The Sea Also Rises,*

– Any SLR adaptation and mitigation regional planning group will incur ongoing costs in salaries, benefits, and overhead that will require the political entities surrounding Humboldt Bay to agree to cost sharing. Response to Finding 3 – The Board of Commissioners of the Humboldt Bay, Recreation and Conservation District (Board) disagrees with this finding. The Board cannot commit to cost sharing and/or allocation of staff time for a regional planning group. The Board agrees immediate and ongoing commitment to adaptation and mitigation is essential to addressing the threats posed by sea level rise. The Board also agrees regional collaboration is essential to effective planning and implementation of adaptation and mitigation measures. It is for these reasons that the District has been actively participating in several regional and local efforts related to this topic. However, decisions on the region's approach(es) to collaboration on the issue of sea level rise should be made collectively by regional stakeholders. Given the existing regulatory complexity around Humboldt Bay and the diverse array of local, state, federal and tribal stakeholders involved, it should not be assumed creating a new regional governmental entity will be the most effective, efficient, or just approach to regional collaboration.

– The costs associated with SLR mitigation efforts will be significant and will require the diligent pursuit of Federal, State, and Public funding sources. Response to Finding 4 - The Board agrees with this finding. The District has been, and will continue to diligently pursue funding sources for sea level rise adaptation work. For example, as far back as 2012, the District approved the submittal of a grant from the California Coastal Conservancy to Prepare a Feasibility Study for the Beneficial Reuse of Dredged Materials for Tidal Marsh Restoration and Sea Level Rise Adaptation in Humboldt Bay. Acknowledging the threat of sea level rise to contaminated sites, the District worked to secure funding from a variety of local, . state, and federal sources for the clean-up of the Redwood Marine Terminal II site on the Samoa Peninsula. The District consistently advocates for state and federal granting agencies to ensure grants are earmarked and available and targeted at all project stages so the District can successfully navigate from project development to construction. The District also calls on State and Federal permitting agencies to simplify environmental regulatory processes for restoration and climate resilience projects.

— The decade of studies that defined the areas and physical assets vulnerable to SLR around Humboldt Bay by mid-century clearly indicate there is an urgency to start developing and implementing solutions. Response to Finding 5 - The District agrees with this finding and contributed to many of the relevant studies. The District is already implementing adaptation solutions, while working towards a comprehensive, phased approach to sea level rise adaptation throughout the Bay's shoreline, with short-, mid-, and long-term adaptation triggers for vulnerable areas and assets based on observed sea level rise thresholds. The District has been actively planning for sea level rise since at least 2011. In that time, the District has held many public meetings on the topic, secured multiple grants, and implemented substantial contaminated site cleanup. The District is currently investing substantial effort into advancing the offshore wind industry, which will not only help our nation transition away from carbon-based energy, but will also bring much needed funded to Humboldt Bay that can be used to adapt to and mitigate for the impacts of sea level rise.

- Former industrial and other contaminated sites around the Bay are susceptible to SLR. As such, SLR could push the contamination into wetlands, creeks, and even Humboldt Bay itself, making it harder to mitigate and clean up. Response to Finding 8 – The Board agrees with this finding. The District understands the threat of mobilization of soil and groundwater contamination as a result of sea level rise. The District has secured substantial grants from the U.S. Environmental Protection Agency (EPA) to clean up the Redwood Marine Terminal II industrial site. The District has also recently secured additional EPA funds to study the potential of contamination at the RMT I site. The District has also secured a Technical Assistance grant from the EPA to evaluate former mill sites to ensure dioxins and other contaminants are identified and cleaned up as necessary.

- Research studies of SLR impacts around Humboldt Bay indicate that if no action is taken by 2050, monthly maximum high tides will overtop bay barriers and flood existing infrastructure, wetlands and low-lying communities. Response to Finding 9 - The Board agrees with this finding. However, it is important to note that many areas around Humboldt Bay are already vulnerable to significant flood damage at current water levels, segments of bay barrier have already overtopped, and additional segments will be vulnerable with different amounts of sea level rise, with uncertainty around when sea levels will be reached and overtopping will occur. Many of the levees and flood control structures around Humboldt Bay are aging, in need of maintenance, and subject to failure. These facilities are vulnerable to flooding even without the threat of sea level rise. Therefore, even if sea level rise was not a reality, our region would still need to invest in the aging flood-related infrastructure around Humboldt Bay. As a result, the District is already taking actions to address our regional infrastructure and to adapt to sea level rise. The District is working to time the implementation of future actions based on observed sea level rise thresholds. It is also important to note low-lying areas around Humboldt Bay are not only going to be affected by overtopping of bay barriers by tidewaters, but also by rising and potentially emergent groundwater, and by reduced stormwater drainage capacity, especially when rainfall events coincide with high ocean water levels. As a result, sea level rise adaptation will be more complex and varied than solely relying on elevation and fortification of tidal barriers. The Board supports adaptation responses with multiple benefits, such as the use of living shorelines and the beneficial reuse of dredge spoils to allow habitats to migrate/adjust to rising sea levels, and the use of public access trails as shoreline protection. The Board also believes the District's work to support the offshore wind industry is a critical component of the region's efforts to reduce climate change and sea level rise. Given the amount of work necessary between now and 2050, prioritization of adaptation measures will be critical. The District will strive for thoughtful consideration of the distribution of environmental risks and adaptation benefits in setting priorities, and the meaningful participation of all groups in the decision-making process.