Note:  What is shown below is a copy of the original letter, made for this website.  It is included here only so that the contents of the original letter can be searchable.  (The PDF received from the City is in the form of an image, and so is not a searchable document.)

What is below is not the letter sent by the letter-writer. It will contain typographical errors and other departures from the original.  The PDF displayed above is accurate.  The text below is not accurate.  It is printed here for indexing purposes, so that each word can be indexed and included in the search.

Dear City Council, Planning Commission, Staff, and City of Arcata Leaders,
Last year I was very vocal at the Planning Commission and City Council meeting regarding the conflict that the Gateway Area Plan building heights has with the Coastal Act, Sea Level Rise in California: Planning for the Future and
transportation circulations issues SB1000. https://www.coastal.ca.gov/climate/slr/
The Coastal Act Laws and Regulation Chapter 3‐Coastal Resources Planning and Management Policies Article 6 30251
states
The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas, and,
where feasible, to restore and enhance visual quality in visually degraded areas. New development in highly scenic areas such as those designated in the California Coastline Preservation and Recreation Plan prepared by the Department of Parks and Recreation and by local government shall be subordinate to the character of its setting.
(Added by Stats. 1976, Ch. 1330.)
CALIFORN IA COASTAL ACT
Chapter 3 – COASTAL RESOURCES PLAN N IN G AND M AN AG EM EN T POLICIES
Article 8 – Sea Level Rise
Section 30270 ‐ Consideration of the effects of sea level rise
The commission shall take into account the effects of sea level rise in coastal resources planning and management
policies and activities in order to identify, assess, and, to the extent feasible, avoid and mitigate the adverse effects of
sea level rise.
Ca. Pub. Res. Code § 30270
Added by Stats 2021 ch 236 (SB 1),s 2, eff. 1/1/2022.
2
SB 1000‐Environmental Justice in Local Land Use Planning. “Environmental justice” is defined in California law as the fair
treatment of people of all races, cultures, and incomes with respect to the development, adoption, implementation, and
enforcement of environmental laws, regulations, and policies. (Cal. Gov. Code, § 65040.12, subd. (e).)
(a) A land use element that designates the proposed general distribution and general location and extent of the uses of
the land for housing, business, industry, open space, including agriculture, natural resources, recreation, and enjoyment
of scenic beauty, education, public buildings and grounds, solid and liquid waste disposal facilities, and other categories
of public and private uses of land. The location and designation of the extent of the uses of the land for public and
private uses shall consider the identification of land and natural resources pursuant to paragraph (3) of subdivision (d).
The land use element shall include a statement of the standards of population density and building intensity
recommended for the various districts and other territory covered by the plan. The land use element shall identify and
annually review those areas covered by the plan that are subject to flooding identified by flood plain mapping prepared
by the Federal Emergency Management Agency (FEMA) or the Department of Water Resources.
A noise element that shall identify and appraise noise problems in the community. The noise element shall analyze and
quantify, to the extent practicable, as determined by the legislative body, current and projected noise levels for all of the
following sources:
(A) Highways and freeways.
(B) Primary arterials and major local streets.
Noise contours shall be shown for all of these sources and stated in terms of community noise equivalent level (CNEL) or
day‐night average sound level (Ldn). The noise contours shall be prepared on the basis of noise monitoring or following
generally accepted noise modeling techniques for the various sources identified in paragraphs (1) to (6), inclusive.
The noise contours shall be used as a guide for establishing a pattern of land uses in the land use element that minimizes
the exposure of community residents to excessive noise.
California Environmental Quality Act & Environmental Impact Report. The study is based on standard checklists covering
topics such as air quality, traffic, and noise. The environmental effects of a project will cause substantial adverse effects
on human beings, either directly or indirectly. The EIR shall also analyze any significant environmental effects the project
might cause or risk exacerbating by bringing development and people into the area affected. The Noise Element is
required by California cities and counties (Government Code Section 65302) It falls under the California General Plan
Guidelines. Local governments must analyze and quantify noise levels, and the extent of noise exposure, through actual
measurements. Under Government code section 65302(f) Noise Element Requirement primary arterial and major
streets such as H and 16th streets, G street, K street, to be monitored and noise research be done such as Average daily
level of activity (traffic volume per days of the week, and seasonal variations. Distribution of activity over day and night
time periods, day of the week, and seasonal variations. Average noise level emitted by the source. City of Arcata 3.1.1
Noise Element. Within the Noise Element of the General Plan, it specifies an exterior noise standard of 60 dB CNEL and
an interior noise standard of 45 dB CNEL for multi‐family residential. The Secretary of Interior’s Standards for the
treatment of Historic Properties, Preserving windows, and the relation to noise/environment for Historic Neighborhoods
and houses, circulation systems, such as roads and streets. The Circulation system of traffic flow using the H street and G
street for exiting and entering 101 North freeway is a disaster. The quality of life for people living on these busy streets
in the future will be unbearable with the increase in air pollution and noise. This is a violation of SB1000 Environmental
Justice in local planning.
The Gateway Area Plan must do an EIR on the noise exposure from the addition of thousands of more vehicles using the
major streets H & 16th streets, G street, 8th and 9th Streets, K street and Alliance Road. Government section
65302(f)Noise Element Requirement primary arterial and major streets that falls under the California Environmental
Quality Act and the California General Plan Guidelines.
3
In the near future Cal Poly Humboldt is building additional housing for 2,400 students with the goal of building additional
housing in the future.
Craftsman Student Housing the project will resemble prior planning infill housing at the site. Total project budget 150
million. Planned opening Dec 2024
Library Circle Student Housing, Health, and Dining Building & Parking Structure. Total Project budget 175 million.
Planned opening August 2026
Campus Apartments Student Housing and Parking Structure. Total project budget 110 million. Planned opening August
2026.
All of these projects at Cal Poly and the 3,500 units Gateway Area Project will be putting too much traffic, noise and air
pollution on the North‐town and Downtown of Arcata. Look at how the California courts ruled in the Berkeley vrs
Berkeley case regarding CEQA requirements and the inadequate environmental impact report addressing polluting
neighborhoods with traffic and noise. After air pollution, noise is the second biggest environmental factor causing health
problems, increasing the risk of cardiovascular disorders, high blood pressure, sleep disruption, hearing loss, and heart
attacks. Noise exposure has also been linked to cognitive impairment and behavioral issues in children. All people have
the right to a reasonably quiet environment.
A safety element for the protection of the community from any unreasonable risks associated with the effects of
seismically induced surface rupture, ground shaking, ground failure, tsunami, seiche, and dam failure; slope instability
leading to mudslides and landslides; subsidence; liquefaction; and other seismic hazards identified pursuant to Chapter
7.8 (commencing with Section 2690) of Division 2 of
the Public Resources Code, and other geologic hazards known to the legislative body; flooding; and wildland and urban
fires. The safety element shall include mapping of known seismic and other geologic hazards. It shall also address
evacuation routes, military installations, peak load water supply requirements, and minimum road widths and
clearances around structures, as those items relate to identified fire and geologic hazards. Tsunami Mapping page 7 for
Arcata. https://nctr.pmel.noaa.gov/tsu400/documents/Course 1 Day 2/Session 11/NCEE patton dengler.pdf Updat
e to the NOAA Dengler was published by Lori Dengleer on Oct 8th,2022.
Lori Dengler | What sea level rise, tectonics mean for
North Coast
NOAA relative sea level rise is shown from tide gauge trends graphic. Numbers are in mmillimeters per year. If the
current trend at the North Spit gauge continued for 100 years, the water level would rise 1.6 feet. (Contributed)
By Lori Dengler |
PUBLISHED: October 8, 2022 at 12:14 p.m. | UPDATED: October 8, 2022 at 12:35 p.m.
Sea level is rising more rapidly in the Humboldt Bay region than in any other place on the US West Coast. Cal Poly
Humboldt’s Center for Sea Level Rise has been looking at the implications and last Monday, the San Francisco Chronicle
gave us feature treatment.
4
Sea level rise became news in the 1970s. Studies were published and in 1988 the UN formed the Intergovernmental
Panel on Climate Change was formed. Since 1993, satellite altimetry has provided a global picture of the rising oceans.
The current estimate of average sea level rise is 3.4 millimeters (.13 inches) per year. There is no gray area here, it is a
measured fact.
But the ocean isn’t a bathtub, and the rise is not uniform, rising more rapidly in some areas and dropping in others. How
water level changes locally is a function of many variables. The three most important are thermal expansion, the supply
of water, and deformation of the sea floor.
Water expands as it warms. A warmer ocean raises sea level with no additional water. Expansion rates are complex and
depend on salinity, temperature, and pressure. There are seasonal changes and longer ones. Thermal expansion in
strong El Niño years can raise the background tide levels by nearly a foot.
Added water comes from three main sources: valley glaciers, the Greenland ice sheet, and the Antarctic ice sheet. I
called them the three dominos when I taught about sea level rise. Alas, the valley glaciers are nearly gone and much of
their contribution is already in the ocean. Melting of the Greenland ice sheet is well underway and all eyes are now on
Antarctica. It will be the primary driver of sea level rise over the next century.
Little attention is paid to seafloor depth. It is not a constant. The weight of sediment, ice, or lava flows can depress it;
removing weight causes it to rise. Tectonic stresses squeeze or stretch the crust.
Ice sheet melting and the warming climate are my top concerns when it comes to the future of human habitability but
the response of sea levels to tectonics is closer to my area of expertise. I am fascinated by how sea levels give a picture
of the forces at work beneath our feet.
Sometimes those forces work quickly. The Great Alaska earthquake in 1964 lowered some areas by as much as 8 feet.
Other locations like Montague Island rose up 30 feet. But most tectonic changes are very slow, occurring over decades
and centuries as strain accumulates in between major earthquakes.
Tide gauges provide a record of those subtle changes. By averaging daily water levels, regional trends going back a half‐
century or longer emerge. NOAA maintains fifteen tide gauges in California. South of Cape Mendocino, they all show a
rising sea at rates between 1 and 2.5 mm/year. The North Spit tide gauge south of Fairhaven on the Samoa Peninsula
has a rate about twice as high, just below 5 mm/year. And to further complicate the story, Crescent City, 65 miles north
of Humboldt Bay, is the only site on the California coast where sea level is falling. The land is rising more rapidly than the
water.
Something very unusual is going on along the Northern California coast. Ocean temperatures and water supply are
essentially the same yet over a space of 65 miles, we have the most rapidly dropping and the highest uplifting coasts in
the State. The culprit has to be tectonics.
USGS scientist George Plafker was the first to note an unusual pattern of land level changes after the 1964 Alaska
earthquake. He spent more than a year documenting areas that had uplifted and those that had dropped and proposed
what today we know of as the megathrust earthquake cycle. In between great earthquakes, the slow forces of the
subducting plate pull down the land near the edge of the plate offshore and squeeze the area further away causing a
bulge.
The Cascadia subduction zone is similar to the geologic setting that produced the Alaska earthquake. The edge roughly
coincides with the continental shelf. It is almost at the coast at Cape Mendocino and is further and further offshore
heading north into Oregon and Washington. The simple megathrust model means we would expect that areas in
Humboldt and Del Norte County where the edge is closer to be pulled down during interseismic times.
5
Tide gauges show a more complex story. The relative sea‐level drop in Crescent City and Port Orford in southern Oregon
point to a rising coast. But what is going on in Humboldt Bay?
Ah, the complexities of subduction zones. They aren’t a single fault and Humboldt County is one of the few places on the
planet where we can see the complexity on land. We are perched on the edge of the North American plate and the
Gorda plate is being pulled beneath us. The pull may be slow, but it is relentless causing the edge to crumple, fold and,
in some cases, break.
The 60‐mile zone from the edge to the coast, the accretionary fold and thrust belt. The crumpling created Humboldt Bay
and the lagoons. Secondary faults such as the Little Salmon and the Mad River fault zone cut across the coastal area. All
of these features are also deforming at slow rates.
Could we get a better picture of Humboldt Bay if we had more tide gauges? Yes, and fortunately a group from Cascadia
Geosciences led by Jason Patton has done this. There were temporary tide gauges in the past at a number of Bay
locations and this team was able to track down four of them and compare their rates to the NOAA gauge. No surprise —
their data show differences in rates around the Bay and one area is dropping even more quickly. Their paper is coming
out soon and I will revisit the story then.
The implication for Humboldt is enormous. It will require moving wastewater treatment plants and moving/protecting
roads and highways. Proposed developments like Arcata’s Gateway project will find themselves in the tsunami hazard
zone. And of course, these rates won’t continue indefinitely. They are signs of accumulating strain on faults that will
eventually rupture. When that happens, the Bay will look substantially different.
Note: * NOAA maintains a global database of relative sea level rise as measured by tide gauges at
https://tidesandcurrents.noaa.gov/sltrends/, the Chronicle article is at
https://www.sfchronicle.com/climate/article/california‐sea‐level‐rise‐17478689.php.
Lori Dengler is an emeritus professor of geology at Cal Poly Humboldt, an expert in tsunami and earthquake hazards.
Questions or comments about this column, or want a free copy of the preparedness magazine “Living on Shaky Ground”?
Leave a message at 707‐826‐6019 or email

Upon the next revision of a local hazard mitigation plan, adopted in accordance with the federal Disaster Mitigation Act
of 2000 (Public Law 106‐390), on or after January 1, 2017, or, if a local jurisdiction has not adopted a local hazard
mitigation plan, beginning on or before January 1, 2022, the safety element shall be reviewed and updated as necessary
to address climate adaptation and resiliency strategies applicable to the city or county. This review shall consider advice
provided in the Office of Planning and Research’s General Plan Guidelines and shall include all of the following:
A vulnerability assessment that identifies the risks that climate change poses to the local jurisdiction and the geographic
areas at risk from climate change impacts, including, but not limited to, an assessment of how climate change may affect
the risks addressed to the Arcata WasteWater Treatment Plant and Gateway Area Plan. The Humboldt County Grand
Jury report The Sea Also Rises states that Antarctica could disintegrate within ten years leading to flooding the roads to
the Arcata Wastewater Treatment Plant and creating an island.
https://coast.noaa.gov/slr/#/layer/slr/3/‐
13813859.28977252/4993173.846714883/14/satellite/none/0.8/2050/interHigh/midAccretion
Making California’s Coast
Resilient to Sea Level Rise:
Principles for Aligned State Action
6
California’s coast, bays, estuaries, and ocean are facing an immediate threat from sea‐
level rise. To improve effectiveness in addressing the immediate challenge of adapting
our state to sea‐level rise, California state agencies with coastal, bay, and shoreline
climate resilience responsibilities, including for coastal infrastructure and Californians’
safety, endorse the following Principles for Aligned State Action. These Principles will guide
unified, effective action toward sea‐level rise resilience for California’s coastal
communities, ecosystems, and economies around:
Best Available Science, Partnerships, Alignment, Communications,
Local Support, Coastal Resilience Projects, and Equity
Background
• Californians’ safety, local and state economies, critical infrastructure, and natural
resources face increasing threats from sea‐level rise (SLR).
• Every scientific assessment since California’s 2009 Climate Adaptation Strategy has
revealed that coastal impacts from climate change‐caused SLR will occur more
quickly and be more severe than previously projected. California’s coast faces a
significant risk of experiencing SLR of up to 1.0 feet by 2030 and 7.6 feet by 2100.
• Projections of future SLR point to significant impacts to California communities, with
considerable environmental justice implications, upwards of hundreds of billions of
dollars in impacts to property and development, impacts to statewide and regional
water supplies, as well as significant damage to and loss of many miles of beaches,
tidepools, coastal rivers, estuaries, and wetlands.
• As California has repeatedly demonstrated, a bold, statewide climate agenda
benefits our natural resources, health and safety, economy, critical infrastructure,
and communities. Our state has led global efforts on climate change mitigation
and is poised to do so on climate change adaptation.
• These Principles will enable California to scale up coastal resiliency efforts through
aligned strategies that create consistent, efficient decision‐making processes and
actions coastwide while improving collaboration across state, local, tribal, and
federal partners.
• Action now saves up to six times the cost of action later, allows time for the state
and communities to test and leverage needed solutions, and prevents untold
impacts. By enhancing alignment and partnerships now, we will significantly
improve the climate resiliency of our coast, bays, shorelines, and communities,
particularly frontline communities most vulnerable to the impacts of SLR.
Goal
1. Develop and Utilize Best Available Science
• Apply best available science to planning, decision‐making, project design, and
implementation. Prioritize frequent engagement with stakeholders to ensure the
science is actionable.
• Utilize SLR targets based on the best available science and a minimum of 3.5
feet of SLR by 2050. Develop and utilize more protective baseline 2050 and 2100
targets for road, rail, port, power plants, water and waste systems.
Experts believe that most of the Gateway area will be inundated by 2120 and that almost all of the sea level rise
will happening in the next 25 years as the dikes are overtopped.
Even if you shore up the dikes, we are also going to have rising ground water and salt-water intrusion into
wells. According to SLR experts, this could happen within the next 10 to 40 years, which when combined with
7
the King tides will lead to more frequent and chronic flooding.
In about 25 years the WTP will be an island surrounded by water, so you will need to insulate all the plumbing
and infrastructure leading to the WTP, then build a causeway out to it, which will be very expensive – not to
mention the difficulty of performing maintenance when most of the surrounding area will be under water.We
need to be planning for where to relocate the plant now. It’s likely that the only viable place to relocate it is in
the southern section of the Gateway Area, such as the Barrel District.SLR experts have stated that building
mid-rise structures on mud flats is a very bad idea.
We can expect salt-water intrusion and rising ground water levels in this area. SLR experts have provided an
illustration of what can happen by pointing to the beachfront buildings in Surfside, Florida that collapsed due to
salt-water intrusion into the foundations of the buildings. Given these conditions,is it viable to build in the GAP?
“Does it make sense to invest public money on a part of the city that will ultimately be part of the bay?”Are we
just creating the next lower G Street problem by building in the GAP Coastal Zone? We need a plan for where
to move the residents, businesses and infrastructure south of Samoa and West of Old Arcata Rd and not move
them into another high risk area.
Please address the conflicts the Gateway Area Draft Plan has with the California Coastal Act, Sea Level Rise,Local Coastal
Program,SB1000,and General Plan Update with Emphasis on the Land Use and Growth Management Element
Updates.
Sincerely,
Gregory Daggett
One attachment • Scanned by Gmail