swept much of the oil out to sea during the first 24 hours.

As of December 2015, cleanup activities continue for the areas around the immediate site of the spill, and surveys and sampling will continue for portions of the affected coastline throughout the winter and spring.

T

33.57 THE NRDA PROCESS IS COMPRISED OF THREE MAIN PHASES:

1. Preassessment Phase

2. Restoration Planning Phase

3. Restoration Implementation Phase8
The final phase of oil spill response will focus on an
assessment of the total environmental damage caused
by the spill, and development of a plan to mitigate,
compensate and provide for restoration of the damaged
natural resources. As with the other phases of oil spill response, this phase is governed by the Oil Pollution Act of 1990 (“OPA”), and is referred to as the NRDA process.

This Guide provides background information regarding
the NRDA process and explains its application to the
Refugio Oil Spill. The Guide also identifies opportunities for public input and participation. Examples of other
NRDA processes in California are discussed in Appendix
E.

NRDA PROCESS AND THE REFUGIO OIL SPILL
The goal of the NRDA process is to make the community and affected public whole by providing restoration and compensation for injuries to wildlife, habitat, and other natural resources1 caused by an oil spill, also called an incident.2 This is achieved by returning the natural resources and the services they provide back to their baseline conditions.3 The baseline conditions are the levels of services the resources would be providing had the discharge of oil not occurred.4
Under OPA, the National Oceanic and Atmospheric Administration (“NOAA”) is responsible for conducting the NRDA process after there has been an offshore oil spill.6 Damages are assessed against the Responsible Party (“RP”), in this case, Plains Pipeline LP. The RP is liable for removal costs and damages, including damages for injury to natural resources, real or personal property, subsistence use, revenues, profits and earning capacity, and public services.7
PHASE 1: PREASSESSMENT
The Preassessment Phase begins as soon as the trustees are notified of an incident by response agencies or other persons. The Refugio NRDA process began within hours of the incident9 and will be continually used to mitigate negative effects of the spill.

The responsibilities of the trustees are to “assess natural resource damages” and “develop and implement a plan for the restoration, rehabilitation, replacement, or acquisition of the equivalent, of the natural resources under their trusteeship.”10 The trustees involved in this NRDA process are: NOAA; Department of the Interior, acting through the Fish and Wildlife Service; National Park Service; Bureau of Land Management; California Department of Fish and Wildlife-Office of Spill Prevention and Response; California Department of Parks and Recreation; California State Lands Commission; and University of California.11 Although Indian Tribes can be appointed as trustees, no Tribes have been appointed as trustees to the Refugio NRDA process as of the date of this Guide.
5 To ensure adequate compensation,
restoration and recovery, damages are
assessed for the following:
• The cost of restoring, rehabilitating,
replacing, or acquiring the equivalent of,
the damaged natural resources;
• The diminution in value of those natural
resources pending restoration plans;
and
• The reasonable cost of assessing those
damages.5

33.58 The goal of the Preassessment Phase is for the trustees to determine whether they have jurisdiction under OPA to pursue restoration. Once they determine they have jurisdiction, they must then decide whether it is appropriate to pursue the restoration.

State elected officials received a tour of Refugio Beach by the Unified Command on May 23, 2015. Photos by EDC
6 To determine whether they have
jurisdiction, the trustees must find
that (1) a discharge of oil has already
occurred, or there is a substantial
threat of a discharge of oil into or
upon navigable waters or adjoining
shorelines;12 (2) the discharge was not
permitted;13 and (3) natural resources
or the services they provide have
been injured. “Injury” for purposes
of the NRDA means “an observable
or measurable adverse change in a
natural resource or impairment of a
natural resource service.”14 The injury
may result directly or indirectly from
the incident.15
Once the trustees determine they
have the jurisdiction under OPA to
continue, the next step is for them to
decide whether restoration actions
should be pursued.16 Again, three
conditions must be met for this to
be determined: (1) injuries have
resulted, or are likely to result, from
the incident; (2) response actions
have not adequately addressed,
or are not expected to adequately
address, the injuries resulting from
the incident; and (3) feasible primary
and/or compensatory restoration
actions exist to address the potential
injuries.17
If all of these conditions are met,
then the trustees may go forward
The Refugio NRDA process is in the data gathering phase. Teams called Technical Working Groups (TWG)23 have been assembled to quantify injuries to the following resources:
• Birds (including pelicans and western snowy plovers)
• Marine mammals (including sea lions and dolphins)
• Fish (including grunion and surfperch)
• Crustaceans and Invertebrates
• Sandy Beach Habitat
• Rocky Intertidal Habitat
• Subtidal Habitat • Recreation (including beaches, parks and campgrounds)24

33.59 with the NRDA process by preparing and publishing a Notice of Intent to Conduct Restoration Planning.18 [All Notices referenced in this Guide are published in the Federal Register, which is accessible to the public at https://www.federalregister.gov/. As noted below, the public can also sign up for notices through the Refugio Oil Spill Response website.] This Notice must be made publicly available; however, it is up to the discretion of the trustees to determine the means by which it is made publicly available and whether public comments will be allowed.19 In general, the Notice will include: the facts of the incident; the basis for the trustees’ authority to proceed with the assessment; a description of the natural resources and services that are, or are likely to be, injured as a result of the incident; and potential restoration activities.20 If the information is available at the time, the Notice may also include the proposed strategy to assess the injury as well as the type and scale of restoration that the trustees agreed upon.21 Once the Notice has been created, the trustee will also provide a copy to the RP and ask for the RP’s participation in the process of restoration planning.22
In addition to the evidence collected during
the response to the spill, several field studies
are being conducted to assess injuries to
coastal habitats, including Sandy Beach Habitat
(focusing on sand crabs, bloodworms, beach
hoppers and kelp wrack); Rocky Intertidal
Habitat (focusing on mussels, feather-boa kelp,
barnacles, and limpets); and Subtidal Habitat
(focusing on lobsters, abalone, surfgrass, and
eelgrass).27
The trustees will also assess impacts to
recreational uses. These uses include camping,
non-commercial fishing and other beach-related
activities.28
Finally, the teams will continue to monitor for the
presence of oil, especially during the winter and
spring when storms may bring oil back onshore
and in tidal areas. Specifically, the teams will
survey for buried oil, conduct periodic sampling
throughout the Santa Barbara response area
until at least May 2016, search for and sample oil
after the first significant storm event, determine
additional cleanup needs if oil is detected that
is a match to the Refugio Oil Spill, and monitor progress in areas where scientists determine that further cleanup would do greater harm to the environment versus natural recovery processes.29 Information collected during these activities will be considered as part ofthe Preassessment Phase.

Appendix B (attached hereto) contains a flowchart illustrating the Preassessment Phase decision-making framework. Once the Preassessment Phase is completed, the trustees will proceed to the Restoration Planning Phase.

PHASE 2: RESTORATION PLANNING
The goal of this phase is to evaluate the potential injuries to natural resources and their services and to determine the need for and scale of restoration planning or actions.

The restoration actions allowed under OPA can either be primary or compensatory.30 Primary restoration is action that is taken in order to return injured natural resources to their baseline levels.31 Compensatory 7 According to the November 2015 Refugio Oil Spill
(including dolphins, sea lions and one elephant
seal).25 Many more injured birds and marine
mammals were also collected.26

33.60 restoration is action taken to compensate for the interim losses of natural resources and their services.32 Primary restoration actions range from simple things, such as closing off an area to humans, to much more intensive actions that would return the natural resources and services back to baseline much quicker.33 In addition to the primary restoration actions, the trustees must also consider a natural recovery alternative.34 Under this alternative the trustees take no action and they allow the environment to recover to baseline on its own.

When the trustees are trying to identify primary restoration actions, they should consider whether:
• Activities exist that would prevent or limit the effectiveness of restoration actions (e.g., residual sources of contamination);
• Any primary restoration actions are necessary to return the physical, chemical, and biological conditions necessary to allow recovery or restoration of the injured natural resources (e.g., replacement of sand or vegetation, or modifying hydrologic conditions); and • Restoration actions focusing on certain natural resources and services would be an effective approach to achieving baseline conditions (e.g., replacing essential species, habitats, or public services that would facilitate the replacement of other, dependent, natural resource and service components).35
Compensatory restoration is also important to address the loss of natural resources and the services they provide. Whenever possible, trustees should favor alternatives that provide services of the same type and quality in order to most closely replace the service damaged by the incident.36 Santa Barbara County coastline on May 20, 2015 after the Refugio Oil Spill. Photo courtesy of South Coast Habitat Restoration 8 33.61
The Restoration Planning Phase is broken up into two components:

1. Injury Assessment

2. Restoration Selection.

INJURY ASSESSMENT
Injury Assessment is important because it determines
the nature, degree, and extent of any injuries to natural resources and their services due to an incident.37
Trustees use this information as a basis to evaluate the need for, type of, and scale of their restoration efforts.

At this point, the trustees must determine whether
there is an injury and either (1) exposure, a pathway,
and an adverse change to a natural resource or service
as a result of a discharge; or (2) an injury to a natural resource or impairment of a natural resource service as a result of response actions or a substantial threat of a discharge.38
The trustees must determine whether an injury has
occurred as well as the type or nature of the injury.

Photo courtesy of South Coast Habitat Restoration
Examples of injuries include: “changes in survival, growth, and reproduction; health, physiology and biological condition; behavior; community composition; ecological processes and functions; physical and chemical habitat quality or structure; and public services.”39 In assessing injury, the trustees must be able to quantify the degree and extent of the injury relative to the baseline.40 The trustee must also consider the potential for natural recovery.41
More than 300 marine mammals and birds were killed due to the Refugio Oil Spill.

Photo by Gail Osherekno
9 33.62
NOAA provides trustees with a framework that helps to outline the injury assessment component and determine whether an injury has occurred. The framework has five steps.42 First, the trustees must review the information on potential injuries provided in the Preassessment Phase.

The trustees review all of the information and their preliminary conclusions that were found in this phase.

Boom placed to protect the wetlands at Haskells Beach. Photo by Gail Osherenko The second step is to construct an inventory of potential injuries. During this step, the trustees organize and structure what they know about the potential injuries that resulted from the incident. In order to organize the information, the trustees should answer the following questions:
• What are the natural resources and services of concern? • What are the procedures available to evaluate and quantify injury and the associated cost and time requirements?
• What is the evidence indicating exposure?
• What is the pathway from the incident to the natural resource and/or service of concern? • What is the adverse change or impairment that constitutes injury? • What is the evidence indicating injury?
• What is the mechanism by which injury occurred?
• What is the potential degree and spatial and temporal extent of the injury? • What is the potential natural recovery period? • What are the kinds of primary and/or compensatory restoration actions that are feasible?43 Next, the trustees must evaluate injuries for the strength of evidence. The following questions are all useful in attempting to evaluate the strength of evidence:
• Can the injury be stated in terms that comply with the definition of injury in the OPA regulations? • Can the injury be reliably documented under appropriate quality assurance procedures? • Can the pathway of exposure be established through empirical observations, modeling, or a 10 33.63
combination of observations and models?
• Is it reasonable to conclude that the injury was caused by the incident in question or do other plausible explanations exist?44
The next two steps occur during the Restoration Selection Phase of the NRDA process.

RESTORATION SELECTION
After the trustees have completed the first three steps of NOAA’s five-step process, they move into the Restoration Selection component.45 The purpose of this process is to develop a Restoration Plan to restore the injured natural resources and services. It is in this stage where the trustees complete the last two steps of the five-step process.

The fourth step is to establish preliminary restoration objectives. In this step, the trustees set forth a list of restoration goals. These goals could be based on a number of factors, some of which include “knowledge of the incident gained during the preassessment phase, additional information developed as part of the injury assessment design process, and the knowledge of experts.”46 Workers cleaning up oil at Refugio Beach, May 20, 2015. Photo by EDC For the last step of the process, the trustees must evaluate the injuries for their relevance to restoration.

This means that they must evaluate the potential injuries and how easily the problem could be fixed through restoration actions. These evaluations can be further sorted into the categories of relevance to primary restoration and relevance to compensatory restoration. The following questions are helpful when determining the relevance to restoration:

1. RELEVANCE TO PRIMARY RESTORATION
• Can the injury be remedied by direct restoration of chemical, physical, or biological attributes of the environment?
• Do the trustees conclude, on a tentative basis, that active primary restoration is preferable to natural recovery?
11 33.64
• Can the injury be quantified in a way that allows the scale of primary restoration to be determined?47

2. RELEVANCE TO COMPENSATORY RESTORATION
• Can the environment or public be compensated for lost services through compensatory restoration such as habitat construction, stocking, or other activities, to replace lost services? • Can the injury be quantified in terms that allow the scale of compensatory restoration to be estimated?48
This map shows the fishery closure in response to the Refugio Oil Spill, as well as the safety zone established around the response site as of June 4, 2015. Map provided by the Unified Command Information Center According to the OPA regulations, the trustees must identify a range of reasonable restoration alternatives, and then evaluate and eventually select the preferred alternative(s).49The preferred alternative(s) are evaluated based on a number of factors, some of which include:
• Cost to carry out the alternative;
• Extent to which each alternative is expected to meet the trustees’ goals and objectives in returning the injured natural resources and services to baseline and/or compensating for interim losses;
• Likelihood of success of each alternative;
• Extent to which each alternative will prevent future injury as a result of the incident, and avoid collateral injury as a result ofimplementing the alternative; • Extent to which each alternative benefits more than one natural resource and/or service; and • Effect of each alternative on public health and safety.50

33.65 12
The Refugio trustees have identified the following criteria which will guide their consideration of restoration projects:
• Relationship to injured resources and/or services
• Likelihood of success
• Time to provide benefits
• Duration of benefits
• Multiple resource and service benefits
• Comprehensive range of projects
• Opportunities for collaboration
• Educational/Research value • Cost-effectiveness.51
Refugio Beach immediately after the May 19, 2015 oil spill. Photo by Erin Feinblatt.

After reviewing the various options, the trustees will select the preferred alternative. If the trustees conclude that two or more alternatives are equally preferable, they must select the most cost-effective alternative.52 After the preferred alternative(s) are selected, the trustees must then develop a Draft Restoration Plan.53 The Draft Plan must include:
• A summary of the injury assessment;
• Goals and objectives of restoration;
• The range of restoration alternatives and results of the evaluation; • Identification of the trustees’ preferred alternative(s); • A description of the role of the RP(s); and • Performance criteria and a proposal for monitoring and determining restoration effectiveness.54 The Draft Restoration Plan must be made available for public review and comment.55 Based on the Draft Plan and public comments, the trustees will then create the Final Restoration Plan.56 The Final Plan must include responses to the public comments and indicate any changes that were made to the Draft Plan.57 13 33.66

ENVIRONMENTAL REVIEW
The National Environmental Policy Act (“NEPA”)58 applies to the Draft Restoration Plan.59 The purpose of NEPA is to encourage harmony between humans and the environment, promote efforts to prevent environmental damage, and enrich the understanding of the ecological systems and natural resources important to the nation.60NEPA achieves these goals by requiring federal agencies to consider the environmental impact of proposed actions, alternatives that are available to avoid or minimize such impacts, and any irreversible and irretrievable commitment of resources that would result if the project is implemented.61 If it is uncertain whether the
trustees’ proposed action will
have a significant effect on
the human environment, the
NEPA process begins with an
Environmental Assessment
(“EA”).62 The EA serves to
indicate and document
whether the agency’s proposed
action (referred to as the
“preferred alternative”) is likely
to have a significant effect.

To begin the EA process,
the trustees may issue a
Notice of Intent to Prepare
a Draft Restoration Plan/EA,
or simply prepare a Draft
Restoration Plan/EA.63 Once
the Draft Restoration Plan/EA
is prepared, the trustees must
publish a Notice of Availability
of Draft Restoration Plan/
EA (“NOA”). The NOA shall
provide a minimum thirty-day
period for the public to review
and comment on the Draft
Restoration Plan/EA.64
After the trustees review
the public comments they
received, they must determine
whether it is likely that there
will be a significant effect on
the human environment from
their preferred alternative(s). If
not, a Finding Of No Significant
Impact (“FONSI”) determination
Plains All American Pipeline’s Line 901 being excavated after the Refugio Oil Spill.

Photos by Bruce Reitherman, obtained through a Public Records Act request. is made, and a Final Restoration Plan/EA will be issued.65 On the other hand, if it is determined that there will be significant effects an Environmental Impact Statement (“EIS”) is required.66 The EIS process begins with the trustees issuing a Notice of Intent to Prepare a Draft Restoration Plan/ EIS.67 After receiving comments on the scope of issues to address in the EIS, a Draft Restoration Plan/EIS will be prepared. A Notice of Availability of Draft Restoration Plan/EIS must be published in the Federal 14 33.67
Register, and must be made available to the public for review and comment for a minimum of forty-five calendar days.68 The trustees will then prepare the Final EIS, which must include all public comments and incorporate changes to the Draft EIS where necessary.69 A Notice of Availability must be published in the Federal Register for the Final Restoration Plan/EIS.70 No decisions can be made regarding the proposed action until thirty days after the Notice of Availability of the Final EIS.71 Once the Final EIS has been approved, the trustees must prepare a Record of Decision (“ROD)” to be included in the Administrative Record.72 The ROD must be made publicly available and must summarize the trustees’decision-making process.73
The process of Restoration Planning is depicted in Appendix D, attached hereto.

PHASE 3: RESTORATION IMPLEMENTATION
Once the Final Restoration Plan is developed, the trustees will then prepare a demand to the RP(s).74 The demand must direct the RP(s) to either implement the Final Restoration Plan or advance funds to cover the trustees’ costs of assessment and restoration.75 The RP(s) have ninety days to respond to the demand.76 If the RP(s) do not agree to the demand, the trustees may file a judicial action, submit a claim for damages to the federal Oil Spill Liability Trust Fund, or seek an appropriation from the Oil Spill Liability Trust Fund.77 The trustees must then either implement the Final Restoration Plan or oversee the implementation of the Plan by the RP(s).78

OPPORTUNITIES FOR PUBLIC INVOLVEMENT
The Oil Pollution Act of 1990 expresses support for public participation, including the requirement that NRDA plans “shall be developed and implemented…only after adequate public notice, opportunity for a hearing, and consideration of all public comment.”80 The OPA regulations reinforce this sentiment, by

RECEIVE ELECTRONIC NOTICES
The public can sign up to receive notifications
pertaining to the Refugio Oil Spill NRDA
process at https://www.wildlife.ca.gov/OSPR/
NRDA/Refugio. The website includes general
information, available documents, contact
information, and a link to sign up for the latest
news and updates.

ATTENDINFORMATIONALMEETING
As noted in the November 2015 newsletter,
an informational public meeting will be held :

January 20, 2016
7:00-8:30 p.m.

Santa Barbara Public Library
Faulkner Gallery
40 E. Anapamu Street
Santa Barbara, CA79
15 33.68
16 requiring trustees to provide opportunities for public involvement in the restoration planning process, or any time prior“if such involvement may enhance trustees’ decision-making or avoid delays in restoration.”81 Despite these statements, OPA does not provide many mandatory opportunities for public participation.

As noted above, for example, the Notice of Intent to Conduct Restoration Planning is not issued until after the Preassessment Phase is concluded and public comment on the Notice is not required. In addition to the opportunities afforded as part of the NRDA process, however, NEPA also provides for public input regarding the assessment of environmental impacts and potential alternatives for restoration planning and selection. Public involvement is important to ensure an accurate and complete NEPA process, and an adequate assessment of damages and restoration planning.

The following chart identifies which steps in the NRDA/NEPA process require public comment, and which steps provide discretion to the trustees. The first formal public notice will be the issuance of a Notice of Intent to Conduct Restoration Planning. As of the date of this Guide, there is no deadline or projected date forissuance ofthis Notice forthe Refugio NRDA process.

Type of Notice/
Document
Public Comment
Required
Public Comment
Optional
No Public Comment
Notice of Intent to
Conduct Restoration
Planning
X
Notice of Intent
to Prepare a Draft
Restoration Plan/EA
X
Notice of Availability
of Draft Restoration
Plan/EA
X
Notice of
Availability of Final
Restoration Plan/
Final EA/FONSI
Required in certain
circumstances 82
Not required unless
certain circumstances
apply
Notice of Intent
to Prepare a Draft
Restoration Plan/EIS
X
Notice of
Availability of Draft
Restoration Plan/EIS
X
Notice of
Availability of Final
Restoration Plan/
Final EIS/ROD
Not required but the
public may comment
during a 30-day
circulation period

33.69 17
A. Appendix A—Identifying Natural Resources & Services at Risk B. Appendix B---Flowchart Illustrating the Preassessment Phase Decision-Making Process C. Appendix C—Example of Preliminary Objectives during Injury Assessment D. Appendix D—Graphic Illustrating the Restoration Plan Development Process E. Appendix E—Examples of Other NRDAs

A P P E N D I C E S

33.70 18
Determining whether natural resources or services are or are likely to be injured requires that trustees consider the:
• Circumstances of the incident. Factors to consider include the:

Location of the incident;
Cause of the incident (e.g. collision, grounding, blowout, etc.); Condition of the vessel or facility;
Environmental conditions contributing to the incident (e.g., climatic, weather, and water conditions, land-water configuration, etc.); and Status of the incident (e.g., actual or potential discharge, discrete/intermittent/ continuous discharge, etc.) ;
• Characteristics of the discharge or substantial threat of the discharge.

Factors to consider include:

The type of oil(s) discharged or threatened to be discharged, which may be described by its physical and chemical parameters;
Date, time, and duration of the discharge or its threat; Extent of the discharge or its threat (e.g., volume, spatial and temporal boundaries, etc.); and
Characteristics of the discharge or its threat that address its transport and fate (e.g., weathering, evaporation rates, dissolution, tendency for formation of emulsions, photo-oxidation rates, biodegradation potential, and toxicity) ; • Characteristics of the natural resources. Factors to consider include:

The natural resources in the area of the incident;
The services they provide
Habitat and species types;
Seasonal implications on sensitive life stages; and
Unique ecological components (e.g., protected habitats, and endangered and threatened species; etc.); and
• Potential for injury. Factors to consider include:

Potential for exposure;
Pathways;
Causal mechanisms; and
Availability of assessment procedures and data to analyze these factors 1 Eli Reinharz and Jacqueline Michel, Preassessment Phase Guidance Document for Natural Resources Damage Assessment Under the Oil Pollution Act of 1990, accessed September 22, 2015, http://www.fws.gov/Contaminants/FWS_OSCP_05/ fwscontingencyappendices/W-NRDA/PreassessmentNOAA.pdf, pp. 3-6.

I d e n t i f y i n g N a t u r a l R e s o u r c e s & S e r v i c e s a t R i s k 1

33.71 19
2 Reinharz, et al., page 3-2.

A p p e n d i x B
Flowchart Illustrating the Preassessment Phase Decision-Making Process 2

33.72 20
Objective 1. Clean up, isolate, or remediate any continuing sources of oil that would inhibit natural recovery or limit the success of further restoration efforts.

Actions might include removal of buried oil in a gravel beach that continues to generate sheens.

Objective 2. Restore or rehabilitate injured habitats to baseline conditions. Actions might include replanting of salt marsh vegetation and protection of oiled areas from erosion during vegetation recovery.

Objective 3. Enhance the recovery of specific injured natural resources and services that are important to the environment or public. Actions might include replacement of killed birds by encouraging recolonization of the area (e.g. nesting sites), reseeding of shellfish beds, and placement of clean sand on degraded public beaches.

Objective 4. Create of enhance habitat or human facilities to provide equivalent services as compensation for services lost from the onset of injury to rehabilitation of additional areas of degraded salt marsh near the discharge area (but not caused by the discharge).
3 Michael T. Huguenin, David H. Haury, John C. Weiss, et al., Injury Assessment Guidance Document for Natural Resource Damage Assessment Under the Oil Pollution Act of 1990, accessed September 22, 2015, http://www.losco.state.la.us/pdf_ docs/NOAA_NRDA_Guidance_Injury_Assessment_1996.pdf, pp. 2-18.

33.73 21
t
t
t
+
t
t
t
t
t t
t
WillRestoration no ., No Plan
Planning be Required
Conducted?
DRP/DEIS Required?
no ves
Publish NOI for DRP/EA
Prepare DRP/EA
Publish NOA ofDRP/EA
Public Review
(usually 30 days)
Publish lorfor DRP/DEIS
Prepare DRP/DEIS
Publish NOA for DRP!DEIS
Public Review (min. 45
days) I
No Significant
®p7
Significant Impact
(30 day review)
Prepare FRPIFEIS
Publish NOA for FRPIFEIS (30 days)
Prepare FRP/EA and
FONSI ♦
Prepare ROD
In:iplement Restoration Plan
Exhibit 2.1 Restoration plan development. (NOI = Notice of Intent, NOA= Notice of Availability, DRP = Draft Restoration Plan, FRP = Final Restoration Plan, EA= Environmental Assessment, DEIS= Environmental Impact Statement, FEIS = Final Environmental Impact Statement, FONSI= Finding of No Significant Impact, ROD= Record of Decision) 4 Reinharz, et al., page 2-8. 2-8

33.74 22
A review of other NRDA processes in California can provide valuable information regarding the process, the types of injuries quantified and damages assessed, and the range of restoration projects approved by trustee agencies. This section provides a detailed summary of the Torch Pipeline Oil Spill due its proximity and similarity to the Refugio Oil Spill, as well as summaries of otherrecent NRDA decisions in California.

TORCH PIPELINE OIL SPILL 5
The Torch Pipeline Oil Spill took place on September 28, 1997, and affected seventeen miles of California coastline near Vandenberg Air Force Base. The incident was caused by a rupture in a pipeline that was owned or operated by the Torch Operating Company, Nuevo Energy Company,
and Black Hawk Oil and Gas Company—together, these
companies are referred to as the Responsible Parties. The pipeline ran from an offshore platform, Platform Irene, to a processing facility located onshore north of the City of Lompoc in Santa Barbara County. The rupture released
around 6,846 gallons of a petroleum product, diesel and an anti-corrosion chemical compound, into the ocean,
affecting mainly seabirds and shoreline habitats.

The Trustee Council was made up of representatives from the U.S. Fish and Wildlife Service, the U.S. Department of Air Force at Vandenberg Air Force Base, California Department of Fish and Game-Office of Spill Prevention and Response, and the California State Lands Commission, with assistance from the Santa Barbara County Planning and Development
Department. Together, the trustees determined that the
Spill was considered an “incident” under 15 C.F.R. §990.30 and was not permitted under federal or state law. Because natural resources under the trusteeship of the trustees were most likely affected, they had jurisdiction to pursue restoration.

Platform Irene, MMS photo
The decision to pursue a NRDA was based on the following information:
“(1) Data gathered during Spill response indicated that injuries to natural resources resulted from the incident, e.g., seabird mortality;
(2) the response actions were not expected to address the injuries resulting from the incident; and (3) feasible primary and/or compensatory restoration actions existed that could address the potential injuries.”
The trustees came up with specific goals for what they wanted the Restoration Plan to recover. Specifically, they wanted to restore the following natural resources and services: seabirds, sandy and gravel beach habitats, rocky intertidal shoreline habitats, and the use of beaches for human recreation. 3 Michael T. Huguenin, David H. Haury, John C. Weiss, et al., Injury Assessment Guidance Document for Natural Resource Damage Assessment Under the Oil Pollution Act of 1990, accessed September 22, 2015, http://www.losco.state.la.us/pdf_ docs/NOAA_NRDA_Guidance_Injury_Assessment_1996.pdf, pp. 2-18.

A p p e n d i x E
Examples of Other NRDAs

33.75 23
TORCH PIPELINE OIL SPILL (continued)
During the Injury Assessment Phase, the trustees focused on the magnitude of each injury, for example, number
of deaths of animals, as well as the time to full recovery.

The trustees narrowed down and selected appropriate
assessment procedures to address the injured resources
mentioned above. They selected the assessment
procedures based on the following:
“(1) Range of procedures available under section 990.27(b) of the OPA regulations; (2) time and cost necessary to
implement the procedures; (3) potential nature, degree, and spatial and temporal extent of the injury, (4) potential restoration actions for the injury, (5) relevance and
adequacy of information generated by the procedures to
meet information requirements of planning appropriate
restoration actions, and (6) input from consultants with damage assessment experience, scientific experts, and/or technical consultants.” 8
The trustees decided on five restoration projects to help mitigate the injuries sustained from the Incident. The five projects are:
• Seabird Colony Enhancement Project: The goal of this
project is to protect seabirds by reducing human
disturbance of their roosts and colonies;
• Sandy Beach and DuneHabitat Restoration: The goal ofthis projectis to eradicate invasive plant species and to replant native vegetation more conducive to the wellbeing and survival of indigenous species; • Mussel Bed Restoration: The goal of this project is to accelerate the natural restoration of mussel beds along the rocky intertidal areas;
• Rocky Intertidal Habitat Protection Program—Focus on Abalone and Other Rocky Intertidal Species: The goal of this project is to combine educational elements from other proposed restoration alternatives 8 Id., p. 20.
9 Id. at pp. 5-6.
10 Id. at p. 14.

A p p e n d i x D ( c o n t i n u e d )
Examples of Other NRDAs

TORCH/PLATFORM IRENE OIL SPILL
Final Restoration Plan and Environmental Assessment
October 24, 2007
Prepared by Torch/Platform Irene Trustee Council:

United States Fish and Wildlife Service
California Department of Fish and Game
United States Department of Air Force, Vandenberg Air Force Base California State Lands Commission
With Assistance from Santa Barbara County Planning and Development Department

33.76 24
TABLE OUTLINING OTHER SPILLS IN CALIFORNIA11
11 The information in the chart, as well as information regarding other NRDA processes in California, can be found here: https://www.wildlife.ca.gov/OSPR/NRDA.

A p p e n d i x D ( c o n t i n u e d )
Examples of Other NRDAs

33.77 25
1 Natural resources are defined as: “land, fish, wildlife, biota, air, water, ground water, drinking water supplies, and other such resources belonging to, managed by, held in trust by, appertaining to, or otherwise controlled by the United States (including the resources of the exclusive economic zone), and State or local government or Indian tribe, or any foreign government.” 33 U.S.C. § 2701(20); 15 C.F.R. § 990.30.
2 33 U.S.C. § 2701(14); 15 C.F.R. § 990.10.
3 Eli Reinharz and Jacqueline Michel, Preassessment Phase Guidance Document for Natural Resources Damage Assessment Under the Oil Pollution Act of 1990, accessed September 22, 2015, http://www.fws.gov/Contaminants/FWS_OSCP_05/ fwscontingencyappendices/W-NRDA/PreassessmentNOAA.pdf, page 1-1 4 Id.
5 33 U.S.C. § 2706 (d).
6 15 CFR § 990 et seq.
7 33 U.S.C. §2702.
8 15 C.F.R. § 990.12.
9 “Natural Resource Trustees Begin Natural Resource Damage Assessment Process for the Refugio Beach Oil Spill.” Refugio Beach Oil Spill, last modified July, 2015, accessed September 22, 2015. http://www.fws.gov/ventura/docs/news/RBOS%20 NRDA%20newsletter_final.pdf, page 2.
10 33 U.S.C. § 2706(c).
11 “Refugio,” last modified July 14, 2015, accessed September 22, 2015, https://www.wildlife.ca.gov/OSPR/NRDA/Refugio; “Refugio Response Joint Information Center,” last accessed October 13, 2015, http://refugioresponse.com/go/doc/7258/254286. 12 15 C.F.R. § 990.30.
13 15 C.F.R. § 990.41(a)(2).
14 15 C.F.R. § 990.30.
15 Id.
16 15 C.F.R. § 990.42(a).
17 Id.
18 15 C.F.R. § 990.44(a).
19 Id.
20 15 C.F.R. § 990.44(b).
21 Id.
22 15 C.F.R. § 990.44(d).
23 Cyndi Dawson to California Ocean Protection Council, “Update on the Refugio Oil Spill,” last modified July 29, 2015, accessed September 23, 2015, http://www.opc.ca.gov/webmaster/ftp/pdf/agenda_items/20150729/Item4-OPC-July292015- RefugioOilSpill-Memo.pdf.
24 Id.
25 “Refugio Beach Oil Spill Natural Resource Damage Assessment Update,” November 2015. 26 Id.
27 Id.
28 Id.
29 “Fact Sheet: Refugio Oil Spill Cleanup Phases,” last modified August 25, 2015, accessed September 22, 2015, http://www. refugioresponse.com/go/doc/7258/2588430/.
30 15 C.F.R. § 990.53(a)(2).
31 15 C.F.R. § 990.53(b)(3).
32 15 C.F.R. § 990.53(c)(1). 33 Deborah P. French, Henry Rines, Dian Gifford, et al., Primary Restoration Guidance Document for Natural Resource Damage Assessment Under the Oil Pollution Act of 1990, accessed September 22, 2015, http://www.fws.gov/contaminants/fws_oscp_05/ fwscontingencyappendices/W-NRDA/PrimaryRestorationNOAA.pdf, page 1-5. 34 Id.
35 Michael T. Huguenin, David H. Haury, John C. Weiss, et al., Injury Assessment Guidance Document for Natural Resource Damage Assessment Under the Oil Pollution Act of 1990, accessed September 22, 2015, http://www.losco.state.la.us/pdf_docs/ NOAA_NRDA_Guidance_Injury_Assessment_1996.pdf, page 2-7. 36 15 C.F.R. § 990.53(c)(2).
37 15 C.F.R. § 990.51.
38 15 C.F.R. § 990.51(b).

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39 15 C.F.R. § 990.51(c).
40 15 C.F.R. § 990.52.
41 15 C.F.R. § 990.52(c).
42 Huguenin, et al., page 2-1.
43 Id, page 2-11—2-12.
44 Id, page 2-16.
45 15 C.F.R. § 990.53.
46 Huguenin, et al., page 2-2.
47 Id, page 2-19.
48 Id.
49 15 C.F.R. §§ 990.53, 990.54.
50 15 C.F.R. § 990.54(a).
51 “Refugio Beach Oil Spill Natural Resource Damage Assessment Update,” November 2015. 52 15 C.F.R. § 990.54)b).
53 15 C.F.R. § 990.55.
54 15 C.F.R. § 990.55(b).
55 15 C.F.R. § 990.55(a), (c).
56 15 C.F.R. § 990.55(d).
57 Id.
58 42 U.S.C. §§ 4321 et seq.
59 15 C.F.R. § 990.23(b).
60 42 U.S.C. § 4321.
61 42 U.S.C. § 4332.
62 15 C.F.R. § 990.23(c)(1).
63 15 C.F.R. § 990.23(c)(1)(ii)(A).
64 15 C.F.R. § 990.23(c)(1)(ii)(D).
65 15 C.F.R. § 990.23(c)(1)(ii).
66 15 C.F.R. § 990.23(c)(2)(ii)(A).
67 Id.
68 15 C.F.R. § 990.23(c)(2)(ii)(A)-(C).
69 15 C.F.R. § 990.23(c)(2)(ii)(D).
70 15 C.F.R. § 990.23(c)(2)(ii)(E).
71 Id.
72 15 C.F.R. § 990.23(c)(2)(ii)(G).
73 15 C.F.R. § 990.23(c)(2)(ii)(G).
74 15 C.F.R. § 990.62.
75 15 C.F.R. § 990.62(b).
76 15 C.F.R. § 990.62(d).
77 15 C.F.R. § 990.64(a).
78 15 C.F.R. § 990.66.
79 Id.
80 33 U.S.C. § 2706(c)(5).
81 15 C.F.R. § 990.14(d).
82 A 30-day public review period is required when a FONSI is prepared when the proposed action is similar to one that normally requires an EIS, or the action is precedent-setting. See 40 C.F.R. § 1501.4(e)(2). Individual agencies may add other criteria for requiring public comment on a FONSI. Id.
83 Eli Reinharz and Jacqueline Michel, Preassessment Phase Guidance Document for Natural Resources Damage Assessment Under the Oil Pollution Act of 1990, accessed September 22, 2015, http://www.fws.gov/Contaminants/FWS_OSCP_05/ fwscontingencyappendices/W-NRDA/PreassessmentNOAA.pdf, page 3-5. 84 Id, page 3-6.

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Health Effects Notebook for Hazardous Air
Pollutants
• Benzene
• Toluene
• Ethylbenzene
• Xylene

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Benzene
71-43-2
Hazard Summary
Benzene is found in the air from emissions from burning coal and oil, gasoline service stations, and motor vehicle exhaust. Acute (short-term) inhalation exposure of humans to benzene may cause drowsiness, dizziness, headaches, as well as eye, skin, and respiratory tract irritation, and, at high levels, unconsciousness. Chronic (long-term) inhalation exposure has caused various disorders in the blood, including reduced numbers of red blood cells and aplastic anemia, in occupational settings. Reproductive effects have been reported for women exposed by inhalation to high levels, and adverse effects on the developing fetus have been observed in animal tests. Increased incidence of leukemia (cancer of the tissues that form white blood cells) have been observed in humans occupationally exposed to benzene. EPA has classified benzene as known human carcinogen for all routes of exposure.

Please Note: The main sources of information for this fact sheet are the Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological Profile for Benzene (1) and EPA's Integrated Risk Information System (IRIS) (4), which contains information on the health effects of benzene including the unit cancer risk for inhalation exposure.

Uses
Benzene is used as a constituent in motor fuels; as a solvent for fats, waxes, resins, oils, inks, paints, plastics, and rubber; in the extraction of oils from seeds and nuts; and in photogravure printing. It is also used as a chemical intermediate. Benzene is also used in the manufacture of detergents, explosives, pharmaceuticals, and dyestuffs. (1,2,6)
Sources and Potential Exposure
Individuals employed in industries that manufacture or use benzene may be exposed to the highest levels of benzene. (1)
Benzene is found in emissions from burning coal and oil, motor vehicle exhaust, and evaporation from gasoline service stations and in industrial solvents. These sources contribute to elevated levels of benzene in the ambient air, which may subsequently be breathed by the public. (1) Tobacco smoke contains benzene and accounts for nearly half the national exposure to benzene. (1) Individuals may also be exposed to benzene by consuming contaminated water. (1) Assessing Personal Exposure
Measurement of benzene in an individual's breath or blood or the measurement of breakdown products in the urine (phenol) can estimate personal exposure. However, the tests must be done shortly after exposure and are not helpful for measuring low levels of benzene. (1) Health Hazard Information
Acute Effects:

Coexposure to benzene with ethanol (e.g., alcoholic beverages) can increase benzene toxicity in humans. (1)

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Neurological symptoms of inhalation exposure to benzene include drowsiness, dizziness, headaches, and unconsciousness in humans. Ingestion of large amounts of benzene may result in vomiting, dizziness, and convulsions in humans. (1)
Exposure to liquid and vapor may irritate the skin, eyes, and upper respiratory tract in humans. Redness and blisters may result from dermal exposure to benzene. (1,2) Animal studies show neurologic, immunologic, and hematologic effects from inhalation and oral exposure to benzene. (1)
Tests involving acute exposure of rats, mice, rabbits, and guinea pigs have demonstrated benzene to have low acute toxicity from inhalation, moderate acute toxicity from ingestion, and low or moderate acute toxicity from dermal exposure. (3)
The reference concentration for benzene is 0.03 mg/m3 based on hematological effects in humans. The RfC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous inhalation exposure to the human population (including sensitive groups) that is likely to be without appreciable risk deleterious noncancer effects over a lifetime. (4)
Chronic Effects (Noncancer):

Chronic inhalation of certain levels of benzene causes disorders in the blood in humans. Benzene specifically affects bone marrow (the tissues that produce blood cells). Aplastic anemia (a risk factor for acute nonlymphocytic leukemia), excessive bleeding, and damage to the immune system (by changes in blood levels of antibodies and loss of white blood cells) may develop. (1) In animals, chronic inhalation and oral exposure to benzene produces the same effects as seen in humans. (1)
Benzene causes both structural and numerical chromosomal aberrations in humans. (1) EPA has established an oral Reference Dose (RfD) for benzene of 0.004 milligrams per kilogram per day (mg/kg/d) based on hematological effects in humans. The RfD is an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily oral exposure to the human population (including sensitive subgroups) that is likely to be without appreciable risk of deleterious noncancer effects during a lifetime. It is not a direct estimator of risk, but rather a reference point to gauge the potential for effects. At exposures increasingly greater than the RfD, the potential for adverse health effects increases. Lifetime exposure above the RfD does not imply that an adverse health effect would necessarily occur. (4) EPA has established a Reference Concentration (RfC) of 0.03 milligrams per cubic meter (0.03 mg/m3) for benzene based on hematological effects in humans. The RfC is an inhalation exposure concentration at or below which adverse health effects are not likely to occur. It is not a direct estimator of risk, but rather a reference point to gauge the potential for effects. At lifetime exposures increasingly greater than the reference exposure level, the potential for adverse health effects increases. (4) Reproductive/Developmental Effects:

There is some evidence from human epidemiological studies of reproductive and developmental toxicity of benzene, however the data do not provide conclusive evidence of a link between exposure and effect. (4) Animal studies have provided limited evidence that exposure to benzene may affect reproductive organs, however these effects were only observed at exposure levels over the maximum tolerated dose. (4) Adverse effects on the fetus, including low birth weight, delayed bone formation, and bone marrow damage, have been observed where pregnant animals were exposed to benzene by inhalation.(4)

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Cancer Risk:

Increased incidence of leukemia (cancer of the tissues that form white blood cells) has been observed in humans occupationally exposed to benzene. (1,4)
EPA has classified benzene as a Group A, known human carcinogen. (4) EPA uses mathematical models, based on human and animal studies, to estimate the probability of a person developing cancer from breathing air containing a specified concentration of a chemical. EPA calculated a range of 2.2 x 10-6 to 7.8 x 10-6 as the increase in the lifetime risk of an individual who is continuously exposed to 1 µm/m3 of benzene in the air over their lifetime.

EPA estimates that, if an individual were to continuously breathe the air containing benzene at an average 3 -4 -4 3 of 0.13 to 0.45 µg/m (1.3x10 to 4.5x mg/m ) over his or her entire lifetime, that person would theoretically have no more than a one-in-a-million increased chance of developing cancer as a direct result of continuously breathing air containing this chemical. Similarly, EPA estimates that continuously breathing 3 -3 -3 3 air containing 1.3 to 4.5 µg/m (1.3x10 to 4.5x10 mg/m ) would result in not greater than a one-in-a3 hundred thousand increased chance of developing cancer, and air containing 13 to 45 µg/m - (1.3 x 10 2 -2 3
to 4.5 x 10 mg/m ) would result in not greater than a one-in-ten thousand increased chance of developing cancer. For a detailed discussion of confidence in the potency estimates, please see IRIS.(4) -2
EPA has calculated an oral cancer slope factor ranging from 1.5 x 10 extrapolation from inhalation dose-response data. (4)
to 5.5 x 10
-2 -1
(mg/kg/d) that is an

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Physical Properties
The chemical formula for benzene is C H , and it has a molecular weight of 78.11 g/mol. 4) Benzene occurs as a volatile, colorless, highly flammable liquid that dissolves easily in water. (1,7) 3 Benzene has a sweet odor with an ASTDR reported odor threshold of 1.5 ppm (5 mg/m ).

The vapor pressure for benzene is 95.2 mm Hg at 25 °C, and it has a log octanol/water partition coefficient (log Kow) of 2.13. (1)
Conversion Factors (only for the gaseous form):

To convert concentrations in the air (at 25°C from ppm to mg/m3: mg/3 = (ppm) x (molecular weight of the compound) /

24.45). For benzene: -1 ppm = 3.19 mg/m. To convert concentrations in air from µg/m to mg/m3: mg/m3 = (µg/m3) × (1 mg/1,000 µg).

Health Data from Inhalation Exposure
ACGIH STEL--American Conference of Governmental and Industrial Hygienists' short-term exposure limit.

ACGIH TLV--American Conference of Governmental and Industrial Hygienists' threshold limit value expressed as a time-weighted average; the concentration of a substance to which most workers can be exposed without adverse effects.

AIHA ERPG--American Industrial Hygiene Association's emergency response planning guidelines. ERPG 1 is the maximum airborne concentration below which it is believed nearly all individuals could be exposed up to one hour without experiencing other than mild transient adverse health effects or perceiving a clearly defined objectionable odor; ERPG 2 is the maximum airborne concentration below which it is believed nearly all individuals could be

33.85 33
exposed up to one hour without experiencing or developing irreversible or other serious health effects that could impair their abilities to take protective action. The American Industrial Hygiene Association's detection and recognition odor thresholds for benzene are 61 ppm and 97 ppm, respectively.

LC -> (Lethal Concentration )—A calculated concentration of a chemical in air to which exposure for a specific length of time is expected to cause death in 50% of a defined experimental animal population.

NIOSH REL--National Institute of Occupational Safety and Health's recommended exposure limit; NIOSHrecommended exposure limit for an 8- or 10-h time-weighted-average exposure and/or ceiling.

NIOSH STEL--NIOSH's short term exposure limit; NIOSH recommended exposure limit for a 15-minute period.

OSHA PEL--Occupational Safety and Health Administration's permissible exposure limit expressed as a timeweighted average; the concentration of a substance to which most workers can be exposed without adverse effect averaged over a normal 8-h workday or a 40-h workweek.

OSHA STEL--Occupational Safety and Health Administration's short-term exposure limit.

The health and regulatory values cited in this graph were obtained in April 2009. a
Health numbers are toxicological numbers from animal testing or risk assessment values developed by EPA. b
Regulatory numbers are values that have been incorporated in Government regulations, while advisory numbers are nonregulatory values provided by the Government or other groups as advice. OSHA numbers are regulatory, whereas NIOSH, ACGIH, and AIHA numbers are advisory.
c
The BMCL (statistical lower confidence limit on the concentration at the benchmark concentration, which is the concentration producing a specified change in a response rate that is considered a critical effect) was used as the point of departure for the RfC derivation. The BMCL for benzene is for hematological effects (reduction in absolute lymphocyte count) in humans (4).

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Summary created in April 1992, updated in January 2000 and January 2012.

References

1. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for Benzene. U.S. Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA. 2007.

2. M. Sittig. Handbook of Toxic and Hazardous Chemicals and Carcinogens. 2nd ed. Noyes Publications, Park Ridge, NJ. 1985.

3. U.S. Department of Health and Human Services. Registry of Toxic Effects of Chemical Substances (RTECS, online database). National Toxicology Information Program, National Library of Medicine, Bethesda, MD. 1993.

4. U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Benzene. National Center for Environmental Assessment, Office of Research and Development, Washington, DC. 2009.

5. California Environmental Protection Agency(CalEPA). Air Toxics Hot Spots Program Risk Assessment Guidelines: Part III. Technical Support Document for the Determination of Noncancer Chronic Reference Exposure Levels. SRP Draft. Office of Environmental Health Hazard Assessment, Berkeley, CA. 1999.

6. The Merck Index.An Encyclopedia of Chemicals, Drugs, and Biologicals. 11th ed. Ed. S. Budavari. Merck and Co. Inc., Rahway, NJ. 1989.

7. American Conference of Governmental Industrial Hygienists (ACGIH). 1999 TLVs and BEIs. Threshold Limit Values for Chemical Substances and Physical Agents. Biological Exposure Indices. Cincinnati, OH. 1999.

8. 8. Occupational Safety and Health Administration (OSHA). Occupational Safety and Health Standards, Toxic and Hazardous Substances. Code of Federal Regulations. 29 CFR 1910.1000. 1998.

9. National Institute for Occupational Safety and Health (NIOSH). Pocket Guide to Chemical Hazards. U.S.

Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention. Cincinnati, OH. 1997.

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Toluene
108-88-3
Hazard Summary
Toluene is added to gasoline, used to produce benzene, and used as a solvent. Exposure to toluene may occur from breathing ambient or indoor air affected by such sources. The central nervous system (CNS) is the primary target organ for toluene toxicity in both humans and animals for acute (short-term) and chronic (long-term) exposures. CNS dysfunction and narcosis have been frequently observed in humans acutely exposed to elevated airborne levels of toluene; symptoms include fatigue, sleepiness, headaches, and nausea. CNS depression has been reported to occur in chronic abusers exposed to high levels of toluene. Chronic inhalation exposure of humans to toluene also causes irritation of the upper respiratory tract and eyes, sore throat, dizziness, and headache. Human studies have reported developmental effects, such as CNS dysfunction, attention deficits, and minor craniofacial and limb anomalies, in the children of pregnant women exposed to high levels of toluene or mixed solvents by inhalation. EPA has concluded that that there is inadequate information to assess the carcinogenic potential of toluene.

Please Note: The main sources of information for this fact sheet are EPA's Integrated Risk Information System (IRIS) (2), which contains information on inhalation chronic toxicity of toluene and the RfC, oral chronic toxicity and the RfD, and the carcinogenic effects of toluene, and the Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological Profile for Toluene. (1)
Uses
The major use of toluene is as a mixture added to gasoline to improve octane ratings. Toluene is also used to produce benzene and as a solvent in paints, coatings, synthetic fragrances, adhesives, inks, and cleaning agents. (1)
Toluene is also used in the production of polymers used to make nylon, plastic soda bottles, and polyurethanes and for pharmaceuticals, dyes, cosmetic nail products, and the synthesis of organic chemicals. (1)
Sources and Potential Exposure
The highest concentrations of toluene usually occur in indoor air from the use of common household products (paints, paint thinners, adhesives, synthetic fragrances and nail polish) and cigarette smoke. The deliberate inhalation of paint or glue may result in high levels of exposure to toluene, as well as to other chemicals, in solvent abusers. (1)
Toluene exposure may also occur in the workplace, especially in occupations such as printing or painting, where toluene is frequently used as a solvent. (1)
Automobile emissions are the principal source of toluene to the ambient air. Toluene may also be released to the ambient air during the production, use, and disposal of industrial and consumer products that contain toluene. (1)
Levels of toluene measured in rural, urban, and indoor air averaged 1.3, 10.8, and 31.5 micrograms per cubic meter (µg/m ), respectively. (1)

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Assessing Personal Exposure
Toluene and its breakdown products can be detected in the blood or urine to determine whether or not exposure has occurred. Metabolites measured in the urine are not specific to toluene, and testing must occur within 12 hours of exposure. (1)
Health Hazard Information
Acute Effects:

The CNS is the primary target organ for toluene toxicity in both humans and animals for acute and chronic exposures. CNS dysfunction (which is often reversible) and narcosis have been frequently observed in humans acutely exposed to low or moderate levels of toluene by inhalation; symptoms include fatigue, sleepiness, headaches, and nausea. CNS depression and death have occurred at higher levels of exposure. (1)
Cardiac arrhythmia has also been reported in humans acutely exposed to toluene. (1) Following the ingestion of toluene a person died from a severe depression of the CNS. Constriction and necrosis of myocardial fibers, swollen liver, congestion and hemorrhage of the lungs, and tubular kidney necrosis were also reported. (1)
Acute exposure of animals to toluene has been reported to affect the CNS as well as to decrease resistance to respiratory infection. (1)
Acute animal tests in rats and mice have demonstrated toluene to have low acute toxicity by inhalation or oral exposure. (1)
Chronic Effects (Noncancer):

CNS depression has been reported to occur in chronic abusers exposed to high levels of toluene.

Symptoms include drowsiness, ataxia, tremors, cerebral atrophy, nystagmus (involuntary eye movements), and impaired speech, hearing, and vision. Neurobehavioral effects have been observed in occupationally exposed workers. (1,2)
Effects on the CNS have also been observed in studies of animals chronically exposed by inhalation. (1,2) Chronic inhalation exposure of humans to toluene causes irritation of the upper respiratory tract and eyes, sore throat, dizziness, headache, and difficulty with sleep. (1,2) Inflammation and degeneration of the nasal and respiratory epithelium and pulmonary lesions have been observed in rats and mice chronically exposed to high levels of toluene by inhalation. (1) Mild effects on the kidneys and liver have been reported in solvent abusers chronically exposed to toluene vapor. However, these studies are confounded by probable exposure to multiple solvents. (1,2) Slight adverse effects on the liver, kidneys, and lung and high-frequency hearing loss have been reported in some chronic inhalation studies of rodents. (1)
The Reference Concentration (RfC) for toluene is 5 milligrams per cubic meter (5 mg/m3) based on neurological effects in humans. The RfC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous inhalation exposure to the human population (including sensitive subgroups) that is likely to be without appreciable risk of deleterious noncancer effects during a lifetime. It is not a direct estimator of risk but rather a reference point to gauge the potential effects. At exposures increasingly greater than the RfC, the potential for adverse health effects increases. Lifetime exposure above the RfC does not imply that an adverse health effect would necessarily occur. (2) EPA has high confidence in the RfC, the studies on which the RfC was based, and in the overall toluene database. There are many high quality chronic human studies available including a subset of studies presenting a cluster of NOAELs for neurological effects below reported LOAELs for all available endpoints.

In addition, there are numerous supportive animal studies including those showing reproductive and developmental effects at doses higher than that identified as the point of departure. (2)

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The Reference Dose (RfD) for toluene is 0.08 milligrams per kilogram body weight per day (0.08 mg/kg/d) based on increased kidney weight in rats. (2)
EPA has medium confidence in the study on which the RfD was based because it was considered an adequate gavage study of subchronic duration. The confidence in the database is also medium because of a lack of chronic oral data, and a lack of adequate data on endpoints of potential concern for toluene including neurotoxicity . For these reasons, there is medium confidence in the RfD. (2) Reproductive/Developmental Effects:

CNS dysfunction, attention deficits, minor craniofacial and limb anomalies, and developmental delay were observed in the children of pregnant women exposed to toluene or to mixed solvents during solvent abuse. Growth retardation and dysmorphism were reported in infants of another study. However, these studies were confounded by exposure to multiple chemicals. (1,2) Children born to toluene abusers have exhibited temporary renal tubular acidosis. (1) Paternal exposure (in which the mothers had no occupational exposure to toluene but the fathers did) increased the odds ratio for spontaneous abortions; however, these observations cannot be clearly ascribed to toluene because of the small number of cases evaluated and the large number of confounding variables.

An increased incidence of spontaneous abortions was also reported among occupationally exposed women.

However, these studies are not conclusive due to many confounding variables. (1) Several inhalation studies have shown toluene to be a developmental toxicant, but not a reproductive toxicant, in rodents. (1)
Cancer Risk:

Available studies in workers have reported limited or no evidence of the carcinogenic potential of toluene.

Similarly, the few available epidemiological studies have failed to demonstrate increased risk of cancer due to inhalation exposure to toluene. However, these studies were limited due to the size of the study population and lack of historical monitoring data. (1)
Chronic inhalation exposure of rats did not produce an increased incidence of treatment-related neoplastic lesions. (1,2)
Under the Guidelines for Carcinogen Risk Assessments (US. EPA, 2005), the EPA considers that there is inadequate information to assess the carcinogenic potential of toluene. (2) Physical Properties
The chemical formula for toluene is C H CH , and its molecular weight is 92.15 g/mol. (1) 6 5 3
Toluene occurs as a colorless, flamma ble , re fractive liquid, that is slightly soluble in water. (1) Toluene has a sweet, pungent odor, with an odor threshold of 2.9 parts per million (ppm). (1,4) The vapor pressure for toluene is 28.4 mm Hg at 25 °C, and its log octanol/water partition coefficient (log K ) is 2.69. (1)
ow
Conversion Factors:
3 3
To convert concentrations in air (at 25 °C) from ppm to mg/m 3 : mg/m = (ppm) × (molecular weight of the

33.90 38
compound)/(24.45). For toluene: 1 ppm = 3.77 mg/m .

Health Data from Inhalation Exposure
AIHA ERPG --American Industrial Hygiene Association's emergency response planning guidelines. ERPG 1 is the maximum airborne concentration below which it is believed nearly all individuals could be exposed up to one hour without experiencing other than mild transient adverse health effects or perceiving a clearly defined objectionable odor; ERPG 2 is the maximum airborne concentration below which it is believed nearly all individuals could be exposed up to one hour without experiencing or developing irreversible or other serious health effects that could impair their abilities to take protective action.

ACGIH TLV --American Conference of Governmental and Industrial Hygienists' threshold limit value expressed as a time-weighted average; the concentration of a substance to which most workers can be exposed without adverse effects.

LC (Lethal Concentration
50 )--A calculated concentration of a chemical in air to which exposure for a specific 50

33.91 39
length of time is expected to cause death in 50% of a defined experimental animal population.

LOAEL--Lowest-observed-adverse-effect level.

NIOSH IDLH -- National Institute of Occupational Safety and Health's immediately dangerous to life or health concentration; NIOSH recommended exposure limit to ensure that a worker can escape from an exposure condition that is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from the environment.

NIOSH REL --NIOSH's recommended exposure limit; NIOSH-recommended exposure limit for an 8- or 10-h timeweighted-average exposure and/or ceiling.

NIOSH STEL --NIOSH's recommended short-term exposure limit; a 15-minute TWA exposure which should not be exceeded at any time during a workday.

OSHA ceiling --Occupational Safety and Health Administration's permissible exposure limit ceiling value; the concentration of a substance that should not be exceeded at any time.

OSHA PEL --OSHA's permissible exposure limit expressed as a time-weighted average; the concentration of a substance to which most workers can be exposed without adverse effect averaged over a normal 8-h workday or a 40-h workweek.

The health and regulatory values cited in this factsheet were obtained in September 2005. a Health numbers are toxicological numbers from human studies, animal testing or risk assessment values developed by EPA.
b
Regulatory numbers are values that have been incorporated in Government regulations, while advisory numbers are nonregulatory values provided by the Government or other groups as advice. OSHA numbers are regulatory, whereas NIOSH, ACGIH, and AIHA numbers are advisory.
c
This NOAEL average from several co-critical studies was used as the basis for the EPA RfC.

References Summary created in April 1992, updated in July 2012

1. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for Toluene. U.S. Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA. 2000.

2. U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Toluene. National Center for Environmental Assessment, Office of Research and Development, Washington, DC. 2005.

3. American Industrial Hygiene Association (AIHA). The AIHA 2010 Emergency Response Planning Guidelines and Workplace Environmental Exposure Level Guides Handbook. 1998.

4. J.E. Amoore and E. Hautala. Odor as an aid to chemical safety: Odor thresholds compared with threshold limit values and volatilities for 214 industrial chemicals in air and water dilution. Journal of Applied Toxicology, 3(6):272-290. 1983.

5. American Conference of Governmental Industrial Hygienists (ACGIH). 2009 Guide to Occupational Exposure Values. Cincinnati, OH. 2009.

6. National Institute for Occupational Safety and Health (NIOSH). Pocket Guide to Chemical Hazards. U.S.

Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention. Cincinnati, OH. 1997.

7. Occupational Safety and Health Administration (OSHA). Occupational Safety and Health Standards, Toxic and Hazardous Substances. Code of Federal Regulations 29 CFR 1910.1000. 1998.

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Ethylbenzene
100-41-4
Hazard Summary
Ethylbenzene is mainly used in the manufacture of styrene. Acute (short-term) exposure to ethylbenzene in humans results in respiratory effects, such as throat irritation and chest constriction, irritation of the eyes, and neurological effects such as dizziness. Chronic (long-term) exposure to ethylbenzene by inhalation in humans has shown conflicting results regarding its effects on the blood. Animal studies have reported effects on the blood, liver, and kidneys from chronic inhalation exposure to ethylbenzene.

Limited information is available on the carcinogenic effects of ethylbenzene in humans. In a study by the National Toxicology Program (NTP), exposure to ethylbenzene by inhalation resulted in an increased incidence of kidney and testicular tumors in rats, and lung and liver tumors in mice. EPA has classified ethylbenzene as a Group D, not classifiable as to human carcinogenicity.

Please Note: The main sources of information for this fact sheet are EPA's Integrated Risk Information System (IRIS) (5), which contains information on inhalation and oral chronic toxicity of ethylbenzene and the RfC, and oral chronic toxicity and the RfD, and the Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological Profile for Ethylbenzene. (1)
Uses
Ethylbenzene is used primarily in the production of styrene. It is also used as a solvent, as a constituent of asphalt and naphtha, and in fuels. (1)
Sources and Potential Exposure
In one study, ethylbenzene was detected in urban air at a median concentration of 0.62 parts per billion (ppb). The median level in suburban air was about 0.62 ppb, while the mean level measured in air in rural locations was about 0.13 ppb. (1)
Ethylbenzene has been detected in indoor air at mean concentrations of approximately 1 ppb. The indoor levels tend to be higher than the ambient levels, due to the use of household products such as cleaning products or paints. (1)
Occupational exposure to ethylbenzene occurs in factories that use ethylbenzene to produce other chemicals; for gas and oil workers; and for varnish workers, spray painters, and persons involved in gluing operations. (1)
Exposure to ethylbenzene occurs from the use of consumer products, gasoline, pesticides, solvents, carpet glues, varnishes, paints, and tobacco smoke. (1)
Assessing Personal Exposure
Laboratory tests can determine ethylbenzene exposure by measuring the breakdown products in the urine. (1)

33.93 41
Health Hazard Information
Acute Effects:

Respiratory effects, such as throat irritation and chest constriction, irritation of the eyes, and neurological effects such as dizziness, have been noted from acute inhalation exposure to ethylbenzene in humans. (1-3) Animal studies have reported central nervous system (CNS) toxicity; pulmonary effects; and effects on the liver, kidney, and eyes (irritation) from acute inhalation exposure to ethylbenzene. (1) Tests involving acute exposure of rats have shown ethylbenzene to have moderate toxicity from inhalation and oral exposure. (1,4)
Chronic Effects (Noncancer) :

Chronic exposure to ethylbenzene by inhalation in humans has shown conflicting results regarding its effects on the blood. In one study of workers occupationally exposed to ethylbenzene, effects on the blood were noted, while in another study, no adverse effects on the blood were seen. (1) In a 20-year study of humans occupationally exposed to ethylbenzene, no liver toxicity was noted. (1) Animal studies have reported effects on the blood, liver, and kidneys from chronic inhalation exposure to ethylbenzene. (1,3)
3 The Reference Concentration (RfC) for ethylbenzene is 1 milligram per cubic meter (mg/m ) based on developmental toxicity in rats and rabbits. The RfC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous inhalation exposure to the human population (including sensitive subgroups), that is likely to be without appreciable risk of deleterious noncancer effects during a lifetime. It is not a direct estimator of risk but rather a reference point to gauge the potential effects. At exposures increasingly greater than the RfC, the potential for adverse health effects increases. Lifetime exposure above the RfC does not imply that an adverse health effect would necessarily occur. (5) EPA has low confidence in the study on which the RfC was based because higher exposure levels may have provided more information on the potential for maternal toxicity and developmental effects; low confidence in the database because, although other studies have examined a variety of other endpoints (e.g., liver and lung), by histopathology in rats and mice, there are no chronic studies and no multigeneration developmental studies; and, consequently, low confidence in the RfC. (5) The Reference Dose (RfD) for ethylbenzene is 0.1 milligrams per kilogram body weight per day (mg/kg/d) based on liver and kidney toxicity in rats. (5)
EPA has low confidence in the study on which the RfD was based because rats of only one sex were tested and the experiment was not of chronic duration; low confidence in the supporting database because other oral toxicity data were not found; and, consequently, low confidence in the RfD. (5) Reproductive/Developmental Effects:

No information is available on the developmental or reproductive effects of ethylbenzene in humans. (1) Animal studies have reported developmental effects, such as fetal resorptions, retardation of skeletal development, and an increased incidence of extra ribs in animals exposed to ethylbenzene via inhalation. (1,3,5)
Cancer Risk:

The only available human cancer study monitored the conditions of workers exposed to ethylbenzene for 10 years, with no tumors reported. However, no firm conclusions can be made from this study because exposure information was not provided, and 10 years is insufficient for detecting long latency tumors in humans. (1)
In a study by the NTP, exposure to ethylbenzene by inhalation resulted in a clearly increased incidence of kidney and testicular tumors in male rats, and a suggestive increase in kidney tumors in female rats, lung tumors in male mice, and liver tumors in female mice. (6) EPA has classified ethylbenzene as a Group D, not classifiable as to human carcinogenicity. (5)

33.94 42
Physical Properties
Ethylbenzene is a colorless liquid that smells like gasoline. (1) The odor threshold for ethylbenzene is 2.3 parts per million (ppm). (7) The chemical formula for ethylbenzene is C H , and the molecular weight is 106.16 g/mol. (1) 8 10 The vapor pressure for ethylbenzene is 9.53 mm Hg at 25 °C, and its octanol/water partition coefficient (log K ) is 3.13. (1)
ow
Conversion Factors:

To convert concentrations in air (at 25 °C) from ppm to mg/ m3 : mg/ m3 = (ppm) × (molecular weight of the compound)/(24.45). For ethylbenzene: 1ppm = 4.34 mg/m3
Health Data from Inhalation Exposure
ACGIH STEL --American Conference of Governmental and Industrial Hygienist's threshold limit value short-term exposure limit; a 15-minute TWA exposure which should not be exceeded at any time during a workday.

ACGIH TLV -- ACGIH's threshold limit value expressed as a time-weighted average; the concentration of a substance to which most workers can be exposed without adverse effects.

LC50 (Lethal Concentration 50)--A calculated concentration of a chemical in air to which exposure for a specific length of time is expected to cause death in 50% of a defined experimental animal population.

33.95 43
NIOSH IDLH --National Institute of Occupational Safety and Health immediately dangerous to life and health; NIOSH concentration representing the maximum level of a pollutant from which an individual could escape within 30 minutes without escape-impairing symptoms or irreversible health effects.

NIOSH REL --NIOSH's recommended exposure limit; NIOSH-recommended exposure limit for an 8- or 10-h timeweighted-average exposure and/or ceiling.

NIOSH STEL --NIOSH's recommended short-term exposure limit; a 15-minute TWA exposure which should not be exceeded at any time during a workday.

NOAEL--No-observed-adverse-effect level.

OSHA PEL --Occupational Safety and Health Administration's permissible exposure limit expressed as a timeweighted average; the concentration of a substance to which most workers can be exposed without adverse effect averaged over a normal 8-h workday or a 40-h workweek.

The health and regulatory values cited in this factsheet were obtained in December 1999. a Health numbers are toxicological numbers from animal testing or risk assessment values developed by EPA. b
Regulatory numbers are values that have been incorporated in Government regulations, while advisory numbers are nonregulatory values provided by the Government or other groups as advice. OSHA numbers are regulatory, whereas NIOSH and ACGIH numbers are advisory.
c
NOAEL is from the critical study used as the basis for the EPA RfC.

Summary created in April 1992, updated January 2000
References

1. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for Ethylbenzene (Update). Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA. 1999.

2. E.J. Calabrese and E.M. Kenyon. Air Toxics and Risk Assessment. Lewis Publishers, Chelsea, MI. 1991.

3. U.S. Department of Health and Human Services. Hazardous Substances Data Bank (HSDB, online database).

National Toxicology Information Program, National Library of Medicine, Bethesda, MD. 1993.

4. U.S. Department of Health and Human Services. Registry of Toxic Effects of Chemical Substances (RTECS, online database). National Toxicology Information Program, National Library of Medicine, Bethesda, MD. 1993.

5. U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Ethylbenzene. National Center for Environmental Assessment, Office of Research and Development, Washington, DC. 1999.

6. National Toxicology Program. Toxicology and Carcinogenesis Studies of Ethylbenzene (CAS No. 100-41-4) in F344/N Rats and B6C3F1 Mice (Inhalation Studies). TR No. 466. U.S. Department of Health and Human Services, Public Health Service, National Institutes of Health, Bethesda, MD. 1999.

7. J.E. Amoore and E. Hautala. Odor as an aid to chemical safety: Odor thresholds compared with threshold limit values and volatilities for 214 industrial chemicals in air and water dilution. Journal of Applied Toxicology, 3(6):272-290. 1983.

8. American Conference of Governmental Industrial Hygienists (ACGIH). 1999 TLVs and BEIs. Threshold Limit Values for Chemical Substances and Physical Agents. Biological Exposure Indices. Cincinnati, OH. 1999.

9. National Institute for Occupational Safety and Health (NIOSH). Pocket Guide to Chemical Hazards. U.S.

Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention. Cincinnati, OH. 1997.

10. Occupational Safety and Health Administration (OSHA). Occupational Safety and Health Standards, Toxic and Hazardous Substances. Code of Federal Regulations. 29 CFR 1910.1000. 1998.

33.96 44
(A)
Xylenes (Mixed Isomers)
o-XYLENE
m-XYLENE
p-XYLENE
1330-20-7, 95-47-6, 108-38-3, 106-42-3
Hazard Summary
Commercial or mixed xylene usually contains about 40-65% m-xylene and up to 20% each of o-xylene and p-xylene and ethylbenzene. Xylenes are released into the atmosphere as fugitive emissions from industrial sources, from auto exhaust, and through volatilization from their use as solvents. Acute (shortterm) inhalation exposure to mixed xylenes in humans results in irritation of the eyes, nose, and throat, gastrointestinal effects, eye irritation, and neurological effects. Chronic (long-term) inhalation exposure of humans to mixed xylenes results primarily in central nervous system (CNS) effects, such as headache, dizziness, fatigue, tremors, and incoordination; respiratory, cardiovascular, and kidney effects have also been reported. EPA has classified mixed xylenes as a Group D, not classifiable as to human carcinogenicity.

Please Note: The main sources of information for this fact sheet are EPA's Integrated Risk Information System (IRIS) (6), which contains information on oral chronic toxicity and the RfD, and the Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological Profile for Xylenes. (1) Uses
Mixed xylenes are used in the production of ethylbenzene, as solvents in products such as paints and coatings, and are blended into gasoline. (1)
Sources and Potential Exposure
Mixed xylenes are distributed throughout the environment; they have been detected in air, rainwater, soils, surface water, sediments, drinking water, and aquatic organisms. (1) Xylenes are released into the atmosphere as fugitive emissions from industrial sources, from auto exhaust, and through volatilization from their use as solvents. (1) Ambient air concentrations of mixe d xylenes in urban areas of the United States range from 0.003 to 0.38 3 milligrams per cubic meter (mg/m ). (1)
Mixed xylenes have also been detected at low levels in indoor air; xylenes have been widely used in home use products such as synthetic fragrances a nd paints. One study reported concentrations of m- and p- 3 xylene ranging from 0.010 to 0.047 mg/m . (1)
Levels of mixed xylenes in drinking water have been reported to range from 0.2 to 9.9 micrograms per liter (µg/L), with mean concentrations of less than 2 µg/L. (1) Occupational exposure to mixed xylenes may occur at workplaces where mixed xylenes are produced and used as industrial solvents. (1)
Xylene exposure may be to any of the three isomers or to mixtures of the isomers. (1) Assessing Personal Exposure

33.97 45
Exposure to mixed xylenes may be determined by measuring the breakdown products of mixed xylenes in the urine or by measuring levels of xylene in blood or exhaled breath. (1) Health Hazard Information
Acute Effects:

Human and animal data show that all xylene isomers or xylene mixtures produce similar effects, although specific isomers may not be equally potent in producing the effects. (1) Acute inhalation exposure to mixed xylenes in humans has been associated with dyspnea and irritation of the nose and throat; gastrointestinal effects such as nausea, vomiting, and gastric discomfort; mild transient eye irritation; and neurological effects such as impaired short-term memory, impaired reaction time, performance decrements in numerical ability, and alterations in equilibrium and body balance. (1-3) Acute dermal exposure in humans results in transient skin irritation and dryness and scaling of the skin. (1-3)
Acute inhalation exposure to a mixture of toluene and xylenes resulted in more than additive respiratory and neurological toxicity in humans and animals. (1)
Acute animal studies have reported respiratory, cardiovascular, CNS, liver, and kidney effects from inhalation exposure to mixed xylenes. (1)
Acute animal tests in rats and mice have shown mixed xylenes to have low to moderate toxicity from inhalation exposure and moderate toxicity from oral exposure. (4,5) Chronic Effects (Noncancer):

Chronic exposure of humans to mixed xylenes, as seen in occupational settings, has resulted primarily in neurological effects such as headache, dizziness, fatigue, tremors, incoordination, anxiety, impaired shortterm memory, and inability to concentrate. Labored breathing, impaired pulmonary function, increased heart palpitation, severe chest pain, abnormal EKG, and possible effects on the kidneys have also been reported. (1,2)
Mixed xylenes have not been extensively tested for chronic effects, although animal studies show effects on the liver and CNS from inhalation and oral exposures and effects on the kidneys from oral exposure to mixed xylenes. (1)
The Reference Dose (RfD) for mixed xylenes is 2 milligrams per kilogram body weight per day (mg/kg/d) based on hyperactivity, decreased body weight, and increased mortality in rats, and the provisional RfD for m- and o-xylenes is also 2 mg/kg/d. EPA has not established an RfD for p-xylene.

The RfD is an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily oral exposure to the human population (including sensitive subgroups) that is likely to be without appreciable risk of deleterious noncancer effects during a lifetime. It is not a direct estimator of risk but rather a reference point to gauge the potential effects. At exposures increasingly greater than the RfD, the potential for adverse health effects increases. Lifetime exposure above the RfD does not imply that an adverse health effect would necessarily occur. The provisional RfDs are values that have had some form of Agency review, but do not appear on IRIS. (6,10)
EPA has medium confidence in the study on which the RfD was based because it was a well-designed study in which adequately sized groups of two species were tested over a substantial portion of their lifespan, comprehensive histology was performed, and a no-observed-adverse-effect level (NOAEL) was defined; but clinical chemistries, blood enzymes, and urinalysis were not performed; medium confidence in the database because although supporting data exist for mice, and teratogenicity and fetotoxicity data are available with positive results at high oral doses, a lowest-observed-adverse-effect level (LOAEL) for chronic oral exposure has not been defined; and, consequently, medium confidence in the RfD. (6) EPA has not established a Reference Concentration (RfC) for mixed xylenes or an y isomers. (6) 3 ATSDR has calculated a chronic inhalation minimal risk level (MRL) of 0.4 mg/m (0.1 parts per million [ppm]) for mixed xylenes based on neurological effects in occupationally exposed workers. The MRL is an

33.98 46
estimate of the daily human exposure to a hazardous substance that is likely to be without appreciable risk of adverse noncancer health effects over a specified duration of exposure. (1) Reproductive/Developmental Effects:

Several human studies examined exposure to organic solvents (including mixed xylenes) and developmental effects. An increased potential for spontaneous abortions among the wives of occupationally exposed men was reported. However, no conclusions can be drawn from these studies because they all involved concurrent exposure to multiple chemicals. (1) Mixed xylenes have been shown to produce developmental effects, such as an increased incidence of skeletal variations in fetuses, delayed ossification, fetal resorptions, and decreased fetal body weight in animals via inhalation exposure. Some studies observed maternal toxicity as well. (1-3) Cancer Risk:

No information is available on the carcinogenic effects of mixed xylenes in humans. (1) An increase in tumors was not reported in rats or mice exposed to mixed xylenes via gavage (experimentally placing the chemical in the stomach). Other animal studies have reported equivocal results. (1,3,6)
EPA has classified mixed xylenes as a Group D, not classifiable as to human carcinogenicity. (6) Physical Properties
m-, o-, and p-Xylene are the three isomers of xylene; commercial or mixed xylene usually contains about 40-65% m-xylene and up to 20% each of o- and p-xylene and ethylbenzene. (1) Mixed xylenes are colorless liquids that are practically insoluble in water and have a sweet odor. (1) The odor threshold for m-xylene is 1.1 ppm. (4)
The chemical formula for mixed xylenes is C H , and the molecular weight is 106.16 g/mol. (1) 8 The vapor pressure for mixed xylenes is 6.72
10 m m Hg at 21 °C, and the log octanol/water partition coefficient (log K ) is 3.123.20. (1) ow
Conversion Factors:

To convert concentrations in air (at 25 °C) from ppm to mg/m3 : mg/m3 = (ppm) × (molecular weight of the compound) / (24.5). For xylenes: 1 ppm = 4.34 mg / m3. To convert concentrations in air from µg / m3 to mg / m3 : mg / m3 = (µg / m3) × (1 mg / 1,000 µg).

33.99 b 47
Health Data from Inhalation Exposure
ACGIH STEL --American Conference of Governmental and Industrial Hygienists' short-term exposure limit; 15-min time-weighted-average exposure that should not be exceeded at any time during a workday even if the 8-h timeweighted-average is within the threshold limit value.

ACGIH TLV --ACGIH's threshold limit value expressed as a time-weighted average; the concentration of a substance to which most workers can be exposed without adverse effects.

LC (Lethal Concentration
50 )--A calculated concentration of a chemical in air to which exposure for a specific 50

33.100
48 length of time is expected to cause death in 50% of a defined experimental animal population.

LOAEL-- Lowest observed adverse effect level.

NIOSH IDLH -- National Institute of Occupational Safety and Health's immediately dangerous to life or health concentration; NIOSH recommended exposure limit to ensure that a worker can escape from an exposure condition that is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from the environment.

NIOSH REL --NIOSH's recommended exposure limit; NIOSH-recommended exposure limit for an 8- or 10-h timeweighted-average exposure and/or ceiling.

NIOSH STEL --NIOSH's recommended short-term exposure limit; a 15-minute TWA exposure which should not be exceeded at any time during a workday.

OSHA PEL --Occupational Safety and Health Administration's permissible exposure limit expressed as a timeweighted average; the concentration of a substance to which most workers can be exposed without adverse effect averaged over a normal 8-h workday or a 40-h workweek.

The health and regulatory values cited in this factsheet were obtained in December 1999. a Health numbers are toxicological numbers from animal testing or risk assessment values developed by EPA.

Regulatory numbers are values that have been incorporated in Government regulations, while advisory numbers are nonregulatory values provided by the Government or other groups as advice. OSHA numbers are regulatory, whereas NIOSH and ACGIH numbers are advisory. c
This LOAEL is from the critical study used as the basis for the ATSDR chronic inhalation MRL.

Summary created in April 1992, updated in January 2000
References

1. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for Xylenes (Update).

Public Health Service, U.S. Department of Health and Human Services, Altanta, GA. 1995.

2. E.J. Calabrese and E.M. Kenyon. Air Toxics and Risk Assessment. Lewis Publishers, Chelsea, MI. 1991.

3. U.S. Department of Health and Human Services. Hazardous Substances Data Bank (HSDB, online database).

National Toxicology Information Program, National Library of Medicine, Bethesda, MD. 1993.

4. J.E. Amoore and E. Hautala. Odor as an aid to chemical safety: Odor thresholds compared with threshold limit values and volatilities for 214 industrial chemicals in air and water dilution. Journal of Applied Toxicology, 3(6):272-290. 1983.

5. U.S. Department of Health and Human Services. Registry of Toxic Effects of Chemical Substances (RTECS, online database). National Toxicology Information Program, National Library of Medicine, Bethesda, MD. 1993.

6. U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Xylenes. National Center for Environmental Assessment, Office of Research and Development, Washington, DC. 1999.

7. American Conference of Governmental Industrial Hygienists (ACGIH). 1999 TLVs and BEIs. Threshold Limit Values for Chemical Substances and Physical Agents. Biological Exposure Indices. Cincinnati, OH. 1999.

8. National Institute for Occupational Safety and Health (NIOSH). Pocket Guide to Chemical Hazards. U.S.

Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention. Cincinnati, OH. 1997.

9. Occupational Safety and Health Administration (OSHA). Occupational Safety and Health Standards, Toxic and Hazardous Substances. Code of Federal Regulations 29 CFR 1910.1000. 1998.

10. U.S. Environmental Protection Agency. Health Effects Assessment Summary Tables. FY 1997 Update. Office of Research and Development, Office of Emergency and Remedial Response, Washington, DC. EPA/540/R97-036. 1997.

A. * This fact sheet refers to the mixture of all three isomers of mixed xylenes as "mixed mixed xylenes" and the isomers by their individual isomer names.

33.101
49 Size comparisons for PM
particles
Particulate Matter (PM) Basics
On This Page:

What is PM, and how does it get into the air? <https://www.epa.gov/pm-pollution/particulate-matter-pm-basics#pm> What are the harmful effects of PM? <https://www.epa.gov/pm-pollution/particulate-matter-pm-basics#effects> What is being done to reduce particle pollution? <https://www.epa.gov/pm-pollution/particulate-matter-pm-basics#reducing> How can I reduce my exposure to PM? <https://www.epa.gov/pm-pollution/particulate-matter-pm-basics#exposure> What is PM, and how does it get into the air?
PM stands for particulate matter (also called
particle pollution): the term for a mixture of
solid particles and liquid droplets found in the
air. Some particles, such as dust, dirt, soot, or
smoke, are large or dark enough to be seen
Size comparisons for PM particles
with the naked eye. Others are so small they can only be detected using an electron microscope.

Particle pollution includes:

PM10 : inhalable particles, with diameters that are generally 10 micrometers and smaller; and PM2.5 : fine inhalable particles, with diameters that are generally 2.5 micrometers and smaller.

How small is 2.5 micrometers? Think about a single hair from your head. The average human hair is about 70 micrometers in diameter – making it 30 times larger than the largest fine particle.

Sources of PM
These particles come in many sizes and shapes and can be made up of hundreds of different chemicals.

Some are emitted directly from a source, such as construction sites, unpaved roads, fields, smokestacks or fires.

Most particles form in the atmosphere as a result of complex reactions of chemicals such as sulfur dioxide and nitrogen oxides, which are pollutants emitted from power plants, industries and automobiles.

What are the Harmful Effects of PM?
Particulate matter contains microscopic solids or liquid droplets that are so small that they can be inhaled and cause serious health problems. Some particles less than 10 micrometers in diameter can get deep into your lungs and some may even get into your bloodstream. Of these, particles less than 2.5 micrometers in diameter, also known as fine particles or PM2.5, pose the greatest risk to health.

Fine particles are also the main cause of reduced visibility (haze) in parts of the United States, including many of our treasured national parks and wilderness areas.
<https://www.epa.gov/sites/default/files/2016-09/pm2.5_scale_graphiccolor_2.jpg>

33.102
50 Learn more about health and environmental effects <https://www.epa.gov/pm-pollution/health-and-environmental-effects-particulatematter-pm> What is Being Done to Reduce Particle Pollution?
EPA regulates inhalable particles. Particles of sand and large dust, which are larger than 10 micrometers, are not regulated by EPA.

EPA’s national and regional rules to reduce emissions of pollutants that form PM will help state and local governments meet the Agency’s national air quality standards. Learn about how air quality standards help reduce PM. <https://www.epa.gov/pm-pollution/setting-and-reviewing-standards-control-particulate-matter-pm-pollution> How Can I Reduce My Exposure to PM?
You can use air quality alerts to protect yourself and others when PM reaches harmful levels:

AirNow <https://www.airnow.gov/>: Every day the Air Quality Index (AQI) tells you how clean or polluted your outdoor air is, along with associated health effects that may be of concern. The AQI translates air quality data into numbers and colors that help people understand when to take action to protect their health.

Go to About AirNow <https://www.airnow.gov/about-airnow/> to learn how you can get AQI notifications.

Also learn how the Air Quality Flag Program <https://www.airnow.gov/air-quality-flag-program/> can help air agencies, schools, and other community organizations to notify their citizens of harmful conditions and adjust outdoor physical activities as needed.

Last updated on May 30, 2025

33.103
51 U.S. DEPARTMENT OF LABOR
Occupational Safety and Health Administration
Hydrogen Sulfide
Overview
Hydrogen sulfide (also known as H2S, sewer gas, swamp gas, stink damp, and sour damp) is a colorless gas known for its pungent "rotten egg" odor at low concentrations. It is extremely flammable and highly toxic.

Hydrogen sulfide is used or produced in a number of industries, such as Oil and gas refining
Mining
Tanning
Pulp and paper processing
Rayon manufacturing
Hydrogen sulfide also occurs naturally in sewers, manure pits, well water, oil and gas wells, and volcanoes. Because it is heavier than air, hydrogen sulfide can collect in low-lying and enclosed spaces, such as manholes, sewers, and underground telephone vaults. Its presence makes work in confined spaces potentially very dangerous.

The health effects of hydrogen sulfide depend on how much H2S a worker breathes and for how long. However, many effects are seen even at low concentrations. Effects range from mild, headaches or eye irritation, to very serious, unconsciousness and death.

This web page providesinformation on how hydrogen sulfide can affect your health, where you might find it, and how to prevent harmful exposures.

33.104
52 Hydrogen sulfide is one of the leading causes of workplace gas inhalation deaths in the United States. According to the Bureau of Labor Statistics (BLS), hydrogen sulfide caused 46 worker deaths between 2011 and 2017.

Standards
Evaluating/Controlling Exposure
Providesinformation on evaluating whether hydrogen sulfide gasis present and how to eliminate or control the source when possible.

Additional Resources
Provideslinks and referencesto additional resourcesrelated to hydrogen sulfide.

OSHA Standards Enforcement Topics Media Center Contact Us U.S. DEPARTMENT OF LABOR
Occupational Safety and Health Administration
200 Constitution Ave NW
Washington, DC 20210
7 1-800-321-OSHA
1-800-321-6742
www.osha.gov

FEDERAL GOVERNMENT OCCUPATIONAL SAFETY & HEALTH ABOUT THE SITE White House Frequently Asked Questions Freedom of Information Act Disaster Recovery Assistance A - Z Index Disclaimers
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33.105
53 Basic Information about Carbon Monoxide
(CO) Outdoor Air Pollution
On this page:

What is CO?
What are the harmful effects of CO?
What is being done to reduce CO pollution?
What is CO?
CO is a colorless, odorless gas that can be harmful when inhaled in large amounts. CO is released when something is burned.

The greatestsources of CO to outdoor air are cars,trucks and other vehicles or machinery that burn fossil fuels. A variety of items in your home such as unvented kerosene and gas space heaters, leaking chimneys and furnaces, and gasstoves also release CO and can affect air quality indoors.

Learn more about CO's impact on indoor air quality <https://epa.gov/indoor-air-quality-iaq/carbon-monoxides-impact-indoor-air-quality>.

What are the harmful effects of CO?
Breathing air with a high concentration of CO reduces the amount of oxygen that can be transported in the blood stream to critical organs like the heart and brain.

At very high levels, which are possible indoors or in other enclosed environments, CO can cause dizziness, confusion, unconsciousness and death.

Very high levels of CO are not likely to occur outdoors. However, when CO levels are elevated outdoors,they can be of particular concern for people with some types of heart disease. These people already have a reduced ability for getting oxygenated blood to their hearts in situations where the heart needs more oxygen than usual. They are especially vulnerable to the effects of CO when exercising or under increased stress. In these situations, short-term exposure to elevated CO may result in reduced oxygen to the heart accompanied by chest pain also known as angina.

What is being done about CO pollution?
Under the Clean Air Act, EPA sets and reviews standards for CO in outdoor air.

Setting and Reviewing Standardsto Control CO Pollution <https://epa.gov/co-pollution/setting-and-reviewing-standards-control-carbonmonoxide-co-pollution-outdoor-air> EPA standards and data help state, tribal and local agencies to make sure that CO is kept at a safe level.

Learn about how air quality standards help reduce CO <https://epa.gov/co-pollution/applying-or-implementing-outdoor-air-carbonmonoxide-co-standards> Last updated on June 17, 2025

33.106
54 Basic Information about NO2
On This Page:

What is NO2 and how does it get in the air?
What are the harmful effects of NO2?
What is being done to reduce NO2 pollution?
What is NO2 and how does it get in the air?
Nitrogen Dioxide (NO2) is one of a group of highly reactive gases known as oxides of nitrogen or nitrogen oxides (NOx). Other nitrogen oxides include nitrous acid and nitric acid. NO2 is used asthe indicator for the larger group of nitrogen oxides.

NO2 primarily gets in the air from the burning of fuel. NO2 forms from emissions from cars, trucks and buses, power plants, and off-road equipment.

Effects of NO2
Health effects
Breathing air with a high concentration of NO2 can irritate airwaysin the human respiratory system. Such exposures over short periods can aggravate respiratory diseases, particularly asthma, leading to respiratory symptoms (such as coughing, wheezing or difficulty breathing), hospital admissions and visitsto emergency rooms. Longer exposuresto elevated concentrations of NO2 may contribute to the development of asthma and potentially increase susceptibility to respiratory infections. People with asthma, as well as children and the elderly are generally at greater risk for the health effects of NO2.

NO2 along with other NOx reacts with other chemicals in the air to form both particulate matter and ozone. Both of these are also harmful when inhaled due to effects on the respiratory system.

Learn more about Particulate Matter <https://epa.gov/pm-pollution> and Ozone <https://epa.gov/ground-level-ozone-pollution>.

Environmental effects
NO2 and other NOx interact with water, oxygen and other chemicals in the atmosphere to form acid rain. Acid rain harms sensitive ecosystems such as lakes and forests.

Learn more about Acid Rain <https://epa.gov/acidrain>.

The nitrate particles that result from NOx make the air hazy and difficult to see though. This affects the many national parks that we visit for the view.

Learn more about Visibility and Haze <https://epa.gov/visibility>.

NOx in the atmosphere contributes to nutrient pollution in coastal waters.

Learn more about Nutrient Pollution <https://epa.gov/nutrientpollution>.

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55 What is being done to reduce NO2 pollution?
EPA’s national and regional rules to reduce emissions of NO2 and NOx will help state and local governments meet the National Ambient Air Quality Standard (NAAQS).

Learn about how air quality standards help reduce NO2 <https://epa.gov/no2-pollution/setting-and-reviewing-standards-control-no2- pollution>
EPA identifies areas where the air quality does not meet the national NO2 standards. For these areas, state, local, and tribal governments develop plans to reduce the amount of NO2 in the air.

Learn more about NO2 air quality designations and state implementation plans (SIPs) <https://epa.gov/no2-pollution/applying-orimplementing-nitrogen-dioxide-standards>.

Last updated on July 10, 2025

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56 Sulfur Dioxide Basics
What is SO2 and how does it get in the air?
What are the harmful effects of SO2?
What is being done to reduce SO2 pollution?
What is SO2 and how does it get in the air?
What is SO2?
EPA’s national ambient air quality standards for SO2 are designed to protect against exposure to the entire group of sulfur oxides(SOx). SO2 is the component of greatest concern and is used as the indicator for the larger group of gaseous sulfur oxides(SOx). Other gaseous SOx (such as SO3) are found in the atmosphere at concentrations much lower than SO2.

Control measures that reduce SO2 can generally be expected to reduce people’s exposures to all gaseous SOx. This may have the important co-benefit of reducing the formation of particulate sulfur pollutants,such asfine sulfate particles.

Emissions that lead to high concentrations of SO2 generally also lead to the formation of other SOx. The largest sources of SO2 emissions are from fossil fuel combustion at power plants andother industrial facilities.

How does SO2 get in the air?
The largest source of SO2 in the atmosphere isthe burning of fossil fuels by power plants and other industrial facilities.

Smaller sources of SO2 emissions include: industrial processes such as extracting metal from ore; natural sources such as volcanoes; and locomotives,ships and other vehicles and heavy equipment that burn fuel with a high sulfur content.

What are the harmful effects of SO2?
SO2 can affect both health and the environment.

What are the health effects of SO2?
Short-term exposures to SO2 can harm the human respiratory system and make breathing difficult. People with asthma, particularly children, are sensitive to these effects of SO2.

SO2 emissionsthat lead to high concentrations of SO2 in the air generally also lead to the formation of other sulfur oxides (SOx). SOx can react with other compounds in the atmosphere to form small particles. These particles contribute to particulate matter(PM) pollution. Small particles may penetrate deeply into the lungs and in sufficient quantity can contribute to health problems.

Learn more about particulate matter <https://epa.gov/pm-pollution> What are the environmental effects of SO2 and other sulfur oxides? At high concentrations, gaseous SOx can harm trees and plants by damaging foliage and decreasing growth.

SO2 and other sulfur oxides can contribute to acid rain which can harm sensitive ecosystems.

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57 Learn more about acid rain <https://epa.gov/acidrain> Visibility
SO2 and other sulfur oxides can react with other compounds in the atmosphere to form fine particles that reduce visibility (haze) in parts of the United States, including many of our treasured national parks and wilderness areas.

Learn more about visibility and regional haze <https://epa.gov/visibility> Deposition of particles can also stain and damage stone and other materials, including culturally important objects such as statues and monuments.

What is being done to reduce SO2 pollution?
EPA’s national and regional rules to reduce emissions of SO2 and pollutants that form sulfur oxides (SOx) will help state and local governments meet the Agency’s national air quality standards.

Learn about how air quality standards help reduce SO2 <https://epa.gov/so2-pollution/setting-and-reviewing-standards-control-so2- pollution>
EPA identifies areas where the air quality does not meet EPA SO2 standards. For these areas, state, local, and tribal governments develop plans to reduce the amount of SO2 in the air.

Learn more about SO2 air quality designations and state implementation plans (SIPs) <https://epa.gov/so2-pollution/applying-orimplementing-sulfur-dioxide-standards> Last updated on January 2, 2026

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58 References
Environmental Protection Agency. (2025, June 17). Basic Information about Carbon Monoxide (CO) Outdoor Air Pollution. Retrieved from United States Environmental Protection Agency: https://www.epa.gov/co-pollution/basic-information-aboutcarbon-monoxide-co-outdoor-air-pollution Environmental Protection Agency. (2025, July 10). Basic Information about NO2. Retrieved from United States Environmental Protection Agency: https://www.epa.gov/no2- pollution/basic-information-about-no2
Environmental Protection Agency. (2025, November 24). Health Effects Notebook for Hazardous Air Pollutants. Retrieved from United States Environmental Protection Agency: https://www.epa.gov/haps/health-effects-notebook-hazardous-airpollutants Environmental Protection Agency. (2025, May 30). Particulate Matter (PM) Basics. Retrieved from United States Environmental Protection Agency: https://www.epa.gov/pmpollution/particulate-matter-pm-basics Environmental Protection Agency. (2026, January 2). Sulfur Dioxide Basics. Retrieved from United States Environmental Protection Agency: https://www.epa.gov/so2- pollution/sulfur-dioxide-basics
Krop, L., & Haden, M. (2015). Refugio Oil Spill: Public Guide to Natural Resource Damage Assessment Process. Santa Barbara, CA: Environmental Defense Center.

Occupational Safety and Health Administration. (n.d.). Hydrogen Sulfide. Retrieved from U.S. Department of Labor Occupational Safety and Health Administration:
https://www.osha.gov/hydrogen-sulfide

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Brittany Inclan
From: Tim Ibbotson-Sindelar <[email protected]> Sent: Tuesday, June 2, 2026 7:17 PM
To: City Council
Subject: RE: Support for June 9th Council Agenda Item – Ordinance related to protections against off-shore oil and gas and deep-sea mining
Dear Santa Cruz City Council,
I'm writing in strong support of the proposed updates to local ordinances that govern offshore oil and deep-sea mining onshore support facilities.

I surf, I work in agriculture at Driscoll's, and I love the pristine Santa Cruz ocean and coast. Santa Cruz's pristine coast is essential to much of Santa Cruz's beauty, economy, and spirit. It would be shortsighted to allow offshore oil drilling and deep sea mining off the coast of Santa Cruz. I would be incredibly disappointed in our local government if we did not take action to prevent this to the best of our ability.

Key points:
 Deep-sea mining and offshore oil poses significant threats to marine ecosystems: habitat destruction, biodiversity loss, sediment plumes, and impacts to ocean health.  Preventing the construction of onshore staging, processing, storage, and transportation infrastructure associated with these industries is one of the most effective tools local governments have to protect coastal communities and marine environments.  By updating these ordinances now, [Santa Cruz County/City] will once again help lead a statewide effort to preserve California’s coastline, marine sanctuary waters, coastal economy, and public trust resources for future generations.
 The 2026 revised ordinance provides a modern and legally robust framework that reflects the latest science and policy understanding regarding offshore oil development and deep sea mining.  The ordinance preserves the right of Santa Cruz voters to decide whether future zoning changes should enable onshore facilities supporting these industries Thanks,
-Timothy Ibbotson-Sindelar

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Brittany Inclan
From: Fifer Garbesi <[email protected]>
Sent: Tuesday, June 2, 2026 7:20 PM
To: City Council
Cc: Katie Thompson
Subject: RE: Support for June 9th Council Agenda Item – Ordinance related to protections against off-shore oil and gas and deep-sea mining
Dear City Council,
I am writing to express my strong support of the proposed updates to local ordinances that govern offshore oil and deep-sea mining onshore support facilities.

I live by the ocean, spearfish, dive, and surf. Development of deep sea mining and offshore drilling here would destroy our city's soul as well as our economy. Instead of being a hub for ocean lovers to visit from all over the world, we would sacrifice our environmental and public health for a couple of companies to make profits. Students come here to literally study ocean health and we would lose the ability to truly teach about this.

While we cannot control what happens in Federal waters, let's make this a HIGHLY UNDESIRABLE place to bid for oil leases. The first version of these ordinances were effective in stopping new oil development and I'd love to continue to live and love the ocean here.

Thank you very much,
Fifer Garbesi
Resident - Natural Bridges Area

33.113
Brittany Inclan
From: Christopher Cogan <[email protected]>
Sent: Tuesday, June 2, 2026 7:35 PM
To: City Council
Subject: RE: Support for June 9th Council Agenda Item – Ordinance related to protections against off-shore oil and gas and deep-sea mining
Dear City Council,
I am writing to strongly encourage you to vote yes on the Blue Wall 2.0 ordinance.

I run a small consulting company based in Santa Cruz that is dedicated to expanding the use of renewable energy. We do this work to counteract the myopic pursuit of short-term profits at the expense of the long-term health of humanity and the planet. Offshore drilling and deep-sea mining perpetuate these problems rather than solve them.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California's coast for generations.

Deep-sea mining poses significant and still poorly understood threats to marine ecosystems, including habitat destruction, biodiversity loss, sediment plumes, and impacts to ocean health. Preventing the construction of onshore staging, processing, storage, and transportation infrastructure associated with these industries is one of the most effective tools local governments have to protect coastal communities and marine environments.

Strengthening these protections also reinforces Santa Cruz's longstanding environmental leadership.

The success of the original Blue Wall demonstrated that local governments can effectively defend the coast, even in the face of industry litigation and federal pressure. By updating these ordinances now, the City of Santa Cruz will once again help lead a statewide effort to preserve California's coastline, marine sanctuary waters, coastal economy, and public trust resources for future generations.

Thanks,
Chris Cogan
Resident, Seabright neighborhood, Santa Cruz

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Brittany Inclan
From: Hannah Meade <[email protected]>
Sent: Tuesday, June 2, 2026 7:41 PM
To: City Council
Cc: [email protected]
Subject: RE: Support for June 9th Council Agenda Item – Ordinance related to protections against off-shore oil and gas and deep-sea mining
Dear City Council,
My name is Hannah Meade and live in Seabright neighborhood.

I’m writing in strong support of the proposed updates to local ordinances that govern offshore oil and deep-sea mining onshore support facilities.

I live and work on the coast. I live in the beautiful Seabright neighborhood and walk to the beach after work everyday. I work at Verve Coffee Roasters, a global brand that claims Santa Cruz as home and its natural beauty is a major part of the brand. Anything harming the natural beauty of Santa Cruz directly negatively impacts the brand and business.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

Deep-sea mining poses significant and still poorly understood threats to marine ecosystems, including habitat destruction, biodiversity loss, sediment plumes, and impacts to ocean health. Preventing the construction of onshore staging, processing, storage, and transportation infrastructure associated with these industries is one of the most effective tools local governments have to protect coastal communities and marine environments.

Strengthening these protections also reinforces Santa Cruz’s longstanding environmental leadership.

The success of the original Blue Wall demonstrated that local governments can effectively defend the coast, even in the face of industry litigation and federal pressure. By updating these ordinances now, Santa Cruz City will once again help lead a statewide effort to preserve California’s coastline, marine sanctuary waters, coastal economy, and public trust resources for future generations.

Thank you kindly,
Hannah Meade

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Brittany Inclan
From: Kaitilin Gaffney <[email protected]>
Sent: Thursday, June 4, 2026 1:30 PM
To: City Council
Subject: Support for Onshore Infrastructure Ordinance
Attachments: Gaffney Support Letter OCS and Seabed Mining Ord Santa Cruz City Council June 2026.pdf
Please distribute to the City Council in advance of their June 9 meeting. Thank you! Kaiitlin Gaffney

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Kaitilin Ganey
179 Pryce Street
Santa Cruz, CA 95060
Delivered by electronic mail to: [email protected] June 4, 2026
Mayor Keeley and
Members of the Santa Cruz City Council
809 Center Street
Santa Cruz, CA 95060
Re: SUPPORT: Oil/Deep-sea mining onshore infrastructure ordinance Dear Mayor Keeley and Members of the Santa Cruz City Council:

I am a 27-year resident of Santa Cruz and I have spent my entire career working to advance ocean conservation. I am writing today to urge your support for revision of Santa Cruz County’s existing onshore infrastructure ordinance to modernize and strengthen its language to better address current and emerging threats to the Monterey Bay National Marine Sanctuary and Central Coast.

I care about the onshore infrastructure ordinance because a clean and thriving ocean is personally important to me and my family. A couple of times each week I wake up early to walk along West Cliff Drive and watch the sunrise across Monterey Bay. In the summer and fall, I swim with friends off Cowells Beach. My kids grew up boogie boarding, tidepooling, and kayaking at Elkhorn Slough on special occasions. The state of the ocean and coast is important to us recreationally and spiritually and as a place of community. And my family is not alone. In annual statewide public surveys, 94 percent of Californians say that the condition of our oceans and beaches is important or very important to both the state’s future economy and our quality of life.1
The City of Santa Cruz City and Santa Cruz County have a strong historical legacy of ocean and coastal conservation leadership. More than four decades ago, local leaders organized what became a statewide effort to protect the California Coast from new offshore oil drilling which led to establishment of the Monterey Bay National Marine Sanctuary.

With the Trump Administration’s aggressive push to develop new offshore oil and gas leases and promote risky deep-sea mining, Santa Cruz political leadership is again needed to fight emerging threats.

We have seen time and time again the inevitable harm associated with offshore oil and gas development as oil spills have fouled beaches in Santa Barbara and Marin in recent years, harming wildlife to our immediate north and south. And we can predict new harms to fragile deep-sea habitats and species that would come with industrial mining activities.

As a local resident who deeply values a clean and healthy Monterey Bay, I urge your support for the 2026 revised onshore infrastructure ordinance as a critical step Santa Cruz can take to defend against the potential harm of poorly planned and insufficiently regulated offshore energy and mineral development.

Please vote for the strengthened and expanded ordinance and partner with other coastal jurisdictions and state leaders to ensure the California coast is protected from the threats this ordinance is intended to address.

Thank you for your consideration.

Regards,
Kaitilin Ganey
1 Public Policy Institute of California. Statewide Survey: Californians and the Environment (2025).

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1 Julia Wood
From: Tara Leonard <[email protected]>
Sent: Friday, June 5, 2026 8:19 AM
To: City Council
Subject: NO Offshore Oil Drilling!
Dear City Council Members,
I am writing to express my strong support for an ordinance that strengthens the City of Santa Cruz’s protections against offshore oil drilling and deep-sea mining (agenda item #33). The rapaciousness of the current federal administration knows no bounds. We must fight back to prevent the economic, ecological, and public health damage that these activities would impose on our coastal community. A clean, healthy ocean is not just an economic driver for our local economy, but the bedrock of our environmentally conscious way of life. Santa Cruz has always been a leader in environmental protection. Please continue that proud legacy by strengthening and modernizing the existing protections.

Sincerely,
Tara Leonard
City of Santa Cruz resident

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2 Julia Wood
From: Pauline Seales <[email protected]>
Sent: Friday, June 5, 2026 8:34 AM
To: City Council; Katie Thompson; SC CAN discussion
Subject: RE: Support for June 9th Council Agenda Item 33 – Ordinance related to protections against offshore oil and gas and deep-sea mining” Dear City Council

My name is Pauline Seales. I live in lower westside and represent the 2025 members of Santa Cruz Climate Action Network

I’m writing in strong support of the proposed updates to local ordinances that govern offshore oil and deep-sea mining onshore support facilities.

Any degradation of our beautiful ocean coastal environment cannot be allowed. A healthy ocean is an essential part of the heart and soul of the city. And it's a huge part of our economy.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

THANKS for voting YES on item 33 June 9.

Pauline Seales

33.119
3 Julia Wood
From: Mark McKinney <[email protected]>
Sent: Friday, June 5, 2026 9:38 AM
To: City Council
Subject: Agenda Item 33: Amendments to Municipal Code Title 24 To: Santa Cruz City Council Members
From: Mark McKinney
Date: June 5, 2026
Dear Santa Cruz City Council Members:

As a resident of Santa Cruz County, I strongly support the Board’s efforts to revise its 1980’s onshore infrastructure ordinance to strengthen its legal foundations and address the renewed pressure for nonrenewable resource extraction along the California coast.

Please approve this strengthened and expanded ordinance so that the people of Santa Cruz County can continue to make their voices heard in defense of our coast, our communities, and future generations.

Thank you for your continued leadership on this important issue.

Sincerely,
Mark McKinney
Santa Cruz Resident

33.120
4 Julia Wood
From: Tracey Weiss <[email protected]>
Sent: Friday, June 5, 2026 1:15 PM
To: City Council
Subject: Letter of Support - Agenda Item 33
Attachments: OSO Blue Wall Endorsement 2026.pdf
Good Morning -
Please accept the following letter of support regarding the Agenda Item #33 for the Santa Cruz City Council Meeting on June 9th in favor amending municipal code in protections Against On-Shore Facilities Supporting Off-Shore Oil and Gas Drilling and Deep-Sea Mining and Exploration, and Corresponding Changes to the City’s Local Coastal Program Implementation Plan (CM/CD/CN) Thank you to Vice Mayor Kalentari-Johnson for her leadership regarding this matter.

In Community,
Tracey
--
Tracey Weiss (she/her)
Executive Director
P: 831-465-9390
M: 408-472-1415
W: www.oneillseaodyssey.org
E: [email protected]
Save the Date! Celebrating 30 Years of Legacy on the Ocean!

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O’Neill Sea Odyssey provides free and transformative ocean-going educational experiences to students from diverse backgrounds, igniting scientific curiosity and empowering them to take action to protect our oceans and watersheds.

A California Non-Profit Corporation Federal ID #77-0464784 2222 East Cliff Drive Suite 222
Santa Cruz CA 95062
P: (831) 475-1561
oneillseaodyssey.org
Board of Supervisors, Santa Cruz County
701 Ocean Street, Room 500
Santa Cruz, CA 95060
Re: Support for Updates to Ordinance Governing Offshore Oil and Deep-Sea Mining Support Facilities June 4, 2026
Dear Chair Martinez and Supervisors Koenig, Cummings, Hernandez, De Serpa:

On behalf of O’Neill Sea Odyssey (OSO) and in partnership with Save Our Shores and other our community partners, I write in strong support of the proposed updates to local ordinances that govern offshore oil and deep-sea mining onshore support facilities.

Founded by wetsuit innovator and philanthropist Jack O’Neill, OSO embodies his foundational call to action:
“The ocean is alive, and we’ve got to take care of it.” As a 501(c)(3) environmental education nonprofit here in Santa Cruz, we engage 4th through 6th grade youth with hands-on science and environmental education field trips aboard our 65-foot catamaran on Monterey Bay, as well as in our shore-side education center. Our core mission is to provide these immersive experiences to encourage the protection and preservation of our living sea and communities.

We know firsthand that pristine, safe, and clean ocean environments are essential for youth to build the personal and communal connections needed to understand how the ocean influences their health and wellbeing. Our regional identity and thriving "Blue Economy" rely entirely on the health of the Monterey Bay National Marine Sanctuary.

California’s coastal governments are once again mobilizing to defend the state’s shoreline from intensified federal efforts to expand offshore oil and gas development and authorize seabed mining. The federal government’s Five-Year Outer Continental Shelf (OCS) Oil and Gas Leasing Program proposes offshore lease areas along the California coast, representing an aggressive push for offshore extraction. At the same time, recent federal actions have opened the door to deep-sea mining for rare earth and critical minerals in federal waters. Investing in outdated fossil fuel infrastructure in an ecosystem as ecologically sensitive as Monterey Bay is a step backward; it exacerbates climate change and leaves delicate marine systems vulnerable to devastating oil spills.

Santa Cruz has long played a leading role in protecting California’s coast from these threats. During the 1980s, local governments across California exercised their land-use authority to prevent the development of onshore facilities necessary to support offshore drilling operations. This framework became known as California’s “Blue Wall” — a network of twenty-seven coastal jurisdictions that effectively deterred offshore drilling by preventing access to the onshore infrastructure required to support extraction activities. Santa Cruz was at the forefront of this movement.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Deep-sea mining poses significant threats to marine ecosystems, including habitat destruction, biodiversity loss, sediment plumes, and severe impacts to ocean health. Updating these ordinances to explicitly address facilities supporting seabed mining

33.122
O’Neill Sea Odyssey provides free and transformative ocean-going educational experiences to students from diverse backgrounds, igniting scientific curiosity and empowering them to take action to protect our oceans and watersheds.

A California Non-Profit Corporation Federal ID #77-0464784 ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

Preventing the construction of onshore staging, processing, storage, and transportation infrastructure associated with these industries is one of the most effective tools local governments have to protect coastal communities and marine environments. By updating these ordinances now, Santa Cruz County will once again lead a statewide effort to preserve California’s coastline, marine sanctuary waters, and public trust resources for the next generation of ocean stewards.

On behalf of today’s youth, and tomorrow’s ocean stewards, I respectfully urge the Santa Cruz City Council and the Board of Supervisors to adopt these ordinance updates and continue Santa Cruz’s proud legacy of coastal protection and environmental stewardship.

Thank you for your leadership and consideration.

In Community,
Tracey Weiss
Executive Director O’Neill Sea Odyssey

33.123
5 Julia Wood
From: Anekha Goyal <[email protected]>
Sent: Friday, June 5, 2026 2:26 PM
To: City Council
Cc: [email protected]
Subject: RE: Support for June 9th Council Agenda Item #33 Dear City Council,
My name is Anekha Goyal, and I live in Live Oak. I serve as the Manager of Sustainable Operations at UCSC.

I’m writing in strong support of the proposed updates to local ordinances that govern offshore oil and deep-sea mining onshore support facilities.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

With so many ecosystems being destroyed and depleted, this is one step the city can take to protect something. Any further destruction has long-term humanitarian, economic, and social consequences.

By updating these ordinances now, Santa Cruz City will once again help lead a statewide effort to preserve California’s coastline, marine sanctuary waters, coastal economy, and public trust resources for future generations.

Thanks,
Anekha Goyal (she/her)
Manager of Sustainable Operations
University of California, Santa Cruz
Calendly | 831.459.3889 (o)

33.124
Brittany Inclan
From: Alan Peevers <[email protected]>
Sent: Saturday, June 6, 2026 8:58 AM
To: City Council
Subject: RE: Support for June 9th Council Agenda Item – Ordinance related to protections against off-shore oil and gas and deep-sea mining
Dear City Council and Mayor Keeley,

My name is Alan Peevers, and I’ve lived in Santa Cruz since 1994. I love our beautiful city.

I’m writing in strong support of the proposed updates to local ordinances that govern onshore infrastructure for offshore oil and deep-sea mining.

All efforts to permit oil extraction or seabed mining should be blocked using whatever tools and alliances we have available. The environmental consequences and habitat loss of such developments would be catastrophic. A new report has determined that oil spills are inevitable from new oil rigs. Our local economy would be adversely affected as well. Finally, burning more oil will make for more misery for future generations.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to reflect more recent case law and explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

THANKS for voting YES on item 33 June 9.

Alan W Peevers

33.125
Brittany Inclan
From: Eric Lombardo <[email protected]>
Sent: Saturday, June 6, 2026 12:29 PM
To: City Council
Cc: Bonnie Bush
Subject: Public comment - support for item #33
Dear Santa Cruz City Council,
My name is Eric Lombardo, I am a Santa Cruz resident, and I am writing in support of Item 33 on the 6/9/26 agenda. I submit this comment as a private citizen not on behalf of any organization or my employer.

I’m in strong support of the proposed update to City ordinances that govern onshore support facilities for offshore oil extraction and deep-sea mining. These facilities have no place in Santa Cruz, they are risky, dangerous, and threaten our National Marine Sanctuary and the health of our community.

I'm very glad our city government is taking a leadership position on this issue, continuing its environmental protection legacy from the passage of Measure A by City voters in 1985 that originally banned these facilities but did not contemplate deep sea mining as that industry did not exist yet.

I am in strong support of item #33.

Sincerely,
Eric Lombardo
Santa Cruz, California

33.126
Brittany Inclan
From: Pauline Seales <[email protected]>
Sent: Saturday, June 6, 2026 2:25 PM
To: Alan Peevers
Cc: City Council
Subject: Re: Support for June 9th Council Agenda Item – Ordinance related to protections against off-shore oil and gas and deep-sea mining
Hey Alan
Thanks Alan
On Sat, Jun 6, 2026 at 9:32 AM Alan Peevers <[email protected]> wrote:

Dear City Council and Mayor Keeley,

My name is Alan Peevers, and I’ve lived in Santa Cruz since 1994. I love our beautiful city.

I’m writing in strong support of the proposed updates to local ordinances that govern onshore infrastructure for offshore oil and deep-sea mining.

All efforts to permit oil extraction or seabed mining should be blocked using whatever tools and alliances we have available. The environmental consequences and habitat loss of such developments would be catastrophic. A new report has determined that oil spills are inevitable from new oil rigs. Our local economy would be adversely affected as well. Finally, burning more oil will make for more misery for future generations.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to reflect more recent case law and explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

THANKS for voting YES on item 33 June 9.

Alan W Peevers

33.127
Brittany Inclan
From: George Galt <[email protected]>
Sent: Sunday, June 7, 2026 11:01 AM
To: City Council
Subject: Support for June 9, 2026 Council Agenda Item #33 Dear Members of the City Council,
My name is George Galt, and I live in Boulder Creek. I'm writing in support of the proposed updates to local ordinances that control offshore oil and deep-sea mining onshore support facilities.

Emerging technologies are often not reflected in the wording of laws and ordinances. Unforeseen advances can make well thought out regulations no longer complete enough to fulfill their original purpose. That is the case with the so-called "Blue Wall" measures. In order for those measures to continue to perform their intended functions, they must be updated to include restrictions on deep sea mining and related onshore support facilities.

I strongly support the proposed updates to these ordinances.

Thank you so much for your time and your public service.

Sincerely, George Galt

33.128
Brittany Inclan
From: Michelle McKinney <[email protected]>
Sent: Sunday, June 7, 2026 11:57 AM
To: City Council
Subject: Agenda Item 33: Amendments to Municipal Code Title 24 Dear Santa Cruz City Council,
As a resident of Santa Cruz County, I strongly support the City Council’s efforts to revise its 1980’s onshore infrastructure ordinance to strengthen its legal foundations and address the renewed pressure for non-renewable resource extraction along the California coast.

At a time when the Trump Administration is advancing new offshore oil and gas lease sales off California and promoting the rapid expansion of deep sea mining in U.S. and international waters, Santa Cruz has an important opportunity to reaffirm our community’s long-standing commitment to protecting the Monterey Bay and our coastal economy from harmful industry practices. Recent federal actions have included proposals for six new offshore drilling lease sales off California for the first time in decades, along with efforts to accelerate commercial deep seabed mining elsewhere that may put California at future risk.

The extraction of non-renewable resources from our ocean environment poses significant risks to marine biodiversity, fisheries, surfing, tourism, public health, water quality, coastal resilience, and the natural character of our region. Santa Cruz County and the City of Santa Cruz were leaders in the 1980s in adopting local protections against onshore infrastructure supporting offshore oil drilling. Updating these ordinances now is both prudent and necessary.

As someone who deeply values clean beaches, thriving kelp forests, healthy fisheries, clean air and water, and the extraordinary natural beauty of Monterey Bay, I understand that offshore oil drilling and seabed mining threaten the very qualities that make Santa Cruz special. I recently became grandma to Jackson and Halle June. They deserve to understand the importance of the interactions between living and non-living things, and to continue our family’s dedication to stewardship of not only our home, but all the creatures and components that work together to maintain a thriving planet.

The 2026 revised ordinance provides a modern and legally robust framework that reflects the latest science and policy understanding regarding offshore oil development and deep sea mining. Importantly, the ordinance preserves the right of Santa Cruz voters to let their voices be heard considering whether future zoning changes should enable onshore facilities supporting these industries.

Please approve this strengthened and expanded ordinance so that the people of Santa Cruz County can continue to make their voices heard in defense of our coast, our communities, and future generations.

Thank you for your continued leadership on this important issue.

Sincerely,
Michelle McKinney
Retired educator and grandma to Jackson and Halle June

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Brittany Inclan
From: Carol Maynard <[email protected]>
Sent: Sunday, June 7, 2026 2:38 PM
To: City Council
Subject: RE: Support for June 9th Council Agenda Item #33 Dear City Council,
My name is Carol Maynard and I have lived in the Branciforte East neighborhood for 30 years.

I am writing is very strong support for updating local ordinances governing offshore oil drilling and deep-sea mining onshore support facilities.

I believe that the Monterey Bay Sanctuary, as it is designated, should continue to be protected to ensure a healthy eco system in our oceans as well as onshore. In addition, we need to protect the economic systems that have been in place for generations: fishing, boating, surfing and other water sports, tourism. We have also committed to protect the health and general well-being of our community, which would directly threatened by these new industries.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

Please vote yes on the ordinance.

Thank you,
Carol Maynard
[email protected]
831-345-3432

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Brittany Inclan
From: Gwynn Benner <[email protected]>
Sent: Sunday, June 7, 2026 5:22 PM
To: City Council
Cc: [email protected]
Subject: RE: Support for June 9th Council Agenda Item #33 Please find attached my letter of support for the June 9th City Council Agenda Item #33. 26.06.07-SC City Council-SaveOurShores.pdf

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Dear Santa Cruz City Council,
My name is Gwynn Benner and I live in the upper west side of Santa Cruz.

I’m writing in strong support of the proposed updates to local ordinances that govern offshore oil and deep-sea mining onshore support facilities.

I serve as a Sanctuary Steward for Save Our Shores, working closely with the staff on beach clean ups and pollution prevention. I am also a volunteer with the Snowy Plover Guardian program for California State Parks…which is all to say that I am at the beach weekly, monitoring birds, educating the public (visitors and residents), picking up trash, and enjoying the magnificent beaches and ocean views of Monterey Bay.

As stewards of this extraordinary place, you have a responsibility to protect this critical habitat that sustains us, supports our economy, and is the life-blood for so many species. Therefore, I am asking you to pass these ordinances before you on June 9th because they close existing loop holes, ensure this magnificent coast line is protected for future generations, and will ensure long-lasting economic benefits for our communities.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

Deep-sea mining poses significant and still poorly understood threats to marine ecosystems, including habitat destruction, biodiversity loss, sediment plumes, and impacts to ocean health.

Preventing the construction of onshore staging, processing, storage, and transportation infrastructure associated with these industries is one of the most effective tools local governments have to protect coastal communities and marine environments.

Strengthening these protections also reinforces Santa Cruz’s longstanding environmental leadership. The success of the original Blue Wall demonstrated that local governments can effectively defend the coast, even in the face of industry litigation and federal pressure. By updating these ordinances now, Santa Cruz will once again help lead a statewide effort to preserve California’s coastline, marine sanctuary waters, coastal economy, and public trust resources for future generations.

Thank you,
Gwynn Benner
209 Sheldon Avenue
Santa Cruz, CA 95060

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Brittany Inclan
From: Melissa Mahoney <[email protected]>
Sent: Sunday, June 7, 2026 5:44 PM
To: City Council
Subject: Reference Agenda Item 33 - public comment
Attachments: To_ Santa Cruz City Council Members.pdf
please see attached.
thank you,
Melissa Mahoney
SC Resident

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To: Santa Cruz City Council Members
From: Melisa Mahoney
Date: June 8, 2026
Re: Reference Agenda Item 33: Amendments to Municipal Code Title 24, Zoning, Related to Protections Against On-Shore Facilities Supporting Off-Shore Oil and Gas Drilling and Deep-Sea Mining and Exploration, and Corresponding Changes to the City’s Local Coastal Program Implementation Plan (CM/CD/CN)
Dear Members of the Santa Cruz City Council:

As someone who lives, works, and enjoys recreation in Santa Cruz County, I care deeply about the health of our coast and the communities that depend on it. I am a resident of Santa Cruz County and have worked in ocean conservation and West Coast fisheries management for more than 20 years. I strongly support the Board’s efforts to modernize its 1980s onshore infrastructure ordinance to strengthen its legal foundation and address renewed threats from offshore oil drilling and deep seabed mining.

At a time when the federal government is advancing new offshore oil and gas lease sales off California and promoting the expansion of deep seabed mining, Santa Cruz County has an important opportunity to reaffirm its long-standing commitment to protecting Monterey Bay and the coastal economy that depends on a healthy ocean. Updating this ordinance to reflect today’s realities is both prudent and necessary.

The extraction of non-renewable resources from our marine environment poses significant risks to marine biodiversity, commercial and recreational fisheries, tourism, surfing, water quality, public health, coastal resilience, and the natural character that defines our region. Santa Cruz County has long been a leader in opposing infrastructure that would facilitate offshore oil development, and adopting this updated ordinance would continue that legacy while addressing emerging threats.

Beyond environmental concerns, offshore oil development and deep seabed mining threaten our food security. As someone who works closely with California’s fishing communities, I have seen firsthand the importance of healthy ocean ecosystems to sustain local livelihoods and provide nutritious local food. Wild-caught seafood is one of the most climate-efficient sources of animal protein available, and responsibly managed federal fisheries provide a renewable domestic food supply with a lower carbon footprint than most land-based protein production. Introducing high-risk industrial activities into these waters jeopardizes that sustainable food source at a time when climate change, supply chain disruptions, and global instability are placing increasing pressure on food systems. Protecting ocean health is inseparable from protecting food security as well as our coastal economy.

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The proposed ordinance provides a modern, legally sound framework that reflects current science and policy while preserving the public’s ability to weigh in on future proposals for onshore facilities supporting offshore oil development or deep seabed mining.

I respectfully urge you to approve this strengthened ordinance so that Santa Cruz County can continue to protect its coast, its communities, and future generations from unnecessary and irreversible risks.

Thank you for your leadership and your commitment to safeguarding the extraordinary natural resources that make Santa Cruz County such a remarkable place to live.

Sincerely,
Melissa Mahoney,
Santa Cruz City resident
[email protected]

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Brittany Inclan
From: Denise Blair <[email protected]>
Sent: Sunday, June 7, 2026 6:25 PM
To: [email protected]; City Council To: Santa Cruz Board of Supervisors and Santa Cruz City Council Members From: Denise Blair
Date: June 7, 2026
Re: SUPPORT: Agenda Item: Oil/Deep-sea mining onshore infrastructure ordinance
Dear Members of the Santa Cruz County Board of Supervisors and Santa Cruz City Council Members:

As a resident of Santa Cruz County, I strongly support the Board’s/Council’s efforts to revise its 1980’s onshore infrastructure ordinance to strengthen its legal foundations and address the renewed pressure for non-renewable resource extraction along the California coast.

At a time when the Trump Administration is advancing new offshore oil and gas lease sales off California and promoting the rapid expansion of deep sea mining in U.S. and international waters, Santa Cruz has an important opportunity to reaffirm our community’s long-standing commitment to protecting the Monterey Bay and our coastal economy from harmful industry practices. Recent federal actions have included proposals for six new offshore drilling lease sales off California for the first time in decades, along with efforts to accelerate commercial deep seabed mining elsewhere that may put California at future risk.

The extraction of non-renewable resources from our ocean environment poses significant risks to marine biodiversity, fisheries, surfing, tourism, public health, water quality, coastal resilience, and the natural character of our region. Santa Cruz County and the City of Santa Cruz were leaders in the 1980s in adopting local protections against onshore infrastructure supporting offshore oil drilling.

Updating these ordinances now is both prudent and necessary.

As someone who deeply values clean beaches, thriving kelp forests, healthy fisheries, clean air and water, and the extraordinary natural beauty of Monterey Bay, I understand that offshore oil drilling and seabed mining threaten the very qualities that make Santa Cruz special. As a long time educator in the community, my students and I have been dedicated stewards of our coastal community
The 2026 revised ordinance provides a modern and legally robust framework that reflects the latest science and policy understanding regarding offshore oil development and deep sea mining. Importantly, the ordinance preserves the right of Santa Cruz voters to let their voices be heard considering whether future zoning changes should enable onshore facilities supporting these industries.

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Please approve this strengthened and expanded ordinance so that the people of Santa Cruz County can continue to make their voices heard in defense of our coast, our communities, and future generations.

Thank you for your continued leadership on this important issue.

Sincerely,
Denise Blair
Santa Cruz Resident and Retired Educator

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Brittany Inclan
From: Susan Sogard <[email protected]>
Sent: Sunday, June 7, 2026 6:40 PM
To: City Council
Subject: Support for June 9th Council Agenda Item #33
I am writing to express my support of local ordinances that restrict onshore support facilities for offshore oil drilling and deep-sea mining. Protecting our local marine ecosystems is vital for the continued economic and environmental benefits they provide now and will continue to do so into the distant future. Preventing the construction of onshore infrastructure is essential for inhibiting destructive industry practices in offshore waters beyond state jurisdiction.

Please vote yes to update the infrastructure ordinances and protect our ocean resources.

Thank you.

Susan Sogard
567 Hacienda Dr.

Scotts Valley, CA 95066

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Brittany Inclan
From: Dave Alexander <[email protected]>
Sent: Sunday, June 7, 2026 10:25 PM
To: City Council
Subject: Agenda Item 33: Amendments to Municipal code title 24 I am requesting the council approve the resolution approving the ballot measure to amend Chapter

16.55 of the Santa Cruz County Code.

Having just returned from meeting with colleagues in Washington DC who participate in executive and congressional energy policy discussions, we cannot be complacent locally. This administration will use all means to distract voter attention from failed energy policies and target California. We must make every effort to change our energy infrastructure and promote renewables over fossil fuel extraction.

Amendmending Municipal code title 24 to encumber extractive industry practices while leaving open possibility for wind or other renewable energy sends a message to energy businesses about where the opportunities are in California. Extractive and polluting industry practices are not acceptable and not allowed. No signal to this administration will matter, but the fossil fuel business and other enviromentally unsafe extractive practices can be regulated and disincentivised at the local level.

Kindly,
David Alexander, PhD.

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Brittany Inclan
From: Susan Kauffman <[email protected]>
Sent: Monday, June 8, 2026 12:09 AM
To: City Council
Subject: Support Item 33: prohibit oil drilling/deep sea mining RE: Support for Updates to Ordinances Governing Offshore Oil and Deep-Sea Mining Support Facilities Dear Santa Cruz City Council
Please support and approve the proposed updates to local ordinances that govern offshore oil and deepsea mining onshore support facilities.

California’s coastal governments are once again mobilizing to defend the state’s shoreline from intensified federal efforts to expand offshore oil and gas development and authorize seabed mining. The federal government’s recently released Five-Year Outer Continental Shelf (OCS) Oil and Gas Leasing Program proposes offshore lease areas along the California coast, representing the most aggressive push for offshore extraction in decades. At the same time, recent federal executive actions and legislation have opened the door to deep-sea mining for rare earth and critical minerals in federal waters.

Santa Cruz has long played a leading role in protecting California’s coast from these threats. During the 1980s, local governments across California exercised their land-use authority to prevent the development of onshore facilities necessary to support offshore drilling operations. These Local Onshore OCS Facilities Ordinances either prohibited such facilities outright or required voter approval before development could occur. Despite legal challenges from the oil industry, the ordinances survived.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to explicitly address facilities supporting seabed mining ensures that emerging offshore extractive industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

Deep-sea mining poses significant and still poorly understood threats to marine ecosystems, including habitat destruction, biodiversity loss, sediment plumes, and impacts to ocean health. Preventing the construction of onshore staging, processing, storage, and transportation infrastructure associated with these industries is one of the most effective tools local governments have to protect coastal communities and marine environments.

Strengthening these protections also reinforces Santa Cruz’s longstanding environmental leadership. The success of the original Blue Wall demonstrated that local governments can effectively defend the coast, even in the face of industry litigation and federal pressure. By updating these ordinances now, [Santa Cruz County/City] will once again help lead a statewide effort to preserve California’s coastline, marine sanctuary waters, coastal economy, and public trust resources for future generations.

We respectfully urge the City Council to adopt these ordinance updates and continue Santa Cruz’s STRONG legacy of coastal protection and environmental stewardship.

Thank you for your leadership and consideration.

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Sincerely,
Susan Kauffman
Seabright neighborhood, Santa Cruz, CA

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Brittany Inclan
From: Steve Lustgarden <[email protected]>
Sent: Monday, June 8, 2026 12:21 AM
To: City Council
Subject: support item 33: no oil drilling/deep sea mining facilities Dear Mayor and City Council members,
Please update and strengthen the City Code to prohibit and and all facilities and activities related to off short oil, drilling, and deep sea mining.

Approve item 33 for the following reasons:

1. Catastrophic & Long-Lasting Risk of Oil Spills
From the Exxon Valdez to the Deepwater Horizon disaster, the harm to marine life, coastlines, and local economies from oil spills is long-lasting and sometimes permanent. Even smaller spills can devastate ecosystems and wipe out years of recovery efforts.  Locally, a catastrophic spill off the California coast could wipe out vulnerable species like southern sea otters, which live in a limited range, and could harm other endangered and threatened species like murrelets, albatrosses, blue and humpback whales, and leatherback sea turtles. 

2. Irreversible Harm to a Uniquely Biodiverse Ecosystem Drilling for offshore oil and gas is a dirty and dangerous process from beginning to end. From seismic surveying and building infrastructure to drilling and transporting oil and gas, every step disrupts ocean wildlife and harms the fragile systems that keep the ocean healthy. Seismic surveying and drilling can cause hearing damage, hearing loss, changes in basic behaviors like feeding, and long-term stress for many species — and these impacts can occur hundreds of miles away from where the drilling and surveying happen. 

3. Devastating Economic Impact on Coastal Communities
Many other impacts would accompany drilling and the onshore facilities needed for offshore oil and gas production in the Monterey Bay region, including routine discharges of pollutants during drilling or transport, and disruption of fishing, agriculture, and tourism.  These industries are the economic backbone of the region, and the damage from spills can be substantial and long-lasting for both ecosystems and human communities.

Please approve item #33.

Thank you.

Sincerely,
Steve Lustgarden
Santa Cruz CA (longtime seabright resident)

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Brittany Inclan
From: Katie Thompson <[email protected]>
Sent: Monday, June 8, 2026 12:44 PM
To: City Council
Subject: Support Letter for Agenda Item #33
Attachments: SupportLetter_SaveOurShores_Agenda33.pdf
Dear City Council Members,
Please find attached a letter from Save Our Shores and 260 community members in support of the June 9th meeting's Agenda Item #33 on protections against on-onshore facilities supporting offshore oil and gas drilling and deep-sea mining.

Now more than ever we need to be proactive in our policies to protect our coast from extractive activities--thank you once again to the City of Santa Cruz for leading the way! Katie
To help protect your privacy, Microsoft Office
prevented automatic download of this picture from
the Internet. Katie Thompson, M.M.A. (she/her)
Executive Director, Save Our Shores
Office: 1.831.462.5660 x8
Website: www.saveourshores.org
Address: 345 Lake Ave, Suite A. Santa Cruz, CA 95062
We are located on the unceded territory of the Awaswas-speaking Uypi Tribe, represented by the Amah Mutsun Tribal Band

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June 8, 2026
Santa Cruz City Council
809 Center Street, Room 10
Santa Cruz, CA 95060
[email protected]
RE: Support for Agenda Item #33, Amendments to Municipal Code Title 24, Zoning, Related to Protections Against On-Shore Facilities Supporting Off-Shore Oil and Gas Drilling and Deep-Sea Mining and Exploration, and Corresponding Changes to the City’s Local Coastal Program Implementation Plan (CM/CD/CN) LOCATION: Citywide
Dear Mayor Keeley, Vice-Mayor Kalantari-Johnson, and Council Members Brunner, Golder, Newsome, O’Hara, and Trigueiro,
On behalf of Save Our Shores and the 260 community members below, we write in strong support of the proposed updates to local ordinances that govern offshore oil and deep-sea mining onshore support facilities.

California’s coastal governments are once again mobilizing to defend the state’s shoreline from intensified federal efforts to expand offshore oil and gas development and authorize seabed mining. The federal government’s recently released Five-Year Outer Continental Shelf (OCS) Oil and Gas Leasing Program proposes offshore lease areas along the California coast, representing the most aggressive push for offshore extraction in decades. At the same time, recent federal executive actions and legislation have opened the door to deep-sea mining for rare earth and critical minerals in federal waters.

Santa Cruz has long played a leading role in protecting California’s coast from these threats. During the 1980s, local governments across California exercised their land-use authority to prevent the development of onshore facilities necessary to support offshore drilling operations. These Local Onshore OCS Facilities Ordinances either prohibited such facilities outright or required voter approval before development could occur. Despite legal challenges from the oil industry, the ordinances survived.

This framework became known as California’s “Blue Wall” — a network of twenty-seven coastal jurisdictions that effectively deterred offshore drilling by preventing access to the onshore infrastructure required to support extraction activities. Santa Cruz was at the forefront of this movement.

The proposed ordinance updates are both timely and necessary because deep-sea mining was not contemplated when the original measures were adopted decades ago. Updating these ordinances to explicitly address facilities supporting seabed mining ensures that emerging offshore extractive

33.144
industries are subject to the same strong local protections that have successfully safeguarded California’s coast for generations.

Deep-sea mining poses significant and still poorly understood threats to marine ecosystems, including habitat destruction, biodiversity loss, sediment plumes, and impacts to ocean health. Preventing the construction of onshore staging, processing, storage, and transportation infrastructure associated with these industries is one of the most effective tools local governments have to protect coastal communities and marine environments.

Strengthening these protections also reinforces Santa Cruz’s longstanding environmental leadership. The success of the original Blue Wall demonstrated that local governments can effectively defend the coast, even in the face of industry litigation and federal pressure. By updating these ordinances now, the City of Santa Cruz will once again help lead a statewide effort to preserve California’s coastline, marine sanctuary waters, coastal economy, and public trust resources for future generations.

We respectfully urge the City Council to adopt the amendments to the municipal code and continue Santa Cruz’s proud legacy of coastal protection and environmental stewardship.

Thank you for your leadership and consideration.

Sincerely,
Katie Thompson
Meg Brown
Charles Plopper
Dan Haifley
Kerry Skemp
Marion Morris
Gigi Kelbert
Pam Ackerman
Susan Marx
Krista Rogers
Melinda Kralj
Miriam Bischoff
Neela Srinivasan
Julie Murphy
Lucia Panini
Dave Hill
Catherine Wittig
Pauline Seales

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Michael Wittig
Karen Kroslowitz
Erin Velikoff
Makana Crannell
Ellen Richter
Scott Galloway
Maggie Mathias
Richard Muller
Dawn Elise Sailers
Ronald Foster
Erik Svehaug
Karsten Mueller
Debbie Diersch
Elena Burgos
Kathleen Orsini
Mark Anderson
Connor Chesus
Christina Farnsworth
Gail Cruse
Gail Cruse
Julie Shattuck
Claire Haiken
Isabella Rosekrans
Rick Larsen
anna ybarra
Dale Hillard
Claire Witherspoon
Christine Morgan
Ros Munro
Jayleen Welch
Maureen Davidson
Kim Carlos Tschantz
Laura L. Smith
Rhonda Levine

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Kevin Wingert
Susan Cavalieri
Lindsay Knights
Esther Sylvan
Rabia Barkins
Robin Spring
Connie Maschan
Karen Jackson
Karen Jackson
Kris Beall
Malin Pinsky
Erica Rubio
Lori Teller
Diana Daughtrey
Cindy Rubin
Gloria Wells
Sara Nelson
Sara McLellan
Cheri O'Neil
Robert Kibrick
Christine Morgan
Racquele Welsh-Driscoll
Karen Warren
Katharyne Mitchell
Steve Levin
Matthew Sparke
Tracey Weiss
Mary Falk
Kris Damhorst
Rebecca Jensen-Clem
Kristoph von Hahn
Rev. Steve Palmisano
Carol Winton
Cori Wolfland

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Gwynn Benner
Sage Goncharoff
rosemary
Rose K Murphy
Reichman
Sarah Ringler
daryl dichek
Kathy Sparrow
kris beall
Kathleen Callaghan
Keith Bloom
Nancy Miller
Kathy Toner
Janice. Lasnier
Patrick Kelley
Jeri bodemar
Lisa Liu
Leslie
Robin Spring
Pamela Gerk
Cecily Gambrell
Hilary Gillette-Walch
Pam Stearns
Lisa Nicole Segnitz
Dee Roe
Judi Sherman
Jeffery West
Morganna Johnson
Michael Zatzke
Trace Laskey
Jenna DeLong
Eric Nylen
Russell Weisz
Helen Ratico

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Wendy Bussiere
Whitney Phillips
Tina Bonar
desiree carter
Tom Butler
Mary Scheller
Jeff Caplan
Adrienne Frisbee
Alexandra Lintner
Richard Jack
Elena Stanciu
John Reberger
Laura Clary Parker
Jessica Guild
Julian Dahan
Cynthia Clark
Timothy Ibbotson-Sindelar
Fifer Garbesi
Hannah Meade
Maureen Davidson
Becky Nutt
Anina. Van Alstine
Eric Jarmie
James Engelman
Christine Morgan
Bradford Bissell
Peter Goodman
Emily Antonino
Darcie Connell
Theresa Marks
Sheryl peters
Michelle Tarian
Paul Andrade
Melissa Cline

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Diana Rowan
Jennifer Sandstrom
Kathleen Appenrodt
Tony Barnett
Frank
Charles Goodwin
Leonard Foreman
David V. Parker
Ketury Stein
Martha Tousseau
Elaine Boles
Carol Latta
Sam Rupel
Janine Canada
Maureen Hart
Cher Roberts
Diane Hickok
Caitlin Spohrer
Chip Riegler
Rachel Hekemian
Tais Schmitt
Kevin Bell
Karen J Koch
Marianne Callahan
Joy Wood
Nancy Connelly
Suzanne Kent
Eric Lombardo
Alize Wright
Garrett Tolin
Debra Feickert
Juliano Calil
Shaun Burns
Anekha Goyal

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Nancy Manning
Eliza Hannah
Melinda Kralj
William Welsh
Eunie Del Rosario
Jean Markarian
Wendy Wyckoff
Erika Delemarre
Devi Nugent
Carolyn Johnson-Gutter
Kaitlyn Tolin
Nancy Bowman
Irana Shepherd
Margaret Galli
Lori Teller
Anna Haulenbeek Huskey
Alan Peevers
Lisa Peevers
Emma Levy
Pamela Sundell
William Cunningham
Michele D. Wolfe
Michele D. Wolfe
Jan Messer
Diana NORTHROP
Edy
Sara Nelsom
Bonnie McDonald
Donna Cavaillé
Jacqueline Tuttle
Sara McLellan
Leticia Medina-Kohrs
Trish Pinnella
Yonat Michaelov

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Katherine Doctor
Lynda lewit
Christine Boles
Patricia Wiles
Tarini Rae
William Rupel
Ann Whitlock
John Thompson
Michelle McKinney
Wendy Wheeler
Linda Felicio
Genevieve Platt
Eric Platt
Mark Akeson
Mary Falk
Beverly DesChaux

SUSIE SNYDER
Nancy Louise Wolfe
Kathy Kelly
Janis Crompton
Susan Brouwer
Amber Sumrall
Erica Berg
Diane Eisenbach
Cerina Vallejo
Caitlin Joseph
Mary Alice Susca
Susan Kauffman
Steve Lustgarden
Sharon Paul
Christine Morgan
Madelyn Arnold
Oli Wickett
Riana Prieto

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Asa Chavarro
Santiago Meza
Leora Baumgarten
Bri Mishin

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Brittany Inclan
From: Josie Lester <[email protected]>
Sent: Monday, June 8, 2026 2:32 PM
To: City Council
Subject: SUPPORT: Agenda Item 33 – Amendments to Municipal Code Title 24 and Local Coastal Program Protections Against On-Shore Facilities Supporting Off-Shore Oil and Gas Drilling and Deep-Sea Mining
Dear Santa Cruz City Council Members:

As a lifelong resident of Santa Cruz County and a graduate student studying Coastal Science and Policy at UC Santa Cruz, I strongly support the City’s proposed amendments to Municipal Code Title 24 and corresponding updates to the Local Coastal Program Implementation Plan that strengthen protections against on-shore facilities supporting offshore oil and gas drilling and deep-sea mining.

Recent federal efforts to expand offshore oil drilling and accelerate deep-sea mining make it especially important for local governments to maintain strong protections for Monterey Bay and the coastal economy that depends on it. These industries threaten marine ecosystems, fisheries, recreation, tourism, and the environmental health of our region.

As someone who has lived in Santa Cruz County for nearly my entire life, I have grown up alongside this coastline and understand how deeply Monterey Bay shapes our community, economy, and identity.

Now, as a Coastal Science and Policy Master’s student at UC Santa Cruz and a recent Public Policy Fellow at the Panetta Institute, my academic and policy experiences have deepened my understanding of both the environmental risks associated with deep-sea mining and the national security and supply chain concerns driving interest in critical minerals.

Through an independent study with Professor Gary Griggs, I researched the geologic suitability and feasibility of deep-sea mineral resources offshore California and examined the scientific, economic, and governance challenges associated with deep-sea mining. My research found that while limited mineral occurrences exist offshore California, they are not currently realistic mining targets. More broadly, even in well-studied regions, significant uncertainties remain regarding the environmental impacts, economic viability, and governance of deep-sea mining. Potential consequences include habitat destruction, sediment plumes, biodiversity loss, toxic pollution, disruption of ocean carbon cycling, and noise and light pollution, many of which could result in long-lasting or irreversible damage to deep-sea ecosystems.

Together, these experiences reinforced the importance of precautionary, science-based policymaking and strengthened my belief that alternatives such as recycling and circular supply chains are more responsible long-term strategies than expanding extractive ocean industries.

The proposed amendments provide a modern, legally robust framework that reflects current scientific understanding and policy considerations regarding offshore oil development and deep-sea mining. By strengthening the City’s zoning code and Local Coastal Program, Santa Cruz can continue to protect coastal resources, marine ecosystems, community character, and the local economy from the risks associated with these industries.

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I respectfully urge the City Council to approve these amendments and continue Santa Cruz’s longstanding commitment to protecting Monterey Bay, our coastal communities, and future generations.

Thank you for your continued leadership on this important issue.

Sincerely,
Josie J. Lester
Coastal Science & Policy Master’s Student at the University of California, Santa Cruz Santa Cruz County Resident

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Brittany Inclan
From: Shaun Burns <[email protected]>
Sent: Monday, June 8, 2026 4:01 PM
To: City Council
Cc: Nik Strong-Cvetich; Diego Sancho Gallegos; Trent Hodges Subject: RE: Save The Waves Support for June 9th Council Agenda Item #33 Dear Santa Cruz City Councilmembers,
I am writing on behalf of Save The Waves Coalition and as a local Santa Cruz surfer who values our world-class waves and healthy marine environment; to express our strong support for the proposed updates to local ordinances governing onshore support facilities for offshore oil and deep-sea mining.

Offshore Oil Will Damage Santa Cruz’s Home Sport: Surfing These updates are timely and necessary to modernize the decades-old coastal protections against emerging extractive industries whose infrastructure poses severe threats to the Santa Cruz World Surfing Reserve surf ecosystem and Monterey Bay Sanctuary marine life. Deep-sea mining and offshore drilling present risks to ocean health, including habitat destruction, chronic leaks, and oil spills - which directly threaten Santa Cruz's coastal recreation, public health, and a surf economy that directly contributes $194.7 million annually.

Local governance is one of the most effective tools we have to defend our coast. By strengthening these onshore infrastructure bans, Santa Cruz will reinforce its legacy of environmental leadership, protect California’s official state sport of surfing, and secure our thriving coastal economy and culture for generations to come.

Thank you for your leadership and consideration!
--
Shaun Burns
Conservation Program Coordinator
+1-831-331-5817
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.

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Ordinance to Protect Against
Off-Shore Oil & Gas Drilling and Deep-Sea MiningCity Council Meeting – First HearingJune 9, 2026

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History & Current Context
• In the 1980s, Federal government proposed first 5-
Year Outer Continental Shelf (OCS) Oil & Gas Leasing Program. • Local efforts succeeded in excluding OCS waters off
the Central Coast from oil & gas leasing programs.
• In 2025, Federal government indicated strong interest in pursuing both oil & gas drilling and seabed mining in waters off the coast of Santa Cruz.