Agenda packet, study session — Half Moon Bay City Council, September 22, 2026

CITY OF HALF MOON BAY

JOINT STUDY SESSION

CITY COUNCIL & PLANNING COMMISSION

AND CITY COUNCIL MEETING REVISED
AGENDA
TUESDAY, SEPTEMBER 22, 2026
7:00 PM

TED ADCOCK COMMUNITY CENTER
535 KELLY AVENUE

HALF MOON BAY, CA

IN-PERSON/HYBRID
This agenda contains a brief description of each item to be considered. Those wishing to address the Planning Commission and City Council on any matter not listed on the agenda, but within the jurisdiction of the Planning Commission and City Council to resolve, may come forward to the podium during the Public Forum portion of the agenda and will have a maximum of three minutes to discuss their item. Those wishing to speak on a Business or Public Hearing matter will be called forward at the appropriate time during that item’s consideration.

Public Comment – Staff will respond to written public comments submitted before Monday 1:00 PM, the day prior to scheduled meeting date. Comments submitted after that time will be forwarded to Planning Commission and City Council up to one hour before the meeting start time.

NOTE: Anyone wishing to present materials to the Planning Commission and City Council, please submit seven copies to the Planning Clerk.

Copies of written documentation relating to each item of business on the agenda are on file in the Office of the City Clerk at City Hall where they are available for public inspection. If requested, the agenda shall be available in appropriate alternative formats to persons with a disability, as required by Section 202 of the Americans with Disabilities Act of 1990 (42 U.S.C. Sec. 12132.) Information may be obtained by calling 650-726-8271.

In compliance with the Americans with Disabilities Act, special assistance for participation in this meeting can be obtained by contacting the City Clerk’s Office at 650-726-8271. A 48-hour notification will enable the city to provide reasonable accommodation to ensure accessibility to this meeting (28 CFR 35.102-35.104 ADA Title II).

Debbie Ruddock, Mayor
Deborah Penrose, Vice Mayor
Robert Brownstone, Councilmember
Patric Jonsson, Councilmember
Paul Nagengast, Councilmember
David Gorn, Chair
Rick Hernandez, Vice Chair
Jacob (Jim) Rems, Commissioner
Christopher DelNagro, Commissioner
Stephen Ruddock, Commissioner
1 http://halfmoonbay.gov/
MEETING WILL CONCLUDE BY 10:30 PM UNLESS OTHERWISE EXTENDED BY SIMPLE MAJORITY VOTE OF THE PLANNING COMMISSION AND CITY COUNCIL AND CITY COUNCIL.

HYBRID MEETING PARTICIPATION PROTOCOLS
This meeting will be held in-person and via Zoom for public participation. Public comments may be made in-person or remotely via Zoom, and interpretation will be available. Planning Commission and City Council and staff will participate in person. During any public comment portions, attendees may use the “raise your hand” feature and will be called upon and unmuted when it is their turn to speak.

If joining by phone, use *9 to raise your hand, *6 to mute and unmute. The meeting will also be streamed on Channel 27, on pacificcoast.tv.

Please click on the link below to join the webinar:

Click here to join the Joint Study Session
Phone: 1-669-900-6833, 83502131401#,*94019#
Webinar ID: 835 0213 1401
Passcode: 94019
Wi-Fi: HMB Public
Password: Recreation1
TELECONFERENCE/REMOTE: Vice Chair Rick Hernandez, Hyatt Regency Huntington Beach Resort & Spa Lobby; 21500 Pacific Coast Hwy, Huntington Beach, CA 92648.

PLEDGE OF ALLEGIANCE AND ROLL CALL

PUBLIC COMMENT

RECOGNITION AND APPRECIATION OF THE ARCHITECTURAL ADVISORY COMMITTEE (AAC)

1. PUBLIC HEARING ITEMS

1.A JOINT STUDY SESSION WITH CITY COUNCIL AND PLANNING COMMISSION

AND CITY COUNCIL IMPLEMENTATION PLAN UPDATE - ANALYSIS AND

IDENTIFICATION REPORT
Staff Recommendation: Receive a presentation introducing the overall Implementation Plan Update project, including the findings and recommendations of the project's Analysis and Identification Report, and provide an opportunity for public comment, discussion, and direction to staff to inform the development of the preliminary draft regulations. No action to adopt or amend the Implementation Plan or Municipal Code is proposed at this meeting.

Presentation by: Paul Chytla-Hinze, Associate Planner and Martha Miller, Implementation Plan Consultant

STAFF REPORT
ATTACHMENT 1
2 ADJOURNMENT

LATE CORRESPONDENCE

Public Comment 09/22/2026
3 CIUDAD DE HALF MOON BAY
SESIÓN DE ESTUDIO CONJUNTA
CONCEJO MUNICIPAL Y COMISIÓN DE PLANIFICACIÓN, Y REUNIÓN DEL CONCEJO MUNICIPAL: AGENDA REVISADA
MARTES, 22 DE SEPTIEMBRE DE 2026
7:00 PM
Debbie Ruddock, Alcaldesa
Deborah Penrose, Vicealcaldesa
Robert Brownstone, Concejal
Patric Jonsson, Concejal
Paul Nagengast, Concejal
David Gorn, Presidente
Rick Hernandez, Vicepresidente
Jacob (Jim) Rems, Comisionado
Christopher Del Negro, Comisionado
Stephen Ruddock, Comisionado

CENTRO COMUNITARIO TED ADCOCK
535 KELLY AVENUE

HALF MOON BAY, CA
PRESENCIAL/HÍBRIDA
Esta agenda contiene una breve descripción de cada asunto que se considerará. Quienes deseen dirigirse a la Comisión de Planificación y al Concejo Municipal sobre cualquier asunto que no figure en la agenda, pero que sea competencia de la Comisión de Planificación y del Concejo Municipal, pueden pasar al podio durante el Foro Público de la agenda y tendrán un máximo de tres minutos para exponer su tema. Quienes deseen hablar sobre un asunto de Negocios o de Audiencia Pública serán llamados al podio en el momento oportuno durante la consideración de ese punto.

Comentarios del público: El personal responderá a los comentarios escritos del público que se presenten antes de las 1:00 PM del lunes, el día anterior a la fecha programada de la reunión. Los comentarios presentados después de esa hora se remitirán a la Comisión de Planificación y al Concejo Municipal hasta una hora antes del inicio de la reunión.

NOTA: Toda persona que desee presentar materiales a la Comisión de Planificación y al Concejo Municipal deberá entregar siete copias al Secretario de Planificación.

Las copias de la documentación escrita relativa a cada asunto de la agenda se encuentran archivadas en la Oficina de la Secretaría Municipal en el Ayuntamiento, donde están disponibles para inspección pública. Si se solicita, la agenda estará disponible en formatos alternativos apropiados para las 4 personas con discapacidad, según lo exige la Sección 202 de la Ley de Estadounidenses con Discapacidades de 1990 (42 U.S.C. Sec. 12132). Puede obtener información llamando al 650-726- 8271.

En cumplimiento de la Ley de Estadounidenses con Discapacidades, puede obtener asistencia especial para participar en esta reunión comunicándose con la Oficina de la Secretaría Municipal al 650-726- 8271. Un aviso con 48 horas de anticipación permitirá a la ciudad proporcionar adaptaciones razonables para garantizar la accesibilidad a esta reunión (28 CFR 35.102-35.104, ADA Título II). http://halfmoonbay.gov/
LA REUNIÓN CONCLUIRÁ A LAS 10:30 PM, A MENOS QUE LA COMISIÓN DE PLANIFICACIÓN Y EL CONCEJO MUNICIPAL, Y EL CONCEJO MUNICIPAL, DECIDAN EXTENDERLA POR VOTO DE MAYORÍA SIMPLE.

PROTOCOLOS DE PARTICIPACIÓN EN LA REUNIÓN HÍBRIDA
Esta reunión se celebrará de forma presencial y por Zoom para la participación del público. Los comentarios del público podrán hacerse en persona o de forma remota por Zoom, y habrá servicio de interpretación disponible. La Comisión de Planificación, el Concejo Municipal y el personal participarán en persona. Durante los periodos de comentarios del público, los asistentes podrán usar la función "levantar la mano" y se les llamará y se les activará el micrófono cuando sea su turno de hablar. Si se conecta por teléfono, use *9 para levantar la mano y *6 para silenciar y activar el micrófono. La reunión también se transmitirá en el Canal 27 y en pacificcoast.tv.

Haga clic en el siguiente enlace para unirse al seminario web:

Haga clic aquí para unirse a la Sesión de Estudio Conjunta Teléfono: 1-669-900-6833, 83502131401#,*94019#
ID del seminario web: 835 0213 1401
Código de acceso: 94019
Wi-Fi: HMB Public
Contraseña: Recreation1
TELECONFERENCIA/REMOTO: Vice presidente Rick Hernandez, Vestíbulo del Hyatt Regency Huntington Beach Resort & Spa; 21500 Pacific Coast Hwy, Huntington Beach, CA 92648.

JURAMENTO A LA BANDERA Y PASE DE LISTA
COMENTARIOS DEL PÚBLICO
RECONOCIMIENTO Y AGRADECIMIENTO AL COMITÉ ASESOR DE ARQUITECTURA (AAC)

1. ASUNTOS DE AUDIENCIA PÚBLICA
5 1.A SESIÓN DE ESTUDIO CONJUNTA CON EL CONCEJO MUNICIPAL Y LA COMISIÓN DE PLANIFICACIÓN, Y EL CONCEJO MUNICIPAL: ACTUALIZACIÓN DEL PLAN DE IMPLEMENTACIÓN – INFORME DE ANÁLISIS E IDENTIFICACIÓN
Recomendación del personal: Recibir una presentación que introduzca el proyecto general de Actualización del Plan de Implementación, incluidos los hallazgos y las recomendaciones del Informe de Análisis e Identificación del proyecto, y brindar la oportunidad de recibir comentarios del público, debatir y dar instrucciones al personal para orientar la elaboración de los borradores preliminares de la normativa. En esta reunión no se propone adoptar ni modificar el Plan de Implementación ni el Código Municipal.

Presentación a cargo de: Paul Chytla-Hinze, Planificador Asociado, y Martha Miller, Consultora del Plan de Implementación

INFORME DEL PERSONAL
ANEXO 1

CLAUSURA
6 BUSINESS OF THE PLANNING

COMMISSION AND CITY COUNCIL OF

THE CITY OF HALF MOON BAY

STAFF REPORT
For meeting of: September 22, 2026
TO: Honorable Mayor and City Council
Honorable Chair and Planning Commissioners
VIA: Matthew Chidester, City Manager
FROM: Paul Chytla-Hinze, Associate Planner
TITLE: Implementation Plan Update – Analysis and Identification Report

PURPOSE
Receive a presentation introducing the overall Implementation Plan Update project, including the findings and recommendations of the project's Analysis and Identification Report, and provide an opportunity for public comment, discussion, and direction to staff to inform the development of the preliminary draft regulations. No action to adopt or amend the Implementation Plan or Municipal Code is proposed at this meeting.

BACKGROUND
Under the Coastal Act, a Local Coastal Program (LCP) consists of a Land Use Plan (LUP) and an Implementation Plan (IP). In Half Moon Bay, the IP serves as the City's zoning and development code and is implemented primarily through Municipal Code Titles 17 (Subdivisions) and 18 (Zoning). The IP was originally certified in 1996 and has never been comprehensively updated, while the LUP was comprehensively updated in 2020.

The City is undertaking a comprehensive Implementation Plan Update to: (1) implement the 2020 LUP; (2) ensure internal consistency within the Municipal Code; (3) align local regulations with recent State law; and (4) make the code easier to use and maintain. The project includes a comprehensive update of Title 18, updates to Title 17, and updates to related Municipal Code chapters and permitting processes.

The project is a Council Priority under the Organizational Health and Excellence focus area of the FY 2026–28 Strategic Priorities Workplan, with a target completion date of Q3 FY 2027–28. It also supports the Healthy Communities, Public Safety, and Inclusive Governance Strategic Elements by modernizing regulations for consistency, usability, and maintenance while incorporating climate adaptation and equity considerations. 7 Milestones to Date
Since project initiation, Staff, with consultant assistance, has:

1. Completed consultant procurement and engagement, with the RFP process concluding in February 2026;

2. Established a project Working Group comprising Community Development staff, two Planning Commission members, and two California Coastal Commission members;

3. Launched the project website;

4. Completed the research and assessment phase, including focus group interviews with stakeholders; and

5. Completed the Analysis and Identification Report evaluating the current IP and related Municipal Code chapters (Attachment 1).

Upcoming milestones include:

1. the community survey and final two of eight Project Introduction Roadshows scheduled for September 23 and 28, 2026;

2. development of preliminary draft regulations;

3. preparation of a draft Zoning Code/Implementation Plan and related Municipal Code amendments; and

4. subsequent public hearings and adoption.

DISCUSSION
The Analysis and Identification Report is a foundational document for the Implementation Plan Update. It identifies deficiencies, inconsistencies, and opportunities for improvement in the City's existing regulations and establishes recommendations to guide preparation of the preliminary draft regulations. The recommendations are intended to improve code clarity and usability, implement the 2020 LUP, streamline development review, and maintain compliance with State and federal law while advancing the City's goals related to equity and climate adaptation.

The Analysis and Identification Report evaluated the current IP and related Municipal Code chapters across four topic areas: Code Usability, Land Use Plan Implementation, Review Processes, and Compliance with State and Federal Law. Key findings and recommendations are summarized below; the full report is provided as Attachment 1.

Focus Group Interviews
Stakeholder focus groups generally found that existing development standards and use allowances provide a workable regulatory framework, while identifying opportunities for greater flexibility and improved clarity. Participants highlighted opportunities to expand flexibility for home occupations and changes of use, reduce permit processing times, clarify application requirements, and streamline review by multiple bodies. Participants also identified challenges associated with parking on small lots and navigating the existing Municipal Code (i.e., Titles 17 and 18).
8 Municipal Code Usability
Information in the current Municipal Code can be difficult to find, some regulations are redundant, and there is no clear distinction between provisions implementing the Coastal Act and those implementing the LUP. Recommendations include reorganizing the City’s Zoning Code (Title 18) into five articles: General Provisions, District Regulations, Citywide Standards, Administration, and Terms and Definitions; deleting obsolete sections; clearly identifying the chapters and sections that comprise the IP; and identifying equity intentions through purpose statements.

Land Use Plan Implementation
The City's zoning districts must be evaluated for consistency with the 2020 LUP land use designations, and new or revised regulations must be adopted to implement applicable LUP policies. Recommendations include minimizing the number of individual zoning districts, correlating district names with LUP land use designations, and evaluating regulations for distributional and structural equity so that requirements are transparent and consistently applied.

Review Processes
Development review procedures should provide greater certainty and flexibility while maintaining appropriate opportunities for review and relief. Recommendations include adjusting review thresholds to rely more heavily on objective standards; establishing a Coastal Development Permit (CDP) waiver process for de minimis development consistent with LUP Policy 2-11; establishing a Minor Use Permit procedure with a hearing before the Community Development Director; extending Architectural, Landscape, and Site Plan Review to projects that do not require a CDP; and allowing limited modifications to dimensional standards where warranted by special circumstances.

Compliance with State and Federal Law
The existing IP must be updated to reflect changes in State and federal law and to ensure that local regulations remain within the City's regulatory authority. The report identifies required or recommended amendments related to housing, including SB 9, SB 330, AB 686, accessory dwelling units (ADUs), affordable and workforce housing, and manufactured housing; adultoriented businesses; cottage food operations; emergency shelters; environmental justice; signs; solar energy systems; telecommunications; and other applicable Coastal Act, constitutional and statutory requirements.

FISCAL IMPACT
There is no additional fiscal impact to the General Fund associated with this item. The total project cost for the Implementation Plan Update is approximately $861,000, consisting of a $500,000 California Coastal Commission (CCC) Local Coastal Program Local Assistance Grant (Agreement No. LCP-25-05), $200,000 in City match/other project funds, and approximately $161,000 in City staff labor.
9 CCC grant funds will support eligible consultant and project costs associated with project management, analysis and code updates, community outreach, environmental compliance, development of the draft Implementation Plan and associated ordinances, and public hearings. The City's matching funds and staff resources are included in the existing project budget and funding commitments.

Conclusion
The Analysis and Identification Report provides a comprehensive assessment of the City's current Implementation Plan and identifies opportunities to improve code usability, implement the 2020 LUP, streamline development review, and maintain compliance with State and federal law. The report's findings and recommendations will serve as a foundation for developing the preliminary draft regulations and subsequent amendments to the Implementation Plan and related Municipal Code provisions.

Staff is seeking input from the Planning Commission and City Council on the findings and recommendations presented in the report. Any direction provided at this meeting will be considered as staff and the project team proceed with development of the preliminary draft regulations and subsequent opportunities for public review and comment.

Attachments
1) Analysis and Identification Report
10 HALF MOON BAY

IMPLEMENTATION PLAN UPDATE
CLEAR RULES. CONSISTENT STANDARDS.

AUGUST 2026

ANALYSIS AND IDENTIFICATION
REPORT
11 2
Contents
1 Introduction .................................................................................... 4 2 Code Usability ................................................................................. 6 ORGANIZATION AND STYLE ................................................................................................... 6 Develop a New Format and Organization ..................................................................................................... 7 Clearly Identify Chapters and Sections that Comprise the Implementation Plan ........................................ 7 Simplify Regulations and Procedures ........................................................................................................... 8 Identify Intentions to Advance Equity .......................................................................................................... 8 3 Land Use Plan Implementation ........................................................ 9 ZONING DISTRICTS ................................................................................................................ 9 Revised Zoning Districts and District Provisions Necessary to Implement Land Use Plan Designations and Policies ..................................................................................................................................... 10 REGULATIONS AND PROCEDURES ........................................................................................ 11 Revised Regulations to Implement Land Use Plan Designations and Policies ............................................ 12 Distributional and Structural Equity ........................................................................................................... 13 4 Review Processes .......................................................................... 15 RELIANCE ON DISCRETIONARY REVIEW ................................................................................ 15 Adjust Review Thresholds ........................................................................................................................... 16 Clarify Review Procedures .......................................................................................................................... 17 LACK OF RELIEF FROM STANDARDS FOR PARTICULAR SITUATIONS ...................................... 17 Provide Certainty and Allow Flexibility ....................................................................................................... 17 ENFORCEMENT, IMPLEMENTATION, AND CIVIC ENGAGEMENT ............................................ 18 Promote Equity through Administration of the Code Administration ....................................................... 18 12 3
5 State and Federal Law ................................................................... 19 HOUSING ................................................................................................................ 19 SB330 – Housing Crisis Act .......................................................................................................................... 19 Accessory Dwelling Units (ADUS) ................................................................................................................ 19 Affordable Housing ..................................................................................................................................... 20 Housing for Persons with Disabilities .......................................................................................................... 20 Manufactured Housing ............................................................................................................................... 21 AB 686 – Affirmatively Furthering Fair Housing (AFFH) .............................................................................. 21 ADULT ORIENTED BUSINESSES ............................................................................................. 21 COASTAL ACT ................................................................................................................ 21 COTTAGE FOOD OPERATIONS .............................................................................................. 22 EMERGENCY SHELTERS; TRANSITIONAL AND SUPPORTIVE USES ........................................... 22 ENVIRONMENTAL JUSTICE ................................................................................................... 22 FAMILY DAY CARE HOMES ................................................................................................... 23 PROCESSING AND REVIEW PROCEDURES ............................................................................. 23 RELIGIOUS USES ................................................................................................................ 23 SIGNS ................................................................................................................ 24 SOLAR ENERGY SYSTEMS ..................................................................................................... 24 TELECOMMUNICATIONS ...................................................................................................... 24 WATER CONSERVATION AND LANDSCAPING ....................................................................... 24 Appendix A: Focus Group Interview Summary ................................. 25 Appendix B: Zoning/Land Use Designation Conflict Analysis ............ 29 13 4
1 Introduction
The Implementation Plan Update is an effort to comprehensively update the City of Half Moon Bay’s Coastal Implementation Plan (IP) and Zoning Code. The goal of the project is to produce a state of the art, flexible, clear, and user-friendly IP that will serve as an effective tool to achieve the community’s vision for development and coastal resource protection established in the City’s Land Use Plan (LUP).

California’s Coastal Act requires coastal communities to have a Local Coastal Program (LCP) that guides development and protects coastal resources. Each LCP includes an LUP, which establishes policies for the type, location, and intensity of uses, and an Implementation Plan (IP), which implements the LUP through zoning regulations, zoning maps, and other actions. In Half Moon Bay, the IP serves as the City’s zoning and development code.

While Half Moon Bay’s LUP was comprehensively updated in 2020, the IP has not been comprehensively updated since 1996. The IP Update Project will revise zoning regulations, procedures, and development standards to:
 Implement the 2020 LUP
 Ensure internal consistency within the City’s Municipal Code  Align with recent State laws
 Ease use & maintenance for years to come
The project will result in a comprehensive update to Title 18, Zoning, of the Half Moon Bay Municipal Code with clear identification of the portions of Title 18 that make up the City’s IP and which portions are part of the City’s general regulatory framework; as well as targeted updates to related Municipal Code chapters and permitting processes.

This Report
As one of the first steps in the revision process, City staff and the consultant team have been evaluating the current Zoning Code/Implementation Plan to identify issues that need to be addressed and changes that should be considered as part of the update.

This memo summarizes the principal findings and conclusions of the consultant team’s work and recommends a number of ways that the current code could be improved to meet the overall objectives of the update. It is intended to distill key choices and present “big ideas” for the update, which will be further developed and refined as draft regulations are created. 14 5
The report is organized by four topical areas:
 Code Usability;
 Land Use Plan Implementation;
 Review Processes; and
 Compliance with State and Federal Law.
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2 Code Usability
The City’s current Implementation Plan (IP) is made up of Municipal Code Titles 17, Subdivisions, and 18, Zoning. The need to make Half Moon Bay’s IP and regulatory framework more user-friendly and concise was noted during focus group meetings with code users as well as City staff. Staff commented that the Implementation Plan/Zoning Code is complex and difficult to interpret. Users and City staff have complained that when they look up the regulations governing a project, they have no confidence that they are seeing a comprehensive list. Because standards are dispersed users are left with a nagging fear that a “hidden” regulation might affect the viability of a project. Uncertainty regarding development possibilities, rules, and regulations can be a significant barrier when attempting to protect coastal resources and attract suitable development. A well-organized Zoning Code and Implementation Plan is easy to use, navigate, and understand. This section contains general observations about the existing organization, format, and usability, as well as strategies for improving these aspects of the existing Implementation Plan and regulatory framework.

Organization and Style
The basic framework of the City’s current Zoning Code, Title 18 of the Half Moon Bay Municipal Code, was established nearly 30 years ago. It is organized in a manner that exhibits an underlying structure, but has been amended numerous times, where additional chapters and regulations were added without sufficient attention to the overall structure and organization. The end result is a complex Code that is difficult to navigate.

Additionally, the current approach of including the entireties of the Zoning Code and Subdivision Ordinance in the IP causes confusion and additional complexity. An IP must include measures for implementing and carrying out the policies of the LUP, including providing the requirements for the issuance of Coastal Development Permits. While zoning codes and subdivision ordinances include provisions for implementing LCPs, they also include other provisions important to the regulation of land use and development within the City but that do not implement the Coastal Act or the LUP. For example, the largely procedural provisions in a subdivision ordinance are dictated by the Subdivision Map Act, which sets forth very detailed and substantive requirements to govern how municipalities create parcels of land for sale and development, rather than the Coastal Act.

Including the entireties of the Zoning Code and Subdivision Ordinance in the IP hampers the ability of the City to update and maintain its land use and development provisions over time as Coastal Commission certification is necessary to change any portion of the documents, whether or not the amendment is related to the implementation of the Coastal Act or the LUP. 16 7

DEVELOP A NEW FORMAT AND ORGANIZATION
The organization of Half Moon Bay’s Zoning Code can be improved in several ways, with the overall organization and formatting of the code reflecting a systematic, consistent, and sound arrangement to facilitate ease of use. Overall, the Code should progress from the most often referenced to the least— with basic provisions in the beginning, followed by regulations of specific zones, citywide standards, and then administrative chapters. A final chapter can group all definitions together, so that users have access to a comprehensive reference section in an easily located place.

First, Articles that group related chapters should be refined as follows.  Article I: General Provisions
 Article II: District Regulations
 Article III: Citywide Standards
 Article IV: Administration
 Article V: Terms and Definitions
Chapters and sections within the Articles should be reorganized so that they flow logically and have a consistent structure. As a general rule, the most frequently consulted provisions should come before those less frequently consulted; and the more general should come before the more specific. These organizational revisions should be coupled with improvements to the appearance of the text itself to help readability, including wider spacing, different fonts for chapters, sections, and the main text, and consistent indentation.

In addition, it is important to design the format and organization of the IP and Zoning Code to ensure that it is accessible and usable for as many community members as possible. This includes using plain language, clear organization, and accessible digital formats that make regulatory information easier to search, understand, and use.

CLEARLY IDENTIFY CHAPTERS AND SECTIONS THAT COMPRISE THE IMPLEMENTATION PLAN Through the IP Update, the City will align IP provisions with the updated LUP. The City should also take this opportunity to clearly identify the specific components of the Zoning Code and Subdivision Ordinance, if any, that are part of the IP. Rather than designating the entire Zoning Code and Subdivision Ordinances as the City’s IP, the provisions that comprise the IP could be indicated with an (IP) following the chapter or section name. This approach has the advantage of maintaining the City’s existing overall organizational framework for land use and development regulations while separating out the IP provisions that are under the purview of the Coastal Commission.
17 8

SIMPLIFY REGULATIONS AND PROCEDURES
Half Moon Bay should ensure that the Zoning Code and IP functions efficiently and with the fewest number of provisions necessary to achieve its goals. Unnecessary and obsolete sections of the code should be removed in order to avoid ambiguity and reduce the sheer bulk of the code.

Duplication and unnecessary redundancy should be removed. When the code repeats information in nearly or exactly the same language, it is not always clear whether nuances in wording or positioning are intended to accomplish different goals, or if they override each other entirely. Duplication such as this not only lengthens the text, but also introduces an element of doubt that differently worded regulations might affect a person’s ability to develop and use properly. It can also complicate zoning administration.

Overall, related content should be organized together. Standards that apply solely to a particular set of base districts (i.e., Residential Districts, Commercial Districts, etc.), should be grouped together. Standards that are applicable to specific uses or development citywide, such as parking or sign standards, should be grouped together. Rules governing the construction of language, interpretation of code provisions, and measurement should likewise be grouped together to serve as a reference section that users can turn to in the event of uncertainty regarding code provisions. Consolidating related regulations into one section will help to ensure that standards are logical and consistently interpreted and applied.

IDENTIFY INTENTIONS TO ADVANCE EQUITY
Implementation of LCP Policy 1-5 Social Equity and Environmental Justice has implications for regulations and procedures across a wide range of planning topics. The updated Implementation Plan should highlight where regulations and procedures are intended to advance equity. This can be done through purpose statements that explain the intent of the regulations and how they relate to social equity. This will help ensure these regulations and procedures are implemented and that intended equity outcomes are successfully achieved.
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3 Land Use Plan
Implementation
The City’s LUP, comprehensively updated in 2020, specifies the allowable kinds, locations, and intensities of development in the jurisdiction’s coastal zone, and the resource protection and development policies necessary to meet the requirements of the Coastal Act.

The challenge for the IP update is to translate the LUP land use designations and policies into a userfriendly, legally adequate, and effective set of zoning, development standards and permitting procedures consistent with and adequate to carry out the LUP. The IP should clearly communicate and effectively implement the LUP’s policies and incorporate its carefully crafted direction for the development, maintenance, and improvement of land and properties and protection of coastal resources. This section contains general observations and strategies for improving the IP to be more conducive and effective in achieving the policies and land use designations in the LUP.

Zoning Districts
Zoning districts create the framework for implementation of LUP policies and land use designations.

Generally, zoning codes include two types of zones or districts, base and overlay. “Base zones” or “base districts” set the basic regulations that apply within the geographic area that defines the district. A community may want to vary some of the regulations within the base district to respond to particular conditions within defined areas. “Overlay districts” are often used for this purpose.

Overlay districts are “laid over” or applied to base districts in situations in which modification of permitted uses or required standards is appropriate due to specific conditions, circumstances, or goals. Overlay districts can be geographically defined and mapped or can apply wherever specific conditions exist.

In areas where the LUP anticipates change or refinement of direction, new districts may be needed. There may also be opportunity for streamlining existing districts. In interest of creating a concise and userfriendly zoning code, the total number of districts within the code should be minimized and districts that are no longer needed should be removed.
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REVISED ZONING DISTRICTS AND DISTRICT PROVISIONS NECESSARY TO IMPLEMENT LAND USE

PLAN DESIGNATIONS AND POLICIES
Each existing district should be assessed for its applicability, ability to implement LUP land use designations and policies. The overall approach to the zone scheme in the updated code is to implement the LUP while minimizing the total number of individual zones.

The table below lists the LUP land use designations and the corresponding current zoning districts. Areas where the existing zoning matches the corresponding LUP land use designation in the table below are considered ‘consistent’. In these areas, zone changes are not necessary for LUP consistency. Areas where the existing zoning does not match the corresponding LUP land use designation in the table below may be considered ‘in conflict’. As part of the IP Update, the zoning of these areas should be changed to a zone that corresponds to the LUP designation. These areas are identified in Appendix A Zoning/Land Use Designation Conflict Analysis.

LUP LAND USE DESIGNATION/ZONING CORRESPONDENCE
LUP Land Use Designation Corresponding Zoning District(s) Residential - Low Density None (new district is needed) Residential - Medium Density
R-1
R-1 B-1
R-1 B-2
R-1 B-3
R-2
Residential – High Density R-3
Mobile Home Park MHP
Commercial - General
C-D
C-G
C-R
Commercial – Visitor Serving C-VS
Industrial - Light IND
Horticulture - Business A-1
Rural Coastal UR
OS-R
Open Space for Conservation OS-C
Public Facilities and Institutions P-S
Regional Public Recreation OS-P
OS-A
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LUP LAND USE DESIGNATION/ZONING CORRESPONDENCE
LUP Land Use Designation Corresponding Zoning District(s) City Parks OS-A
Planned Development PUD
Additionally, in the interest of making the code easier to use and understand, the names of individual zoning districts could be refined to more clearly reflect the character and intent of each district. For example, in the current code, each base residential zone is defined by a lettered prefix (R for Residential) followed by a numbered suffix (based on development density/intensity). Some jurisdictions have moved away from this letter-number format and simply assign an easily defined name to each zoning district, so that the resulting letter designations are easily understandable and relate more clearly to the associated purpose of the zone. The existing R-1, R-2, and R-3 zoning districts could be renamed to employ letter designations, RL (Residential Low Density), RM (Residential Medium Density), and RH (Residential High Density). This would provide greater clarity regarding the predominant character and purpose of each zoning district.

Finally, the LUP identifies two overlay designations, the Workforce Housing and the Greenbelt Stream Corridor overlays. The updated IP should include land use criteria and development standards to implement these designations. Through the update, additional overlay districts should be evaluated for their usefulness in implementing other LUP policies.

Regulations and Procedures
The LUP adopted in 2020 contained new and revised policies from the previous LUP. In order to implement the current LUP policies, the City will need to adopt new and revised development regulations and procedures. Additionally, while the Zoning Code has been amended numerous times, it has not been comprehensively updated since its original adoption. Many of the standards were established more than 30 years ago and reflect the specific development style and context popular at the time. Over the years, additional development standards and requirements have been added with little analysis of how all the standards work together and collectively influence resulting development. The adoption of the new LUP has created an obligation and an opportunity to update the IP and Zoning Code, to create a concise and user-friendly set of regulations that will implement the LUP’s policies and incorporate its carefully crafted direction for the development, maintenance, and improvement of land and properties and protection of coastal resources. Through the update, the City should also ensure that the Zoning Code and IP functions efficiently and with the fewest number of provisions necessary to achieve its goals. 21 12

REVISED REGULATIONS TO IMPLEMENT LAND USE PLAN DESIGNATIONS AND POLICIES Through the IP Update, development regulations and procedures should be updated for conformance with the LUP based on new policies, programs, and land use designations. These updates are summarized in the table below.

LUP CONSISTENCY AMENDMENTS
Topic Related LUP
Policy
Scope/notes Corresponding IP component
GP Amendment
initiation
2-10 Require City Council
authorization to process private
General Plan amendment
applications
Amendment initiation
provisions
CDP Waivers 2-11 Expedited processing for de
minimus development projects
CDP procedures –
incorporate process for
Waivers of De Minimis
Development
Minimum
Densities
2-18
2-67
Establish minimum residential
densities
R-3 District development
standards
Planned Unit
Development
zoning district
2-41 through 2-
65 Update to conform with LUP
(permitted uses, master planning
requirements, Dykstra Ranch
zoning ordinance)
Planned Unit Development
(PUD) provisions
Small lot infill 2-73 Update standards and
procedures for substandard infill
residential lots
Residential District
development standards
Home
Occupation
2-75 Establish performance standards
for traffic, parking, noise, etc.

Home Occupation provisions
Workforce
Housing
Overlay
2-70, 2-94, 2-98,
2-104, 2-107
Establish new overlay district
with affordability requirements,
development standards, etc.

Workforce Housing Overlay
Industrial
zoning district
2-82, 2-83, 2-84 Include live-work uses, update
development standards for land
use compatibility
Industrial District standards
Rural Coastal
zoning district
2-86 through 2-
94 Establish new zoning district with
use regulations and development
standards
Rural Coastal or equivalent
district standards
Agriculture
zoning district
2-86 through 2-
94 Establish new zoning district with
use regulations and development
standards
Horticultural Business or
equivalent district standards
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LUP CONSISTENCY AMENDMENTS
Topic Related LUP
Policy
Scope/notes Corresponding IP component
Public Services
zoning district
2-108 Update development standards
for land use compatibility
Public and Quasi-Public or
equivalent district standards
Public Access
zoning
ordinance
Chapter 5.

Coastal Access
and Recreation
Update to conform with LUP Local Coastal Program Public Access provisions
Coastal
Resource
Conservation
Standards
zoning
ordinance
Chapter 6.

Natural
Resources,
Chapter 7.

Environmental
Hazards
Update to conform with LUP Coastal Resource
Conservation standards
Visual
Resources
zoning
ordinance
Chapter 9.

Scenic and
Visual Resources
Update to conform with LUP Resource Protection
standards
Zoning Code
Definitions
Glossary Update to conform with LUP Definitions
Lot Retirement 2-21 Require lot retirement when a
new residential lot is created
Citywide requirement
Lot Mergers 2-23 Require lot mergers for
contiguous substandard lots
under common ownership
Citywide requirement
Town Center 2-30 Use requirements, design
standards, circulation and
parking strategies
Use regulations and
development standards
Note: Commercial – General
Land Use Designation (CR
and CD zoning districts) are
located only within the Town
Center
Additionally, through the update, all standards and review processes should be reviewed for relevance and their effectiveness in implementing LUP policies and meeting community objectives.

DISTRIBUTIONAL AND STRUCTURAL EQUITY
Implementation of LCP Policy 1-5 Social Equity and Environmental Justice has implications for regulations and procedures across a wide range of planning topics. The Implementation Plan Update should evaluate 23 14
changes to development regulations and procedures that can distribute community benefits and environmental burdens more equitably and remove structural barriers to equitable outcomes.

This evaluation should consider whether existing regulations inadvertently perpetuate or reinforce systemic inequities. Particular attention should be given to policies affecting housing affordability, workforce housing, mobility options, economic opportunity, accessibility for people with disabilities, access to coastal resources, civic participation, and the distribution of community-serving facilities and services.

Where appropriate, the updated Implementation Plan should incorporate clear standards and procedures that support equitable implementation of Land Use Plan policies. The focus should be on ensuring that regulatory requirements are transparent, consistently applied, and aligned with the City’s broader goals of expanding opportunity, reducing unnecessary barriers to healthy living, and promoting community benefits for all residents.
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4 Review Processes
Provisions governing development review and other administrative matters create the procedural environment through which the City can achieve the goals and policies laid out in its LUP, General Plan, and other adopted policies. At their best, development review provisions can promote the type of development a community wants by providing a clear, predictable path to project approval; conversely, vague review processes with unclear requirements can cause developers a high level of anxiety, frustrate community residents, and severely dampen a City’s ability to attract desirable growth. Review processes must also be consistent with State and federal law which sometimes requires streamlined review for certain types of projects.

Generally, prospective investors value two central qualities in any administrative code: (1) certainty in the requirements and structure of the review process and (2) built-in flexibility to adjust development standards to the needs of individual projects. Certainty about the types of development they can expect to see in their community is also important to residents. The degree to which Half Moon Bay can incorporate these qualities into its IP and Zoning Code will help improve its ability to compete for desirable development. This section contains general observations about the existing development review procedures and strategies to streamline development review and approval process.

Reliance on Discretionary Review
The flexibility of a Zoning Code and IP is largely defined by its hierarchy of uses and their required permits.

This hierarchy establishes the different levels of review the Code requires to make various types of land use and development decisions. These decisions typically range from a relatively informal counter staff review of proposed uses and structures for compliance prior to the issuance of a building permit, to more formal and complex procedures requiring public notice and a hearing before the Planning Commission and/or City Council prior to issuance of a use permit or other discretionary zoning approval. The greater the level of review, the more time it takes to process the project; thus, the more time it takes for a business or homeowner to know if they can make a change or operate a business.

The primary factor influencing a project’s place in the hierarchy of uses is whether the proposed use is permitted "by right" or allowed subject to certain conditions, or whether a Conditional Use Permit, with review by the Planning Commission is required. This determination is a reflection of community issues and concerns embodied in the Land Use Plan and General Plan. Decisions about where an application fits in the hierarchy may also, however, be influenced by how a jurisdiction selects and designs administrative techniques. It is often possible, for example, to reduce the review threshold for a particular type of application (i.e. place it lower in the hierarchy), by increasing the specificity of development standards and performance-based criteria.
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The regulatory process in Half Moon Bay is inherently complex, due in part to its location within the Coastal Zone. This complex regulatory environment makes establishing clear administrative procedures imperative. In some cases, the Zoning Code and IP simply lack review appropriate procedures. For example, the current design review provisions contained in HMB Municipal Code Chapter 14.37, Architectural, Landscape and Site Plan Review, apply only in conjunction with a Coastal Development Permit or other discretionary permit. As such, the City cannot simply require design review; in order to conduct design review the City must also require a Coastal Development Permit or other discretionary permit.

ADJUST REVIEW THRESHOLDS
The Implementation Plan Update provides an opportunity to adjust review thresholds based on analysis of the types of issues and projects in the City that have typically generated the most interest and concern.

Generally speaking, responsibilities should be assigned with a view toward minimizing the number of players involved in making any given decision, while increasing opportunities for meaningful public input.

The number of uses that require discretionary review can be reduced by including carefully crafted standards and restrictions that are specific to specific uses throughout the City or in particular zoning districts into the Code. As a result, the community and decision-makers may be confident their vision is being implemented and may reduce its watch over individual projects, allowing more projects to be approved administratively.

There are a variety of approaches the City could use to reduce the number of uses requiring review, including permitting more uses by right subject to:
 Compliance with development and design standards that could be added to the Zoning Code and IP based on the community’s goals for design quality;
 Compliance with new standards and requirements that reflect “standard conditions” that are typically imposed when such uses have been conditionally approved by the Planning Commission or City Council; and
 Compliance with specific limitations on location, floor area, hours of operation, and similar features that are the source of potential adverse impact.

The incorporation of “limited uses” makes it possible to eliminate discretionary review for those uses that meet specific standards and limitations and do not exceed specified threshold criteria.

Additionally, the City can establish a local coastal development permit waiver process for types of de minimis development including qualifying agricultural uses, smaller structures, or temporary uses into Coastal Development Permit procedures, consistent with Land Use Plan Policy 2-11. 26 17

CLARIFY REVIEW PROCEDURES
The new IP and Zoning Code should set forth clear administrative procedures to be followed for all types of decisions. The level and extent of administrative process required for different types of decisions will vary.

The City should incorporate new and revised review procedures to provide a more complete menu of review options available to projects in the City. Specifically, the City should amend the Architectural, Landscape and Site Plan Review provisions so they may also be applied to projects that don’t also require Coastal Development Permit or other discretionary permit. The City may consider a new type of use permit—a Minor Use Permit—approved by the Community Development Director. The Minor Use Permit would be required for uses that are “limited in scope and impacts” but which currently require a hearing by the Planning Commission. Applications for Minor Use Permits would be subject to public notice and a hearing by the Director. Such a procedure creates a more streamlined approach for review while still providing opportunities for meaningful public input. Conditional Use Permits would be reserved for uses that pose potential or significant land use compatibility issues and warrant Planning Commission review and approval.

Additionally, the review process can be streamlined simply by consolidating and clarifying procedures and permit approval criteria. Decision-making protocols should be clearly defined so that it is clear how approvals are processed, and the intent of these regulations should be included to help determine if a proposal meets the purpose of the regulation. All pertinent public hearing information (e.g., what information should be included in the notices, how notices are to be given [e.g., mailing, posting, publishing, use of the Internet], to whom notices should be sent, how hearings are to be conducted) should be located in one succinct chapter so that users will only need to look in one place to locate the applicable information.

Lack of Relief From Standards For Particular Situations The existing code provides for little flexibility in the application of development standards. The Code includes provisions for Variances; however, Variances are limited in their application. There are limited allowances for consideration of Variances to adjust district boundary lines and to allow additional height in the R-3, C-G, C-VS, IND, OS-A, and PUD districts. Otherwise, specific findings related to unique characteristics of a property are required to approve Variances.

PROVIDE CERTAINTY AND ALLOW FLEXIBILITY
There is common sentiment that more flexibility should be built into the development standards. At the same time, everyone wants to know the rules and standards by which new development will be judged.

The City may strike a balance between flexibility and certainty in its development standards by establishing a system where development standards address key elements of development form (i.e., 27 18
height, building placement, site layout) with defined allowances for modifications to the standards provided specific criteria are met. For example, a lesser setback may be provided on one side if a greater setback is provided on the other side. Another option is to offer a menu of options as a flexible way to comply with a particular design principle.

Through the update, the City should consider creating additional opportunities for gaining relief from codified locational, developmental, and operational standards in cases where modifications are consistent with Land Use Plan and General Plan objectives and warranted by special circumstances that may not meet the requirements for approval of a Variance based on physical hardship. This could be done in the form of additional provisions for the consideration of limited modifications or exceptions to dimensional standards.

Enforcement, Implementation, and Civic Engagement
An effective regulatory framework should not only establish clear standards but also promote fair and consistent implementation of those standards. As part of the Implementation Plan update, the City should evaluate whether existing review, permitting, and enforcement procedures create unintended disparities in outcomes among different populations or neighborhoods.

PROMOTE EQUITY THROUGH ADMINISTRATION OF THE CODE ADMINISTRATION The City should consider measures that improve consistency, predictability, and transparency in administrative decision-making. Clear procedures, objective approval criteria, and equitable enforcement practices can help ensure that regulations are applied uniformly, that all applicants have a clear understanding of requirements and expectations, that enforcement is not selective, and that consequences of enforcing regulations do not disproportionately affect certain population groups.

The City should formalize processes to gather and use input from populations facing the greatest inequities to inform the decision-making processes and procedures which implement the policies laid out in its Land Use Plan, General Plan, and other adopted policies. This input can help ensure these decisions address the most pressing community-identified needs and do not inadvertently perpetuate or reinforce existing inequities.

The City should consider establishing tools to monitor implementation outcomes over time. Periodic review of permitting activity, enforcement actions, civic engagement, and development trends can help identify potential inequities and inform future refinements to regulations and procedures. Ongoing evaluation will help ensure that the Implementation Plan continues to advance the City’s goals while serving all members of the community in an equitable and effective manner. Regularly reporting these outcomes in a variety of formats and through a variety of communication channels will increase transparency and can help build community trust.
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5 State and Federal Law
California law grants cities and counties relatively broad discretion in the regulation of land uses and development, and the Federal courts and United States Congress have, for the most part, left land use and environmental regulation up to state and local government. There are, however, some important exceptions to this approach. If local regulations conflict with federal law, pursuant to the supremacy clause of the United State Constitution, then local laws are preempted. In some cases, both Congress and the State have identified matters of critical concern that limit the authority of California cities.

This section discusses some State and Federal laws to consider through the Implementation Plan Update.

Housing
As California's housing supply and homelessness crisis continues, the State Legislature has passed numerous pieces of housing legislation in each legislative session of the past several years. Most recent legislation is aimed at reducing barriers to the creation of housing. Highlights of housing-related legislation most relevant to the Implementation Plan are briefly summarized below.

SB330 – HOUSING CRISIS ACT
SB330, the Housing Crisis Act, limits cities’ and counties’ ability to regulate housing developments, including residential development, mixed use development with 2/3 of the square footage for residential, and transitional and supportive housing. It creates a preliminary application process where the date the preliminary application is submitted vests, or locks in, the existing regulations (objective development standards, General Plan policies and fees) that are in effect at that time, establishes timeframes for when a historic determination and project approval must be made, and limits the number of public hearings.

A number of provisions address housing density. General Plan and zoning densities may not be reduced below 2018 numbers. This includes changes to development standards that lessen intensity of housing.

Zoning may not be changed to remove housing, and there may be no onsite reduction in the number of units.

The Housing Crisis Act also prohibits local jurisdictions from imposing or enforcing new subjective design standards, requiring housing developments to be reviewed against ‘objective standards’ that are uniformly verifiable and do not involve personal or subjective judgment.

ACCESSORY DWELLING UNITS (ADUS)
Recent laws further restrict what local agencies may regulate regarding ADUs. Local agencies may not adopt ADU ordinances that: impose minimum lot size requirements for ADUs; set certain maximum ADU 29 20
dimensions; or require replacement off-street parking when a "garage, carport or covered parking structure" is demolished or converted to construct the ADU. New laws allow for an ADU as well as a "junior" ADU where certain access, setback and other criteria are met and explicitly identifies opportunities for ADUs in multifamily buildings. Additionally, cities may not condition approval of ADU building permit applications on the applicant being the "owner-occupant" of either the primary dwelling or the ADU.

AFFORDABLE HOUSING
The State Density Bonus Law (Cal. Gov’t Code §65915) allows for density bonuses and additional incentives for affordable housing. Cal. Gov’t Code §65913 expedites state and local residential development, assuring local agencies can sufficiently zone for affordable housing, and encourage and incentivize affordable housing. Recent changes to the State Density Bonus Law increase the density bonus and other concessions for 100 percent affordable housing projects. Housing projects with a minimum of 80 percent low income units and up to 20 percent moderate income units are eligible for a density bonus of up to 80 percent the maximum allowed density or a density bonus with no limit if located within ½ mile of a major transit stop and qualify for at least four concessions, reduced parking requirements, and a height increase of up to three stories or 33 feet when located within ½ mile of a major transit stop.

HOUSING FOR PERSONS WITH DISABILITIES
Various provisions in both federal and State law limit the authority of local agencies to regulate facilities for mentally and physically handicapped persons. In 1988, Congress extended the 1968 Fair Housing Act’s prohibitions against housing discrimination to include discrimination on the basis of handicap or familial status (families with children). The Federal Fair Housing Act Amendments (FHAA) defined "handicapped" to include persons with physical or mental disabilities and recovering alcoholics and drug addicts. The FHAA not only prevents communities from discriminating against handicapped individuals but also requires "reasonable accommodations in rules policies, practices, or services, when such accommodations are necessary to afford [handicapped persons an] equal opportunity to use and enjoy a dwelling." The California Fair Employment and Housing Act, codified as Government Code Sections 12900 to 12996, reinforces provisions of federal statute to prohibit any unlawful discrimination against persons with disabilities. The State Supreme Court has prohibited local agencies from limiting the number of persons unrelated by blood, marriage, or adoption who can reside in a single-family home.

Pursuant to Cal. Health & Safety Code §1566.3, a residential care facility that serves six or fewer people is considered a residential use and its occupants, regardless of legal relation, are considered a family for purposes of residential use laws and zoning codes. Further, such a use shall not be included within the definition of a boarding house, rooming house, institution or home for the care of minors, the aged, or persons with mental health disorders, foster care home, guest home, rest home, community residence, 30 21
or other similar term that implies that the residential facility is a business run for profit or differs in any other way from a family dwelling.

MANUFACTURED HOUSING
The Zoning Ordinance is compliant with Cal. Gov’t. Code §§65852.35 which requires local agencies to allow the installation of manufactured homes certified under the National Manufactured Housing Construction and Safety Standards Act of 1974 (42 U.S.C. §§5401 et seq.) on a foundation system, pursuant to Cal. Health & Safety Code §1855, on lots zoned for single-family dwellings.

AB 686 – AFFIRMATIVELY FURTHERING FAIR HOUSING (AFFH)
AB 686 requires all local public agencies to facilitate deliberate action to explicitly address, combat, and relieve disparities resulting from past patterns of segregation by examining existing and future policies, plans, programs, rules, practices, and related activities and make proactive changes to promote more inclusive communities. While AFFH obligations are primarily implemented through Housing Elements, the Implementation Plan update provides an opportunity for the City to evaluate whether zoning regulations, development standards, permitting procedures, and housing-related policies support fair housing goals and avoid creating unnecessary barriers to housing opportunity, accessibility, and neighborhood choice.

Adult Oriented Businesses
Local agencies may regulate, pursuant to a content-neutral ordinance, the time, place, and manner of operation of sexually-oriented business when the ordinance serves a substantial government interest, does not unreasonably limit alternative avenues of communication, and is based on narrow, objective, and definite standards (Cal. Gov’t Code §65850.4). Regulations must ensure there are a reasonable range of alternative sites where adult-oriented businesses may be located.

Coastal Act
In 1976, the California Coastal Act was passed to protect coastal resources and maximize public access to the shoreline in the coastal zone, which is designated by the State Legislature. As part of the Coastal Act, local governments can prepare and implement Local Coastal Programs (LCPs) that are consistent with and achieve the objectives of the Coastal Act.

The Coastal Act gives priority to:
 Coastal-dependent and coastal-related uses and activities, such as commercial fishing, recreational boating and water-oriented recreational activities;  Coastal access and recreational needs, such as public coastal access and recreation, along with consideration of traffic, parking, circulation and infrastructure needs; and 31 22
 Environmentally sensitive areas, including the protection and restoration of water quality and sensitive habitat areas, along with consideration of shoreline erosion and sea level rise.

Once an LCP is approved by the Coastal Commission, local governments have the responsibility of issuing coastal permits for most new development, subject to the standards set in the certified LCP.

Each LCP consists of a Land Use Plan, which the City updated in 2020, and an Implementation Plan with measures to implement the plan (primarily the Zoning Code). Thus, the Implementation Plan Update must conform with and carry out the Local Coastal Plan.

Cottage Food Operations
Pursuant to Cal. Gov't Code §51035, a city or county may not prohibit cottage food operations (homemade and packaged food defined in Cal. Health & Safety Code §113758) in any residential dwelling, but shall do one of the following: Classify the use as a permitted use in any residential zone, grant a nondiscretionary permit for the use, or require a permit for the use.

Emergency Shelters; Transitional and Supportive Uses
Cal. Gov’t Code §§65582, 65583, and 65589.5 require each local government to: 1) amend its Zoning Code to identify district(s) where emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit to include sufficient capacity to accommodate the need for emergency shelter identified in the housing element, and 2) treat transitional and supportive housing as a residential use of the property subject only to those restrictions that apply to other residential dwellings of the same type in the same district. Cal. Gov’t Code §65582 contains definitions for "supportive housing," "target population," and "transitional housing" to be more specific to housing element law.

AB2162 requires that supportive housing be a use by right in districts where multifamily and mixed uses are permitted, including nonresidential districts permitting multifamily uses, if the proposed housing development meets specified criteria, and requires a local government to approve, within specified periods, a supportive housing development that complies with these requirements. Local governments are prohibited from imposing any minimum parking requirement for units occupied by supportive housing residents if the development is located within ½ mile of a major public transit stop.

Environmental Justice
While not explicitly required for Local Coastal Plans, SB 1000 establishes a comprehensive framework for local jurisdictions to consistently address environmental justice concerns faced by identified populations in their communities. The statutory requirements of SB 1000 can be divided into seven topic areas. These topic areas can be used to identify, organize, and highlight updates intended to advance equity and environmental justice.
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1. Prioritize the Needs of Underserved Communities

2. Reduce Pollution Exposure

3. Improve Access to Public Facilities

4. Promote Food Access

5. Promote Safe, Sanitary, and Stable Housing

6. Promote Physical Activity

7. Promote Civic Engagement
Family Day Care Homes
Pursuant to Cal. Health & Safety Code §§1597.30 et seq., small family day care homes which provide care for eight or fewer children in a residential unit is a residential use and is not subject to a fee or business license. Large family day care homes which provide care for seven to 14 children may not be prohibited in any district where residential is allowed, but a city or county shall do one of the following: classify the use as a permitted residential use, grant a non-discretionary permit for the use, or require a permit for the use. However, zoning requirements for large family day care home must be reasonable and are limited to spacing and concentration, traffic control, parking, and noise control. Noise control standards must be consistent with the general noise ordinance and must take noise levels generated by children into consideration.

Processing and Review Procedures
State law specifies a number of processing requirements and review procedures related to land use regulations. These include procedures and requirements for development agreements (Cal. Gov't Code §§65864 et seq.), general plan consistency (Cal. Gov't Code §65860), permit review timelines (Cal. Gov't Code §§65920 et seq.), prezoning land upon annexation (Cal. Gov't Code §65859), notice of public hearings (Cal. Gov't Code §§65090 et seq.), variances (Cal. Gov't Code §§65900 et seq.), and zoning amendment procedures Cal. Gov't Code §§65853 et seq.).

Religious Uses
The Federal Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) requires public agencies to demonstrate a compelling government interest and to use the least restrictive means when making a land use decision that imposes a substantial burden on religious exercise. Religious uses must be treated the same as similar non-religious uses. Additionally, regulations cannot impose a substantial burden to religious exercise.
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Signs
In June 2015, the U.S. Supreme Court decision in Reed v. Town of Gilbert (No. 135 S.CT. 2218, 2015) affirmed that sign regulations must be “content-neutral” to survive a legal challenge. In order to be content-neutral and satisfy First Amendment limitations, sign regulations must be based on “time, place, and manner” restrictions, rather than by content- or message-based restrictions. Content-based regulations are subject to what is called a “strict scrutiny” standard – that is, a compelling governmental interest must be demonstrated and regulations must be narrowly tailored to serve that interest.

Solar Energy Systems
Cal. Gov't Code §65850.5 requires that solar energy systems be approved administratively with requirements limited to health and safety requirements per local, State, and federal law and those necessary to ensure systems will not have a specific, adverse impact on public health or safety. A use permit may be required if the Building Official makes a finding based on substantial evidence that a specific, adverse impact on public health or safety would result. Every city and county is required to have an ordinance expediting permitting for small residential rooftop solar energy systems.

Telecommunications
The Federal Telecommunications Act of 1996 Limits state or local governments' authority to regulate placement, construction, and modification of personal wireless service facilities. State or local governments must not unreasonably discriminate against providers of functionally equivalent services and not prohibit or effectually prohibit use of personal wireless devices. Further, state or local governments shall not regulate placement, construction, and modification of personal wireless service facilities based on the environmental effect of radio frequency emissions, to the extent that such facilities comply with FCC regulations. Cal. Gov't Code § 65850.6 requires a city or county to ministerially approve an application for a co-location facility on or immediately adjacent to an existing wireless telecommunications co-location facility. It also prohibits a city or county from imposing certain conditions of approval on permits for construction or reconstruction of wireless telecommunications facility.

Water Conservation and Landscaping
Cal. Gov't Code §53087.7 prohibits cities or counties from enacting any regulation that substantially increases the cost of installing, effectively prohibits, or significantly impedes the installation of drought tolerant landscaping, synthetic grass, or artificial turf on residential property. The Water Conservation in Landscaping Act of 2006 (Cal. Gov't Code §65597) requires local agencies to adopt the updated Department of Water Resources (DWR) Model Water Efficient Landscape Ordinance (MWELO) or a local landscape ordinance that is at least as effective in conserving water. 34 25
Appendix A:

Focus Group Interview
Summary
35 26
Focus Group Interviews
Between June 25 and July 10, 2026, the project team held seven focus group meetings with 10 individuals familiar with planning, development, land use, design, and real estate in Half Moon Bay. This group included developers, property owners, large and small business owners, architects, and general contractors. Some of the individuals have been in appointed positions with City commissions and committees, as well as involved in local organizations and on past planning projects. Participants were asked a series of questions regarding their experience with the City’s regulations, but conversations revolved around areas of familiarity or issues of significance to the individual interviewee.

The experiences and perspective of the interviewees varied, which influenced the input from each participant. Despite the varied input, some common topics emerged:
 Development Standards
 Use Allowances
 Permit Process
 Parking Requirements
 Ease of Use
These topics are described in the following sections. In addition, other topics raised are described in the “Other Topics” section.

DEVELOPMENT STANDARDS
Interviewees expressed that generally, development standards work well but would benefit from increased flexibility to respond to unique circumstances or small and constrained sites, as well as flexibility for small businesses. Flexibility is particularly important as, moving forward, development will likely occur as redevelopment or on constrained sites. Interviewees noted that the current development standards do not work for smaller lots, infill development, or the city’s historic development pattern. Other issues included:
 The rigidity of daylight plane requirements
 Challenges with the Planned Unit Development (PUD) provisions  Balancing fire protection standards with landscaping requirements Interviewees also noted that revisions should include consideration of:
 Electrification and solar standards
 Reducing pervious surfaces
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USE ALLOWANCES
Most interviewees found use allowances generally acceptable and work well, including allowances for mixed uses in the Downtown. Areas for improvement include:
 Align visitor-serving uses with other commercial areas  More flexibility in regard to home occupations to reflect current ‘work from home’ context while still protecting the character of residential neighborhoods  Streamline process for changes of use

PERMIT PROCESS
Almost all interviewees noted extensive permit processing times as an issue and expressed desire for a streamlined process with more clarity on the processes and timelines. Some felt the process provides for the appropriate level of checks and balances. Others felt there seemed to be no foreseeable path forward; the requirements were so unclear it was impossible to determine how long something was going to take or how much it would cost. Overall there was recognition that a complex regulatory process was understandable given the nature and location of Half Moon Bay and it was important in maintaining the character of the community; however it should still be made as clear as possible.

Specific interviewees found it to be difficult to process applications for change of use or site improvements, even when the proposed uses and site improvements complied with all requirements and would be an enhancement to what was currently there. Others found the requirements unclear and/or seemingly not relevant to their project. Many felt there could be a more streamlined process for small projects and that the City tends to err on the side of overregulating, even regarding things that could be beneficial to the community.

Interviewees expressed frustration with the time and expense required for projects to go before multiple review bodies, including the Architectural Advisory Committee, Planning Commission, and the Coastal Commission. Expressed frustrations included the amount of oversight and the incurred cost and time delays. Some thought some smaller projects, such as small sign projects, fire safety improvements, reorientation of stairs, ADA ramps, driveway relocation, parking exemptions, and change of use projects may be appropriate for more staff-level review; while larger projects and projects in the Downtown warrant more scrutiny.

PARKING REQUIREMENTS
Interviewees expressed that the number of required parking spaces is an issue, especially in Downtown, as small lots lack feasible capacity for parking on-site. Some suggested that minor changes to existing buildings should be exempt from parking requirements and that there should be opportunities for parking reductions.
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To alleviate parking concerns, interviewees suggested the establishment of public parking areas or garages, providing temporary parking, or establishing a residential parking permit program for Downtown residents.

Some interviewees noted that many residents use their personal garage for storage, parking their vehicles on the driveway or curb. They recommend removing the mandate on two covered spaces and appreciated how the addition of an ADU allows parking to be reduced.

EASE OF USE
Interviewees reiterated that the existing code is difficult to understand and navigate, and desired more clarity in the code itself as well as the planning process. Interviewees who were more familiar with the code, such as developers and architects, found it straightforward; however, business and property owners found the zoning code difficult to use. The lack of one-to-one correlation between land use and zoning was highlighted as an issue of confusion.

OTHER ISSUES
Other issues identified included:
 Increased code enforcement
 A focus on drainage and hydrology
 A more legible land use map
 Clearer wayfinding signage to assist with traffic flow 38 29
Appendix B:

Zoning/Land Use Designation
Conflict Analysis

39 30
Zoning/Land Use Designation Conflict Analysis
The table below lists the LUP land use designations and the corresponding current zoning districts. Areas where the existing zoning matches the corresponding LUP land use designation in the table below are considered ‘consistent’. In these areas, zone changes are not necessary for LUP consistency. Areas where the existing zoning does not match the corresponding LUP land use designation in the table below may be considered ‘in conflict’. Areas of Zoning/Land Use Designation conflict are shown on the map on the following page and listed in the spreadsheet that follows.

40 OS-R
C-VS
OS-A
OS-P

PUD PUD
OS-P R-1-B-1
?
A-1
OS-A
PUD
R-1
C-VS
P-S R-1-B-2
OS-P
PUD
R-1-B-2
R-1-B-2
U-R
R-1-B-2
U-R
OS-A
U-R
P-S
U-R
U-R
U-R
U-R
PUD
R-1-B-2
PUD
C-G
R-3
OS-C
C-G
OS-P
PUD
R-1
P-S
C-D
P-S
C-D
C-D
P-S
C-D
PUD
PUD
R-1-B-1
R-1-B-2
R-2
OS-P R-1-B-2
A-1
C-VS
R-1-B-2
PUD

P-S PUD
PUD
IND
OS-C
IND
PUD
C-D
C-G
P-S
C-G
A-1
U-R
A-1
OS-R
R-1-B-2
C-D
C-R
OS-C
R-2
C-R
R-1-B-3
R-3
PUD
C-G
P-S
PUD
OS-R
A-1
C-VS
R-1-B-2
PUD
OS-P
PUD
PUD
PUD
OS-R
R-1-B-3 P-S
A-1
OS-R
R-1-B-3
C-VS
C-G
MHP
OS-R
OS-C
4 1
16 34
39 49
52 59
9 23
29 41
33 40
54 53
60 57
61 62
2 55
6 7
15 42
22 14
56 48
50 51
63 46
5 17
38 47
8 24
18 13
19 27
58 28
30 31
37 12
10 26
45 36
44 25
M-Group & Miller Planning Associates
Scale 1:25,500
0 0.25 0.5 1 Mile
¯
August 2026
Zoning/Land Use Designation
Conflict Analysis Map
R-1-B-2
C-G
R-3

OS-C C-G
R-1
P-S
C-D
P-S
C-D
C-D
P-S
C-D
PUD
R-1-B-1
R-2
P-S
PUD
PUD
IND
PUD
C-D

C-G P-S
C-G
A-1
U-R
OS-R
R-1-B-2
C-D
C-R
OS-C
R-2
C-R
R-1-B-3
OS-C 34
39 23
29 41
33 40
42 22
17 18 27
28 30
31 26
44 25
0 0.25 Mile
The City's LCLUP was comprehensively updated in 2020, as adopted by City Council in Oct 2020 and certified by the California Coastal Commission in Apr 2021. Boundaries of the shown zoning districts as implemented by CHMB Zone Code Title 18 Art. 2.

San Mateo County Assessor's Office parcels are mapped for tax purposes only. This map should not be used to determine if a parcel is a legal lot for land development purposes. Legal lots are validly created or recognized under the State Subdivision Map Act and local ordinances.

Due to limitations inherent to the mapping process, the precise location of features depicted may not be as shown.

Land Use Designations
Residential - Low Density
Residential - Medium Density
Residential - High Density
Mobile Home Park
Commercial - General
Commercial - Visitor Serving
Industrial Light
Horticulture Business
Public Facilities & Institutions
City Parks
Regional Public Recreation
Open Space for Conservation
Planned Development
Rural Coastal
Map Features
Identified Zoning/Land Use Designation Conflict
Reference to Zoning/Land Use Designation Conflict Table Zoning Districts (Labeled)
Housing Element R-3 Rezone Sites
#
41 32

IDENTIFIED ZONING/LUP LAND USE DESIGNATION CONFLICTS
Map Number Existing Zoning LUP Land Use Designation
Zoning for
Consistency
1 PUD Residential - Medium Density R-2
2 R-1-B-1 Open Space for Conservation OS-C
4 OS-R Open Space for Conservation OS-C
5 None Regional Public Recreation OS-P
6 PUD Residential - Low Density RL
7 R-1-B-2 Residential - Low Density RL
8 R-1-B-2 City Parks OS-A
9 PUD Open Space for Conservation OS-C
10 OS-P Public Facilities & Institutions P-S
12 P-S Open Space for Conservation OS-C
13 U-R Open Space for Conservation OS-C
14 U-R Rural Coastal R-C
15 R-1-B-2 Open Space for Conservation OS-C
16 R-1-B-2 Open Space for Conservation OS-C
17 OS-C Commercial - General C-G
18 R-3 City Parks OS-A
19 OS-C Residential - High Density R-3
22 P-S Industrial Light IND
23 IND Mobile Home Park MHP
24 A-1 Industrial Light IND
25 U-R Public Facilities & Institutions P-S
26 PUD Mobile Home Park MHP
27 PUD Industrial Light IND
28 PUD Residential - Medium Density R-2
29 PUD Commercial - General C-G
30 PUD City Parks OS-A
31 PUD Open Space for Conservation OS-C
42 33

IDENTIFIED ZONING/LUP LAND USE DESIGNATION CONFLICTS
Map Number Existing Zoning LUP Land Use Designation
Zoning for
Consistency
33 R-1-B-2 Commercial - General C-R
34 C-D Public Facilities & Institutions P-S
36 R-1, R-1-B-1, R-1-B-2 Open Space for Conservation OS-C 37 PUD Regional Public Recreation OS-P
38 R-1 City Parks OS-A
39 PUD Residential - High Density R-3
40 R-2 Residential - High Density R-3
41 R-1-B-2 Commercial - General C-R
42 OS-R Residential - Medium Density R-1-B-2
44 R-1-B-2 Commercial - General C-R
45 R-2 Commercial - General C-D
46 R-2 Residential - High Density R-3
47 OS-P City Parks OS-A
48 PUD Regional Public Recreation OS-P
49 PUD Open Space for Conservation OS-C
50 PUD Rural Coastal R-C
51 PUD City Parks OS-A
52 A-1 Commercial - Visitor Serving C-VS
53 PUD Commercial - General C-G
54 PUD Residential - High Density R-3
55 P-S Commercial - General C-G
56 PUD Open Space for Conservation OS-C
57 R-1-B-2 Horticulture Business A-1
58 PUD Residential - Medium Density R-1-B-2
59 R-1-B-2 Planned Development PUD
60 OS-R Horticulture Business A-1
61 OS-R Horticulture Business A-1
43 34

IDENTIFIED ZONING/LUP LAND USE DESIGNATION CONFLICTS
Map Number Existing Zoning LUP Land Use Designation
Zoning for
Consistency
62 C-G Commercial - Visitor Serving C-VS
63 PUD Commercial - Visitor Serving C-VS
44 James Benjamin Joint City Council – Planning Commission Meeting 400 Pilarcitos Avenue Item I.A: Implementation Plan Study Session Half Moon Bay, CA 94019-1475
September 22, 2026
Leslie Lacko, Community Development Director
City of Half Moon Bay
501 Main Street
Half Moon Bay California
Dear Director Lacko:

Thank you for the neighborhood meetings conducted by your staff to discuss the City of Half Moon Bay’s Local Coastal Program Implementation Plan (LCPIP) update. I attended the meeting at Wave Avenue and found your staff friendly and open to hearing public concerns, particularly the need for planning review that incorporates the best available information about geologic hazards, particularly erosion, liquefaction, sedimentation and flooding.

As you know, the Coastal Act and other state laws require development to avoid causing or contributing to these hazards. The City’s certified Local Coastal Land Use Plan Update (“LCLUP Update”) policy 7-46 requires a report in areas of high geologic hazard, including areas of liquefaction. The LCLUP Update contains hydrology and water quality policies such as 6-78, 6-79, 6-81, 6-84, 6-85, 6-87, 6-88, 6-90, 6-91, 6-92, 6-100, 6-101, 6-103 and 6-104 requiring projects to avoid adverse impacts to watercourses. Policy 7-45 requires the City to regard LCLUP maps as guidance, but to use the best available science. Maps published by the US Geological show poorly consolidated or unconsolidated soils throughout the City.
1, 2 The state has also published a map identifying areas of liquefaction risk covering broad areas of the City.3 Development in these watersheds which obstructs and diverts subsurface flows (e.g., with a building foundation), entrains sheet flows (e.g., by collecting sheet flow into a gutter), and increases the volume of existing entrained flows through poorly consolidated soils (whether adjacent to or downstream from development) presents obvious geologic hazards and may damage coastal resources. They require mitigation The LCPIP’s requirement for geologic reports (§18.38.045(A) Geological report) must be expanded to be consistent with those policies. A great deal of our community is built on land covered by soil that eroded from hillside agriculture that started in the nineteenth century. New projects that accelerate watershed drainage will not only dry wetlands and degrade riparian corridors; they also worsen fire hazards, damage public and private property, and threaten critical infrastructure. These things are already occurring. And that is before considering climate change:

Orographic lift will extract even more precipitation from atmospheric rivers. Our easily eroded soils are no match for these forces. This is why geomorphology and hydrology criteria must be clearly integrated into development review. 1 Lajoie, K.R., Helly, E.J., Nichols, Dr. and Burke, D.B., Geologic Map of Unconsolidated and Moderately Consolidated Deposits of San Mateo County, California, scale 1:125,000, Miscellaneous Field Studies Map MF - 575, U.S.

Geological Survey 1974. https://doi.org/10.3133/mf575. Last accessed Sept. 22, 2026. 2 Brabb, E.E. and Pampeyan, E.H., Geologic Map of San Mateo County, California, scale 1:62,500, Misc. Investigations Series Map I – 1257 - A, U.S. Geological Survey 1983. https://doi.org/10.3133/i1257A Last accessed Sept. 22, 2026. 3 California Geological Survey, Earthquake Fault Zones (1976) and Seismic Hazard Zones (2021), Half Moon Bay 7.5 Minute Quadrangle: Map of Earthquake Zones of Required Investigation, scale 1:24,000, https://maps.conservation.ca.gov/cgs/informationwarehouse/. Last accessed Sept. 22, 2026. 45 Director Lacko
September 22, 2026

Page 2 ends

Readers who discount these concerns as doomsday thinking may wish to read the history of planning of the Grandview Terrace subdivision. It is a fine subdivision that provides valuable housing; indeed, City Administrator Paxton, Half Moon Bay Review Editor Bauer and members of the Planning Commission, City Council and Central Coast District Coastal Commission lived there. However, City Council minutes show that the City diverted water across watershed boundaries and they failed to account for sheet flow arriving from uplands. They did not consider the downstream impacts of the entrained diversion into a channels that kept those uphill homes dry. Threats of flooding were attributed to mattresses thrown into channels, and calls to remove them gave rise to a “clean the ditch” mindset – even removal of soil-holding vegetation – implying that erosion and sedimentation are not meaningful concerns. This myopic approach continues to inflict worsening damage in our watershed.

The Kehoe watershed is certainly not our town’s only example of why LCPIP-level planning must anticipate and mitigate hydrologic impacts. Skeptical readers may also wish to review the history of Terrace Avenue, whose flashy drainage contributes to the scour at the massive Chesterfield culvert outfall at Pilarcitos Creek. Flows from a 37-year storm threatened to inundate the Coastside’s wastewater treatment plant, and additional flows could change the shoreline near the plant. Readers may wish to consider infrastructure-damaging erosion on state park lands at Frenchmans Creek, or the erosion occurring in the Pullman watercourse or Roosevelt Creek, or the bank failure on Arroyo Leon east of downtown. Incredibly, the word “erosion” appears nowhere in our storm drainage master plan.

These are not abstract, distant future concerns. They are relevant to the implementation of current and near-term projects. The present and future citizens of the City will depend on this LCPIP amendment improving our regulatory processes to address problems caused by past lapses of judgment, but especially to prevent the creation of new problems in a rush to accommodate development. I realize that you will be under enormous pressures to approve development without public review. When those projects come forward, we are counting on our decision-maker not to let those planning errors be repeated.

Again, these illustrations are not criticisms of those lovely neighborhoods; they just call out the consequences of decades of regrettable planning errors. A cookie-cutter process of matching building density, adding a formulaic BMP rain garden or dry well or, or an impoundment that can detain last century’s 10-year storm will not protect us.

Science-based geomorphologic and hydrologic planning is our only sustainable way forward.

I reiterate my willingness to speak with you, City staff, and other community or state officials about the hydrologic hazards that should be addressed in implementing the LCP, because they are significant but tractable, if we plan ahead. Thank you again for the community outreach meetings, and for considering my comments.

Sincerely,
James Benjamin
CC: Mayor Ruddock and City Council Members Penrose, Brownstone, Jonsson and Nagengast Planning Commission Chair Gorn and Member Hernandez, Rems, DelNagro and Ruddock 46

Half Moon Bay City CouncilSeptember 22, 2026

Half Moon Bay City Council
September 22, 2026