New sediment management policies for wetland restoration and climate change resilience in San Francisco Bay

1. Wetlands Program Development Grants (WPDG) FY21-22, Track Two Grant Application
2. EPA Core Elements: This project addresses Regulatory Core Element (2) as it will amend the San Francisco Bay Plan to ensure that policies related to sediment/soil use are effectively linked to subsided wetland restoration projects. Funds provided will be used to enact new policies to improve collaboration and coordination of regulatory and local government agencies to increase quantities of sediment/soil used in wetland restoration. It addresses the Restoration and Protection Core Element (3) by establishing goals for the beneficial reuse of sediment in wetland restoration and institutionalizing long-term protection of wetlands through policy enactment that ensures wetlands adapt to rising seas through sediment augmentation. This project will lead to increased wetland acreage and advance wetland resilience to sea level rise in the San Francisco Bay estuary.
3. The San Francisco Bay Conservation and Development Commission, DUNS No. 808322424
4. Key personnel and contact information:
   Erik Buehmann, Long Range Planning Manager
   (415-352-3645) erik.buehmann@bcdc.ca.gov,
   and
   Brenda Goeden, Sediment Program Manager
   (415-352-3623) brenda.goeden@bcdc.ca.gov
5. Geographic Location – California; 18050004 – San Francisco Bay
6. Total project cost: $379,624.00
   Federal Funds requested: $284,716 State Cost Share/Match: $94,904.00
7. Abstract: New sediment management policies for wetland restoration and climate change resilience in San Francisco Bay proposes to directly respond to regional demands for reuse of sediment and soil in wetland restoration projects. This project addresses regulatory and financial barriers to further wetland restoration success through Results Chain Collaborative Analysis, a San Francisco Bay Plan amendment, and a financing strategy. In the Bay Area, wetland restoration efforts have concentrated on deeply subsided sites. Now at less than 20% of their historic range, the momentous “Sediment for Survival” report (2021) established that up to 650 million cubic yards of sediment are needed to restore and sustain wetlands through 2100. The report identified beneficial reuse of dredged sediment and other sources of soil as the best way to meet this demand. Direct placement of sediment on subsided sites successfully raises marsh plain elevations, leading to rapid vegetation establishment. However, lack of an actionable road map, and policy and funding constraints have resulted only 40% of dredged sediment used over the past 20 years. Our project will help resolve the regional sediment need and increase the acreage of restored wetlands through: (1) a results chain analysis which will create a coalition of stakeholders with actionable tasks to support additional sediment use at wetland restoration sites; (2) policy improvements in a San Francisco Bay Plan amendment and issue documents; and (3) a financing strategy to support the use of sediment in restoration projects.

1. Project Description

The San Francisco Bay Conservation and Development Commission (BCDC), created under the McAteer-Petris Act (1965), manages San Francisco Bay (Bay) and applies its state and federal laws and the San Francisco Bay Plan (Bay Plan) policies to protect natural resources, provide public access and water-oriented uses for enjoyment and use of the Bay. BCDC seeks to change the Bay Area narrative regarding sediment and soil use in wetland restoration and adaptation projects. Currently the primary source of sediment needed to raise site elevations at deeply subsided wetland restoration projects is provided by either placing sediment dredged from navigation projects at the site or through natural deposition once a site is breached. There has been limited success with bringing upland soils from construction projects to restoration sites, yet this method has significant challenges. The Bay Area regulatory community created policies in the early 2000’s seeking to increase beneficial reuse of dredged sediment primarily targeting large restoration projects and levee maintenance to reduce potential impacts to water quality, fisheries, and listed species in the Bay. The Long Term Management Strategy for the Placement of Dredged Material in the Bay Region (LTMS) Management Plan evaluated alternatives and determined that approximately 40% reuse was feasible. As a result, the regulatory agencies created policies associated with dredged sediment reuse but did not coordinate on the concept or policies for the use of upland soils, flood protection, and other sources of sediment/soil in restoration projects.

This proposal is designed to create a collaborative opportunity for the regulatory agencies, restoration, dredging, flood protection, construction, adaptation, environmental justice communities and other regional stakeholders to expand sediment/soil use. Everyone benefits from restoring the Bay’s wetlands as a key climate and rising seas adaptation strategy and conservation strategy for native and listed species. The proposal has three approaches, the first is to work with the San Francisco Bay Joint Venture (SFBJV) to engage stakeholders in an “Open Standards for the Practice of Conservation Results Chain Analysis.” The second is a Bay Plan policies amendment to refocus on sediment as a resource and further maximize the reuse of dredged sediment and soil in wetland restoration. The third is the development of a financial strategy using BCDC’s Financing the Future Work Group to identify financing needs and potential sources to support beneficial reuse as a wetland adaptation mechanism.

The Open Standards for the Practice of Conservation is a set of best practices for the successful implementation of conservation projects, oriented around a five-step management cycle that includes assess, plan, implement, analyze and adapt, and share. The Sediment for Survival report, San Francisco Estuary Institute (SFEI) (2021) established the extreme sediment needs for restoration and the need to increase beneficial use of sediment and soil. Using these reports, the results chain analysis will start from the issue identified position and primarily focus on the “implement” phase to develop several viable strategies. The goal of this effort is to bring together the key stakeholders to analyze a range of strategies and develop action plans in graphic theories and text of change/results chains. The results chain analysis will establish a road map with a progression of expected short, intermediate, and long-term actions that lead to regional results that stakeholders can follow to create resilient tidal marshes supported through sediment use. Engaging the Bay Area’s stakeholders in the results chain analysis will build a coalition of organizations across sectors, provide support for policy change, and identify the key constraints, actionable tasks, roles, and responsibilities to encourage managing sediment and soil in a way that advances wetland restoration.

The project will engage a trained Open Standards for Conservation facilitator to lead a two-day workshop to develop the results chain analysis. The SFBJV and BCDC will develop background documents and host a before and after workshop meeting to ensure that participants are prepared for the workshop, have an opportunity to debrief and further discuss next steps. The SFBJV will be the primary liaison with the facilitator and restoration community, with BCDC as liaison with the dredging, construction, and flood protection communities. BCDC and SFEI will develop the technical background documents and the Aquatic Science Center of the San Francisco Estuary Institute (SFEI) will contribute scientific information in the form of presentations and expert contributions to these meetings and workshop.

The Bay Plan amendment to address sediment needs and adaptation will focus on BCDC policy development process using an intra-agency staff team comprised of planners and technical staff from the Sediment Management Program. The Commission strives to keep policies updated based on best available science and planning practices. In 2019, the Commission identified a beneficial reuse Bay Plan Amendment as a climate adaptation priority action. With the wealth of reports issued over the past five years focusing on how flood protection, sediment supply, and stakeholders can address restoration and climate adaptation, there is momentum for this amendment. The amendment process will follow state regulations and includes a Commissioner working group to identify key issues and policies; three public workshops offering opportunities for public engagement; issues papers and presentations for Commission and public consideration; an amendment background report with in-depth analysis of the issues, potential impacts of the policy changes, findings from interviews, and proposed policy changes for public review and comment and Commission consideration; and a recommended set of policy changes for a public hearing and Commission vote. The results chain analysis provides a unique twist to the amendment process in that it will occur during the background document development and will allow regional consensus to be reflected in that document. The regional consensus provides the Commission support for the policy changes identified, allowing for a smooth process.

The LTMS program identified that additional funding is needed to address the incremental costs of taking dredged sediment to beneficial reuse. This cost has varied significantly and there has been no identified source of consistent funding. Similar considerations have been identified with flood protection projects, creek realignment, and construction soils transport. To address this need, BCDC will work with its Financing the Future working group, and individuals and institutions with an understanding of financing focused on sea level rise adaptation, to develop a financing strategy. Working with the stakeholder community BCDC will identify cost issues and draft issue papers to highlight the challenges. These issue papers will inform the working group which in turn will provide suggested strategies to be explored and documented. Once the investigations are complete, the strategic document will be reviewed by the working group and project partners for efficacy. Once complete, the strategy would be provided back to the coalition for implementation via a workshop.

2. Description of Need

As most are aware, vast wetlands historically rimmed San Francisco Bay. Wetlands provide transitional habitat between estuarine waters and uplands, flood water absorption, and buffer waves along the shoreline. By the mid 1950’s human activity caused the loss of approximately 80% of these wetlands. By the 1990’s the Bay Area had mobilized to restore these areas, now deeply subsided due to diking and draining of the marshes. During the same period, efforts were underway to make use of sediment being dredged for navigation in the Bay. Regionally, beneficial reuse of dredged sediment has proven to successfully restore elevation of subsided wetlands at four landscape scale projects, and a combination of dredged sediment and upland soil has been used at one restoration site. Placing dredged sediment at subsided locations allows wetland vegetation to quickly establish. However, only approximately 40% of dredged sediment has been used in the past 20 years due to policy, funding, equipment, and site availability constraints. In 2021, the San Francisco Estuary Institute (SFEI), issued a momentous report, “Sediment for Survival,” which established the need for between 450 and 650 million cubic yards of sediment and soil to restore and sustain the Bay’s wetlands through 2100. This report further mobilized stakeholders from different sectors to address this urgent need.

The Sediment for Survival report along with recent research indicates that there is a severe sediment supply shortage in San Francisco Bay, up to 650 million cubic yards, which will affect restoration efforts and the Bay’s tidal marshes’ ability to keep pace with sea level rise. As Bay Area communities become increasingly threatened with displacement, especially vulnerable communities, restoring the baylands provides a green infrastructure approach to resilient shorelines. Focused regional collaboration is needed and the Results Chain Analysis would thoroughly examine the issues preventing dredged sediment and soil reuse in restoration projects and identify appropriate agency roles and actions needed to foster the desired outcome of more sediment reuse. The Bay Area stakeholders have shown that they partner well when cross-sector issues arise and funds from this award would be used to further strengthen regional partnerships in the interest of restoring wetlands as fast and efficiently as possible.

The Sediment for Survival report identified that navigation dredging can provide more than 50% of this sediment demand, and flood protection channel dredging and realignment can provide more in key locations. Construction soils are less frequently used but can supply some of the elevation capital needed if the construction industry is engaged and invested. Laws and policies developed in the 1990’s highlighted this need but are limited in the ability to fully use these sources of material restoration projects. Currently reuseable sediment and soils are often disposed of as a waste product at aquatic disposal sites, landfills or site piles. The recent call for up to 650 million cubic yards of sediment to sustain the Bay’s wetlands in combination with a high likelihood that the Bay waters will rise along with sea level by 13 inches by 2050 (Ocean Protection Council 2018), indicates that we must act now to revise policies and use local sediment to restore wetlands and increase their adaptive capacity. While the LTMS program is a highly coordinated effort, the sediment in flood projection channels and excavated soils from construction projects have not benefited from policies that support their use. In addition, the Healthy Baylands, Resilient Shorelines Project identified the potential to realign flood control channels to better support tidal and brackish wetlands. No policies currently exist to support this work. Thus, BCDC proposes to amend the Bay Plan to increase the types and amounts of sediment and soil can be used in wetland restoration projects as well as to address the mechanisms to build this capacity.

As part of its climate resiliency actions, BCDC identified the need for a sediment focused Bay Plan amendment. However, a Bay Plan amendment is not the only need associated with sediment and soil use for wetlands. Regional action has been hampered by lack of established roles and responsibilities and funding to fully implement sediment and soil use in restoration projects. The Open Standards Results Chain Analysis with stakeholder input will establish the roles, responsibilities and actions that can be taken, and the financing strategy will provide a critical understanding of what can be funded and how. These three phases will strengthen the regional coalition focused on this effort and provide transferrable information that can be used by multiple entities. Creating a coalition with an actionable road map is key to success. Creating policies that support this adaptive process is equally important, but without a financing strategy, the actions and policies may not be achievable. The finances to support wetland restoration, sediment use, and adaptation has been an issue since the onset of the LTMS program.

Shifting the state’s policy framework through a Bay Plan amendment is a regulatory activity core element aligned with EPA-approved California Wetland Program Plan (CAWPP) overall goal to increase the abundance, condition and diversity of California’s wetlands and riparian areas and to sustain and enhance the delivery of ecosystem services and is needed to prevent further loss of the sediment and to support rapid wetland restoration. It further supports the CAWPP planned activity of developing other regional initiatives for wetland resources and draws on the updated San Francisco Baylands Ecosystem Habitat Goals Report2.

3. Regional Priority Areas

The project addresses restoration of tidal marshes and tidal flats (special aquatic resources in EPA Region 9) increasingly at risk of degradation and destruction. Diking and filling has not only drastically reduced the original extent of the baylands, it has reduced suspended sediment deposition onto the marsh plain due to levee barriers and channelization. This anthropogenic reduction is further compounded with the threat of sea level rise. The California Ocean Protection Council’s Sea Level Rise Guidance (2018) states that there is a 66% chance that sea levels in the Bay Area will be 2.4 feet higher by 2100 under a low emissions scenario and 3.4 feet higher under a high emissions scenario. Recent analysis by Thorne et al. UGGS (2018) showed that under conservative sea level rise scenarios, 60% of middle marsh and 95% of high marsh habitats will be lost by the end of the century throughout the Pacific Coast. The Bay’s existing tidal wetlands face a sediment shortage. The Sediment for Survival Report found that wetlands will not receive enough natural sediment to survive sea level rise unless management practices change to prevent unnecessary losses of this resource. Further, wetlands planned for restoration will only be possible if the subsided baylands are supplied sediment/soil prior to breaching. This project will directly address the need to change sediment management practices by building a road map with roles, responsibilities, and actions, creating new policies that maximize the beneficial reuse of sediment/soil in restoration projects, and developing a financing strategy to support these actions. Adopting new sediment management policies will ensure that the Bay’s wetlands provide an opportunity to combat sea level rise, thereby ensuring that infrastructure and local communities are protected from displacement. The Commission is committed to implementing its program in ways that prevents discrimination, promotes equal access to the Commission’s programs, and supports fair treatment in the development, adoption and implementation of laws, regulations and policies. When implementing its program, BCDC uses its community vulnerability map and CalEnviroScreen to identify communities and ensure meaningful community involvement. Restored and sustainable wetlands will directly and indirectly improve environmental conditions for communities disproportionally impacted by climate change.

4. Project Tasks

Phase 1 includes: scoping and work plan formulation; stakeholder identification and engagement; background document development; a pre workshop meeting of stakeholders; a two-day Open Standards of Practice Results Chain Analysis workshop; a post workshop meeting and debrief; and development of a final road map for restoring wetlands using sediment and soils for climate adaptation. This work will be completed with BCDC staff developing much of the technical information with assistance from SFEI. The SFBJV will develop the workshop and analysis process with the Open Standards trained facilitator. BCDC will draft report at direction of the facilitator.

Phase 2, the Bay Plan Amendment, begins with a Commission vote to initiate the process. A small Commissioner work group will be selected and work through a series of issues associated with the policy changes at public meetings. BCDC will review, document, and present information from the recent reports to the Commissioner work group. BCDC will interview stakeholders and develop information and activities for three workshops on the identified issues. BCDC would prepare the information gathered through report review, interviews and workshop and develop a background report with draft findings and policies. This document would be circulated for review by the public and Commissioners. Revisions to the background report would be made, a staff recommendation would be drafted, and a public hearing and vote would be held. Once vote is complete, documents would be prepared for the Office of Administrative Law and Office of Coastal Management review. SFBJV would be a stakeholder and SFEI would provide expert scientific advice and make presentations to the work group.

Phase 3, the Financing Strategy development would involve interviewing stakeholders and doing research to identify costs and funding issues and documenting findings. Five issue papers would be drafted and presented to the Financing the Future work group for review, consideration, and recommendations. Recommendations will be investigated and incorporated into a proposed financing strategy which would be presented to the work group and at a public workshop. The final strategy would be presented to the Commission and provided to stakeholders for use.

5. Milestone Schedule

6. Detailed Budget

7. Transfer of Results

This project is designed to have transferable results – from increasing the region’s understanding of the complex issues associated with sediment and soil use at wetland restoration projects to the funding challenges it seeks to address. The Results Chain Analysis Report will be provided to stakeholders and participants who can implement actions identified in the process within their own organization. The regional road map and background documents presented at the meetings and workshops will be available to other regulatory and resource agencies to be used in their own policy development. Because the regional regulatory and resource agencies are also aware of and focused on this issue, the information will be useful to the Regional Water Quality Control Board, the Army Corps of Engineers, Environmental Protection Agency’s Wetlands Division, the Fish and Wildlife Service, and the Department of Fish and Wildlife. Once the BCDC policies are established, there will be improvements to permitting activities such that the information is readily implementable through the LTMS program and the Bay Restoration Regulatory Interagency Team.

Further, background documents can be provided to stakeholder’s leadership along with the roadmap so that the organization doesn’t need to do additional leg work to support the proposed actions. Similarly, the financing strategy will thoroughly investigate the funding issues associated with each part of the process, and provide potential solutions. By applying a regional focus, and developing supporting documents, the coalition of stakeholders will have the same information available to support requests for funding from different sources that are clear, well envisioned, and effective. Working together, Congressional and State legislatures can be more strategically approached and engaged. As each element of the work is completed, BCDC’s website will be updated with the new material. In addition, BCDC staff regularly attends state and national conferences, as do stakeholders in the project, and will present findings such that information can be further shared.

8. Outputs, Outcomes, and Tracking

1. Link to the EPA Strategic Plan: Our project furthers the EPA’s Strategic Plan goal of delivering a cleaner, safer, and healthier environment for all and future Americans through policies and regional goals to provide more sediment and soil to wetland restoration rather than being disposed of as a waste produce and is a critical step in building wetland resilience to climate change. This project is a step towards sustainably managing aquatic ecosystems (Objective 1.2) by changing sediment management policies to benefit sustainable, local wetland restoration projects. To avoid inundation and keep pace with sea level rise, wetlands in the Bay area require sediment augmentation. The most sustainable and efficient sediment source is dredged sediment and a Bay Plan amendment is needed to ensure that dredged sediment is optimally used in wetland restoration.
2. Outputs: Phase 1 of this project will deliver issue documents for background understanding, a facilitated workshop using the results chain analysis technique to identify roles, responsibilities, and actions necessary to increase sediment/soil use in tidal wetland restoration projects, a regional roadmap to assist stakeholders in taking appropriate and necessary action, and a report documenting the findings and process. Phase 2 will deliver a background report, three public stakeholder workshops, a Commissioner workgroup, and new or amended Bay Plan policies focused on sediment/soil needs for wetlands and adaptation. Phase 3 will deliver five issue papers, Financing the Future workgroup meetings focused on sediment/soil and wetland restoration, and a financing strategy for the region to use to support future efforts to increase sediment/soil use at wetland restoration projects. Other outputs will include website updates and social media posts on Twitter and Facebook supporting project and the reuse of sediment in wetland restoration projects.
3. Outcomes: The anticipated outcomes that will benefit the Bay Area include: (1) a better informed regional coalition motivated to use sediment and soils in restoration projects; (2) less waste of sediment/soil; (3) improved policies that lead to increased acreage of restored and resilient wetland restoration projects through the use of sediment/soil or reconnected/redirect flood systems; (5) reduced use of the deep ocean disposal site; (6) use of transferable policies by other agencies as appropriate; (7) increased protection of the shoreline and communities via green infrastructure improvements; and improved ability to secure funding for wetland restoration, flood protection, and (9) the dredging community’s contribution to beneficial reuse.
4. Tracking Outputs and Outcomes: We will measure and track our progress toward achieving the expected outputs and outcomes through use of a detailed work plan for each task, including a spreadsheet with milestones to achieve the project goals. The work plans will include scheduled meetings with SFBJV and SFEI to ensure work is on schedule. Monthly team meetings will document completed tasks, action items, and milestones met. Success once the Bay Plan amendment is approved can be compared to results from the previous 20 years and information from EcoAltas.

9. Programmatic Capability/ Technical Experience/ Qualifications

1. Organizational Experience. BCDC will engage expert staff in the Planning and Sediment Management teams who work on a variety of planning, regulatory, and scientific projects related to the development and restoration of Bay Resources. They have extensive experience working with stakeholders through Bay Plan amendments, public workshops, project management, and policy and regulation implementation. The team has specific expertise through decades of work on sediment and restoration issues throughout the Bay Area and are regionally and nationally recognized for climate change resiliency planning. Team collaborates broadly with scientists, agency representatives and project proponents evaluating and solving intricate problems and can readily identity common issues in this complex topic and programmatic resolutions.
   The SFBJV is a nationally recognized organization that promotes wetland restoration and coordinates and collaborates with organizations to promote healthy habitats across the region. SFEI is a recognized regional leader in Bay restoration and sediment science, wrote many of the key documents identifying the issues and potential solutions.
2. Staff Experience/Qualifications. The key staff members from Planning include Jessica Fain, Planning Director and the Planning Manager, Erik Buehmann, a Senior Environmental Scientist Supervisor has several years of experience as the Bay Resources Permits Manager, overseeing wetland restoration projects and the Bay Restoration Restoration Regulatory Interagency Team as a Policy Manager Committee member. The Sediment Management team has over three decades of experience in sediment issues and includes Brenda Goeden, Sediment Program Manager, Pascale Soumoy and Julia Kelly, Environmental Scientists. Members of this team have managed large restoration projects, dredging and sand mining from the regulatory perspective and through the successful LTMS program.

10. Partnership Information

With this project, BCDC will partner internally between the Planning and Sediment Management teams to deliver the Regional Road Map, the Bay Plan Amendment, and the financing strategy. SFBJV and SFEI join in this effort as partners bringing the restoration community’s interest in healthy resilient wetlands and a strong scientific perspective on what is needed to achieve the goal through the region’s best effort to meet the challenges of risings seas and climate change. SFBJV and SFEI are committed to assisting with document development and coalition building. BCDC’s Financing the Future working group is currently engaged in identifying funding support for climate adaptation and will readily contribute their knowledge and expertise to this effort. Regional stakeholders regularly participate in efforts designed to improve the region’s capacity for climate resilience and a healthy Bay.

BCDC will provide staffing for the meetings, workshop and work group development and will be the author of the Bay Plan amendment and issue documents, as well as drafting the financing strategy. SFBJV and the Open Standards facilitator will be primarily responsible for leading the Results Chain Analysis process. SFEI will provide expert advice, make presentations, and review documents. Stakeholders will likely include the LTMS agencies (Water Board, EPA, and USACE), the restoration community, the Bay Planning Coalition, the California Maritime and Navigation Conference, the Bay Area Flood Protection Agencies Association, other non-governmental organizations, and the marine construction industry representatives.

Past Performance

BCDC has received federal funding through the Federal Surface Transportation Block Grant Program (STP) and NOAA 309 funds. The STP funding program provides an average of $230,000.00 towards climate adaptation programming and is in its ninth year. BCDC has successfully completed and managed this grant agreement tasks to date without issue. An annual scope of work with specific tasks is developed and BCDC reports quarterly and monthly on its accomplishments. The quality of the work is high and has been recognized for its contribution in climate adaptation planning. BCDC receives $128,750 NOAA 309 Funding per year for its Coastal Zone Management Program based on its Needs Assessment. BCDC regularly meets the required timelines, but if unable to achieve the expected outcomes due to changed circumstances it works with NOAA to modify the scope of work or request no-cost time extensions. Reporting requirements are regularly fulfilled and determined successful.

Sections C. Restoration Demonstration Project Information, D. Quality Assurance/Control Statement, and E. Invasive Species Control are not applicable to this project.

F. Optional. Abbreviated staff resumes, letters of commitment and support letters attached.