SPN-2023-00412 San Francisco International Airport Shoreline Structures Repair Program

WATERWAY AND LOCATION:  The RGP 44 program area includes 13 specific locations along SFO’s approximately 8-mile-long shoreline, primarily in unincorporated San Mateo County, California (see enclosure 1). The program area is located within the San Francisco Bay Estuaries HUC (180500041001).

EXISTING CONDITIONS: The program area consists of SFO infrastructure within and adjacent to the San Francisco Bay. This infrastructure includes piles, piers, trestles, and outfalls.         

PROJECT PURPOSE:

Basic:  The basic project purpose is to improve RGP 44 as an efficient permitting process for SFO to conduct routine maintenance of its shoreline structures at SFO.

Overall:  The overall project purpose is to provide an efficient permitting pathway to conduct maintenance activities on 13 pier/pile-supported structures around the perimeter of SFO that are in the San Francisco Bay.

PROPOSED WORK:  RGP 44 currently authorizes the following maintenance activities at 13 discrete structures around the perimeter of SFO:

1. In-Water Repairs: Activities involving in-water work consist of strengthening the existing timber piers and piles by installing a fiberglass wrap around each pier/pile. A rebar cage and marine grout will typically be applied between the existing pier/pile infrastructure and the fiberglass wrap. This work may require localized excavation at the base of the pier/pile to set the rebar cage and fiberglass wrap; excavated material will be backfilled. Depending on the location of the pier/pile, a barge or boat may be required for access, leveling (as needed), and strengthening activities. This RGP does not authorize the replacement of piers/piles.
2. Overwater Repairs: Activities involving overwater work consist of reinforcing or replacing (in kind) deteriorated components of timber trestles, including various timber beams, guardrails, stringers, floor planks, decking, and knee and cross braces. Existing straps that connect the stormwater outfall pipes to the trestle support structures will be replaced with stainless steel connection straps. Sediment accumulated in the existing outfall pipes would also be removed to restore as-built conditions; the sediment will be disposed of at an appropriate upland location. Depending on the location of the repairs, a barge or boat may be required for access and implementation.
3. Concrete/Unsupported Structure Maintenance and Repairs: Activities to maintain and repair existing infrastructure consist of repairs to the concrete basin at E013, concrete piers at E007 and E008, and concrete cradles at various storm drain pump station (SDPS) outfalls. Concrete cradle repairs will generally occur outside of waters of the United States. Repair activities may include in-kind repairs of surface cracks or spalls. Maintenance activities may involve the removal of small amounts of accumulated sediment and other minor maintenance activities.

SFO has requested to modify the first category to state (additions in bold):

1. In-Water Repair or Replacement: Repair activities involving in-water work consist of strengthening the existing timber piers and piles by installing a fiberglass wrap around each pier/pile. A rebar cage and marine grout will typically be applied between the existing pier/pile infrastructure and the fiberglass wrap. Deteriorated unrepairable timber piles will be removed, and replaced with concrete, steel or wood piles depending on site-specific engineering requirements. Pile repair and removal may require localized excavation at the base of the pier/pile to set the rebar cage and fiberglass wrap; excavated material will be backfilled. Depending on the location of the pier/pile, a barge or boat may be required for access, leveling (as needed), and strengthening or replacement activities.

SFO has also requested to modify General Condition 10, which originally limited RGP 44 to 15 category 1 projects each year, not to exceed 75 projects over five years. SFO has requested to modify General Condition 10 to state:

10. SFO may request authorization for up to 100 projects requiring in-water repairs or replacement each year, not to exceed 500 in-water projects over five years. There are no program limits on projects requiring overwater repairs, or concrete repairs and other minor maintenance activities.

AVOIDANCE AND MINIMIZATION: The applicant has provided the following the following additional minimization measures in support of efforts to avoid and/or minimize impacts to the aquatic environment:

1. 1. Pile removal will be removed by direct pull or vibratory hammer, where feasible. Piles that cannot be pulled will be cut at least two feet below the mudline, to the extent practicable. Jetting will not be used.
   2. Pile replacement will occur using vibratory hammers whenever possible, and without additional limitation. Impact pile driving will be restricted to the following:
      1. Designated work window from June 15 to November 30.
      2. Impact driving will be limited to wood piles of any size, concrete piles ≤18-inch diameter, or steel piles ≤12-inch diameter. Impact pile driving will be limited to one hammer (≤3,000 pounds) and fewer than 20 piles per day.
      3. A 12-inch-by-12-inch-thick wood cushion block will be used during all impact pile driving operations.
      4. A “soft start” technique will be employed at the beginning of each workday or after any break of 30 minutes or more to allow fish and marine mammals to vacate the area.
   3. No new fill is authorized as part of the pile repair and replacement activities. Any fill required will be minimal and limited to structural piles necessary to achieve the project’s structural objectives, resulting in negligible impact to habitat for listed aquatic species.

COMPENSATORY MITIGATION: The activities authorized by RGP 44 would not result in a loss of waters of the U.S. As such, no mitigation is proposed.

CULTURAL RESOURCES:

The Corps evaluated the undertaking pursuant to Section 106 of the National Historic Preservation Act (NHPA) utilizing its existing program-specific regulations and procedures along with 36 CFR Part 800. The Corps’ program-specific procedures include 33 CFR 325, Appendix C, and revised interim guidance issued in 2005 and 2007, respectively. The District Engineer consulted district files and records and the latest published version of the National Register of Historic Places and initially determines that:

Should historic properties (i.e., properties listed in or eligible for inclusion in the National Register of Historic Places) be present within the Corps’ permit area, the proposed activity requiring the DA permit (the undertaking) is a type of activity that has no potential to cause an effect to an historic property.

The District Engineer’s final eligibility and effect determination will be based upon coordination with the SHPO, as appropriate and required, and with full consideration given to the proposed undertaking’s potential direct and indirect effects on historic properties within the Corps-identified permit area.

ENDANGERED SPECIES: The Corps has performed an initial review of the application to determine if any threatened, endangered, proposed, or candidate species, as well as the proposed and final designated critical habitat may occur in the vicinity of the proposed project. Based on this initial review, the Corps has made a preliminary determination that the proposed project may affect Central California Coast steelhead distinct population segment (DPS) (Oncorhynchus mykiss), the southern DPS of North American green sturgeon (Acipenser medirostris), and California clapper rail (Rallus longirostris obsoletus) and designated critical habitat for green sturgeon.

Pursuant to Section 7 ESA, any required consultation with the Service(s) will be conducted in accordance with 50 CFR part 402.

This notice serves as request to the National Marine Fisheries Service and U.S. Fish and Wildlife Service for any additional information on whether any listed or proposed to be listed endangered or threatened species or critical habitat may be present in the area which would be affected by the proposed activity.

ESSENTIAL FISH HABITAT: Pursuant to the Magnuson-Stevens Fishery Conservation and Management Act 1996, the Corps reviewed the project area, examined information provided by the applicant, and consulted available species information.

This notice initiates the Essential Fish Habitat (EFH) consultation requirements of the Magnuson-Stevens Fishery Conservation and Management Act. Our initial determination is that the proposed action may adversely affect EFH and/or fisheries managed by Fishery Management Councils and the National Marine Fisheries Service (NMFS). Implementation of the proposed project would adversely impact approximately six acres of estuarine habitat. The effects of the project are determined to be minor and temporary. These habitat(s) are utilized by the following species and their various life stages:

Our final determination relative to project impacts and the need for mitigation measures is subject to review by and coordination with the National Marine Fisheries Service.

NAVIGATION: The proposed structures and activities are not located in the vicinity of a federal navigation channel.

SECTION 408: The applicant does not require permission under Section 14 of the Rivers and Harbors Act of 1899 (33 USC 408) because the activity, in whole or in part,  would not alter, occupy, or use a Corps Civil Works project.

WATER QUALITY CERTIFICATION: The existing Water Quality Certification (“Clean Water Act Section 401 Water Quality Certification And Order For The SFO Shoreline Structures Repair Program Project, San Francisco County,” issued on July 12, 2024 (WDID 2 CW456809)) may require modification.

NOTE:  This public notice is being issued based on information furnished by the applicant. This information has not been verified or evaluated to ensure compliance with laws and regulation governing the regulatory program. The geographic extent of aquatic resources within the proposed project area that either are, or are presumed to be, within the Corps jurisdiction has been verified by Corps personnel.

EVALUATION: The decision whether to modify the RGP will be based on an evaluation of the probable impact including cumulative impacts of the proposed activity on the public interest. That decision will reflect the national concern for both protection and utilization of important resources. The benefits, which reasonably may be expected to accrue from the proposal, must be balanced against its reasonably foreseeable detriments. All factors which may be relevant to the proposal will be considered including cumulative impacts thereof; among these are conservation, economics, esthetics, general environmental concerns, wetlands, historical properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food, and fiber production, mineral needs, considerations of property ownership, and in general, the needs and welfare of the people. Evaluation of the impact of the activity on the public interest will also include application of the guidelines promulgated by the Administrator, EPA, under authority of Section 404(b) of the Clean Water Act or the criteria established under authority of Section 102(a) of the Marine Protection Research and Sanctuaries Act of 1972.  A permit will be granted unless its issuance is found to be contrary to the public interest.

COMMENTS: The Corps is soliciting comments from the public; Federal, State, and local agencies and officials; Indian Tribes; and other Interested parties in order to consider and evaluate the impacts of this proposed activity. Any comments received will be considered by the Corps to determine whether to issue, modify, condition, or deny a permit for this proposal. To make this determination, comments are used to assess impacts to endangered species, historic properties, water quality, general environmental effects, and the other public interest factors listed above. Comments are used in the preparation of an Environmental Assessment (EA) and/or an Environmental Impact Statement pursuant to the National Environmental Policy Act (NEPA). Comments are also used to determine the need for a public hearing and to determine the overall public interest of the proposed activity.

The San Francisco District will receive written comments on the proposed work, as outlined above, until January 17, 2026. Comments should be submitted electronically via the Regulatory Request System (RRS) at https://rrs.usace.army.mil/rrs or to Sarah Firestone at Sarah.M.Firestone@usace.army.mil. Alternatively, you may submit comments in writing to:

San Francisco District

Regulatory Division, CESPN-RGS

450 Golden Gate Ave., 4th Floor

San Francisco, CA  94102-3404

Please refer to the permit application number in your comments.

Any person may request, in writing, within the comment period specified in this notice, that a public hearing be held to consider the application. Requests for public hearings shall state, with particularity, the reasons for holding a public hearing. Requests for a public hearing will be granted, unless the District Engineer determines that the issues raised are insubstantial or there is otherwise no valid interest to be served by a hearing.