Climate Adaptation Plans

Lead

Varies; typically, a local, regional, or tribal planning department

Required Consultation, Review, and Approval

• Consultation: N/A
• Review: N/A
• Approval: Varies - if local, the city council, county commissioners, or board of supervisors

Applicable Statutes and Rules

• SB 379 (2015) (Gov. Code, § 65302, subd. (g)(4)) 
• SB 1035 (2018) (Gov. Code, § 65302, subd. (g)(6)) 

Required Components

• SB 379 (2015) (Gov. Code § 65302(g)(4)) requires adaptation and resilience be incorporated in a city or county’s general plan safety element, either directly or by incorporating other plans by reference into the general plan. Jurisdictions may choose to develop a climate adaptation plan as a standalone document, or appendix to another document to meet this requirement; in these cases, the climate adaptation plan must substantially comply with the requirements set forth in Government Code section 65302, subdivision (g)(4) including:
  • A climate change vulnerability assessment (including flood and fire risk);
  • Adaptation goals, policies, and objectives to address identified vulnerabilities; and,
  • Feasible implementation measures.

• SB 1035 (2017) (Gov. Code, § 65302, subd. (g)(6)) requires cities and counties to update their Safety Elements with newly available climate science, flood, and fire information no less frequently than every eight years, upon the next update to either the Housing Element or LHMP. A local jurisdiction may choose to develop a Climate Adaptation Plan as a standalone document or appendix to another document to meet this requirement. This update is triggered upon either the next LHMP update or next Housing Element update, at the jurisdiction’s discretion, but not less frequently than every eight years.

• Updates or changes to local zoning or other codes and ordinances developed through an adaptation planning process must be consistent with local General Plans.

• Jurisdictions should assess whether CEQA applies to any new or updated plans developed through the adaptation planning process.

Coastal Hazards

• Projects within the San Francisco Bay Conservation and Development Commission (BCDC)’s jurisdiction seeking a permit are subject to policies in the Bay Plan. Bay Plan Climate Change Policies include conducting a risk/vulnerability assessment for major shoreline projects (Policy 2), and being resilient and adaptable (Policy 3), among others. For examples of how climate change policies have been applied in past projects, reference BCDC’s Climate Change Policy Guidance.

• California 2020 Adaptation Planning Guide

• General Plan Guidelines, Chapters 4 & 8

• State of California Sea Level Rise Guidance

• Adaptation Roadmap

• Climate Change Policy Guidance (Bay Area Only)

• Review the California Adaptation Planning Guide and General Plan Guidelines (especially the Required Elements and Climate Change chapters), which include both mandates for cities and counties, and best practices for any jurisdiction to consider when incorporating climate change into local planning documents.

  • Jurisdictions in the Bay Area should also consider reviewing the Adaptation Roadmap. Though the Roadmap provides Bay Area- specific guidance and resources, it also provides information relevant statewide.

• Consider whether the adoption of a standalone climate adaptation plan by a public agency would constitute a project subject to CEQA. Agencies should determine whether the adoption is a discretionary action that could result in a direct physical change or a reasonably foreseeable indirect change in the environment (Pub. Resources Code, § 21065). For more information, consult the Governor’s Office of Planning and Research [See OPR’s CEQA page for more]. 

• While some climate change impacts are already happening, others such as sea level rise may be gradually appearing or only appear once certain ecosystem thresholds are met at an uncertain time frame in the future. As such, adaptation plans and planning processes should include a balance of both short-term and longer-term horizons. See the Adaptation Pathways in the Adaptation Plan section below for specific suggestions on phased adaptation planning.

Coastal Hazards

• Numerous state and federal agency staff are available to support local and regional agencies when planning for coastal resilience. SB 1 (2021) authorized the Ocean Protection Council (OPC) to coordinate the California Sea Level Rise State and Regional Support Collaborative, which is intended to provide information and technical assistance to agencies updating local and regional land use plans to take sea level rise into account. (See Pub. Resources Code, §§ 30970-30973.) OPC, in coordination with the Collaborative, is directed to support and align local and regional sea level rise planning efforts. Jurisdictions should consider engaging the Collaborative and member agencies for guidance and assistance translating science into planning and policy, implementing strategies, governing regional adaptation, and accessing state and federal funding.

• A vulnerability assessment for an adaptation plan may be used to meet Safety Element requirements per SB 379 (2015). The specific vulnerability assessment review requirements (Gov. Code, § 65302, subd. (g)(4)) include at minimum the following:
  • An assessment of how climate change may affect flood and fire risks,
  • Climate science and other relevant information from Cal-Adapt and the California Adaptation Planning Guide,
  • Local agency information on assets, resources, and populations sensitive to climate exposures, and the agencies’ current ability to manage climate impacts,
  • Historical data on natural events and hazards including locally prepared maps of areas subject to previous risk, areas that are vulnerable, and sites that have been repeatedly damaged,
  • Information on existing and planned development in identified at-risk areas, including structures, roads, utilities, and essential public facilities, and
  • Federal, state, regional, and local agencies with responsibility for the protection of public health and safety and the environment, including special districts and local offices of emergency services.

Wildfire

• Combine the Community Risk Assessment and detailed wildfire risk assessment from a CWPP process with the risk assessment for the LHMP, Safety Element, and/or Climate Adaptation Plans when appropriate. [See CWPP plan section for more details.

Coastal Hazards

• The LHMP risk and vulnerability assessment, LCP sea level rise vulnerability assessment, general plan flood risk information, coastal hazard, stormwater, and flooding assessments, and other existing local and regional sources can be used to inform an SB 379 (2015) and SB 1035 (2017) – compliant vulnerability assessment review for an adaptation plan, so long as all the information review requirements described in Government Code, section 65302, subdivision (g)(4)(A) are met.

Given the uniquely flexible nature of adaptation plans, they can be opportune for testing an adaptation pathways approach at any scale (See Adaptation Pathways and Plan Alignment for an introductory overview of this concept). Jurisdictions may also choose to complement this approach with risk tolerance and scenario-based planning, as appropriate. Adaptation plans can also be used to fill an adaptation role or cover a phase that may be out of scope for another plan. For example, most plan horizons cover 30 years or less, and may not be well scoped to plan for climate scenarios beyond 2050, as the Adaptation Planning Guide recommends. Examples may look like: 

• A Conceptual framework: The plan may serve mostly as a conceptual long-term, vision-setting framework for an entire jurisdiction or region that identifies high level adaptation goals, priorities, and objectives, and will guide the development of more focused plans and strategies. The plan may describe foundational information such as the timeline, criteria, and process for developing, updating, or integrating plans, processes, actions, thresholds and triggers while balancing short-, mid- and long-term risks and priorities. The framework could describe at a general level the jurisdiction or region-wide phases and pathways, and identify information gaps to inform future research, while leaving flexibility for more area, topic, or project-specific pathways to be covered by other plans. Other non-climate change hazards could be addressed where the potential for compounding or cascading hazards could occur. 

• An Action Plan: This plan format may be a more intricately detailed, implementation or action plan that complements a conceptional framework, and include focused near-term actions, timelines, implementation roles, funding opportunities, and specific adaptation pathways thresholds and triggers. The plan may cover all climate risks, or a specific subset such as sea level rise and coastal hazards, and a blend of near- and longer-term risks and actions. BCDC counsels in the Adaptation Roadmap that “having all actions and strategies exist in one plan can improve coordination efforts across multiple implementors to more clearly communicate and track how various actions function as a cohesive adaptation strategy.” 

• A Focused Plan: Similar to the action plan format, a focused plan may be more detailed, but focus on a specific area, sector, or subset of climate impacts. This type of plan may cover an entire jurisdiction, or perhaps in larger jurisdictions, be part of a suite of adaptation plans that cover smaller geographic portions or specific topics, such as a shoreline area or the transportation sector. The plan may be focused on near-term actions, or include a blend of near- and longer-term actions. Regardless, a focused plan would ideally support and align with other plans, especially an overarching visionary or framework document. 

• An Integrated Plan: This format may be either more visionary/conceptual or more focused/actionable, and is either merged with another type of community plan such as an LCP or hazard mitigation plan, or attached as an appendix or annex. Ideally, if integrated in this way, the integrated plans are complementary and fully aligned, and identify the ways that thresholds, triggers, and other adaptation pathways concepts inform the plan. 

• Incorporate the LHMP into the Safety Element when conducting an adaptation planning process. Under AB 2140 (2006) (Gov. Code, §§ 65302.6 and 8685.9), this enables jurisdictions to be eligible for consideration for state funding to cover the local match (6.25%) of FEMA PA costs for recovery activities after hazard events. Incorporation of the LHMP is also one option of compliance for meeting SB 379 (2015) (Gov. Code, § 65302, subd. (g)(4)) and SB 1035 (2017) (Gov. Code, § 65302, subd. (g)(6)) adaptation requirements.

• When updating the Safety Element to incorporate adaptation information or an adaptation plan, use the opportunity to sync the Housing Element and Safety Element to meet SB 1035 (2017) requirements (Gov. Code, § 65302, subd. (g)(6)). Updating both elements concurrently may trigger an SB 1000 environmental justice element update (Gov. Code, § 65302, subd. (h)).

• Inform disaster recovery planning with climate information (greenhouse gas mitigation, adaptation, and resiliency strategies and actions) included in the general plan Safety Element or local climate adaptation plan. The Safety Element also includes residential vulnerability and evacuation route information that should be used in recovery planning (See SB 99 (2019) and AB 747 (2019), codified at Gov. Code, §§ 65302, subd. (g)(5), 65302.15).

Wildfire

• Multiple integration pathways are possible between a CWPP and Adaptation Plan and/or other plans. Possible pathways to integrate the plans include but are not limited to:
  • Incorporate the entire CWPP. Communities can develop a standalone CWPP and include the plan as either a separate volume or chapter in the Adaptation Plan. 
  • Use sections of the CWPP. The CWPP maps and Risk Assessment may become the basis for the Wildfire Hazard Profile in an Adaptation Plan. The CWPP Priorities and Action Plan could be incorporated into the goals, strategies, and actions of the Adaptation Plan. 
  • Develop a single, unified plan that meets both plans’ requirements. Chart a project course that meets CWPP and Adaptation Plan planning process and content requirements. 
  • Maintain separate, but aligned, plans between jurisdictions. Jurisdictions with different but overlapping boundaries may find it most useful to maintain separate plans that leverage the same information, resources, and processes when appropriate.

• For jurisdictions in the Coastal Zone, when developing or updating a Local Coastal Program Plan, leverage the wildfire information included in the Adaptation Plan to meet the wildfire planning requirements of the Coastal Act (PRC § 30253).

Coastal Hazards

• Local coastal programs tend to require more specificity than general plans. Be aware of potential inconsistent land use policies. If a portion of a jurisdiction is in the Coastal Zone, that area is regulated by the Coastal Act (PRC § 30253) and local coastal programs.

Consider carefully whether your alignment (planning) team or advisory groups should include any of the entities from each of these entity types as applicable to your jurisdiction, and how and when to engage different entities to achieve the most equitable and accurate results.