Pacifica City Council
June 25, 2022

Need to add into Fig 5-1 some alternate sub-routes to Hwy 1 in case of emergency. Sub-routes from Rockway beach ave to Reina del Mar Ave to Lundy Way that lead to Sharp Park Road.

Also need wildlife corridor tunnels underneath Sharp Park Road and Manor Drive. See attached map of propose sub-routes and wildlife corridor tunnels/crossings. **********************

The proposed illustrative roadway for Linda Mar Blvd and Crespi Drive do not seem to take into account the near future development of more housings on the Linda Mar hillside nor the mega church in the back of Linda Mar area which would increase traffic congestion on normal days. By reducing the traffic lanes, the city is essentially creating a fire trap for residents during emergencies.

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Packet Pg. 3338 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) *************************
P129, 5.5 Public transportation and transportation demand management P131, fig 5-5 Existing transit routes
Need more high-density housing at transportation routes. Suggest having some areas set aside near transportation routes for homeless and van folks.
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P134, 5.7 Parking
Suggest installing parking meters at public street parking area. Allow local resident to show some type of QR bar code to the meter and be able to park free. All other visitors would have to pay some parking fees. This would generate revenue for the City of Pacifica. We have a lot of visitors to the Pacifica Beach and having them pay a small fee will help to offset some environmental costs. **********************
P137, 6 Open space and community facilities
P161, 6.3 Coastal Access
P164, fig 6-4 School and Community facilities
Converting closed public school into either high-density housing, a new civic center with local shops, cafes, homeless shelter and clinics.
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P170, OC-I-59 Beach Blvd property
Consider either use this site as the new Civic center, or high-density public housing, expand homeless shelter and clinics. Need to mitigate for Coastal management retreat, sea level rise, beach erosion, and future levee improvement that are acceptable to the Coastal Commission. **********************

P 180, Planned Improvements
Need to include wildlife corridors as part of the conservation. See attached map of suggested wildlife corridor tunnels/crossing.
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What is the city doing about future plan for use of desalination of sea water and coordinating with the North Coast County Water District? Maybe work with the North Coast County Water District to develop water conservation plan such as rebate for water harvesting with rain barrels.

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Packet Pg. 3339 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) ********************
P186, Fig 7-2 Vegetation
P188, Eucalyptus, Monterey Cypress
We need to remove invasive plants in our parks area such as eucalyptus, Monterey Cypress, English ivy, and plant more native plants. The Eucalyptus is also a fire hazard due to it high oil content. Suggest working with the various other agencies who are management of various parks and local areas to combat these invasive plants.
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P190, Fig 7-3 Sensitive and Critical Habitat
P194, Wildlife Movement Corridors
Need wildlife corridors at obstructions such as Sharp Park Blvd, Manor Drive and other roads that blocked wildlife from traveling to various habitats. See attached map of suggested locations for wildlife corridor tunnels/crossings.

P191 Beach/Intertidal
What is the city future plans about coastal management retreat, climate change, and sea level rise? *************
P201 7.3 Land and soil resources
Need to pay attention to slope stability, earthquake, erosion, liquefaction, and downslope drainage for any future planned development for buildings. Don’t let developers put up a smokescreen on their future developments within Pacifica.
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P216, 7.7 Environmental Justice
Did not see any solution to environmental justice at all for homeless and van parking at designated places in this general plan and in the draft EIR. Need to provide plans for placing the homeless in some type of living and rehab areas with bathroom facilities along with place for vans to park without further increase of pollution by them around our beaches, roads, and wetland areas. ***************
P218, 8 Safety
P219, Seismic Hazards
P221, Fig 8-1 Seismic hazard zones

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Packet Pg. 3340 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Need to pay more attention on earthquake problems on building at unstable slope, including erosion, landslide, and drainage issues. Also, the potential of liquefaction and landslide in fig 8-1. Don’t let developers build at unstable areas.
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P222, Tsunami and Seiche
Sharp Park, Rockaway, lower Linda Mar Blvd, Manor Plaza, and Fairmont are prone to tsunami. This plan needs to provide tsunami evacuation routes for all these areas. That is why it is very important to have alternative evacuation routes in case Hwy 1 is not usable either due to flooding and obstructions.

See attached map of suggested alternative sub-routes around Hwy 1. ***************
P222, Slope Failure and Erosion
Where are the tables showing history (when it happened) of slope failure, erosion, liquefaction, earthquake, landslides, earthquake damages?
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P233 Increased coastal flooding from potential sea level rise If the 2009 report from the Pacific Institute mentioned potential flooding, what are the solutions? *******************
P235, 8.3 Coastal Resilience
What are the solutions to the problem raised in this section of potential sea level rise, flooding, etc. **********************
P249, 8.4 Hazardous Materials and Operations
P253, fig 8-7 Fire hazards and public safety services
We need to remove invasive trees such as Eucalyptus to lessen fire hazard as shown on the map. *******************
P260, 9 Noise
Suggest planting of native trees (not invasive trees) to reduce noise level around the noise corridors. *****************
P272, 10 Implementation
This chapter mentioned implementation responsibility by various agencies, but there is no implementation solutions in the general plan. So, what are you implementing? I did not see a section on conclusions and recommendations. Also, the General plan did not spell out the alternatives as shown in the DEIR, why?

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Packet Pg. 3341 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Comments on the Draft Environmental Impact Report
P2 Executive Summary
Glad to see there is an executive summary in the DEIR, but am dismayed that it was just another report and not very clear. Usually, executive summary is about 10 pages at most.

It seems the Executive Summary just copied and repeat word for word what were stated in the document. Someone need to clean up the Executive Summary so it is concise and to the point.

The executive summary should summarize the alternatives within the 10 pages at most and the alternatives should be mentioned in the General Plan in parallel. Also, the alternatives were switching from numbering to alphabets. Need to clean that up.
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P152, Draft and Final Documents
There is a disconnect between the Pacifica General Plan 2040 with the DEIR since the General plan did not spell out the alternatives as shown in the DEIR.
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P162, fig 2.1-1 Regional Setting
P163, figure 2.1-2 Planning Area an Coastal Zone
It seems foolish to plan future development of Sharp Park specific plan when it is mostly in the Coastal zone of management retreat. Better to plan on the east side of Hwy 1 of Sharp Park for long term stability and to account for climate change and sea level rise.

Did not see any concise solutions to offset coastal management retreat, beach erosion, liquefaction, climate change, and sea level rise for these proposed high-density developments. *********************
P164, fig 2.1-3 Sharp Park Specific Plan Planning Area
More high-density development of Eureka Square Shopping Center is warranted, but not the west side of Hwy 1 unless the city can get permission from the Coastal Commission to offset future climate change and sea level rise issues.

Bad idea to do long term development of Sharp Park west of Hwy 1 due to coastal management retreat, climate change, sea level rise, tsunami, beach erosion, and other hazards. If the City can mitigate all of these issues, maybe we can move forward and let everyone know that the various hazards are still in place to avoid future lawsuits.
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P165, Local Coastal Planning

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Packet Pg. 3342 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) P166, Fig 2.1-2 General Plan Land Use
P167, Fig 2.1-3 Sharp Park Specific Plan Land Use Diagram Need to address sea level rise and climate change in this Sharp Park Specific Plan on the west side of Hwy 1.
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P205, Sharp Park Specific Plan Area
More high-density development of Eureka Square Shopping Center is warranted, but not the west side of Hwy 1 unless the city can get permission from the Coastal Commission for future climate change and sea level rise protection.

Bad idea to do long term development of Sharp Park west of Hwy 1 due to coastal management retreat, climate change, sea level rise, tsunami, beach erosion, and other hazards. If the City can mitigate all of these issues, maybe we can move forward and let everyone know that the various hazards are still in place to avoid future lawsuits.
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P235, fig 3.2-1 Roadway Network and Planned Improvements P678, Fig 3.12-3 Trail System
Need wildlife corridors along Sharp Park road, Manor Drive, and other road obstructions to wildlife. See attached map showing potential wildlife corridor tunnels/crossings. ****************
P238, Fig 3.2-2 Existing Transit Routes and Facilities
P724, Infrastructure Modernization
More high density along transit corridors. Where are the designated parking for homeless and vans since there are environmental hazards produced by these folks who park along the beach area with their trash and other hazards. The homeless and travel vans need a designated place along with bathroom facility, and trash bins.

Need to have sub-routes from Rockaway beach Ave to Reina del Mar Ave to Ridgeway Dr to Sharp Park Road for emergency access in case Hwy 1 is not usable in either direction. These sub-routes are also critical during emergency evacuations. See attached map of suggested sub-routes to bypass Hwy 1 in case Hwy 1 is not useable.
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P241, Fig 3.2-3 Existing and Proposed Bicycle Network
The proposed bike lanes along Linda Mar Blvd and Crespi drive could be a people trap during fire and other emergencies, especially with the proposed high-density development on the hill of Linda Mar and at the back of Linda Mar. How is the city going to mitigate for this potential fire trap?

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Packet Pg. 3343 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) *****************
P366, Reduced Parking
P372, LU-I-18 Parking Requirements
It is a bad idea of proposed General Plan policy LU-I-18 to allow developers to reduce parking spaces unless we have a robust and almost free public transportation for folks in Pacifica. What is the city going to do for the residents who need to be able to drive and find free parking? Suggest providing buses for local travel only to locals and tourists, and charge a daily or monthly nominal fee to use the buses. Allow the locals to use some type of Id or QR codes to ride the local buses for free. *****************
P366, Water Conservation
P723, Water Conservation
Is the city and the North Coast County Water District going to provide and help residents to install rain barrels to capture rain water and to provide recycled water containers and truck the recycled water to the residents to use to improve water conservation.

What are the future plans by the city and the North Coast County Water District to develop seawater desalination?
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P370, Trees and Native Vegetation
What is the city going to do to reduce invasive trees such as Eucalyptus, Monterey Pine, Monterey cypress, English ivy, and other invasive plants in our area? We need to educate folks to plant more native plants instead of invasive plants. Suggest the city work with other agencies who are managing various parks and places to work together to get rid of these invasive plants and plant native plants instead.
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P371, Impact of the Sharp Park Specific Plan
Did not see specific plan to offset future climate change and sea level rise for these future developments.

Bad idea to do long term development of Sharp Park west of Hwy 1 due to coastal management retreat, climate change, sea level rise, tsunami, beach erosion, and other hazards. If the City can mitigate all of these issues, maybe we can move forward and let everyone know that the various hazards are still in place to avoid future lawsuits.
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P372, Proposed General Plan Policies that Reduce the Impact LU-I-16, Density Bonus

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Packet Pg. 3344 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Where in the General Plan are the proposed housing for low-income folks, homeless, and vans along our streets? The homeless and vans are producing human environmental waste along with other trash.

They need a place where they can live with bathroom facility, mental health services, and job training? See attached suggested high-density developments.

Do like the stepback for high-density buildings to reduce sun shadowing. *********************
P402, Fig 3.5-1 Hydrology and Flood Zones
What are the mitigations for areas under the Tsunami evacuation areas especially for Sharp Park area and Linda Mar Blvd close to Hwy 1 on the west side? How are the mitigations being in line with the Coastal Commission on management retreat?
Need to show Tsunami evacuation plan for folks to reach high ground. ******************
P407-408, Coastal flooding
How is the improvement of the seawall/revetment structure match up with the Coastal Commission on management retreat, future climate change, and sea level rise? ***********************
P454, Fig 3.6-1 Seismic Hazard Zones
P455, Fig 3.6-2 Liquefaction, Liquefaction Potential
P457, Landslides and slope failure
P459, Fig 3.6-3 Slope Failure and Coastal Erosion
P591, Fig 3.9.4 Impacts on views looking south, 35 feet (current height maximum) P591, Fig 3.9-5 Impacts on views looking south, 45 ft
P591, Fig 3.9-6, Impacts on views looking south, 55 ft
P592, Fig 3.9-7, Impacts of views looking west, 2212 Beach Boulevard Site P593, Fig 3.9-8, Impacts of views looking west, 2212 Beach Boulevard site, with pedestrian pathway P593, Fig 3.9-9 Impact of views looking west, 2212 Beach Boulevard site, with pedestrian pathway and upper stepback
Need to provide tables to show the historical seismic events, liquefaction, flooding, landslides, slope failure, and erosions at various locations in Pacifica and pinpoint within the fig for better understanding of these issues.

What protection measures are planned for the Sharp Park area future high-density development with the volubility of liquefaction, flooding, climate change, sea level rise, earthquake, and Tsunami?

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Packet Pg. 3345 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Nice the Stepback of high-density buildings to reduce sun shadowing. ********************
P458, Beaches and Coastal Erosion
Need a table and fig of historical beaches and coastal erosions for better understanding of these issues. ********************
P492, Vegetation
P506, Fig 3.7-3 Sensitive and Critical Habitat
P637, Fig 3.11-2 Fire Hazards and Public Safety Services P750, 3.14 Wildlife
Need to show in fig wildlife corridors for wildlife. See attached map for suggested wildlife corridor tunnels/crossings.

Need to provide a plan to eliminate Eucalyptus, Monterey Cypress, English Ivy, and other invasive plants/vegetations to reduce wildfire, increase plant diversity, and improve climate change.

We need to educate folks to plant more native plants instead of invasive plants. Suggest the city work with other agencies who are managing various parks and places to work together to get rid of these invasive plants and plant native plants instead.
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P662, Fig 3.12-1 Schools and Community Facilities
Need to show the closed school of Fairmont in the Fig to match the figure shown in the Pacifica General Plan 2040. See P164, fig 6-4 School and Community facilities, from the General Plan.

Suggest reuse the closed school for high-density public housing, mix up facilities, weekly food truck area, or use as a place for homeless and van parking so the homeless and van parking folks won’t pollute the roads, beaches, and wetland areas with human waste and trash.

Suggest high-density development at the Sea Bowl area, including having weekly food trucks gathering. ******************
P805 and P807 Analysis of Alternatives
P8, Executive Summary
Why are the alternatives listed as Alt 1, 2 and No Project Alt in page 8 of the Executive Summary and changed to Alt A, B, and C, and change again in page 807. Need to be consistence in naming the alternatives.
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P812, Fig 4.2-3 Alternative 2

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Packet Pg. 3346 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) How is this alternative stand up to climate change, sea level rise, coastal management retreat? Where is the plan for a parking place for the homeless vans and other vehicles so to reduce environmental hazards along the beach and wetland areas?

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Packet Pg. 3347 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 3348 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) ATTACHMENT H – FEIR APPENDIX B
The full document including an interactive table of contents is available at: https://cityofpacifica.egnyte.com/dl/mccqSGSmU7, and is hereby incorporated by reference into the agenda packet.

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Packet Pg. 3349 Attachment: Attachment H - FEIR Appendix B – Redlined DEIR (5035 : Consideration of Adoption of General Plan Update) Pacifica General Plan
Update and Specific Plan
EIR
CEQA Findings and Facts
in Support of Findings
and Statement of
Overriding
Considerations
SCH No. 2012022046
May 25, 2022
Prepared for the
City of Pacifica by

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Packet Pg. 3350 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR ii
Table of Contents
Role of Findings ..............................................................................................................1 Findings Under CEQA.....................................................................................................2 Alternatives ...................................................................................................................15 Proposed General Plan Benefits ...................................................................................18 Overriding Considerations Conclusions.........................................................................21

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Packet Pg. 3351 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR iii
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Packet Pg. 3352 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings and Facts in Support of
Findings and Statement of Overriding
Considerations for the Pacifica
General Plan EIR
CEQA requires the Pacifica City Council (the Council) to balance the benefits of the City of Pacifica General Plan and Sharp Park Specific Plan (Plan) against its significant and unavoidable environmental effects in determining whether to approve the Project. Since the EIR identifies significant impacts of the General Plan that cannot feasibly be mitigated to below a level of significance, the City must state in writing its specific reasons for approving the Project in a “statement of overriding considerations” pursuant to Sections 15043 and 15093 of the CEQA Guidelines. This Statement of Overriding Considerations sets forth the specific reasons supporting the City’s action in approving the General Plan Update, based on the Final Environmental Impact Report (Final EIR, which incorporates the Draft EIR by reference) and other information in the administrative record.

In making the statement of overriding considerations, “CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered ‘acceptable’.” (CEQA Guidelines, Section 15093, subd. (a).)
The following sections provide findings and statements of facts supporting the findings, describe the general Project benefits considered by decision makers in determining to adopt the proposed General Plan Update despite its potentially significant adverse environmental effects, and then provide conclusions.

Role of Findings
The following findings are hereby adopted by the City Council of Pacifica pursuant to the requirements of the California Environmental Quality Act, California Public Resources Code Section 21000 et seq. (CEQA), and the Guidelines for California Environmental Quality Act, Title 14, California Code of Regulations Section 15000 et seq. (CEQA Guidelines).

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Packet Pg. 3353 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

These Findings and Facts in Support of Findings relate to the approval of the Pacifica General Plan. The City Council of Pacifica is the Lead Agency for the Plan.

The Findings state the City Council’s conclusions regarding the significance of the potential environmental impacts of General Plan after all feasible mitigating policies have been adopted.

These findings have been prepared to comply with the requirements of CEQA and the CEQA Guidelines and are based on information in the Draft and Final Environmental Impact Report (EIR) for the Plan and on all other relevant information contained in the administrative record for the Plan.

CEQA requires agencies to identify mitigation measures that would avoid or substantially lessen a project’s significant impacts or potential significant impacts if such measures are feasible. The mitigating measures identified in the Final EIR mitigate the potential significant impacts of the Plan, to the extent feasible, as described in the Final EIR. All mitigating policies identified in the Final EIR (as listed in Table ES-3 of the Draft EIR) that are within the City Council’s authority to impose are hereby adopted by the Council. Future projects must comply with CEQA, including implementation of project-specific mitigation measures where applicable and feasible. Subsequent environmental review for specific projects identified in the Plan may tier off the programmatic analysis or incorporate information from this analysis by reference (CEQA Guidelines, Sections 15150, 15152, and 15168).

Public Resources Code Section 21002 provides that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” (Emphasis added.) The same statute states that the procedures required by CEQA “are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.” (Emphasis added.) Section 21002 goes on to state that “in the event [that] specific economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof.” (Pub. Resources Code, Section 21002.) The mandate and principles set forth in Public Resources Code Section 21002 are implemented, in part, through the requirement that agencies must adopt findings before approving projects for which EIRs are required. (See Pub. Resources Code, Section 21081, subd. (a); CEQA Guidelines, Section 15091, subd. (a).)
Findings Under CEQA
The Final EIR examined the environmental impacts of the General Plan in the areas of Land Use; Transportation; Air Quality; Energy and Greenhouse Gases; Hydrology and Flooding; Geology, Soils and Seismic Risk; Biological Resources; Cultural Resources; Visual Resources; Noise; Hazardous Materials and Fire Hazards; Parks, Public Services and Facilities; Wildfire; Utilities; Mineral Resources; Significant Irreversible Environmental Changes; Growth-Inducing Impacts; and Cumulative Impacts.

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Packet Pg. 3354 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

IMPACTS DETERMINED TO BE LESS THAN SIGNIFICANT
Under Public Resources Code section 21081(a)(1) and CEQA Guidelines sections 15091(a)(1) and 15092(b), the City determines that the following potential impacts would not occur or would be less than significant, as defined by the EIR:
a) Land Use and Housing: The following impacts were found to be less than significant:
i. Impact 3.1-1: Implementation of the Proposed Project would not physically divide an established community.
ii. Impact 3.1-2: Implementation of the Proposed Project would not conflict with any applicable land use plan, policy, or regulation of adopted for the purpose of avoiding or mitigating an environmental effect.
iii. Impact 3.1-3: Implementation of the Proposed Project would not induce substantial unplanned population growth in an area, either directly or indirectly. iv. Impact 3.1-4: Implementation of the Proposed Project would not displace substantial numbers of existing housing units or people, necessitating the construction of replacement housing elsewhere.
b) Transportation: The following impacts were found to be less than significant:
i. Impact 3.2-1: Implementation of the Proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
ii. Impact 3.2-3: Implementation of the Proposed Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). iii. Impact 3.2-4: Implementation of the Proposed Project would not result in inadequate emergency access.
c) Air Quality: The following impacts were found to be less than significant:
i. Impact 3.3-1: Implementation of the Proposed Project would not conflict with or obstruct implementation of the applicable air quality plan. ii. Impact 3.3-2: Implementation of the Proposed Project would not result in a cumulatively considerable net increase in any criteria pollutant for which the project region is classified as a nonattainment area under an applicable federal or state ambient air quality standard.
iii. Impact 3.3-3: Implementation of the Proposed Project would not expose sensitive receptors to substantial pollutant concentrations. iv. Impact 3.3-4: Implementation of the Proposed Project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.
d) Energy & Greenhouse Gases: The following impacts were found to be less than significant:
i. Impact 3.4-3: Implementation of the Proposed Project would not cause wasteful, inefficient, and unnecessary consumption of energy during project construction, operation, and/or maintenance.
e) Hydrology & Flooding: The following impacts were found to be less than significant:

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Packet Pg. 3355 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

i. Impact 3.5-1: New development and other improvements under the Proposed Project would not violate water quality standards or waste discharge requirements or degrade surface or groundwater quality. ii. Impact 3.5-2: New development under the Proposed Project would not decrease groundwater supplies or interfere substantially with rates of groundwater recharge such that the project may impede sustainable groundwater management of the basin.
iii. Impact 3.5-3: New development under the Proposed Project would not substantially alter existing drainage patterns, including through the alteration of the course of a stream or river or through the addition of impervious surfaces in a manner which could increase the volume of stormwater runoff resulting in erosion, siltation, polluted runoff, and flooding on- or off-site; an exceedance of existing or planned stormwater drainage systems; or impediment or redirection of flood flows.
iv. Impact 3.5-4: Implementation of the Proposed Project would not risk release of pollutants due to project inundation by seiche, tsunami, or flood. v. Impact 3.5-5: The Proposed Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
vi. Cumulative Impact 3.5-8: Increased construction activity and new development facilitated by the Proposed Project, in conjunction with past, present, reasonably foreseeable future development in the San Francisco Peninsula, would not significantly affect stormwater flows and water quality. f) Geology, Soils, and Seismic Risk: The following impacts would not occur or were found to be less than significant:
i. Impact 3.6-1: Implementation of the Proposed Project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; strong seismic ground shaking; seismic-related ground failure, including liquefaction; and landslides.
ii. Impact 3.6-2: Implementation of the Proposed Project would not result in substantial soil erosion or topsoil loss.
iii. Impact 3.6-3: Implementation of the Proposed Project would not locate structures on expansive soils or on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse, therefore creating substantial risks to life or property.
iv. Impact 3.6-4: Implementation of the Proposed Project would not have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water.
v. Impact 3.6-5: Implementation of the Proposed Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

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Packet Pg. 3356 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

vi. Impact 3.6-6: Implementation of the Proposed Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
g) Biological Resources: The following impacts would not occur or were found to be less than significant:
i. Impact 3.7-1: Implementation of the Proposed Project would not have a substantial adverse effect, either directly or through habitat modifications, on candidate, sensitive, or special status species identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
ii. Impact 3.7-2: Implementation of the Proposed Project would not have a substantial adverse effect on riparian habitat or other sensitive natural communities identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. iii. Impact 3.7-3: Implementation of the Proposed Project would not have a substantial adverse effect on state or federally protected wetlands (including, but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.
iv. Impact 3.7-4: Implementation of the Proposed Project would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.
v. Impact 3.7-5: Implementation of Proposed Project would not conflict with local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
vi. Impact 3.7-6: Implementation of the Proposed Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.
h) Cultural Resources & Tribal Cultural Resources: The following impacts were found to be less than significant:
i. Impact 3.8-1: Implementation of the Proposed Project would not cause a substantial change to the significance of a historical resource, defined as physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historic resource would be materially impaired (Guidelines Section 15064.5).
ii. Impact 3.8-2: Implementation of the Proposed Project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5.
iii. Impact 3.8-3: Implementation of the Proposed Project could disturb any human remains, including those interred outside of formal cemeteries. iv. Impact 3.8-4: Implementation of the Proposed Project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape, sacred place, or object with cultural value to a California Native Tribe. i) Visual Resources: The following impacts were found to be less than significant:

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Packet Pg. 3357 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

i. Impact 3.9-1: Implementation of the Proposed Project would not have a substantial adverse effect on a scenic vista.
ii. Impact 3.9-2: Implementation of the Proposed Project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
iii. Impact 3.9-3: Implementation of the Proposed Project would not substantially degrade the existing visual character or quality of the Planning Area and its surroundings.
iv. Impact 3.9-4: Implementation of the Proposed Project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.
j) Noise: The following impacts were found to be less than significant:
i. Impact 3.10-1: New development under the Proposed Project would not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. ii. Impact 3.10-2: Implementation of the Proposed Project would not result in a generation of excessive groundborne vibration or groundborne noise levels. iii. Impact 3.10-3: Implementation of the Proposed Project would not expose people residing or working in the project area to excessive noise levels within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport. k) Hazardous Materials: The following impacts were found to be less than significant:
i. Impact 3.11-1: Implementation of the Proposed Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.
ii. Impact 3.11-2: Implementation of the Proposed Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
iii. Impact 3.11-3: Implementation of the Proposed Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. iv. Impact 3.11-4: Implementation of the Proposed Project would not allow development on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment.
v. Impact 3.11-5: Implementation of the Proposed Project would not result in a safety hazard for people residing or working in the project area, where located within the Comprehensive Airport Land Use Compatibility Plan for San Francisco International Airport.
vi. Impact 3.11-6: Implementation of the Proposed Project would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

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vii. Impact 3.11-7: Implementation of the Proposed Project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires.
l) Parks, Public Services, and Facilities: The following impacts were found to be less than significant:
i. Impact 3.12-1: Implementation of the Proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection, police protection, schools, parks, or other public facilities.
ii. Impact 3.12-2: Buildout of the Proposed Project would not result in an increase in the use of existing parks and recreational facilities such that substantial physical deterioration would occur or be accelerated.
iii. Impact 3.12-3: Buildout of the Proposed Project would not require the construction or expansion of recreational facilities in a manner which might have an adverse physical effect on the environment.
m) Utilities: The following impacts were found to be less than significant:
i. Impact 3.13-1: Implementation of the Proposed Project would not require or result in the relocation or construction of new or expanded water, or wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
ii. Impact 3.13-2: Implementation of the Proposed Project would not result in insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years. iii. Impact 3.13-3: Implementation of the Proposed Project will not result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. iv. Impact 3.13-4: Implementation of the Proposed Project will not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. v. Impact 3.13-5: Implementation of the Proposed Project will not conflict with federal, state, and local management and reduction statutes and regulations related to solid waste.
vi. Impact 3.13-6: Implementation of the Proposed Project would not result in solid waste disposal needs that exceed the permitted landfill capacity serving the project.
n) Wildfire: The following impacts were found to be less than significant:
i. Impact 3.14-1: Implementation of the Proposed Project would not substantially impair an adopted emergency response plan or emergency evacuation plan. ii. Impact 3.14-2: Implementation of the Proposed Project would not, due to slope, prevailing winds, and other factors, exacerbate wildfire risks or expose people or

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structures to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.
iii. Impact 3.14-3: Implementation of the Proposed Project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.
iv. Impact 3.14-4: Implementation of the Proposed Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. o) Mineral Resources: The following impacts would not occur or were found to be less than significant:
i. Impact 3.15-1: Implementation of the Proposed Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.
ii. Impact 3.15-2: Implementation of the Proposed Project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan.

IMPACTS DETERMINED TO BE LESS THAN SIGNIFICANT WITH MITIGATION Under Public Resources Code section 21081(a)(1) and CEQA Guidelines sections 15091 (a)(1) and 15092(b), and to the extent reflected in the EIR, the City finds that changes or alterations have been required in, or incorporated into, the Plan that mitigate to a less than significant level or avoid the following potentially significant effects on the environment:

GHG and Energy, Impact 3.4.1 Implementation of the Proposed Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. (Less than Significant with Mitigation)
Facts in Support of Finding: The EIR assessed mass and per capita greenhouse gas emissions under the proposed General Plan buildout, which are expected to decrease over time. The total GHG emissions under proposed General Plan buildout with quantifiable Proposed Project policies and the Climate Action Plan goal of achieving 75 percent diversion of solid waste community-wide is estimated to be 79,851 MTCO2e in 2040, or 1.9 MTCO2e per capita. Projected emissions meet the CARB and SB 375 emissions targets for 2035, but exceed the interpolated GHG reduction target of 1.53 established in the City of Pacifica CAP for 2040, and for the SB 32 emissions reduction target of 60 percent below 1990 levels by 2040. The DEIR found that additional quantifiable policies would further reduce mass and per capita emissions; however, these reductions are not sufficient to meet the threshold of 1.53 MTCO2e per capita as the threshold for meeting the 2050 reduction target articulated in EO S-3-05 and the 2014 Pacifica Climate Action Plan (CAP), or the SB 32 emissions reduction target.

Effects of Proposed General Plan Policies and Remaining Impacts: As the transportation and energy sectors are the largest source of emissions within the Planning Area in 2020 and is projected to remain the largest sources in 2040, these sectors have the most opportunity for reductions. There are many Proposed Project policies that aim to reduce GHG emissions,

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especially those that relate to pedestrian improvements and increased connectivity; streetscape improvements and traffic calming measures; transit service; trip reduction programs; clean city fleet; increased density and affordability; reduced parking; water conservation; waste reduction; commute trip reduction programs; teleworking; municipal energy efficiency; and outdoor lighting.

The Proposed Project would generate GHG emissions in excess of the interpolated CAP reduction target on both a per capita and mass emissions basis assuming full implementation of quantifiable General Plan policies and 75 percent solid waste diversion, though it would achieve the target on a per service population basis. Other policies that would generally reduce GHG emissions but cannot be quantified include those related to renewable energy; energy efficiency; trees and native vegetation. However, implementation of the Proposed Project would generate GHG emissions in excess of targets established in the existing Pacifica CAP. Therefore, on a local scale, implementation of the Proposed Project would generate GHG emissions that could have a significant impact on the environment and this impact would be potentially significant and mitigation measures would be required.

Rationale and Conclusion: Implementation of the Proposed Project would reduce generation of GHG emissions by 47 percent compared to existing conditions. Per capita GHG emissions under the Proposed Project with and without the reduction potential of proposed policies incorporated would also be consistent with GHG emissions targets established by CARB of 6.0 MTCO2e per capita by 2030 and 2.0 MTCO2e per capita by 2050 to help local governments meet SB 32 and EO S-3-05 targets. The Proposed Project, assuming implementation of quantifiable policies, would result in 1.59 MTCO2e per capita in 2040, and a reduction of mass emissions by 59 percent below 1990 levels, just short of the 60 percent target. This is consistent with the interpolated target of 4.0 MTCO2e per capita in 2040 and the target established by CARB of 2.0 MTCO2e per capita in 2050.

However, implementation of the Proposed Project would generate GHG emissions in excess of targets established in the existing Pacifica CAP. Therefore, on a local scale, implementation of the Proposed Project would generate GHG emissions that could have a significant impact on the environment and this impact would be potentially significant and mitigation measures would be required. The impact will be mitigated with imposition of required Mitigation Measures MMGHG-1 and MM-GHG-2 and feasible, voluntary Mitigation Measure MM-GHG-3 which include implementation of the following actions:

MM-GHG-1: For new residential and commercial development, require installation of the electric vehicle recharging stations and other alternative fuel vehicle support infrastructure and adopt requirements for electric vehicle parking in new developments, consistent with Title 24 requirements, , with the goal of increasing electric vehicle ownership by 20%.

MM-GHG-2: Require installation of photovoltaic systems in new single family residential, multifamily residential, and commercial developments to increase solar capacity per the requirements of State law, with a target of an equivalent of 15 percent of projected electricity by 2040. Photovoltaic panel installation is required for new low-rise residential buildings which include single-family dwellings, and multifamily dwellings with three habitable stories or less pursuant to California Energy Code section 150.1.c.14. Photovoltaic panel installation is also required for new

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nonresidential buildings with three habitable stories or fewer, other than health care facilities; hotel/motel occupancies; and, high-rise multi-family buildings with 10 habitable stories or fewer, pursuant to a local amendment to the California Energy Code codified in PMC section 8-6.08.

MM-GHG-3: Develop and implement a program to encourage the use of available grants for residential and commercial efficiency retrofits and voluntary cool roofing practices in new development with the goal of a 50 percent energy reduction compared to baseline in 30 percent of the total existing residential units and nonresidential square feet citywide by 2040. This measure is voluntary.

Table 3.4-5: Additional GHG Emissions Reduction from General Plan Policies Measure Sector Assumed Effectiveness Emissions Reduction (MTCO2e) MM-GHG-1 Transportation 20% 9,978
MM-GHG-2 Energy 15% 5,082
MM-GHG-3 Energy Voluntary Voluntary
Total Emissions Reduction 25,224
Total 2040 Emissions with Proposed Project Policies 50,100 Emissions per Capita 1.22
Emissions per Service Population 1.03
Source: Dyett & Bhatia, 2021.

Implementation of these measures would reduce GHG emissions to 50,100 MTCO2e or 1.22 MTCO2e per capita. Both total and per capita emissions would achieve the interpolated GHG emissions reduction target established by the Pacifica CAP and the SB 32 mass emissions reduction target for 2040. Because existing GHG (2020) represents a 35 percent reduction over 1990 levels, and the Proposed Project is estimated to result in an approximately 69 percent reduction of MOTCO2e from 1990 levels, it is reasonable to assume that Pacifica will meet its 2030 SB 32 goal, The impact would be less than significant with mitigation.

GHG and Energy, Impact 3.4-2 Implementation of the Proposed Project would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing emissions of GHG. (Less than Significant with Mitigation) Facts in Support of Finding: Implementation of the Proposed Plan could conflict with Pacifica’s 2014 CAP, a roadmap that outlines a path for the City to achieve its GHG reduction goals of 35 percent below 2005 levels by 2020, and 80 percent below 1990 levels by 2050. CAP GHG emissions reduction targets of 35 percent below 2005 levels by 2020, and 80 percent below 1990 levels by 2050, as described in Impact 3.4-1.

Effects of Proposed General Plan Policies and Remaining Impacts: The CAP features goals and reduction strategies in the categories of energy, transportation and land use, solid waste, water, and education and outreach. Table 3.4-6 compares the goals of the 2014 CAP and

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supportive Proposed Project policies and shows that the Proposed Project would directly support all CAP measures. However, without mitigation, implementation of the Proposed Project would generate GHG emissions in excess of targets established in the existing Pacifica CAP.

Rationale and Conclusion: GHG emissions under the Proposed Project would be consistent with the CAP targets with the implementation of Mitigation Measures MM-GHG-1, MM-GHG-2, and MMGHG- 3. Additionally, proposed policy CO-I-59 requires the City to maintain and update the CAP based on the General Plan update. The Proposed Project is consistent with the GHG reduction targets established by the CAP and supports all of the goals and strategies included in the CAP. The impact will be mitigated with imposition of Mitigation Measures GHG1, GHG-2, and GHG-3, as described in Impact 3.4-1.

GHG and Energy, Impact 3.4-4Implementation of the Proposed Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Less than Significant with Mitigation)
Facts in Support of Finding: The Proposed Project would result in a significant environmental impact if it would result in conflicts with regulations adopted for the purpose of increasing renewable energy and energy efficiency. Energy consumption throughout the City may increase as development anticipated by the Proposed Project occurs, therefore, resulting in more consumption than existing conditions and has the potential to conflict with State Goals of reducing GHG emissions, including CalGreen and Title 24, Plan Bay Area and SB 375, SB 32, and the City of Pacifica CAP.

Effects of Proposed General Plan Policies and Remaining Impacts:

Development anticipated by the Proposed Project would be designed in a manner that is consistent with relevant energy conservation plans that encourage efficient use of energy resources. The Proposed Project would comply with CALGreen and Title 24 requirements to reduce energy consumption by implementing energy efficient building designs, reducing indoor and outdoor water demand, providing EV charging spaces, and installing energy-efficient appliances and equipment. Specifically, proposed General Plan policy CO-I-60 calls for the City to monitor the effectiveness of CALGreen in bringing about energy efficiency in architectural design and building construction. Additionally, policy CO-I-67 would increase energy efficiency in existing public buildings and require that any new municipal space exceed Title 24 energy efficiency standards by 20 percent. As a result, the Proposed Project’s impacts would be considered less than significant.

Overall, the Proposed Project would be consistent with the goals and policies of Plan Bay Area 2050 by supporting reduction in transportation-related emissions. Although Plan Bay Area 2050 is not technically an energy efficiency plan, consistency with the RTP/SCS has energy implications (such as the reduction of VMT and thereby fuel energy consumed), including proposed General Plan policies aimed at reducing per capita VMT, which subsequently reduces GHG emissions and reduces fossil fuel consumption from travel. Impact 3.4-2 details the features incorporated into the Proposed Project to reduce vehicle trips, resulting in less gasoline and diesel fuel use. As discussed, implementation of State and local actions, General Plan land use and circulation

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elements, proposed General Plan policies, and Mitigation Measure MMGHG- 1 would reduce transportation-related emissions by 68 percent between 2020 and 2040 (68,394 MTCO2e and 21,885 MTCO2e, respectively). Without mitigation, the Proposed Project could conflict with GHG emission-reduction targets set by CARB through SB 375 by reducing VMT to achieve a 10 percent reduction in per capita passenger vehicle emissions by 2020 and 19 percent reduction by 2035 compared to the 2005 level.

As discussed in Impact 3.4-1, the Proposed Project, assuming implementation of quantifiable policies, would result in 1.59 MTCO2e per capita in 2040. This is consistent with the interpolated target of 4.0 MTCO2e per capita in 2040 and the target established by CARB of 2.0 MTCO2e per capita in 2050. Additionally, proposed policy CO-I-59 requires the City to maintain and update the CAP based on the General Plan update. However, implementation of the Proposed Project would generate GHG emissions in excess of targets established in the existing Pacifica CAP and 2040 SB 32 mass emissions reduction targets without mitigation.

Rationale and Conclusion:

The Proposed Project would incorporate project design features and policies such that it would be consistent with applicable plans, policies and regulations adopted for the purpose of promoting renewable energy and overall energy efficiency. Any other potential impacts related to conflicts with state or local plans for renewable energy or energy efficiency would be mitigated with Mitigation Measures described in Impact 3.4-1.

SIGNIFICANT AND UNAVOIDABLE IMPACTS
Under Public Resources Code section 21081(a)(1) and CEQA Guidelines sections 15091(a)(1) and 15092(b), the City determines that the following significant effects on the environment, as reflected in the EIR, and as mitigated as shown below, remain significant and unavoidable despite the fact that changes or alterations to the Project have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effects identified in the EIR. Further, the City finds that the following significant and unavoidable impacts are acceptable due to the overriding considerations described below. The City also finds that further mitigation measures and a No Project Alternative that may reduce the significance of any of these impacts are rejected as infeasible for the reasons given below.

Impact 3.2-2 Implementation of the Proposed Project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). (Significant and Unavoidable) Facts in Support of Finding: CEQA Guidelines Section 15064.3 requires that the determination of significance for transportation impacts be based on VMT instead of a congestion metric such as LOS. The change in the focus of transportation analysis is the result of SB 743. For the purposes of this EIR, the following thresholds of significance are used to determine if the proposed General Plan has an impact under the terms of Criteria 2:

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(a) Vehicle Miles Traveled: 1. A significant impact would occur if the proposed General Plan Update increases the Vehicle Miles Traveled (VMT) per person above the baseline conditions.

As described in the Methodology, Table 3.2-6 shows VMT calculations for the 2015 baseline scenario for various geographic regions including the City of Pacifica, San Mateo County, and the nine-county Bay Area. As shown, both VMT per capita and VMT per employee are higher for the City of Pacifica than for the county or Bay Area statistics. Table 3.2-6 also establishes thresholds based on a 15 percent reduction from the various baseline VMT rates. The threshold of significance based on a 15% reduction would be a VMT per capita of 13.40 miles per resident for the City of Pacifica; and a home-based work VMT per employee of 14.22 at the Countywide level.

Table 3.2-7 summarizes the VMT calculations for Pacifica under the No Project condition and Proposed Project. As shown in Table 3.2-7, VMT is expected to increase under the proposed General Plan and No Project scenarios. With the smallest increase in population, the No Project scenario would decrease home-based VMT and VMT per capita. Home-based work VMT per employee for jobs located in Pacifica would increase by 14.6 percent under the No Project scenario.

Home-based work VMT per employee for jobs located in Pacifica is expected to increase by 22.9 percent under the Proposed Project. While VMT per capita would decrease by 8.6 percent and home-based VMT would increase by only 0.5 percent, these rates all fall above the threshold of significance.

Effects of Proposed General Plan Policies and Remaining Impacts: Proposed policies listed below would reduce potential impacts by supporting TDM measures and requiring that new developments prepare transportation impact assessments to determine project specific impacts of new development under the proposed General Plan such that impacts can be appropriately mitigated. Additionally, City goals and policies strive to develop a multi-modal transportation network that would provide transportation alternatives to the single-occupant vehicle and encourage complete street design.

The City shall implement all policies identified in the proposed General Plan Circulation Element to reduce the demand for vehicle travel within and through the Planning Area, as well as work with local, regional, and state agencies to implement regional transportation improvements.

Additionally, new developments would be required to evaluate their project-specific impacts on the transportation system and fund improvements to maintain acceptable levels of service, except where exemptions are identified in the Circulation Element of the proposed General Plan.

However, even with implementation of these policies, the impact would remain significant and unavoidable.

Rationale and Conclusion:

Mitigation of VMT is required because levels of VMT per service population is not expected to fall below the threshold of significance without additional measures. Two measures have been proposed:

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MM-TRA-1: Require applicants for non-residential projects that employ 20 or more people— which is equivalent to 12,000 square feet of retail space, 6,000 square feet of office space, 20,000 square feet of industrial space, or 22 hotel rooms to implement an employee commute trip reduction (CTR) program. The CTR program shall identify alternative modes of transportation to the project, including transit schedules, bike and pedestrian routes, and carpool/vanpool availability. Information regarding these programs shall be readily available to employees and clients. The project applicant or designee shall implement at least one of the following incentives for commuters as part of the CTR program, or another equally effective incentive:
• Ride-matching assistance
• Subsidized public transit passes
• Vanpool assistance or employer-provided vanpool/shuttle • Car-sharing program (e.g. Zipcar)
• Bicycle end-trip facilities, including bike parking, lockers, and showers.

MM-TRA-2: Develop an informational program that encourages local businesses to implement telecommuting, hybrid, and alternative work schedules that allow employees to utilize remote work options while reducing vehicle-based commutes. Implementation of commute trip reduction programs and remote work options could reduce home-based work VMT, home-based work VMT per employee, and VMT per capita.

Implementation of commute trip reduction programs and remote work options could reduce home-based work VMT, home-based work VMT per employee, and VMT per capita. It is difficult to quantify the exact reduction potential of these mitigation measures as MM-TRA-1 applies only to new non-residential development of a certain size and MM-TRA-2 is a voluntary measure.

MM-TRA-2 responds to the recent surge of remote and hybrid work schedules following the COVID-19 pandemic. While both measures could reduce VMT metrics, it is unlikely that either would be sufficient in reducing these metrics to the proposed thresholds and the impact would remain significant and unavoidable.

VMT is by its nature a cumulative impact influenced by regional development patterns and policies. As a result there is little that Pacifica can do on its own to address VMT. As a result even after compliance with existing policies and regulations, implementation of Proposed Project, and implementation of feasible mitigation measures impacts remain significant and unavoidable.

FINDINGS
Based on the EIR and the entire record before the Council, the Council finds that there are no feasible mitigation measures that would reduce the impact of the rate of increase in VMT or vehicle trips exceeding the rate of increase in population with implementation of the Plan.

Although there are polices in the General Plan to reduce this impact, the Council finds the impact significant and unavoidable.

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Alternatives
The Final EIR analyzed three alternatives to the Project, examining the environmental impacts and feasibility of each alternative, as well as the ability of the alternatives to meet Project objectives. The Project objectives are listed in Chapter 2(Project Description) of the Draft EIR; the potentially significant environmental effects of the Project, including feasible mitigation measures identified to avoid these impacts, are analyzed in Chapter 3 (Environmental Evaluation) of the Draft EIR; and the alternatives are described in detail in Chapter 4 (Alternatives to the Proposed Project) of the Draft EIR. Brief summaries of the alternatives are provided below. A brief discussion of the Environmentally Superior Alternative follows the summaries of the alternatives.

All analysis in Final EIR Chapter 4 is incorporated by reference.

ALTERNATIVE 1: STRONG CENTER AT QUARRY SITE
In Alternative 1, Pacifica gains a new city center on the Quarry site, extending from the Rockaway Beach district and including a new civic center. This alternative assumes the greatest amount of development on the Quarry site, and the least amount of development on underutilized sites elsewhere. Palmetto Avenue develops as a main street, though at a lower intensity than the Proposed Project, and mixed-use redevelopment occurs at Park Mall.

The “Flats” portion of the Quarry site is developed with a compact mix of offices and housing over retail leading north from the Rockaway Beach district. A new civic center including city offices and a library/learning center is built west of the Reina del Mar intersection, near the Water Recycling facility and the Police station. This civic area meets the mixed use development at a new city park bordering the Calera Creek greenway. Also relating to this park is a Visitors’ Center, with immediate access to both the new shopping district and the regional trail system. The “Pad” portion of the site is reserved for a resort hotel/conference center, with views along the coast and down to the expanded Rockaway Beach district. The remainder of the Quarry uplands is permanently conserved as open space, with public trail access to Mori Point and beyond. Across Highway 1, new mixed-use and high-density residential development takes place along lower Fassler Avenue.

In West Sharp Park, Palmetto Avenue continues to develop as currently envisioned, but at lower intensities than the Preferred Plan, with streetscape improvements helping to stimulate mixed use development on vacant and under-utilized sites. The fishing pier, the revitalized Palmetto shopping area, and a new park and boutique hotel on the site of the Old Wastewater Treatment Plant draw locals and visitors to West Sharp Park. Residential areas are proposed to have the same or nearly the same designations as under the proposed Plan, with an emphasis on conserving sensitive areas, steep slopes and open space; respecting neighborhood character; and facilitating higher-density housing at appropriate locations.

Alternative 1 concentrates the greatest amount of development on the environmentally sensitive Quarry site and the least amount of development on underutilized sites elsewhere in the City, in contrast to the other alternatives. While it has lower population projections to Alternative 2, there are over 710 more jobs forecasted for Alternative 1 compared to the lower growth scheme of

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Alternative 2. This additional job growth would result in greater environmental impacts from additional vehicle trips and greater demand for parking. Ultimately, Alternative 1 has a greater impact on the environment than Alternative 2 and the Proposed Project.

ALTERNATIVE 2: CONSERVATION AND REDEVELOPMENT
In Alternative 2, a balance is created between four smaller centers in a sequence along the Coast Highway: Pacific Manor, West and East Sharp Park, Rockaway Beach, and Linda Mar/Pedro Point. Each has a distinct identity. Most of the Quarry site is conserved. Pedro Point and Linda Mar shopping centers experience redevelopment.

A new civic center is developed in the West Sharp Park neighborhood. Mixed use development also occurs along Palmetto Avenue, as in the other alternatives. Here it is anchored by a visitor attraction at the site of the former Treatment Plant.

Only minimal development takes place on the Quarry site, with the great majority conserved as habitat or open space. The Rockaway Beach district expands slightly to the north with visitororiented uses and a Visitors’ Center with primary access to the regional trail system. The Sea Bowl is developed as a retail commercial center, with a pedestrian bridge across the highway to the Headlands providing trail access to both Rockaway and Pacifica State Beach.

Pedro Point Shopping Center retains its use, with direct access to Pacifica State Beach and visibility from the highway. The undeveloped San Pedro Avenue site is developed with a mix of coastal-related and residential uses. Across Highway 1, mixed-use transit-oriented development occurs on both sides of Linda Mar Boulevard and on Crespi Drive.

Pacific Manor Shopping Center is redeveloped as an office district, with a smaller amount of retail serving the neighborhood. New medical and professional offices could be clustered here, where they have the greatest visibility and access to the largest population.

Residential areas are proposed to have the same or nearly the same designations as under the proposed Plan, with an emphasis on conserving sensitive areas, steep slopes and open space; respecting neighborhood character; and facilitating higher-density housing at appropriate locations.

Alternative 2 creates fewer acres of non-residential buildout than the Proposed Project or Alternative 1, which would result in smaller environmental impacts from less development. It conserves the Quarry site, an environmentally sensitive area. It would result in fewer jobs, population, and housing units than the proposed Plan or Alternative 1, which would lower its environmental impacts.

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NO PROJECT ALTERNATIVE
Pursuant to CEQA Guidelines Section 15126.6(e)(1), the No Project Alternative is required as part of the “reasonable range of alternatives” to allow decision makers to compare the impacts of approving the proposed project with the impacts of taking no action or not approving the proposed project. Consistent with CEQA Guidelines Section 15126.6(e)(3)(A), when the project is the revision of a plan, as in this case, the no project alternative will be the continuation of the existing plan. The No Project scenario represents the continuation of the current City of Pacifica General Plan land use designations. It uses projections from C/CAG’s Travel Demand Model for the year 2040. It assumes that the existing Plan and Zoning Ordinance would continue to guide development in the Planning Area until buildout in 2040. While the proposed Project and the two alternatives share an updated set of land use designations, the No Project alternative uses the existing General Plan designations. This means that there is only one commercial category, compared to five in the proposed Plan and alternatives; and one mixed use category, compared to three designations in the other scenarios.

The No Project alternative would result in more low density residential development compared to the proposed Project, but less residential development overall, including much less in a mixed-use format. The No Project alternative assumes a similar amount of commercial development as the proposed Project, with most commercial development occurring at the Gypsy Hill site, as well as intensification of commercial uses in northern Palmetto and east of Highway 1 near Rockaway Beach, and at the Pedro Point Shopping Center. The No Project Alternative would result in less non-residential development at the Quarry than the Proposed Project and Alternative 1, but more than Alternative 2.

The No Project Alternative creates the least amount of population growth and housing and a similar number of jobs as the Proposed Project. While the Proposed Project results in the least amount of population growth, it does not accommodate the anticipated housing need for Pacifica.

Importantly, the No Project Alternative does not meet any of the Proposed Project goals, such as preserving open space and trails, providing for sustainable development and practices, and creating a unique, vital center for the City.

ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA Guidelines require the identification of an environmentally superior alternative among the alternatives analyzed in an EIR. The Guidelines also require that if the No Project Alternative is identified as the environmentally superior alternative, then another environmentally superior alternative must be identified. Based on a comparison of the alternatives’ overall environmental impacts and their compatibility with General Plan goals and objectives, Alternative 2 is the environmentally superior alternative for this EIR.

The Proposed Project would fully accommodate the anticipated population and job growth in Pacifica with orderly, sequential growth focused in multiple centers, with the Sharp Park Specific Plan Area and Rockaway Beach as the two main centers of the city. The key difference between the Proposed Project and Alternative 2 is the amount of job growth accommodated, and the location and amount of land that is urbanized. With more commercial development and more job

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Packet Pg. 3369 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

growth than Alternative 2, the Proposed Project would create more environmental impacts. It creates more development on the environmentally sensitive Quarry site than Alternative 2.

Ultimately, Alternative 2 would result in lower environmental impact than the Proposed Project; however, the Proposed Project achieves all plan objectives while establishing policies to reduce environmental impacts of the city’s growth and development. However, though Alternative 2 creates less environmental impacts, it may not result in the city center that would be welcomed by community members under the Proposed Project.

Although the No Project Alternative would create less population growth and housing than Alternative 2, it assumes a higher amount of commercial development. In terms of environmental impacts, Alternative 2 would result in impacts similar to the proposed General Plan analyzed in this EIR, as population and housing levels are relatively the same. In some impact areas, such as solid waste, this alternative would result in a lower environmental impact than the proposed General Plan. In addition, this alternative creates less total nonresidential buildout acres than the proposed General Plan, which also leads to a smaller impact as a result of non-residential buildout. Alternative 2 would result in the creation of the four distinct activity centers. With these four centers, the objective to create a strong city center for Pacifica would not be met. Alternative 2 also would not allow for the transition of developable portions of the Quarry site to reuse and integration into the city fabric.

Alternative 2 also does not plan for as much housing as the Proposed Project, a key consideration as Pacifica enters its next housing element cycle.

Proposed General Plan Benefits
CEQA does not require lead agencies to analyze “beneficial impacts” in an EIR. Rather, EIRs focus on potential “significant effects on the environment” defined to be “adverse” (Public Resources Code Section 21068). Nevertheless, decision makers may be aided by information about project benefits. These benefits can be cited, if necessary, in a statement of overriding considerations (CEQA Guidelines Section 15093). The Council’s decision to adopt the proposed General Plan rather than any of the alternatives is based on considering the balance of these benefits of the Plan against its identified unavoidable environmental impacts.

Each benefit of the proposed Project, as stated below, is determined to be a basis for overriding all unavoidable adverse environmental impact identified above. This Statement of Overriding Considerations sets forth the specific reasons supporting the Council’s actions in approving the proposed Plan. In making this Statement of Overriding Considerations in support of the findings of fact and the project, the Council has considered the information contained in the Findings and in the documents comprising the record of proceedings for the project.

CEQA Guidelines Section 15093(a) provides the following guidance for a statement of overriding considerations:

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Packet Pg. 3370 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered “acceptable.” The results of the environmental analysis on the proposed Plan are discussed in detail in the Draft EIR, the Final EIR, and the Findings. The Council reached the conclusions below pursuant to Public Resources Code Section 21081 and State CEQA Guidelines Section 15093. The following statements describe the proposed Plan’s benefits considered by decision makers in determining whether to adopt the proposed Plan despite its potentially significant adverse environmental effects. The Council concludes that any one of the statements below is independently sufficient to justify approval of the project. The substantial evidence supporting the various benefits of the project can be found in public records on the General Plan update process, which are incorporated by reference into this section, and in the documents found in the Record of Proceedings.

Statement 1: The Proposed Plan prioritizes open space preservation and expands Pacifica’s trail system. Pacifica’s hillsides, beaches, and other protected open space are prized by community members for their scenic, recreational, and habitat values. Continued preservation is seen as a key accomplishment over the next 20 years. The Plan identifies priorities for open space preservation and strategies to protect open space while allowing limited development, to be clustered and designed to fit into its natural setting. It also proposes an enhanced trail system connecting the coastline and ridges throughout Pacifica.

Statement 2: The Proposed Plan promotes sustainable development and practices. Pacifica residents want to allow a responsible amount of development while ensuring that habitat and the community’s unique, small-town character are protected. Residents also want to see green building and other sustainable practices promoted by the City. The Plan aims to set a good land use balance and to promote sustainable site planning and design, water conservation, waste reduction, and use of alternative transportation modes.

Statement 3: The Proposed Plan creates a destination for tourism. Throughout the update process, community members and stakeholders emphasized the need for more economic activity.

There is a widely shared sense that Pacifica has the potential to attract more tourists, and that this should be a key component of the City’s economic development strategy. The Plan includes strategies to enhance tourism by leveraging Pacifica’s natural assets, creating more attractive places in visitor-oriented districts, marketing, and pursuing destination hotels and inns at key sites, including Rockaway Beach and Quarry.

Statement 4: The Proposed Plan revitalizes shopping areas and produces walkable, mixed-use areas. Pacifica residents desire more attractive and successful commercial areas, and also envision the development of walkable, mixed-use areas with good transit access. The Plan seeks to support commercial revitalization and redevelopment at key locations, advancing the City’s fiscal health, its quality of life, and its sustainability all at once.

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Packet Pg. 3371 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

Statement 5: The Proposed Plan creates a unique, vital center for Pacifica. Many community members expressed interest in creating a center for Pacifica, to provide a community gathering place and strengthen the City’s identity. Palmetto Avenue was most often pointed to as having great potential to grow into such a vital, unique district. The Plan aims to facilitate the enhancement of Palmetto as a pedestrian-oriented retail area, anchored by new development at the Old Wastewater Treatment Plant site, linking the retail district to the Promenade and the Ocean. New civic facilities, such as a City Hall and a new Library/Learning Center, could be valuable assets to this area as well.

Statement 6: The Proposed Plan ensures diversity of housing and population. Only a small amount of new housing—about 990 units—is expected to be developed during the planning period. Residents are proud of the diversity of housing in the community, and want to ensure that this is carried on. In addition, many observed that new housing types should help provide additional options for residents as they age. The Plan aims to make Pacifica more accessible and ensure adequate housing options for people of all ages and incomes by providing enough sites at a higher density, and creating opportunities for mixed use development in transit-accessible locations.

Statement 7: The Proposed Plan provides recreational facilities and activities for youth.

Pacifica has limited recreation facilities, and community members expressed concern about the lack of things to do, especially for youth. The Plan identifies top priorities for recreation improvements, with an emphasis on improving park land that exists and providing some small new parks. Creating more accessible and vibrant commercial areas with a sense of place that appeals to visitors will also help make Pacifica a better place for young people.

Statement 8: The Proposed Plan improves existing infrastructure. The need for the City to maintain and improve streets, sidewalks, and other infrastructure was a clear consensus point for the community. Most notable is the need to fix the bottleneck on Highway 1. The Plan supports ecoordination and solutions that ease traffic congestion for greatest benefit and least environmental impact as possible, seeks to reduce vehicle miles traveled, and sets priorities for sidewalk and street repairs based on location and safety.

Statement 9: The Proposed Plan devises protective measures against natural hazards. Pacifica faces a variety of natural hazards, including fires, earthquake-induced landslides, flooding, and coastal erosion. The Plan establishes a land use pattern that reflects hazardous conditions, such as steep slopes and coastal bluffs, and includes policies to improve public safety services and emergency management. The need to respond over the long term to coastal erosion will be an ongoing challenge for the City.

These key goals and initiatives were developed through an extensive public outreach process that accompanied the General Plan, which engaged stakeholders, decision-makers, the General Plan Outreach Committee, and members of the general public in discussion and debate over priorities for Pacifica’s future. Members of the public as well as elected officials were consulted and engaged at each key decision point in the update process, ensuring that the proposed General Plan reflects the community’s priorities to the greatest extent possible. During this public process, the Council

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Packet Pg. 3372 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

examined alternatives to the proposed General Plan Update, none of which meet the stated project objectives to the same extent as the proposed Project.

Overriding Considerations Conclusions
The Council finds that the proposed General Plan has been carefully reviewed and that mitigating policies have been included in the Final EIR to be certified by the Council. Nonetheless, the proposed General Plan may have certain environmental effects that cannot be avoided or substantially lessened. As to these significant environmental effects that are not avoided or substantially lessened to a point less than significant, the Council finds that specific fiscal, economic, social, technological, or other considerations make additional mitigation of those impacts infeasible, in that all feasible mitigation measures have been incorporated into the proposed General Plan.

The Council has carefully considered all of the environmental impacts that have not been mitigated to a less than significant level, as listed above. The Council has also carefully considered the fiscal, economic, social, and environmental benefits of the proposed General Plan, as listed above, and compared these with the benefits and impacts of the alternatives, which were evaluated in the Final EIR. The Council has balanced the fiscal, economic, social, and environmental benefits of the proposed Plan against its unavoidable and unmitigated adverse environmental impacts and, based upon substantial evidence in the record, has determined that the benefits of the proposed General Plan outweigh, and therefore override, the remaining adverse environmental effects. Such benefits provide the substantive and legal basis for this Statement of Overriding Considerations.

In approving the proposed General Plan, the Council makes the following Statement of Overriding Considerations pursuant to Public Resources Code Section 21081 and State CEQA Guidelines Section 15093 in support of its findings on the Final EIR:

The Council has considered the information contained in the Final EIR and has fully reviewed and considered all of the public testimony, documentation, exhibits, reports, and presentations included in the record of these proceedings. The Council specifically finds and determines that this Statement of Overriding Considerations is based upon and supported by substantial evidence in the record.

The Council has carefully weighed the benefits of the proposed General Plan Update against any adverse impacts identified in the Final EIR that could not be feasibly mitigated to a level of insignificance, which are enumerated below. While the Council has required all feasible mitigation measures, such impacts remain significant for purposes of adopting this Statement of Overriding Considerations:
 Impact 3.3-1 (Implementation of the proposed Pacifica General Plan would cause the rate of increase in VMT or vehicle trips to exceed the rate of increase in population with implementation of the Plan for the years covered by the proposed Plan (Significant and Unavoidable).

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Packet Pg. 3373 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

FINDINGS
Pursuant to CEQA Guidelines section 15091(a)(3), specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR. These specific considerations have been analyzed in the context of the proposed General Plan and the project alternatives. Based on the evidence in the record, the City Council finds the proposed General Plan is critical in meeting the following key guiding policies relating to economic sustainability, community design, land use, circulation, open space and community facilities, conservation safety, and noise as follows:

Economic Sustainability
• Leverage Assets. Leverage Pacifica’s coastal location and unique assets as a primary means to strengthen the local economy, focusing on increasing tourism facilities, including shops, hotels, restaurants, and hiking trails. • Maintain Fiscal Sustainability. Foster a fiscally healthy City government and enlarge the City’s revenue base as necessary to sustain and support the community. • Promote a Positive Image. Promote a positive image of Pacifica as a desirable place to work, live, and visit.
• Support Existing Businesses. Retain and foster the growth of existing Pacifica businesses, and foster a positive relationship between the business community and the City government.
• Attract New Businesses and Jobs. Seek out new businesses that will employ and serve Pacifica residents, improving the City’s jobs/housing ratio. • Ensure Environmental Protection. Ensure that economic development in Pacifica proceeds synergistically with environmental protection.

Community Design
Urban Structure
• Identifiable City Structure. Reinforce a clear city structure, characterized by a progression of ridges, neighborhoods, and activity centers. • Distinct Activity Centers. Create primary activity centers at West Sharp Park, Rockaway Beach, and Linda Mar, and neighborhood centers in Pacific Manor and Park Pacifica.

Neighborhoods and Districts
• Neighborhood Conservation. Preserve the unique qualities of each of Pacifica’s residential neighborhoods.
• Enhanced Mixed Use Areas. Create distinctive mixed-use areas by ensuring good building form and building-sidewalk interface, and providing pedestrian-oriented streets and public spaces.

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Packet Pg. 3374 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

Hillside and Coastal Development
• Hillsides and Prominent Ridgelines. Maintain development standards that ensure that new development does not detract from the visual qualities of Pacifica’s hillsides and visually prominent ridgelines.
• Scenic and Visual Amenities of the Coastal Zone. Protect the City’s irreplaceable scenic and visual amenities in the Coastal Zone by protecting landforms, vegetation, special communities, and important viewsheds.

Scenic Routes
• Views from Scenic Routes. Ensure that designated viewsheds from Highway 1 and Sharp Park Road are preserved and enhanced. These views are an essential part of Pacifica’s identity.
• Gateways. Create strong entrances and preserve the quality of experience of movement along primary travel routes.

Land Use
Land Use Framework
• Coastal Development. Ensure that development maximizes beach and coastal open space access and is oriented as much as possible to each particular coastal environment in use, design, and intensity.
• Concentrated Development. Focus new development in or directly adjacent to alreadydeveloped areas, where it can be served by existing public services and where it will not have significant impacts on coastal or other resources. • Future Residential Development. Limit development to sites that are not critical for open space connections or habitat preservation, and which will be in harmony with the surrounding natural setting.
• Higher-Density Housing. Locate higher-density housing in accessible places close to community shopping areas.
• Commercial Area Revitalization. Facilitate the revitalization of shopping areas and the creation of distinct commercial districts in Pacifica, resulting in wider shopping and dining opportunities for residents, enhanced attractions for visitors, increased sales tax revenues, and a stronger community image.
• Compact Mixed Use Development. Facilitate compact mixed-use development on sites with good access to transit. Mixed-use development may include housing or office space with retail, restaurants, or personal service businesses. • Open Space Conservation and Habitat Protection. Protect beaches, oceanfront bluffs, ridgelines, hillside areas adjacent to existing open space, and areas that support critical wildlife habitat and special status species.
• Citizen Participation. Continue broad-based citizen participation in the planning process.

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Packet Pg. 3375 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

Circulation
Roadway Network and Planned Improvements
• Comprehensive Circulation System. Create a comprehensive, multi-modal transportation system with streets and highways; transit facilities; a continuous network of sidewalks and bicycle routes.
• Serve All Users. Plan, design, build, and maintain transportation improvements to support safe and convenient access for all users with priority for “complete streets” projects that facilitate walking, bicycling and transit use wherever possible. • Safety. Make safety a primary objective in street planning and traffic regulations. • Level of Service (LOS) for All Modes of Travel. Assess the performance of the transportation system by measuring how well pedestrians, bicycles, and transit vehicles as well as automobiles are able to move within and through the community. • Vehicle Miles Traveled. Strive to reduce overall vehicle miles travelled by developing higher-density, mixed use areas, designing pedestrian-oriented streets, and improving transit options and efficiency.
• Context Sensitivity. Plan, design, and build transportation improvements so that they respect the surrounding environment.

Transportation improvements will be undertaken in consultation with local residents and businesses.
• Congestion on Highway 1. In consultation with Caltrans, seek solutions to ease the traffic congestion that occurs on Highway 1 near the Reina Del Mar, Fassler Avenue, and Linda Mar Boulevard intersections. Strive for the greatest benefit with the least environmental impact possible.
• Congestion on Hickey and Skyline. Improve travel to and from Pacifica’s northern neighborhoods by easing congestion on Hickey Boulevard through coordinated signalization or other changes, and working with the County to improve operations on SR 35 (Skyline Boulevard).
• Coordination of Local and Regional Actions. Coordinate local transportation planning and improvements with State, Regional and County agencies to ensure consistency with the Regional Transportation Plan, the Congestion Management Program, and other regional actions.

Pedestrian and Bicycle Network
• Bicycle and Pedestrian Routes. Establish trails, bike routes and pedestrian amenities connecting neighborhoods to major shopping and public facility destinations, and fill in gaps in the existing network.
• Walkable Neighborhoods. Improve pedestrian amenities to create more walkable neighborhoods, especially in mixed-use activity centers and around schools.

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Packet Pg. 3376 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

• Recreational Access. Provide recreational access to coastal resources and public open space in keeping with Pacifica’s natural environment, with links to regional trails and bicycle corridors.

See Chapter 6 of the proposed General Plan for additional Trail System policies. • Mobility for All Users. Create a safe and attractive walking environment accessible for all users, particularly persons with disabilities, seniors, and younger residents and visitors. • Connections Across Highway 1. Enhance under- and over-crossings of Highway 1 for pedestrians and bikes to improve accessibility and connect neighborhoods to each other and to the coast.
• Coastal Trail and North-South Bikeway. Complete the Coastal Trail and the northsouth bikeway from the north to sound end of the City parallel to Highway 1, providing clear, safe and efficient means to traverse coastal Pacifica.

Public Transportation and Transportation Demand Management • Improved Public Transit. Advocate for SamTrans and other public transit providers to improve transit service and facilities, to enable trips to be made without use of a car. • Transportation Demand Management (TDM). Support TDM strategies to reduce congestion and single-occupant vehicle travel.

Truck Movement
• Truck Movement and Quality of Life. Balance commercial goods movement with the health and quality of life priorities of the community.

Parking
• Private Parking. Ensure adequate off-street parking in all new development. • Public and Visitor Parking. Facilitate beach and recreational use by providing safe and well-located public parking.
• Commuter Parking. Facilitate transit use by providing safe, well-located park-and-ride lots.

Open Space and Community Facilities
Parks, Beaches and Open Space
• Development of City Parks. Create and enhance neighborhood and pocket parks and plazas to provide access to local recreational space to all Pacifica residents. • Recreation Facilities. Enhance outdoor recreation facilities and services in local parks, in coordination with youth and adult leagues and community groups with priority given to sports fields and off-leash dog play areas.
• Community Gathering Place. Create or enhance one or more public plazas or central gathering places where all Pacifica residents come together. This place or places should be connected with concentrated, mixed use areas.

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Packet Pg. 3377 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

• School Playfields. Continue to cooperate with the school districts to make school play fields available for public use after school hours.
• Open Space Preservation. Preserve open space that protects natural resources, visual amenities, and public health and safety.

The top priority areas for conservation are beaches, oceanfront bluffs, ridgelines, hillsides areas adjacent to existing open space, and areas that support critical wildlife habitat and endangered species. See Figure 6-1 in the General Plan. • Coastal Areas Suited for Water-Oriented Recreation. Continue to protect coastal areas suited for water-oriented recreational activities.

This policy applies to, but is not limited to, the following: fishing at Pacifica Pier, surfing and other water recreation at Pacifica State Beach.

Trail System
• Trail System Expansion. Expand the trail system in Pacifica to create a connected trail network with communitywide links to open space and recreation facilities, as shown on Figure 6-3 of the General Plan.

Coastal Access
• Coastal Access and Recreational Opportunities. Provide maximum coastal access and recreational opportunities for all people consistent with public safety and the need to protect public rights, rights of property owners, and natural resource areas from overuse, including access at each point identified on Figure 6-4 of the General Plan. • Management of Public Access. Provide public access in a manner that takes into account the need to regulate the time, place, and manner that access is provided, based on such factors as topographic and site constraints; the fragility of natural resources; and the privacy of adjacent residential uses.
• Distribution of Public Coastal Facilities. Continue to distribute public facilities, including parking areas or facilities, so as to mitigate against the impacts of overcrowding or overuse by the public of any single area.

Schools and Community Facilities
• Optimize School Facilities. Coordinate with the school districts to ensure facilities are adequate, and to plan for reuse and redevelopment opportunities that help to meet goals of both the districts and the City.
• Public Facilities Improvements. Enhance public community facilities in Pacifica, with top priorities being a new library/learning center and a new City Hall or civic center. • Youth Activities. Create more facilities and activities for youth in Pacifica, especially teenagers, at locations accessible by bus and bicycle as well as by car. • Community Services. Continue to provide services to seniors and others in need, either directly or through support to other organizations.
• Cultural Facilities. Foster the expansion and creation of programs and facilities for the visual and performing arts and the study and appreciation of natural resources.

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Packet Pg. 3378 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

Conservation
Water Resources
• Water Quality. Support the improvement of Pacifica’s water quality, including both surface water and groundwater, through Best Management Practices (BMPs) for stormwater management, stream restoration, and riparian habitat restoration. • Watershed Management. Recognize the interrelated nature of Pacifica’s hydrology system, its watersheds, and development in the Planning Area, and protect water resources through comprehensive management of entire watersheds. • Maintain Creeks as a Resource. Ensure both access to and ecological functionality of the creek system in Pacifica.
• Water Conservation. Work with the NCCWD to meet water conservation objectives as required by State law.
• Wastewater Treatment. Ensure that the City maintains adequate capacity to handle wastewater, and continue to expand wastewater recycling. • Retain Natural Processes. Enable natural processes to occur on developed sites, and utilize these processes to enhance the built environment and users’ experiences of it.

Biological Resources
• Wildlife and Critical Habitat. Conserve and protect indigenous threatened, endangered, and other special status species by preserving critical habitat.

Habitat areas shall be identified as top priorities for permanent conservation, and as such habitat shall be protected by avoiding development or buildout to occur in areas of critical habitat for special status species. Additionally, public land shall be managed to ensure species protection. Critical Habitat in the Coastal Zone is considered Environmentally Sensitive Habitat Area (ESHA).
• Coastal Environment and Sensitive Natural Communities. Conserve and protect beaches, sand dunes, coastal bluffs, and other habitats for special status species, particularly the Coastal bluff scrub on the northern bluffs. • Creeks and Riparian Areas. Protect year-round creeks and their riparian habitats.

San Pedro Creek has been designated an “impaired waterway” by the Regional Water Quality Control Board and provides critical habitat to a federally-listed threatened species, the California coast population of steelhead.
• Trees. Conserve trees and encourage native forestation and planting of appropriate trees and vegetation.
• Other Environmentally Sensitive Areas. Protect High Value or High Habitat Value areas, Wildlife Movement Corridors and Coastal Commission-designated Environmentally Sensitive Habitat Areas from development.

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Packet Pg. 3379 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

Land and Soil Resources
• Preserve Agricultural Open Space. Promote the preservation of agricultural open space in the Planning Area.
• Protect Significant Mineral Resources. Cooperate with regional agencies to protect coastal sediment and significant mineral resources in the Planning Area.

Air Quality
• Improve Air Quality. Reduce emissions of ozone-producing pollutants and particulate matter to improve regional air quality and protect the health of Pacifica and Bay Area residents.

Energy and Greenhouse Gases
• Renewable Energy. Support the use and development of renewable energy through City purchasing, and facilitation of local renewable energy generation. • Energy Conservation. Support efforts to reduce energy use by increasing energy efficiency in buildings and promoting awareness of energy use. • Waste Reduction. Seek to reduce overall solid waste by limiting packaging, controlling construction and demolition waste, and promoting composting and recycling.

Cultural Resources and Historic Preservation
• Historic and Cultural Sites. Conserve designated historic and cultural sites and structures that help define Pacifica’s identity and character and increase public awareness and appreciation them.
• Ensure Mitigation. Require mitigation for any new development that would adversely affect archaeological or paleontological resources.

Safety
Seismic and Geologic Hazards
• Reduce Risk. Minimize risks of property damage and personal injury posed by geologic and seismic hazards.

Flooding and Drainage
• Development in Hazardous Areas. Protect new development in 100-year floodplains and tsunami hazard zones with flood damage prevention programs. • Sea Level Rise Adaptation. Establish policies to minimize the risk to persons and property posed by potential sea level rise.

Hazardous Materials and Operations
• Contaminated Sites. Facilitate clean-up programs at contaminated sites, particularly on properties with the potential to develop or be reused for public purposes. • Safe Disposal. Continue to promote the reduction, recycling, and safe disposal of household and business hazardous wastes through public education and awareness.

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Packet Pg. 3380 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

Fire Hazards
• Fire Prevention. Protect Pacifica residents and businesses from potential wildland fire hazards.

Public Safety and Emergency Management
• Emergency Response. Foster an efficient and coordinated response to emergencies and natural disasters.
• Public Awareness. Support continuing public awareness of hazards, including avoidance, disaster preparedness, and emergency response procedures. • Disaster Preparation. Make infrastructure investments, enforce regulations, and disseminate information that will improve disaster response and recovery, with the goal of minimizing damage to people and property.

Noise
Noise Exposure Standards
• Coordination with Other Agencies. Continue to work with other agencies, airports and jurisdictions to reduce noise levels in Pacifica created by their operations. • Acceptable Noise Environment. Strive to achieve an acceptable noise environment for the environmental, health and safety needs of present and future residents of Pacifica. • Sensitive Land Uses. Protect noise sensitive land uses, such as schools, hospitals, and senior care facilities, from encroachment of and exposure to excessive levels of noise.

This Statement of Overriding Considerations applies specifically to those impacts found to be significant and unavoidable as set forth in the Final EIR and the record of these proceedings. In addition, this Statement of Overriding Considerations applies to those impacts that have been substantially lessened but not necessarily lessened to a level of insignificance.

Based upon the goals and objectives identified in the proposed General Plan and the Final EIR, following extensive public participation and testimony, and notwithstanding the impacts that are identified in the Final EIR as being significant and potentially significant and which arguably may not be avoided, lessened, or mitigated to a level of insignificance, the Council, acting pursuant to Public Resources Code Section 21081 and Section 15093 of the State CEQA Guidelines, hereby determines that specific economic, legal, social, environmental, technological, and other benefits and overriding considerations of the proposed General Plan sufficiently outweigh any remaining unavoidable, adverse environmental impacts of the proposed General Plan Update and that the proposed General Plan should be approved.

Based on the foregoing and pursuant to Public Resources Code section 21081 and State CEQA Guidelines Section 15093, the Council further determines that the unavoidable adverse environmental effects of the proposed General Plan are acceptable, and that there are overriding considerations that support the Council’s approval of the proposed General Plan, as stated in the above sections.

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Packet Pg. 3381 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

The Council believes that it is prudent to select the proposed General Plan over the alternatives because it provides dramatic improvements over the continuation of the existing General Plan, and most closely embodies the project objectives. In making this determination, the Council incorporates by reference all of the supporting evidence cited within the Draft and Final EIR, and in the administrative record.

In reaching this conclusion and approving the proposed Plan:
• The Council has considered the information contained in the Final EIR and fully reviewed and considered all of the public testimony, documentation, exhibits, reports, and presentations included in the record of these proceedings. The Council specifically finds and determines that this Statement of Overriding Considerations is based upon and supported by substantial evidence in the record.
• The Council has carefully weighed the benefits of the proposed Plan against any adverse impacts identified in the Final EIR that could not be feasibly mitigated to a level of insignificance. While the Council have required all feasible mitigation measures, some impacts remain potentially significant.

This Statement of Overriding Considerations applies specifically to those impacts found to be potentially significant and unavoidable as set forth in the Final EIR and the record of these proceedings.

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Packet Pg. 3382 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan CEQA Findings of Fact in Support of Findings and Statement of Overriding Considerations for the Pacifica General Plan Update and Specific Plan EIR

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Packet Pg. 3383 Attachment: Attachment I - Findings of Fact and Statement of Overriding Considerations (5035 : Consideration of Adoption of General Plan Mitigation Monitoring & Reporting Program
for the

PACIFICA GENERAL PLAN UPDATE AND SHARP PARK SPECIFIC PLAN SCH No. 2012022046
City of Pacifica
May 2022

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Packet Pg. 3384 Attachment: Attachment J - Mitigation Monitoring and Reporting Program (MMRP) (5035 : Consideration of Adoption of General Plan Update) Mitigation Monitoring and Reporting Program for the City of Pacifica General Plan Update and Sharp Park Specific Plan
2 This page intentionally left blank.

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Packet Pg. 3385 Attachment: Attachment J - Mitigation Monitoring and Reporting Program (MMRP) (5035 : Consideration of Adoption of General Plan Update) Mitigation Monitoring and Reporting Program for the City of Pacifica General Plan Update and Sharp Park Specific Plan
1 1 Purpose
State of California Public Resources Code Section 21081.6(a)(1) requires a lead or responsible agency that approves or carries out a project subject to the California Environmental Quality Act (CEQA) to adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The City of Pacifica (the "City") is the lead agency for the combined Environmental Impact Report (EIR) prepared for the General Plan Update and Sharp Park Specific Plan (SCH No. 2012022046), hereafter referred to as “Proposed Project,” and therefore is responsible for the adoption and implementation of the required mitigation monitoring and reporting program. An EIR has been prepared for the Proposed Project that addresses potential environmental impacts and, where appropriate, recommends measures to mitigate these impacts.

The Mitigation Monitoring and Reporting Program (MMRP) has been prepared in conformance with Public Resources Code Section 21081.6(a)(1). It is the intent of this program to:

1. Verify satisfaction of the required mitigation measures of the EIR;

2. Provide a methodology to document implementation of the required mitigation;

3. Provide a record of the monitoring program;

4. Identify monitoring responsibility;

5. Establish administrative procedures for the clearance of mitigation measures;

6. Establish the frequency and duration of monitoring; and

7. Utilize existing review processes wherever feasible.

The MMRP describes the procedures that will be used to implement the mitigation measures adopted in connection with the approval of the Proposed Plan and the methods of monitoring such actions. A monitoring program is necessary only for impacts which would be significant if not mitigated.

If, during the course of project implementation, any of the mitigation measures identified cannot be successfully implemented, the City shall immediately inform any affected responsible agencies.

The City, in conjunction with any affected responsible agencies, will then determine if modification to the project is required, and/or whether alternative mitigation is appropriate.

The following consists of a monitoring program table noting the responsible entity for mitigation monitoring, the timing, and a list of all project-related mitigation measures.

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Packet Pg. 3386 Attachment: Attachment J - Mitigation Monitoring and Reporting Program (MMRP) (5035 : Consideration of Adoption of General Plan Update) Mitigation Monitoring and Reporting Program for the City of Pacifica General Plan Update and Sharp Park Specific Plan
2 This page intentionally left blank.

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Packet Pg. 3387 Attachment: Attachment J - Mitigation Monitoring and Reporting Program (MMRP) (5035 : Consideration of Adoption of General Plan Update) Mitigation Monitoring and Reporting Program for the City of Pacifica General Plan Update and Sharp Park Specific Plan 3 2 Mitigation Monitoring and Reporting Plan
Impact Mitigation Measure Method of
Verification
Timing of
Verification
Responsibility
for Verification
Verification
Complete
Date Initial
Energy and Greenhouse Gases

3.4-1: Implementation of
the Proposed Plan would
not generate GHG
emissions, either directly
or indirectly, that may
have a significant impact
on the environment.

MM-GHG-1: For new residential and
commercial development, require
installation of the electric vehicle
recharging stations and other
alternative fuel vehicle support
infrastructure and adopt requirements
for electric vehicle parking in new
developments, consistent with Title 24
requirements, with the goal of
increasing electric vehicle ownership by
20%.

The City of
Pacifica Planning
Department will
review project
plans for
compliance and
the City will verify
compliance after
construction, prior
to issuance of
Certificate of
Occupancy
Plan check,
prior to
issuance of
Certificate of
Occupancy
City of
Pacifica
Planning
Department

3.4-1: Implementation of
the Proposed Plan would
not generate GHG
emissions, either directly
or indirectly, that may
have a significant impact
on the environment.

MM-GHG-2: Require installation of
photovoltaic systems in new single
family residential, multifamily
residential, and commercial
developments to increase solar
capacity per the requirements of State
law, with a target of an equivalent of 15
percent of projected electricity by 2040.

Photovoltaic panel installation is
required for new low-rise residential
The City of
Pacifica Planning
Department will
review project
plans for
compliance and
the City will verify
compliance after
construction, prior
to issuance of
Plan check,
prior to
issuance of
Certificate of
Occupancy
City of
Pacifica
Planning
Department

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Packet Pg. 3388 Attachment: Attachment J - Mitigation Monitoring and Reporting Program (MMRP) (5035 : Consideration Mitigation Monitoring and Reporting Program for the City of Pacifica General Plan Update and Sharp Park Specific Plan 4 Impact Mitigation Measure Method of
Verification
Timing of
Verification
Responsibility
for Verification
Verification
Complete
Date Initial
buildings which include single-family
dwellings, and multi-family dwellings
with three habitable stories or less
pursuant to California Energy Code
section 150.1.c.14. Photovoltaic panel
installation is also required for new
nonresidential buildings with three
habitable stories or fewer, other than
health care facilities; hotel/motel
occupancies; and, high-rise multi-family
buildings with 10 habitable stories or
fewer, pursuant to a local amendment
to the California Energy Code codified
in PMC section 8-6.08.

Certificate of
Occupancy

3.4-1: Implementation of
the Proposed Plan would
not generate GHG
emissions, either directly
or indirectly, that may
have a significant impact
on the environment.

MM-GHG-3: Develop and implement a
program to encourage the use of
available grants for residential and
commercial efficiency retrofits and
voluntary cool roofing practices in new
development with the goal of a 50
percent energy reduction compared to
baseline in 30 percent of the total
existing residential units and nonresidential square feet citywide by 2040. This measure is voluntary.

City Manager’s
Office
Planning
Department will
review project
plans for
compliance and
the City will verify
compliance after
construction, prior
to issuance of
Certificate of
Occupancy.

Plan check,
prior to
issuance of
Certificate of
Occupancy
City of
Pacifica
Planning
Department
Transportation
MM-TRA-1: Require applicants for nonresidential projects that employ 20 or more people—which is equivalent to
12,000 square feet of retail space,
Through
development
review process
Prior to
project
approval
City of
Pacifica
Planning
Department

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Packet Pg. 3389 Attachment: Attachment J - Mitigation Monitoring and Reporting Program (MMRP) (5035 : Consideration Mitigation Monitoring and Reporting Program for the City of Pacifica General Plan Update and Sharp Park Specific Plan 5 Impact Mitigation Measure Method of
Verification
Timing of
Verification
Responsibility
for Verification
Verification
Complete
Date Initial
6,000 square feet of office space,
20,000 square feet of industrial space,
or 22 hotel rooms to implement an
employee commute trip reduction
(CTR) program. The CTR program shall
include information regarding these
programs. The program shall be readily
available to employees and clients and
participants shall implement at least
one of the following incentives for
commuters as part of the CTR program,
or another equally effective incentive:
• Ride-matching assistance
• Subsidized public transit passes
• Vanpool assistance or employerprovided vanpool/shuttle • Car-sharing program (e.g. Zipcar)
• Bicycle end-trip facilities, including
bike parking, lockers, and
showers.

3.2-2: Implementation of
the Proposed Project
would conflict or be
inconsistent with CEQA
Guidelines Section
15064.3, subdivision (b).

MM-TRA-2: Develop an informational
program that encourages local
businesses to implement
telecommuting, hybrid, and alternative
work schedules that allow employees to
utilize remote work options while
reducing vehicle-based commutes.

Implementation of commute trip
reduction programs and remote work
options could reduce home-based work
VMT, home-based work VMT per
employee, and VMT per capita. This
measure is voluntary.

Submission of
documents by
participating
businesses
Upon receipt
of reports
submitted by
participating
businesses,
including
any reports
required to
be submitted
pursuant to
San Mateo
County
Congestion
City of
Pacifica
Planning
Department

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Packet Pg. 3390 Attachment: Attachment J - Mitigation Monitoring and Reporting Program (MMRP) (5035 : Consideration Mitigation Monitoring and Reporting Program for the City of Pacifica General Plan Update and Sharp Park Specific Plan 6 Impact Mitigation Measure Method of
Verification
Timing of
Verification
Responsibility
for Verification
Verification
Complete
Date Initial
Managemen
t Program
TDMs.

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Packet Pg. 3391 Attachment: Attachment J - Mitigation Monitoring and Reporting Program (MMRP) (5035 : Consideration 1 Murdock, Christian
From: Matt Lanier < >
Sent: Saturday, May 21, 2022 8:51 PM
To: Murdock, Christian; O'Connor, Bonny
Subject: Sharp Park specific plan comment
[CAUTION: External Email]

Hello‐
This is coming from Matt Lanier, owner and resident at 44 Carmel Ave, Pacifica.

PLEASE include 44 Carmel Ave within the High Density Residential Zone.  We want to use our property as part of High Density infill, and don't want to be stuck with Low Density which is increasingly unaffordable to maintain.

Thank you‐
Matt Lanier
44 Carmel Ave, Pacifica, CA 94044
‐‐
Matt Lanier
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3392 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) 1 Murdock, Christian
From: William.Leo Leon
Sent: Tuesday, May 24, 2022 6:20 PM
To: Public Comment; Pacifica Permit Tech; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg Cc: Murdock, Christian; Woodhouse, Kevin; Coffey, Sarah Subject: June 1, 2022 Planning Commission Hearing, Comment Letter and Attachments for GPU, DEIR, LCLUP Attachments: CCC Exhibit 5.pdf; CCC Exhibit 6.pdf; CCC Exhibit 7.pdf; CCC Exhibit 8.pdf; CCC Exhibit 9.pdf; CCC Exhibit 11.pdf; eMail Aug 16, 2021, William.Leo Leon.pdf; F16a-CCC CDP Report.pdf; Figure 3.7. 3 Sensitive and Critical Habitat.pdf; Figure 4.3_ESHA LCLUP.pdf; Figure 7. 3 Sensitive and Critical Habitat.pdf; My GPU-LCLUP Comment Letter 1.pdf
[CAUTION: External Email]

Subject: Comment Letter and Attachments for GPU, DEIR, LCLUP DATE: May 24, 2022
To: Pacifica Planning Commissioners,
Dear Chair Berman and Planning Commissioners,
I have attached my Comment letter and the related files for the General Plan Update (GPU), Local Coastal Land Use Plan (LCLUP), and Draft Environmental Report (DEIR).

I delivered the original of my comment letter and related files, on March 3, 2022, at the Pacifica Planning Department.

As a former Chair and Planning Commissioner member, I believe It is vital to the interests of the City of Pacifica that you read, ask questions and understand all the data and facts before you make a Recommendation or take action regarding our General Plan Update, Local Coastal Land Use Plan, Draft Environmental Impact Report and Sharp Park Specific Plan.

Please let me know if you have any questions regarding my comment letter or the attachments.

Best Wishes,
William "Leo"Leon
Pacifica CA 94044
see files attached
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3393 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) 505 SAN PEDRO AVENUE, PACIFICA

WETLAND DELINEATION
PREPARED FOR:

Shawn Rhodes
PREPARED BY:

Coast Ridge Ecology, LLC
1410 31st Avenue
San Francisco, CA 94122
November 2019
2-19-0026
Exhibit 5

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Packet Pg. 3394 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Table of Contents

1. SUMMARY........................................................................................................................... 1

2. SETTING ............................................................................................................................... 3

2.1 SITE DESCRIPTION ...................................................................................................................... 3

2.2 PROJECT DESCRIPTION ............................................................................................................... 3

2.3 VEGETATION .............................................................................................................................. 6

2.3.1 Arroyo Willow Thicket.................................................................................................................. 6

2.3.2 Coastal Brambles.......................................................................................................................... 6

2.3.3 Eucalyptus Grove ......................................................................................................................... 6

2.3.4 Kikuyu Grass Sward ...................................................................................................................... 7

2.3.5 Monterey Cypress Stand.............................................................................................................. 7

2.3.6 Ornamental .................................................................................................................................. 7

2.3.7 Perennial Rye Grass Fields ........................................................................................................... 7

2.3.8 Small-fruited Bulrush Marsh........................................................................................................ 8

2.3.9 Smartweed Patch ......................................................................................................................... 8

2.3.10 Upland Mustards and Ruderal Forbs......................................................................................... 8

2.4 SOILS .......................................................................................................................................... 8

2.5 HYDROLOGY............................................................................................................................... 8

3. METHODOLOGY ................................................................................................................. 10

3.1 DEFINITION OF TERMS .............................................................................................................. 10

3.2 REGULATORY SETTING............................................................................................................. 13

3.2.1 U.S Army Corps of Engineers ..................................................................................................... 13

3.2.2 California Coastal Commission................................................................................................... 13

3.2.3 California Department of Fish and Wildlife ............................................................................... 14

3.2.4 Regional Water Quality Control Board ...................................................................................... 14

3.3 DELINEATION METHODS........................................................................................................... 15

3.4 LITERATURE REVIEW................................................................................................................. 15

3.5 FIELD SURVEY ........................................................................................................................... 15

3.5.1 Vegetation Data Collection ........................................................................................................ 15

3.5.2 Soils ............................................................................................................................................ 16

3.5.3 Hydrology ................................................................................................................................... 16

3.6 FEDERAL WETLAND BOUNDARY DETERMINATION .................................................................... 16

3.6.1 Acreage Calculations.................................................................................................................. 17

3.7 STATE WETLAND BOUNDARY DETERMINATION........................................................................ 17

4. RESULTS............................................................................................................................. 18

4.1 FEDERAL WETLANDS................................................................................................................. 18

4.1.1 Vegetation.................................................................................................................................. 20

4.1.2 Soils ............................................................................................................................................ 20

4.1.3 Hydrology ................................................................................................................................... 20 2-19-0026 Exhibit 5

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Packet Pg. 3395 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

4.2 STATE WETLANDS..................................................................................................................... 20

4.3 ENVIRONMENTALLY SENSITIVE HABITAT AREAS (ESHA)............................................................ 21 RECOMMENDATIONS ............................................................................................................ 21

5. REPORT PREPARATION AND REFERENCES .......................................................................... 24

5.1 REPORT PREPARATION............................................................................................................. 24

5.2 REFERENCES ............................................................................................................................. 24

APPENDICES

1. Wetland Determination Data Forms……………………………………………………...A-1

2. Representative Photographs………………………………………………………………B-1

3. Soils Survey Map...……………………………………………………………………….C-1

LIST OF FIGURES

1. Project Location and Study Area…………………………………………………………....5

2. Federal and State Wetland Delineation Map……...…………………………...…………..19

LIST OF TABLES

1. Total acreage of wetland areas within study area……………………………………………18

2. Setback distances for proposed project and state and federal wetlands………………...……22 2-19-0026
Exhibit 5

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Packet Pg. 3396 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 1

1. SUMMARY
This report presents the results of a formal delineation of waters of the United States, including wetlands, at an undeveloped property (drainage channel) adjacent to 505 San Pedro Avenue, Pacifica, California (APN 023-72-010). The property drainage channel is within an unaccepted city of Pacifica Right of Way. The purpose of the delineation of the drainage channel is to assist the California Coastal Commission in identifying the type and extent of waters subject to federal and state jurisdiction and to inform potential impacts from future development of the adjacent property at 505 San Pedro Avenue.

Fieldwork was performed by Coast Ridge Ecology staff biologists in September and October 2019 using the routine determination method described in the 1987 US Army Corps of Engineers (USACE) Wetland Delineation Manual, in incorporation with the USACE 2010 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys and Coast Region (Version 2.0). Wetland vegetation types were mapped in the field using a Trimble GeoExplorer unit on September 18, October 21, and October 25, 2019.

Field data was analyzed to determine a wetland boundary. A total of 0.088 acres of potentially jurisdictional federal wetlands (i.e. three-parameter) are present within the study area and may be subject to jurisdiction under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act. A total of 0.248 acres of potentially jurisdictional state wetlands (i.e. oneparameter) are present within the study area, and may be subject to jurisdiction under the California Coastal Commission. Wetland areas within the study area are composed of freshwater wetlands dominated by water smartweed (Persicaria amphibia), arroyo willow (Salix lasiolepis), small-fruited bulrush (Scirpus microcarpus), and perennial rye grass (Festuca perennis). These wetlands are all located within portions of the channel bottom of the drainage channel, with the exception of the one-parameter Arroyo willow wetlands on the north side of the drainage channel, which extend up the channel bank. Appendix A provides completed data sheets for the study area. Appendix B provides representative photographs.

The drainage channel feature adjacent to the property at 505 San Pedro Avenue is a man-made constructed feature, that is highly degraded due to construction and ongoing maintenance of a City of Pacifica sewer line that runs underneath the feature. The channel has been used as an illegal dumping area for decades and refuse such as gas cans, mattresses, appliances, plastic garbage, concrete rubble, bricks, and other refuse are present within the channel and buried within the soil.
2-19-0026
Exhibit 5

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Packet Pg. 3397 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 2 In the city of Pacifica, construction projects within the coastal zone are regulated through the City’s Local Coastal Land Use Plan (LCLUP). The City regulates construction projects through the LCLUP, to bring projects into conformance with the California Coastal Act of 1976.

The LCLUP states that “As a general rule, a buffer of at least 100 feet measured from the outward edge of riparian vegetation would be appropriate unless such a width is determined to be unnecessary for protecting the resources of the habitat area”. The California Coastal Commission has required buffers of 100 feet from the edge of riparian vegetation in areas where such buffers are feasible. However, it is not unusual for the Commission to allow smaller buffers in urbanized areas where the existing land use patterns do not allow for increased riparian buffer areas.

Based on the existing condition of the drainage channel, and the setback distances, the proposed project would not present a source of physical, chemical or biological disturbance to the wetland habitats including the arroyo willow stand (AW-1). Additional measures to ensure the channel is not impacted by construction activities would include planting of native plant species suitable for the boundary area adjacent to the channel, and installation of appropriate erosion/ sediment controls such as silt fencing, fiber rolls, and erosion control blankets along the top of the bank.

These measures would be suitable to protect the resource and improve the quality of this resource.

Any economic use of the subject property would result in a reduction of the recommended 100- foot buffer because of the proximity of any development on the property to wetland habitat. The CCC has established precedent by issuing permits allowing even more intensive uses that resulted in direct impacts to sensitive coastal resources, consistent with the mandate of Coastal Act § 30010 that prevents taking of private property without compensation (see CCC Appeal Numbers A-2-SMC-11-040 & A-2-SMC-11-041 concerning a controversial project near Half Moon Bay that was ultimately approved).

These conclusions should be regarded as preliminary and subject to verification by the U.S.

Army Corps of Engineers prior to performing any work that would impact wetland resources on site.
2-19-0026
Exhibit 5

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Packet Pg. 3398 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 3

2. SETTING

2.1 SITE DESCRIPTION
The study area encompasses approximately 1.6 acres of land located at 505 San Pedro Avenue (project site) and the drainage channel adjacent to the property in Pacifica, California. The applicant (Shawn Rhodes) is proposing to develop the parcel at 505 San Pedro Avenue, which is

0.86 acres. The adjacent drainage channel is 0.74 acres. The drainage channel is located to the west of the property within an unaccepted city right of way. This delineation was conducted to provide additional information on the drainage channel, in response to California Coastal Commission letter dated July 2, 2019 regarding Coastal Development Permit (CDP) Application Number 2-19-0026 (construction of a mixed-use scheme, including three buildings, a skate park, and a parking lot in Pacifica.

The site is bordered by the Pedro Point Shopping Center to the East, San Pedro Avenue to the south, and residential properties to the north. The area is highly developed, and the property is surrounded by residential and commercial developments on all sides. The Pacific Ocean is located approximately 210 feet to the northwest. Topography on the project site is variable, as is located on an elevated berm-like feature. The top of the berm runs southwest-northeast through the approximate center of the property, and slopes downwards towards the drainage channel on the west side and the shopping center on the east side. Elevations at the study area range from approximately 14 to 23 feet. Figure 1 shows the project boundaries and location. Photographs of the project site can be found in Appendix B.

The drainage channel was created most likely as an irrigation ditch for farming prior to the 1950’s. The City of Pacifica constructed a sewer line below the channel, with sewer manholes in two locations within the channel, at some point later (in the 1960’s possibly). The channel bed and banks are categorized as ‘urban’ soil type due the history of disturbance to the channel and its location adjacent to a 5-acre commercial shopping center and parking lot. Urban runoff from the local community of Pedro Point flows into the channel which then empties through a culvert and into San Pedro Creek on the north side of the 505 San Pedro Avenue property.

2.2 PROJECT DESCRIPTION
The property (APN 023-72-010) is located on San Pedro Avenue in Pacifica, California. The property is 0.86 acres in size (37,273 ft.2) and is located on the west side of Highway 1 in the Pedro Point area. The site is located within the coastal zone and is subject to the City of 2-19-0026
Exhibit 5

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Packet Pg. 3399 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 4 Pacifica’s Local Coastal Land Use Plan. The property is zoned as commercial and is within the Pedro Point – Shelter Cove Land Use Plan Area, and is outside of any special areas delineated in the Local Coastal Land Use Plan (City of Pacifica, 1992). The site is a narrow, rectangular strip of land (755 feet long x 55 feet wide) and is bounded by San Pedro Road on the south, a drainage channel and open field on the west, a strip mall/shopping area to the east and a parking lot on the north. San Pedro Creek and the Pacific Ocean are located further to the north, and northwest of the parking lot. The surrounding area is single family residential homes and small businesses.

The project intends to develop a currently vacant lot into commercial and residential buildings.

The development will consist of a 2-story surf shop building with storage basement (3,500 ft2 ), a
skatepark enclosed within chain-link fencing and a roof (4,730 ft2), a 2-story storage building for the surf shop (1,540 ft2), 2 parking lot areas (16,513 ft2), a 2-story building with retail space at the lower level and 2 residential units above (2,516 ft2 ), and various areas of landscaping (7,302
ft2). The project would be constructed within an upland area that is behind an existing shopping center, and would include a public access easement (pedestrian trail) that would extend along the western boundary of the site, along the top of bank of an adjacent drainage channel. The project area and adjacent drainage channel have been heavily disturbed by grading activities in the past.

The adjacent drainage channel would not be directly impacted by the proposed project.

This wetland delineation was conducted on the adjacent drainage channel, which is designated as an unaccepted right of way (identified as ‘Chester Way’) on the most current San Mateo County Assessor’s parcel map.
2-19-0026
Exhibit 5

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Packet Pg. 3400 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 5 2-19-0026
Exhibit 5

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Packet Pg. 3401 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 6

2.3 VEGETATION
Vegetation at the study site (drainage channel) can be categorized into several different natural communities based upon plant species composition. The boundaries between communities can be distinct, or can change gradually over an area. Due to the semi-developed nature of the project site, vegetation types in this analysis are based upon, but do not strictly follow, species alliances described by the California Native Plant Society (CNPS) Manual of California Vegetation. Natural communities on the site include arroyo willow thicket, coastal brambles, eucalyptus grove, kikuyu grass sward, Monterey cypress stand, perennial rye grass fields, smallfruited bulrush marsh, smartweed patch, upland mustards/ruderal and ornamental.

2.3.1 Arroyo Willow Thicket
The arroyo willow thicket community is dominated by arroyo willow (Salix lasiolepis). This plant community is found within the drainage at the northeast terminus of the drainage. It is comprised of dense arroyo willow trees. Arroyo willows are a facultative wetland (FACW) plant, found more frequently in wetlands than outside of them.

2.3.2 Coastal Brambles
The coastal brambles plant community is characterized as being heavily dominated by brambles (Rubus sp.). Within the study area, this plant community is primarily made up of dense California blackberry (Rubus ursinus) vines, with the ornamental species multiflora rose (Rosa multiflora) and California privet (Ligustrum ovalifolium) occasionally present at lower densities.

The coastal brambles plant community is found along the banks of the drainage channel, sometimes extending into the channel itself. California blackberry is a Facultative plant (FAC), found equally often in wetland and upland habitats. Multiflora rose and California privet are considered upland species (UPL). Due to the prevalence of dominant upland species within this habitat, it is not considered a wetland.

2.3.3 Eucalyptus Grove
Two groves of mature blue gum (Eucalyptus globulus) trees are present at the western and southwestern portions of the study area. Large blue gum trees make up the overstory of this community, while the understory is primarily composed of eucalyptus duff and English ivy (Hedera helix). Blue gum is an upland (UPL) species, and English ivy is considered a Facultative Upland (FACU) species more likely to be found in upland habitats. 2-19-0026
Exhibit 5

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Packet Pg. 3402 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 7

2.3.4 Kikuyu Grass Sward
Swards of the invasive Kikuyu grass (Pennisetum clandestinum) are present within the bottom of the drainage channel. These areas are completely dominated by Kikuyu grass with no other vegetation present. This species is considered a Facultative Upland (FACU) plant, being found more often in upland habitats. The presence of Kikuyu grass indicates that there is unlikely to be significant soil inundation (and thus wetland habitat) in this portion of the drainage channel.

2.3.5 Monterey Cypress Stand
One stand of Monterey cypress (Hesperocyperus macrocarpa) is present within the study area along the western bank of the channel. Vegetative cover within this stand is entirely made up of Monterey cypress, as the density of the trees prevents any understory vegetation from growing beneath them. Monterey cypress is ranked UPL.

2.3.6 Ornamental
The ornamental vegetation community is made up of non-native ornamental plant species that are not widespread enough in natural areas to possess a community designation. Within the study site, areas of ornamental vegetation are dominated by garden nasturtium (Tropaeolum majus), English ivy (Hedera helix), or cape ivy (Delairea odorata). Where present, each species provides nearly 100 percent of the vegetative cover. These areas heavily dominated by non-native vegetation are primarily found along the eastern bank of the drainage channel. All of these plants are considered upland species.

2.3.7 Perennial Rye Grass Fields
This plant community is dominated by perennial rye grass (Festuca perennis). Individual curly and green dock (Rumex crispus/Rumex conglomeratus) plants are also present at lower densities.

Perennial fescue is a Facultative wetland plant (FAC), equally likely to be found inside or outside of wetland habitats. Curly dock is also a FAC plant, while green dock is considered a FACW plant.
2-19-0026
Exhibit 5

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Packet Pg. 3403 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 8

2.3.8 Small-fruited Bulrush Marsh
This plant community is dominated by small-fruited bulrush (Scripus microcarpus). One small patch of these plants is present within the drainage channel, where they make up 100 percent of the vegetative cover. Small-fruited bulrush is an Obligate wetland species (OBL), only being found within wetland habitats.

2.3.9 Smartweed Patch
This plant community is primarily dominated by smartweed (Persicaria sp.). Within the study area, this community is dominated by water smartweed (Persicaria amphibia), a wetland obligate species (OBL). Other plant species observed growing beneath and around the smartweed include silverweed cinquefoil (Potentilla anserina), dock (Rumex sp.), and California blackberry (Rubus ursinus). These plants are only found within the wetter portions of the drainage channel.

2.3.10 Upland Mustards and Ruderal Forbs
This plant community is dominated by non-native mustards and other invasive species. Within the study area, this habitat is heavily dominated by wild radish (Raphanus sativus), which dominates the vegetative cover along the eastern bank/berm and upland portions of the site.

Small patches of fennel (Foeniculum vulgare) can also be found within this community. These plants are designated as upland (UPL) species.

2.4 SOILS
Only one soil type is present within the study area: Urban land. Urban land is defined by the USDA NRCS as areas where 85% or more of the ground surface is covered by asphalt, concrete, buildings, and other structures (USDA SCS 1991). Appendix C provides a soils map of the study area.

2.5 HYDROLOGY
The project site consists of a vacant lot and does not contain any watercourses or wetland habitats. Aquatic features within a 100-meter radius of the project site include the Pacific Ocean, San Pedro Creek (approximately 75 meters northeast of the site), and an intermittent drainage channel on the west side of the project site
2-19-0026
Exhibit 5

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Packet Pg. 3404 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 9 The drainage channel was created most likely as an irrigation ditch for farming prior to the 1950’s. At some point later (in the 1960’s possibly), the City of Pacifica constructed a sewer pipe that runs below the open channel for most of the channel’s length. Two sewer manholes are located in the channel bottom. During rain events, urban stormwater runoff from the local community of Pedro Point flows into the channel which then empties through a culvert into San Pedro Creek to the north side of the property.
2-19-0026
Exhibit 5

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Packet Pg. 3405 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 10

3. METHODOLOGY
This wetland delineation was conducted in accordance with the USACE 1987 Corps of Engineers Wetlands Delineation Manual along with the USACE 2008 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region. A Level 3 Determination (i.e., a combination of onsite inspection and aerial review) was conducted as defined in the Wetland Delineation Manual.

The location of the project site is within the boundary zone between the Arid West Region and the Western Mountains, Valleys, and Coast Region. The climatic conditions and vegetation in Pacifica overlaps with what is described in both supplements. Both regional supplements include coastal areas, and a reasonable justification could be made to support the use of either supplement. The Western Mountains regional supplement was chosen as the appropriate manual based on vegetation and climate; including the following:

Arid West: Generally hot and dry with long summer dry season. Average annual precipitation mostly <15”, except along the coast. Most precipitation falls as rain.

Western Mountains, Valleys and Coast: Cooler and more humid with a shorter dry season.

Average annual precipitation mostly >20” except near the coast. Much of the annual precipitation falls as snow, particularly at higher elevations.

Average annual precipitation in Pacifica is approximately 32”1. Due to heavy fog during the summertime especially, the amount of water available to vegetation is much greater due to fog drip.

3.1 DEFINITION OF TERMS
The following section provides key definitions of terms used in this report that are relevant to the delineation of wetlands and other waters of the US.

Waters of the United States: Title 33, Chapter II, Part 328.3 of the Code of Federal Regulations defines waters of the United States as:
(1) All waters which are currently used, were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide;
(2) All interstate waters including interstate wetlands; 1 https://www.ncdc.noaa.gov/cdo-web/datatools/normals
2-19-0026
Exhibit 5

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Packet Pg. 3406 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 11 (3) All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mud flats, sand flats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation, or destruction of which could affect interstate or foreign commerce including any such waters:
a. which are or could be used by interstate or foreign travelers for recreational or other purposes;
b. or from which fish or shellfish are or could be taken and sold in interstate or foreign commerce;
c. or which are used or could be used for industrial purposes by industries in interstate commerce;
(4) All impoundments of waters otherwise defined as waters of the United States under the definition;
(5) Tributaries of waters identified in paragraphs (1) through (4); (6) Territorial seas; and
(7) Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraphs (1) through (6).

Federal Definition of Wetlands: In Title 33, Chapter II, Part 328.4 of the Code of Federal Regulations, wetlands are defined as: “Those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” For the purposes of a USACE wetland delineation, an area must meet three diagnostic environmental characteristics in order to be considered a wetland. These three characteristics include the presence of hydrophytic vegetation, hydric soils, and wetland hydrology.

Hydrophytic Vegetation: The USACE 1987 Wetland Delineation Manual describes hydrophytic vegetation as “sum total of macrophytic plant life that occurs in areas where the frequency and duration of inundation or soil saturation produce permanently or periodically saturated soils of sufficient duration to exert a controlling influence on the plant species present. The vegetation occurring in a wetland may consist of more than one plant community (species association). Emphasis is placed on the assemblage of plant species that exert a controlling influence on the character of the plant community, rather than on indicator species.”
Hydric Soil: Defined by the USACE Western Mountains Supplement as “a soil that formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part. Most hydric soils exhibit characteristic morphologies that result from repeated periods of saturation or inundation for more than a few days…These processes result in distinctive characteristics that persist in the soil during both wet and dry periods.” 2-19-0026
Exhibit 5

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Packet Pg. 3407 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 12 Wetland Hydrology: The USACE 1987 Wetland Delineation Manual describes wetland hydrology as “all hydrologic characteristics of areas that are periodically inundated or have soils saturated to the surface at some time during the growing season. Areas with evident characteristics of wetland hydrology are those where the presence of water has an overriding influence on characteristics of vegetation and soils due to anaerobic and reducing conditions, respectively.”
Navigable Waters of the United States: Title 33, Chapter II, Part 329.4 of the Code of Federal Regulations defines navigable waters of the U.S. as “those waters subject to the ebb and flow of the tide and/or are presently used, or have been used in the past, or may be susceptible for us to transport interstate or foreign commerce. A determination of navigability, once made, applies laterally over the entire surface of the waterbody, and is not extinguished by later actions or events which impede or destroy navigable capacity.” For the purposes of a USACE jurisdictional determination, navigable waters of the United States are considered Traditionally Navigable Waters.

Ordinary High Water Mark (OHWM): Title 33, Chapter II, Part 328.3 of the Code of Federal Regulations defines the OHWM as “that line on the shore established by the fluctuations of water and indicated by physical characteristics, such as a clear, natural line impressed on the bank, shelving, changes in the character of the soil, destruction of terrestrial vegetation, the presence of litter or debris, or other appropriate means that consider the characteristics of the surrounding area.”
Mean High Water (MHW): Section 10 of the Rivers and Harbors Act (RHA), which regulates certain activities in navigable waters of the U.S., defines the landward limit of Section 10 jurisdiction as the Mean High Water (MHW) mark. The MHW mark, with respect to ocean and coastal waters, is defined as: “The line on the shore established by the average of all high tides. It is established by survey based on available tidal data (preferably averaged over a period of 18.6 years because of the variations in tide). In the absence of such data, less precise methods to determine the mean high water mark are used, such as physical markings, lines of vegetation or comparison of the area in question with an area having similar physical characteristics for which tidal data are readily available.”
In the case of non-tidal waters regulated by the RHA, the MHW is defined as the OHWM.

State Definition of Wetlands: The State defines wetlands more broadly than the federal wetlands program by recognizing that wetlands may have evidence of only one of the three federal parameters. The State definition also conforms to the USFWS definition:
"Wetlands are lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water. For purposes of this classification, wetlands must have one or more of the following three attributes: (1) at least periodically, the land supports hydrophytes, (2) the substrate is 2-19-0026
Exhibit 5

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Packet Pg. 3408 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 13 predominantly undrained hydric soil; and (3) the substrate is non-soil and is saturated with water or covered by shallow water at some time during the growing season of each year" (Cowardin, 1979).

Additionally, for the purposes of identifying Environmentally Sensitive Habitat Areas (ESHA) regulated by the California Coastal Commission, the California Coastal Act of 1976 further specifies that wetlands are:
“Land where the water table is at, near, or above the land surface long enough to promote the formation of hydric soils or to support the growth of hydrophytes, and shall also include those types of wetlands where vegetation is lacking and soil is poorly developed or absent as a result of frequent and drastic fluctuations of surface water levels, wave action, water flow, turbidity or high concentrations of salts or other substances in the substrate. Such wetlands can be recognized by the presence of surface water or saturated substrate at some time during each year and their location within, or adjacent to, vegetated wetlands or deep-water habitats” (CCR Title 14, Section 13577).

Although the State definition may require only a single parameter to establish the presence of wetlands (and ESHA), in practice, such decisions are based on a case-by-case interpretation of data that either support or disprove the presumption of whether wetlands are indicated by a single parameter.

3.2 REGULATORY SETTING

3.2.1 U.S Army Corps of Engineers
The US Army Corps of Engineers (USACE) regulates activities that result in the discharge of dredged or fill materials into waters of the U.S. including wetlands, under Section 404 of the Clean Water Act. USACE also regulates dredging, filling, and construction activities in navigable waters under Section 10 of the Rivers and Harbors Act. Activities involving dredged or filled materials require a Section 404 permit, and/or a Section 10 permit, issued by the USACE. Section 404 projects may be authorized under general permits, also known as nationwide permits, or may require individual permits in the case of more complex projects that exceed the threshold for impacts under the nationwide permits.

3.2.2 California Coastal Commission
The California Coastal Commission (CCC) exercises jurisdiction over development activities within the coastal zone. In the city of Pacifica, construction projects within the coastal zone are regulated through the City’s Local Coastal Land Use Plan (LCLUP). The City regulates construction projects through the LCLUP, to bring projects into conformance with the California Coastal Act of 1976.
2-19-0026
Exhibit 5

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Packet Pg. 3409 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 14 The project site is within the Pedro Point/ Shelter Cove Land Use Plan area, and is not located within a designated environmentally sensitive wetland area (LCLUP 1992). However, in the Plan Conclusions section, under Development Near Wetlands and Creeks; the LCLUP states:
“Riparian vegetation along all intermittent and year-round creeks shall be protected, enhanced and restored where feasible, and buffer zones required.”; And; “As a general rule, a buffer of at least 100 feet measured from the outward edge of riparian vegetation would be appropriate unless such a width is determined to be unnecessary for protecting the resources of the habitat area”

3.2.3 California Department of Fish and Wildlife
The California Department of Fish and Wildlife (CDFW) regulates projects that will:
(1) substantially divert or obstruct the natural flow of any river, stream or lake; (2) substantially change or use any material from the bed, channel, or bank of, any river, stream, or lake; or
(3) deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake. (Section 1602, California Fish and Game Code)
To complete projects which will affect these characteristics of any river, stream, or lake, within the state of California, projects must apply for a Lake or Streambed Alteration Agreement (Section 1600 Series Permit). The jurisdictional boundary of the CDFW typically follows the top-of-bank or the outermost edge of riparian vegetation adjacent to the regulated stream, river, or lake.

3.2.4 Regional Water Quality Control Board
The Regional Water Quality Control Board (RWQCB) has authority over projects that could result in negative impacts to waters of the State and wetlands. The RWQCB, defines “waters of the State” as any surface water or groundwater, including saline waters within the boundaries of the State of California (Cal. Water Quality Control, Division 7, January 2011). In addition, it defines “water quality control” as the regulation of any activity that may affect the quality of the waters of the State, and includes the prevention and correction of water pollution and nuisance.

Under the Porter-Cologne Water Quality Control Act, the RWQCB is authorized to regulate the discharge of waste that could affect the quality of State waters. Regulated discharges include any substances associated with human habitation that are harmful to the aquatic environment, including stormwater runoff associated with construction projects and other activities that could discharge soil, pollutants, or other materials into waters of the State. Projects that could produce pollutants or discharge into waters of the state must apply for a Section 401 Certification from 2-19-0026
Exhibit 5

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Packet Pg. 3410 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 15 the California Regional Water Quality Control Board to ensure that any discharges will be in compliance with California’s water quality standards.

3.3 DELINEATION METHODS
This wetland delineation was conducted through the analysis of aerial photography, historical records, and other relevant data sources, as well as an onsite survey to characterize vegetation, soils, and hydrology.

3.4 LITERATURE REVIEW
Prior to the field survey, aerial photographs were reviewed for current and historical data on lake levels and vegetation. Soil types were assessed using the online USDA Natural Resource Conservation Science Web Soil Survey (NRCS 2019). Historical and current land use data was accessed from various sources, including historical aerial photographs (UCSB 2019).

3.5 FIELD SURVEY
The field delineation for the study area was conducted by Patrick Kobernus of Coast Ridge Ecology on October 21, 2019. Wetland vegetation was mapped by P. Kobernus and CRE Biologist Greg Pfau on September 18, 2019. Weather conditions at the time of the field visits included clear skies, temperatures in the 70’s (ºF), and no wind. The onsite inspection evaluated the three parameters that identify and delineate the boundaries of jurisdictional wetlands, including (1) the dominance of wetland vegetation; (2) the presence of hydric soils; and (3) hydrologic conditions that result in periods of inundation or saturation on the surface from flooding or ponding.

Survey methods follow the protocol outlined in the 1987 USACE Wetland Delineation Manual for Areas Less Than Five Acres in Size. GPS coordinates of each sample location were recorded in the field with a Trimble GeoExplorer 6000 series unit. Vegetation, soils and hydrology data were taken at each of these points. The completed Wetland Determination Data Forms for the Western Mountains Region are located in Appendix A.

3.5.1 Vegetation Data Collection
Vegetation data was collected at each sample point taken during the field survey. As per the 1987 Wetland Delineation Manual and the 2010 Western Mountains, Valleys and Coast Regional Supplement, plants in the tree stratum are defined as woody plants with a diameter three inches or more at breast height (DBH). Saplings/shrubs are defined as woody plants with a diameter of less than three inches DBH, and herbs are defined as non-woody plants regardless of size. Species type and percent dominance of each species was recording at each sample point.

The USACE National Wetland Plant List was used to determine the wetland indicator status of 2-19-0026
Exhibit 5

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Packet Pg. 3411 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 16 plants observed in the study area. Wetland indicator status refers to the probability that a plant will occur within a wetland or upland area. The indicator status categories are defined as follows:
• Obligate (OBL): almost always occurs in wetlands
• Facultative wetland (FACW): usually occurs in wetlands, sometimes may occur in uplands
• Facultative (FAC): equally likely to occur in wetlands or nonwetlands • Facultative upland (FACU): usually occurs in uplands but may occasionally occur in wetlands
• Obligate upland (UPL): almost never occurs in wetlands • No indicator (NI)/ No status (NS): no indicator or status assigned due to lack of information
The presence of hydrophytic vegetation data was then determined using the dominance test and prevalence index described in the USACE Wetland Delineation Manual and Western Mountains Regional Supplement.

3.5.2 Soils
Soil pits were taken at each of the eight sample point sites. Soil pits were excavated to the maximum depth possible and soil color and texture was assessed and recorded onto the Western Mountains data sheets. Soil color was determined by matching samples to Munsell Soils Color Charts (Munsell Colors 2000). Soils were then assessed for hydric features described in the Western Mountains Regional Supplement, such as the presence of redoxomorphic concentrations, mucky soils or hydrogen sulfide odor.

3.5.3 Hydrology
Hydrology at each of the sample points was assessed based upon the USACE Western Mountains, Valleys, And Coast Region hydrology guidelines. Positive hydrological indicators include the presence of a visible water table, saturation and/or muck, water marks or drift deposits.

3.6 FEDERAL WETLAND BOUNDARY DETERMINATION
A preliminary wetland boundary line, based on the 3-parameter wetland definition was determined based on data points and vegetation mapping. Based upon the location of wetland versus non-wetland sample points, the wetland boundary was determined to correspond to specific discrete locations within the channel bottom (Figure 2). 2-19-0026
Exhibit 5

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Packet Pg. 3412 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 17

3.6.1 Acreage Calculations
The area for each individual vegetation polygon within the wetland boundary was calculated in ArcMAP 10.2. All vegetation areas were then added to obtain a total area for wetlands within the study area.

3.7 STATE WETLAND BOUNDARY DETERMINATION
The state definition of wetlands requires only a single parameter to be met in order to indicate the presence of wetlands. Hydrophytic vegetation, hydric soils, or wetland hydrology were used to determine the state upland wetland boundary.

Areas of wetland vegetation were identified and mapped using a Trimble GeoExplorer 6000 unit.

Vegetation units were mapped based upon the dominant species.

Areas of hydric vegetation were defined using the dominance test, and by assessing the indicator status of the dominant species. Vegetation defined as obligate or facultative wetland by the USACE National Plant List was mapped as wetland vegetation.

Wetland acreage was determined using the methods described in Section 3.6.1 Acreage Calculation.
2-19-0026
Exhibit 5

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Packet Pg. 3413 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 18

4. RESULTS

4.1 FEDERAL WETLANDS
A total of 0.088 acres of potential federally jurisdictional wetlands occur within the delineation study area. Table 1 provides the calculations for the total acreage for wetland areas within the study area. Jurisdictional areas lie within the vegetated central portions of the drainage channel.

These areas are within the primary flow of the channel, where the soil remains saturated even after water is no longer visible at the surface. Wetland areas are represented by sample points A2 and A4 within the study area. Figure 2 provides an illustration of potentially jurisdictional wetlands within the study area. Appendix B provides representative photographs of the sample points and study area.

TABLE 1: TOTAL ACREAGE OF WETLAND AREAS WITHIN STUDY AREA Wetland Type Federal State
Area (acres) Area (sq ft) Area (acres) Area (sq ft)
Arroyo Willow Wetland
AW-1 0.025 1109.560 0.096 4193.311
Perennial Rye Grass Wetland
PR-1 0.010 437.146 0.001 35.026
Small-fruited Bulrush Marsh
BM-1 0.003 116.769 0.003 120.651
Smartweed Wetland
SW-1 0.012 508.292 0.004 161.820
SW-2 0.019 833.803
SW-3 0.019 844.048 0.022 963.699
subtotal 0.050 2186.143 0.026 1125.519
Ephemeral Channel
FC-1 0.106 4605.914
Wetted Channel
WC-1 0.017 722.949
Total 0.088 3849.618 0.248 10803.370
2-19-0026
Exhibit 5

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Packet Pg. 3414 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) FC-1
A1
A2
A4A3
AW-1
SW-3
SW-2
SW-1
WC-1
PR-1
BM-1
Figure 2: Federal and State Wetlands
Legend
Site Parcel Boundary
Delineation Point
Waters of the State/State Wetland
Wetted Channel
Federal Wetlands
Arroyo Willow Thicket
Perennial Rye Grass Fields
Small-fruited Bulrush Marsh
Smartweed Patch
State Wetlands
Arroyo Willow Thicket
Perennial Rye Grass Fields
Small-fruited Bulrush Marsh
Smartweed Patch
Flow Channel
Service Layer Credits: Source: Esri,
DigitalGlobe, GeoEye, Earthstar Geographics,
CNES/Airbus DS, USDA, USGS, AeroGRID,
IGN, and the GIS User Community
505 San Pedro Avenue, Pacifica, CA
0 20 40 80 120 160
Feet
±
2-19-0026
Exhibit 5

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Packet Pg. 3415 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 20

4.1.1 Vegetation
Freshwater wetlands on the study site are composed of a variety of plant species. Areas with the greatest water availability, at the northern end of the drainage, are dominated by arroyo willow and small-fruited bulrush. Wetlands within the primary flow of the channel are dominated by water smartweed and perennial rye grass, with curly and green dock also present at lower densities. Silver weed cinquefoil (Potentilla anserina) (OBL) can also be found here beneath the smartweed.

4.1.2 Soils
Within the wetland sample points, soils tended to be dark brown and homogenous with a color matrix of 10YR 3/1 at sample points A2 and A4; and 5YR 3/2 at sample point A1; and 5YR 3/3 at sample point A3. Soil texture ranged from sandy loam at sample points A1, A3, and A4 to sandy clay loam at sample point A2. Several unusual soil compositions were noted at the study site within the channel, due to the site being graded in the past, and the site used as an illegal dumping area. Within each of the sample point areas, concrete rubble, brick, plastic and metal refuse were present on the soil surface and/or within the soil. Soils determined to be wetland soils were based on one indicator (redox dark surface), likely due to a lack of ponding in the channel during most times of year. In addition, dark parent materials and the fact that the drainage feature has only been in existence for a few to several decades likely limits the formation of more hydric soil indicators.

4.1.3 Hydrology
Wetland hydrology indicators at sample points A2 and A4 included mud cracks at the surface of the channel bottom (Photo 9 in Appendix B). No other hydrology indicators were present. No ordinary high water mark was visible in the channel, likely due to a lack of flow through the channel at most times of year.

4.2 STATE WETLANDS
A total of 0.248 acres of potential state jurisdictional wetlands occur within the delineation study area. The acreage of state wetlands exceeds that of the federal wetlands since determination state wetlands is based upon only one parameter (hydrophytic vegetation or hydric soils or wetland hydrology) rather than the presence of all three required by the federal wetland definition. Table 1 provides the calculations for the total acreage for state and federal wetland areas within the study area.
2-19-0026
Exhibit 5

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Packet Pg. 3416 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 21 The entire portion of the channel exhibiting hydrology features was mapped and designated as FC-1. This area qualifies as a state wetland due to hydrology and soil indicators, but vegetation is either lacking or composed of upland plant species in many places. Areas where the hydrophytic vegetation is dominant within the channel satisfy the criteria for federal wetlands.

4.3 ENVIRONMENTALLY SENSITIVE HABITAT AREAS (ESHA)
The CCC defines an ESHA as an area in which plant or animal life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and which could be easily disturbed or degraded by human activities.” (California Coastal Act §30107.5).

The CCC Guidelines contain definitions for specific types of ESHAs, including: wetlands, estuaries, streams and rivers, lakes, open coastal waters and coastal waters, riparian habitats, other resource areas, and special-status species and their habitats. For the purposes of this report, ESHAs include any areas that may meet the definition of any ESHA defined by the CCC guidelines or the City of Pacifica LCLUP. A “special-status natural community” is a natural habitat community that is unique in its constituent components, restricted in distribution, supported by distinctive soil conditions, considered locally rare, potentially supporting specialstatus plant or wildlife species, and/or that receives regulatory recognition from municipal, county, state, and/or federal entities such as the California Natural Diversity Database (CNDDB). Within the study area, the arroyo willow stand is consistent with the description of Arroyo willow thickets (61.201.01 – Salix lasiolepis), which is listed by CDFW as sensitive plant community. This species is common in coastal California and does not have a rarity ranking. However, based on this classification and that it is often associated with riparian habitat, the arroyo willow stand, would be considered an ESHA. Discrete portions of the drainage channel where one or more wetland parameters are present would also be considered an ESHA.

RECOMMENDATIONS
The proposed project would not result in direct or indirect, temporary or permanent impacts to wetlands, other waters, or any ESHA’s. The drainage channel feature adjacent to the property at 505 San Pedro Avenue appears to be a man-made constructed feature, that is highly degraded due to construction and ongoing maintenance of a City of Pacifica sewer line that runs underneath the feature. The channel has been used as an illegal dumping area for decades and refuse such as gas cans, mattresses, appliances, plastic garbage, concrete rubble, bricks, and other refuse are present within the channel and buried within the soil. 2-19-0026
Exhibit 5

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Packet Pg. 3417 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 22 The project as proposed would create a retaining wall and public access easement (pedestrian trail) along the western property boundary, and the following setbacks from the wetlands are shown in Table 2.

TABLE 2. STATE AND FEDERAL WETLANDS AND SETBACK DISTANCES FROM PROPOSED PROJECT AT 505 SAN PEDRO AVENUE, PACIFICA, CA
From Retaining Wall/Trail From Structures (approximate) Name Wetland Type
Distance to
closest point(ft)
Distance (ft) max
to near edge
Distance to closest
point (ft)
Distance (ft) max to
near edge
AW-1 Federal Wetland 4.10 13.34 32.9 84.7
AW-1 State Wetlands 0.00 0 29.31 63
BM-1 Federal Wetland 12.47 13.7 26.9 33.67
BM-1 State Wetland 6.16 10.5 23.17 31.5
FC-1 State Wetland 6.35 18.45 19.4 26.3
PR-1 State Wetland 10.86 12.8 23.46 26.19
PR-1 Federal Wetland 12.79 15.7 26.36 28.18
SW-1 State Wetland 2.31 7 15.31 19.95
SW-1 Federal Wetland 5.52 10.4 17.85 25.59
SW-2 Federal Wetland 8.51 21.4 20.61 33.4
SW-3 State Wetlands 0.00 6.13 8.67 18.64
SW-3 Federal Wetland 7.66 12.3 20.9 24.5
WC-1 State Wetland 0.00 5.5 10.06 22
The LCLUP states that “As a general rule, a buffer of at least 100 feet measured from the outward edge of riparian vegetation would be appropriate unless such a width is determined to be unnecessary for protecting the resources of the habitat area”. The California Coastal Commission has required buffers of 100 feet from the edge of riparian vegetation in areas where such buffers are feasible. However, it is not unusual for the Commission to allow smaller buffers in urbanized areas where the existing land use patterns do not allow for increased riparian buffer areas.

Based on the existing condition of the drainage channel, and the setback distances, the proposed project would not present a source of physical, chemical or biological disturbance to the wetland habitats including the arroyo willow stand (AW-1). Additional measures to ensure the channel is not impacted by construction activities would include planting of native plant species suitable for the boundary area adjacent to the channel, and installation of appropriate erosion/ sediment controls such as silt fencing, fiber rolls, and erosion control blankets along the top of the bank.

These measures would be suitable to protect the resource and improve the quality of this resource.
2-19-0026
Exhibit 5

1.k
Packet Pg. 3418 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 23 Any economic use of the subject property would result in a reduction of the recommended 100- foot buffer because of the proximity of any development on the property to wetland habitat. The CCC has permitted more intensive uses that resulted in direct impacts to sensitive coastal resources, consistent with the mandate of Coastal Act § 30010 that prevents taking of private property without compensation (see CCC Appeal Numbers A-2-SMC-11-040 & A-2-SMC-11- 041)2 concerning a controversial project near Half Moon Bay that was ultimately approved). 2 https://documents.coastal.ca.gov/reports/2013/12/W18a-12-2013.pdf 2-19-0026
Exhibit 5

1.k
Packet Pg. 3419 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 24

5. REPORT PREPARATION AND REFERENCES

5.1 REPORT PREPARATION
Coast Ridge Ecology, LLC
1410 31st Ave
San Francisco, CA 94122
(415) 404-6757
Field work and report preparation were completed by Patrick Kobernus (Senior Biologist) and Greg Pfau (Associate Biologist).

5.2 REFERENCES
Commercial Development for Norcal Surf Shop 505 San Pedro Ave., A.P.N. -23-072-010, Pacifica. Project Plans dated: 01/20/2016.

Baldwin, B. G., D. H. Goldman, D. J. Keil, R. Patterson, T. J. Rosatti, and D. H. Wilken, editors. 2012. The Jepson manual: vascular plants of California, second edition. University of California Press, Berkeley.

US Army Corps of Engineers, Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report Y-87-1, U.S. Army Engineer Waterways Experiment Station. Vicksburg, Miss.

US Army Corps of Engineers, Environmental Laboratory. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys and Coast Region (Version 2.0). U.S. Army Engineer Research and Development Center, Vicksburg, MS.

ERDC/EL TR-10-03. May 2010.

CNPS. 2019. A Manual of California Vegetation, Online
Edition. http://www.cnps.org/cnps/vegetation/; searched on October 21, 2019. California Native Plant Society, Sacramento, CA.
2-19-0026
Exhibit 5

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Packet Pg. 3420 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation – November 2019 Page 25 Lichvar, R.W, D. L. Banks, W. N. Kirchner and N. C. Melvin. 2016. The National Wetland Plant List: 2016 wetland ratings. Phytoneuron 2016-30: 1-17. Available online at http://rsgisias.crrel.usace.army.mil/NWPL/# . Accessed on September 17, 2019.

Munsell Soil Color Charts Year 2000 Revised Washable Edition. 2000. Munsell Color. Grand Rapids, MI.

Sawyer, John; Keeler-Wolf, T.; and Evans, J., 2009. A Manual of California Vegetation, second edition. California Native Plant Society, Sacramento.

Natural Resources Conservation Service, United States Department of Agriculture. Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/. Accessed October 21, 2019.

United States Department of Agriculture. Soil Conservation Science (USDA SCS). 1991. Soil Survey of San Mateo County, Eastern Part, and San Francisco County, California. Available online at http://soildatamart.nrcs.usda.gov . October 21, 2019.

UCSB, 2019. University California Santa Barbara, California Aerial Photography by County (On-Line Library). Accessed October 25, 2019.
https://www.library.ucsb.edu/src/airphotos/california-aerial-photography-county Wood Biological Consulting. 2019. One-Parameter Wetland Delineation for the Proposed Norcal Surf Shop Mixed-use Development, San Mateo County, California. 2-19-0026
Exhibit 5

1.k
Packet Pg. 3421 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation Page A-1

APPENDIX A
Wetland determination data forms
2-19-0026
Exhibit 5

1.k
Packet Pg. 3422 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region Project/Site: NorCal Surf Shop City/County: Pacifica, SMC Sampling Date: 10/21/2019 Applicant/Owner: Shawn Rhodes State: CA Sampling Point: A1 Investigator(s): Patrick Kobernus Section, Township, Range:

Landform (hillslope, terrace, etc.): Channel bank Local relief (concave, convex, none): Convex Slope (%): 50 Subregion (LRR): California Lat: 37.595406 Long: -122.506549 Datum: NAD83 Soil Map Unit Name: Urban NWI classification: None
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes x No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No x
Hydric Soil Present? Yes No x Is the Sampled Area within a Wetland? Yes No x Wetland Hydrology Present? Yes No x
Remarks:

Delineation is being done at request of CA Coastal Commission and potential wetland area is adjacent to, but not on, applicant’s property.

VEGETATION – Use scientific names of plants.

Tree Stratum (Plot size: )
Absolute
% Cover
Dominant
Species?
Indicator
Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: 2m r )

1. Ligustrum ovilifolium 20 Y -NS2.

3. 4.

5. 20 = Total Cover
Herb Stratum (Plot size: 2m r )

1. Delairea odorata 15 N -NS2. Persicaria amphibia 10 N OBL

3. Urtica dioica 5 N FAC

4. 5.

6. 7.

8. 9.

10. 11.
30 = Total Cover
Woody Vine Stratum (Plot size: 2m r )

1. Rubus ursinus 50 Y FACU

2. 50 = Total Cover
% Bare Ground in Herb Stratum
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: 0 (A)
Total Number of Dominant
Species Across All Strata: 2 (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: 0 (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:
1 - Rapid Test for Hydrophytic Vegetation
2 - Dominance Test is >50%
3 - Prevalence Index is ≤3.01
4 - Morphological Adaptations1 (Provide supporting
data in Remarks or on a separate sheet)
5 - Wetland Non-Vascular Plants1
Problematic Hydrophytic Vegetation1 (Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present? Yes No x
Remarks:
2-19-0026
Exhibit 5

1.k
Packet Pg. 3423 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: A1
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth
(inches)
Matrix Redox Features
Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 5YR 3/2 100 Sandy loam
1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)
Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3)
Thick Dark Surface (A12) Redox Dark Surface (F6) 3
Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic
Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)
Sandy Gleyed Matrix (S4) Redox Depressions (F8)
Restrictive Layer (if present):

Type: Hydric Soil Present? Yes No x
Depth (inches):

Remarks:

Uniform color to soil, combined with urban fill (concrete, brick, and other refuse)

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1)
Water-Stained Leaves (B9) (except
MLRA 1, 2, 4A, and 4B)
Water-Stained Leaves (B9) (MLRA 1, 2,
4A, and 4B)
High Water Table (A2) Salt Crust (B11) Drainage Patterns (B10) Saturation (A3) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Water Marks (B1) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Sediment Deposits (B2)
Oxidized Rhizospheres along Living
Roots (C3) Geomorphic Position (D2)
Drift Deposits (B3) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Algal Mat or Crust (B4)
Recent Iron Reduction in Tilled
Soils (C6) FAC-Neutral Test (D5)
Iron Deposits (B5)
Stunted or Stressed Plants (D1)
(LRR A) Raised Ant Mounds (D6) (LRR A)
Surface Soil Cracks (B6) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Inundation Visible on Aerial Imagery (B7)
Sparsely Vegetated Concave Surface (B8)
Field Observations:

Surface Water Present? Yes No x Depth (inches):

Water Table Present? Yes No x Depth (inches): Wetland Hydrology Present? Yes No x Saturation Present?
(includes capillary fringe) Yes No x Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

No hydrologic indicators present.
2-19-0026
Exhibit 5

1.k
Packet Pg. 3424 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region Project/Site: NorCal Surf Shop City/County: Pacifica, SMC Sampling Date: 10/21/2019 Applicant/Owner: Shawn Rhodes State: CA Sampling Point: A2 Investigator(s): Patrick Kobernus Section, Township, Range:

Landform (hillslope, terrace, etc.): Channel bed Local relief (concave, convex, none): Concave Slope (%): 0 Subregion (LRR): California Lat: 37.595406 Long: -122.506549 Datum: NAD83 Soil Map Unit Name: Urban NWI classification: None
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes x No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes x No
Hydric Soil Present? Yes x No Is the Sampled Area within a Wetland? Yes x No Wetland Hydrology Present? Yes x No
Remarks:

Delineation is being done at request of CA Coastal Commission and potential wetland area is adjacent to, but not on, applicant’s property.

VEGETATION – Use scientific names of plants.

Tree Stratum (Plot size: )
Absolute
% Cover
Dominant
Species?
Indicator
Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. 20 = Total Cover
Herb Stratum (Plot size: 2m r )

1. Persicaria amphibia 35 Y OBL

2. Rubus crispus 55 Y FAC

3. Scirpus microcarpus 5 N OBL

4. Potentilla anserina 5 N OBL

5. 6.

7. 8.

9. 10.

11. 100 = Total Cover
Woody Vine Stratum (Plot size: )

1. 2.
= Total Cover
% Bare Ground in Herb Stratum
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: 2 (A)
Total Number of Dominant
Species Across All Strata: 2 (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: 100 (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:
1 - Rapid Test for Hydrophytic Vegetation
x 2 - Dominance Test is >50%
3 - Prevalence Index is ≤3.01
4 - Morphological Adaptations1 (Provide supporting
data in Remarks or on a separate sheet)
5 - Wetland Non-Vascular Plants1
Problematic Hydrophytic Vegetation1 (Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present? Yes x No
Remarks:
2-19-0026
Exhibit 5

1.k
Packet Pg. 3425 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: A2
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth
(inches)
Matrix Redox Features
Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 10YR 3/1 100
Sandy clay
loam
1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)
Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3)
Thick Dark Surface (A12) x Redox Dark Surface (F6) 3
Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic
Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)
Sandy Gleyed Matrix (S4) Redox Depressions (F8)
Restrictive Layer (if present):

Type: Hydric Soil Present? Yes x No
Depth (inches):

Remarks:

Uniform color to soil, combined with urban fill (concrete, brick, and other refuse)

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1)
Water-Stained Leaves (B9) (except
MLRA 1, 2, 4A, and 4B)
Water-Stained Leaves (B9) (MLRA 1, 2,
4A, and 4B)
High Water Table (A2) Salt Crust (B11) Drainage Patterns (B10) Saturation (A3) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Water Marks (B1) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Sediment Deposits (B2)
Oxidized Rhizospheres along Living
Roots (C3) Geomorphic Position (D2)
Drift Deposits (B3) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Algal Mat or Crust (B4)
Recent Iron Reduction in Tilled
Soils (C6) FAC-Neutral Test (D5)
Iron Deposits (B5)
Stunted or Stressed Plants (D1)
(LRR A) Raised Ant Mounds (D6) (LRR A)
x Surface Soil Cracks (B6) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Inundation Visible on Aerial Imagery (B7)
Sparsely Vegetated Concave Surface (B8)
Field Observations:

Surface Water Present? Yes x No Depth (inches):

Water Table Present? Yes x No Depth (inches): Wetland Hydrology Present? Yes x No Saturation Present?
(includes capillary fringe) Yes x No Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:
2-19-0026
Exhibit 5

1.k
Packet Pg. 3426 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region Project/Site: NorCal Surf Shop City/County: Pacifica, SMC Sampling Date: 10/21/2019 Applicant/Owner: Shawn Rhodes State: CA Sampling Point: A3 Investigator(s): Patrick Kobernus Section, Township, Range:

Landform (hillslope, terrace, etc.): Channel bank Local relief (concave, convex, none): Convex Slope (%): 100 Subregion (LRR): California Lat: 37.594600 Long: -122.507276 Datum: NAD83 Soil Map Unit Name: Urban NWI classification: None
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes x No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No x
Hydric Soil Present? Yes No x Is the Sampled Area within a Wetland? Yes No x Wetland Hydrology Present? Yes No x
Remarks:

Delineation is being done at request of CA Coastal Commission and potential wetland area is adjacent to, but not on, applicant’s property.

VEGETATION – Use scientific names of plants.

Tree Stratum (Plot size:
10 m r )
Absolute
% Cover
Dominant
Species?
Indicator
Status

1. Eucalyptus globulus 60 Y -NS2.

3. 4.
60 = Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. = Total Cover
Herb Stratum (Plot size: 2m r )

1. Tropaeolum majus 65 Y UPL

2. Conium maculatum 5 N FAC

3. Zantedeschia aethiopica 5 N -NS4. Solanum nigrum 15 N FACU

5. 6.

7. 8.

9. 10.

11. 90 = Total Cover
Woody Vine Stratum (Plot size: 2m r )

1. Rubus ursinus 10 N FACU

2. 10 = Total Cover
% Bare Ground in Herb Stratum
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: 0 (A)
Total Number of Dominant
Species Across All Strata: 2 (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: 0 (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:
1 - Rapid Test for Hydrophytic Vegetation
2 - Dominance Test is >50%
3 - Prevalence Index is ≤3.01
4 - Morphological Adaptations1 (Provide supporting
data in Remarks or on a separate sheet)
5 - Wetland Non-Vascular Plants1
Problematic Hydrophytic Vegetation1 (Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present? Yes No x
Remarks:
2-19-0026
Exhibit 5

1.k
Packet Pg. 3427 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: A3
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth
(inches)
Matrix Redox Features
Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 5YR 3/3 100 Sandy loam
1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)
Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3)
Thick Dark Surface (A12) Redox Dark Surface (F6) 3
Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic
Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)
Sandy Gleyed Matrix (S4) Redox Depressions (F8)
Restrictive Layer (if present):

Type: Hydric Soil Present? Yes No x
Depth (inches):

Remarks:

Uniform color to soil, combined with urban fill (concrete, brick, and other refuse)

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1)
Water-Stained Leaves (B9) (except
MLRA 1, 2, 4A, and 4B)
Water-Stained Leaves (B9) (MLRA 1, 2,
4A, and 4B)
High Water Table (A2) Salt Crust (B11) Drainage Patterns (B10) Saturation (A3) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Water Marks (B1) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Sediment Deposits (B2)
Oxidized Rhizospheres along Living
Roots (C3) Geomorphic Position (D2)
Drift Deposits (B3) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Algal Mat or Crust (B4)
Recent Iron Reduction in Tilled
Soils (C6) FAC-Neutral Test (D5)
Iron Deposits (B5)
Stunted or Stressed Plants (D1)
(LRR A) Raised Ant Mounds (D6) (LRR A)
Surface Soil Cracks (B6) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Inundation Visible on Aerial Imagery (B7)
Sparsely Vegetated Concave Surface (B8)
Field Observations:

Surface Water Present? Yes No X Depth (inches):

Water Table Present? Yes No X Depth (inches): Wetland Hydrology Present? Yes No x Saturation Present?
(includes capillary fringe) Yes No x Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

No wetland hydrology indicators present
2-19-0026
Exhibit 5

1.k
Packet Pg. 3428 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region Project/Site: NorCal Surf Shop City/County: Pacifica, SMC Sampling Date: 10/21/2019 Applicant/Owner: Shawn Rhodes State: CA Sampling Point: A4 Investigator(s): Patrick Kobernus Section, Township, Range:

Landform (hillslope, terrace, etc.): Channel bed Local relief (concave, convex, none): Concave Slope (%): 0 Subregion (LRR): California Lat: 37.594600 Long: -122.507276 Datum: NAD83 Soil Map Unit Name: Urban NWI classification: None
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes x No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes X No
Hydric Soil Present? Yes X No Is the Sampled Area within a Wetland? Yes x No Wetland Hydrology Present? Yes x No
Remarks:

Delineation is being done at request of CA Coastal Commission and potential wetland area is adjacent to, but not on, applicant’s property.

VEGETATION – Use scientific names of plants.

Tree Stratum (Plot size: )
Absolute
% Cover
Dominant
Species?
Indicator
Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. = Total Cover
Herb Stratum (Plot size: 2m r )

1. Persicaria amphibia 40 Y OBL

2. Plantago major 5 N FAC

3. Sonchus asper 5 N FACU

4. Raphanus sativus 5 N -NS5.

6. 7.

8. 9.

10. 11.
55 = Total Cover
Woody Vine Stratum (Plot size: )

1. 2.
= Total Cover
% Bare Ground in Herb Stratum
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: 1 (A)
Total Number of Dominant
Species Across All Strata: 1 (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: 100 (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:
1 - Rapid Test for Hydrophytic Vegetation
x 2 - Dominance Test is >50%
3 - Prevalence Index is ≤3.01
4 - Morphological Adaptations1 (Provide supporting
data in Remarks or on a separate sheet)
5 - Wetland Non-Vascular Plants1
Problematic Hydrophytic Vegetation1 (Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present? Yes x No
Remarks:
2-19-0026
Exhibit 5

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Packet Pg. 3429 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: A4
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth
(inches)
Matrix Redox Features
Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 10YR 3/1 100 Sandy loam
1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)
Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3)
Thick Dark Surface (A12) x Redox Dark Surface (F6) 3
Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic
Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)
Sandy Gleyed Matrix (S4) Redox Depressions (F8)
Restrictive Layer (if present):

Type: Hydric Soil Present? Yes x No
Depth (inches):

Remarks:

Uniform color to soil, combined with urban fill (concrete, brick, and other refuse)

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1)
Water-Stained Leaves (B9) (except
MLRA 1, 2, 4A, and 4B)
Water-Stained Leaves (B9) (MLRA 1, 2,
4A, and 4B)
High Water Table (A2) Salt Crust (B11) Drainage Patterns (B10) Saturation (A3) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Water Marks (B1) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Sediment Deposits (B2)
Oxidized Rhizospheres along Living
Roots (C3) Geomorphic Position (D2)
Drift Deposits (B3) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Algal Mat or Crust (B4)
Recent Iron Reduction in Tilled
Soils (C6) FAC-Neutral Test (D5)
Iron Deposits (B5)
Stunted or Stressed Plants (D1)
(LRR A) Raised Ant Mounds (D6) (LRR A)
x Surface Soil Cracks (B6) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Inundation Visible on Aerial Imagery (B7)
Sparsely Vegetated Concave Surface (B8)
Field Observations:

Surface Water Present? Yes No X Depth (inches):

Water Table Present? Yes No X Depth (inches): Wetland Hydrology Present? Yes x No Saturation Present?
(includes capillary fringe) Yes No x Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

Electrical cable under channel, bricks, concrete rubble in soil. 2-19-0026
Exhibit 5

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Packet Pg. 3430 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation Page B-1

APPENDIX B
Representative Photographs
Figure 1. Drainage channel, with Eucalyptus trees. Photo date: 09/18/2019.

Figure 2. Drainage channel with brambles, north end. Photo date: 09/18/2019. 2-19-0026 Exhibit 5

1.k
Packet Pg. 3431 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation Page B-2
Figure 3. Drainage channel and bank with Eucalyptus, Rumex, Kikuyu grass and Tropaeolum plants. Photo date: 09/18/2019.

Figure 4. Drainage channel with blackberry and grass vegetation. Photo date: 09/18/2019. 2-19-0026
Exhibit 5

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Packet Pg. 3432 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation Page B-3
Figure 5. Top of berm, (505 San Pedro Ave. property) looking north. Photo date: 09/18/2019.

Figure 6. Top of berm, (505 San Pedro Ave. property) looking south. Photo date: 09/18/2019. 2-19-0026
Exhibit 5

1.k
Packet Pg. 3433 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation Page B-4
Figure 7. Wetted channel on south end. Photo date: 09/18/2019.

Figure 8. Drainage channel (data point A4 and sewer line manhole). Photo date: 10/21/2019. 2-19-0026 Exhibit 5

1.k
Packet Pg. 3434 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) NorCal Surf Shop Project Wetland Delineation Page B-5
Figure 9. Channel bottom near data point A2 showing mud cracks. Photo date: 10/21/2019.

Figure 10. Channel bottom. Data point A2. Photo date: 10/21/2109. 2-19-0026
Exhibit 5

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Packet Pg. 3435 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) f
Page I of 1
Horrisberger, Christina
From: Renee Anahda [rana/[email protected]]
Sent: Wednesday, May 19, 2010 1:14 PM
To: Horrisberger, Christina·
Cc: [email protected]; [email protected]; Donguines, Raymond Subject FW: APN 023--072-010 Study Session
Christlna,
It appears you didn't receive my comments (originally sent on May 13th). Please see the forwarded message below. Sorry for any inconveniences. Thank you.

From: Renee Ananda
Sent: Thursday, May 13, 2010 2:49 PM
To: '[email protected]'
Cc: Renee Ananda
Subject: APN 023-072-010 Study Session
Hello Christina,
This is a follow-up to our conversation (on Monday 5110) re, the applicant's (Shawn Rhodes') preliminary proposal to construct a·z-story commercial-residential unit, a surf shop, and storage shop (a total of 3 structures) and a skate board park on a vacant tot west of San Pedro Point Shoppfng Center. The plans we received are preliminary and serve for early discussions of what would be required for the potential development project.

Please note my preliminary comments below:

The site is located within the Coastal Zone. ft appears that a majority of the site is in an area under the retained jurisdiction the Coastal Commission. The applicant w1fl need to obtain a Coastal Development Permit from the Coastal Commissic>n.

The Commission is concernecvabout the development's consistency with the Coastal Act (particularly Chapter 3, Article 6., Developmen!),JhJ_fefore potential imi:,,mt~.lo b. lological resourcesJcoaslaf views, public access to_the coast (1.e., public beaches), and its visuaf·compat1b11ity With the character ot"the surrounding area. /l"he applicant should include an analysis of traffic that would be generated by the development and assocfated impacts to vehicular public access to the coastJ
The design of the proposed project should consider measures to avoid or reduce potential impacts to the adjacent wetlands and drainage area, as these most likely nneet the definition of a wetlands under the Coastal Act. The applioant should provide an evaluation. of the proposed/potential development's impact on biological resources localed on and adjacent to the site.

These comments do not preclude additional comments Commission staff may have on the proposal, as planning and permitting processes progress.

Thank you for the opportunity to provide you with comments. RTA , ,5/19/2010
2-19-0026
Exhibit 6

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Packet Pg. 3436 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) 2-19-0026
Exhibit 6

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Packet Pg. 3437 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

STATE OF CALIFORNIA-NATURAL RESOURCES AGENCY

CALIFORNIA COASTAL COMMISSION NORTH CENTRAL COAST DISTRICT OFFICE 45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW.COASTAL.CA.GOV
Kathryn F arb stein
Assistant Planner
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA
94044
EDMUND G. BROWN JR., GOVERNOR
May 8, 2015
Subject: Commission Staff Comments on Development Review Coordination for Proposed Project at 505 San Pedro Avenue, Pacifica, CA
Dear Ms. Farbstein:

Thank you for the opportunity to comment on the Development Review Coordination materials for the proposed development of a 2 story retail building plus basement, covered skate park, 2 story storage building, parking lol am12 story mixed use building with 2 residential units at 505 San Pedro Avenue, Pacifica, CA. The proposed development will cover approximately 13,000 square feet on the 37,000 square feet lot with the surf shop totaling 3,500 square feet, the storage building totaling 1,540 square feet and the retail/residential building totaling 2,516 square feet.

The development also proposes a total of26 parking spaces-24 uncovered spots and 2 covered spots.

Coastal Commission Staff has previously sent comments on this development proposal (see attached May 13,2010 email from Renee Ananda and my email from October 30, 2014) citing concerns regarding the proposed development's potential impacts to biological resources, public views, access to the coast, compatibility with surrounding development, and to traffic.

Specifically, our concerns consist of the proposed project's potential impacts to the sensitive biological resources present and associated with the intermittent stream that bmmds the western edge of the subject parcel, potential flooding and geotechnical issues, hardscape protection concerns regardingform of the proposed installation of rip rap on the banks of the intermittent stream, the appropriateness of residential use on this parcel and finally, future parking and access conflicts with the adjacent shopping center use. In addition, Commission Staff raised jurisdictional issues in our previous comments because it appears the subject parcel is located within a split jurisdiction between the City and Coastal Commission coastal permit jurisdiction, either requiring the applicant to apply for two separate coastal development permits or a consolidated permit handled by the Commission (with permission from the applicant and the City).

With regard to biological resources, the 2005 biological report prepared for the subject property found that given the parcel's close proximity to San Pedro Creek, California red-legged frogs 1 2-19-0026
Exhibit 6

1.k
Packet Pg. 3438 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) (CRLF) are likely to be "present and breeding within the immediate area of the surrmmding property," along the high quality habitat of the creek. The subject site is constrained by the presence of the drainage, on the western edge of the parcel that the 2005 biological report by Thomas Reid Associates determined was likely to provide a dispersal corridor for CRLF, especially given the drainage's proximity to San Pedro Creek. This drainage was deemed an "intermittent stream" in the biological report. Because of the presence of this drainage, it is also likely that the adjacent upland habitats may provide refugia for CRLF and upland areas to aestivate. Because of the parcel's constrained shape, it is unlikely the development could be adequately buffered from the drainage in order to avoid sensitive habitat impacts. LCP Policies protect intermittent streams, requiring that such streams shall be "protected, enhanced and restored where feasible"; also requiring that adequate buffer zones be identified to protect habitat areas associated with the stream. LCP Policy C-99 requires that in general, a buffer of at least I 00 feet measured from the outward edge of the vegetation would be appropriate, unless such a buffer is deemed uunecessary. Because the proposed development will immediately abut the drainage edge, and the upland habitats are proposed to be removed for future development or paved over, this proposed project does not confonn to the LCP policies protecting sensitive habitats.

With regard to geotechnical issues, plans dated October 7, 2014 proposed rip rap be installed along the ban1c of the drainage per the recommendation of the geotechnical engineer. The current plans appear to remove this aspect of the development but still propose to install a concrete curb wall with wood railing at the drainage edge. LCP Policies found on page C-1 05 state that since erosion is a problem in Pacifica, a report by the United States Army Corps of Engineers found that in many cases shoreline [protection] structures are not economically justified and would be allowable to protect on1y "major beach access or highly sensitive habitat." Further, if such protections are allowed as part of any development LCP Policy C-1 05 requires that a qualified expert should analyze and propose mitigation for such structures. Further, LCP Policy C-1 01 requires that development in habitat support areas, such as on the banks of this stream, carmot disrupt habitat and must minimize erosion. Given these limitations and the development's proximity to the drainage which provides flood storage capacity for the surrounding areas, it is unclear how the proposed development will be protected from flooding and erosion. Commission Staff has seen no analysis of flooding impacts to the proposed development including without the use of streambank alteration, but such an analysis would be required given the development's proximity to the drainage at the western edge of the parcel and its association with San Pedro Creek.

Finally, with regard to the development's, size, scope, intensity and type of use, Conunission Staff has concerns that locating new residential and other mixed-use/retail development so close to the already existing shopping center may have traffic impacts on the already-impacted Highway I in this area, and subsequent impacts to public access to the coast. No traffic analysis has been shared with Coastal Commission staff. In addition, the parcel is zoned C-2 "Conununity Conunercial District," which conditionally allows residential uses only when they are located entirely above the ground floor. Residential development in C-2 zones is further controlled by a minimum lot area per dwelling unit of 2,000 square feet. Further, development in the C-2 zones located in the Coastal Zone that propose a new use other than visitor-serving commercial use, require a Use Permit determination that demands "an analysis of the balance of visitor-serving commercial uses with other commercial uses, and consistency with the individual neighborhood narratives and the plan conclusions and other relevant policies of the ... Land Use 2 2-19-0026
Exhibit 6

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Packet Pg. 3439 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Plan" (per Implementation Plan Sec. 9-4.1 002). The proposed development, if allowable at all given the biological and potential flood resource concerns, would need to be designed to fit the individual narrative of the neighborhood and other requiremeots of the LUP that are specific to the Pedro Point neighborhood.

If you have any questions regarding these comments or wish to discuss the project further, please contact me at 415-597-5894.

Sincerely,
Stephanie Rexing, Coastal Planner
Encl. May 13,2010 Email
October 30,2014 Email
3 2-19-0026
Exhibit 6

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Packet Pg. 3440 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Response to Comments
505 San Pedro Avenue Project
June 2018
6 Letter 2
2-2
2-1
2-5
2-3
2-7
2-6
2-8
2-4
2-19-0026
Exhibit 6

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Packet Pg. 3441 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Response to Comments
505 San Pedro Avenue Project
June 2018
7 2-8
Cont’d
Letter 2
Cont’d
2-9
2-19-0026
Exhibit 6

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Packet Pg. 3442 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

ANNAPOLIS FIELD STATION
Coastal Plant Observatory
Plant Ecology Serving Conservation
33660 Annapolis Road
Annapolis, California 95412
(415) 310-5109 [email protected]
1 MEMORANDUM
To: Jim Browning, U.S. Fish and Wildlife Service, SFWO, Sacramento From: Peter Baye, Ph.D., coastal plant ecologist
Date: 4 May 2005
SUBJECT: Documentation of California red-legged frog occurrence at Pedro Point, Pacifica, San Mateo County
Jim, I am reporting to USFWS directly the attached documentation of a California redlegged frog population at Pedro Point. The site is a drainage ditch in an historic floodplain of Pedro Creek, recently proposed for residential development. The site is somewhat isolated from Pedro Creek by Highway 1, a road, buildings, and parking lots, but has drainage connections to the mouth of the creek.

LOCATION: Pedro Point Road opposite Grand Avenue, Pedro Point, Pacifica, San Mateo County. Southeast corner of Calson/”Archdiocese” Pedro Point Field.

SETTING: Drainage ditch through blue gum windbreak between commercial shopping plaza and mown grassy field with seasonal wetlands, approximately 0.25 mi from Pedro Creek. See photo attached.

HABITAT CONDITIONS: Road drainage ditch and culvert fed by seasonal to perennial seeps in hillslopes of developed residential area and historic blue gum/Monterey pine plantation. Blue gum-shaded pool less than 3 m diameter, up to 25 cm deep currently, minimal vegetation; mostly flood-deposited sand and silt; abundant non-native wetland vegetation downstream, but no perennial ponds or cattail/tule marsh.

OBSERVED OCCURRENCE: 3 Adult CRLF observed; one within culvert, one at pool edge of concrete culvert support, one submerged at depth of 10 cm. No tree frogs present in pool, but present in downstream portions of ditch system. Photos attached of two CRLF, one highly visible, one obscure (submerged silhouette). Visual observation and photos 5/3/05. Multiple aural detections of diving frogs April; no visual detections in turbid water.

No egg masses observed within visible upper 10 cm of water column.

NEARBY OCCURRENCES: Other confirmed CRLF observations in last 2 years at mouth of Calera Creek (Quarry), with San Francisco garter snake, approx 1.5 mile north. Likely 2-19-0026
Exhibit 7

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Packet Pg. 3443 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

ANNAPOLIS FIELD STATION
Coastal Plant Observatory
Plant Ecology Serving Conservation
33660 Annapolis Road
Annapolis, California 95412
(415) 310-5109 [email protected]
2 occurrence in Pedro Creek floodplain wetlands, perennial freshwater marsh. Garter snakes (likely San Francisco ssp.) also present in residential area gardens, yards.

POTENTIAL THREATS: Residential development proposed for adjacent field; likely to require improved drainage. Drainage problems of adjacent Pedro Road may require repair work; some recently implemented.
(a) (b)
Figure 1: (a) Culvert and scour pool with lobe of flood sediment. (b) Detail of pool and sack-concrete dam. Adult CRLF head emergent at edge of sack-concrete, next to woody debris (sticks) at extreme left. 5/3/05.
2-19-0026
Exhibit 7

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Packet Pg. 3444 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

ANNAPOLIS FIELD STATION
Coastal Plant Observatory
Plant Ecology Serving Conservation
33660 Annapolis Road
Annapolis, California 95412
(415) 310-5109 [email protected]
3 Figure 2. Adult California red-legged frog at edge of sack-concrete dam of culvert. 5/3/05 2-19-0026
Exhibit 7

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Packet Pg. 3445 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

ANNAPOLIS FIELD STATION
Coastal Plant Observatory
Plant Ecology Serving Conservation
33660 Annapolis Road
Annapolis, California 95412
(415) 310-5109 [email protected]
4 Figure 3. Submerged silhouette of second CRLF in pool. 2-19-0026
Exhibit 7

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Packet Pg. 3446 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412
(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 1 Lee Diaz July 7, 2014
Associate Planner
City of Pacifica
Planning Department
1800 Francisco Boulevard
Pacifica, CA 94044
[email protected]
SUBJECT: Draft Environmental Impact Report for The Pacifica General Plan Update Project – SCH No. No. #2012022046
Dear Mr. Diaz,
The comments below regarding the Draft Environmental Impact Report for the Pacifica General Plan Update Project (DEIR) are submitted on behalf of the Pedro Point Community Association, but represent my independent, best professional judgment.

I have reviewed the DEIR sections relevant to assessment of biological resources, land use policies, and selected relevant portions covering hydrology and geology for CEQA compliance and for LCP amendment compliance with the Coastal Act. I have also conducted site visits of the Pedro Point field (also “undeveloped San Pedro Ave site” and described as “vacant” in the DEIR, General Plan and Local Coastal Plan documents) in all seasons since 2000.

My qualifications to provide expert comments are based on nearly 35 years of professional work in coastal wetland and terrestrial ecology, with over 20 years in San Francisco Estuary wetlands, including long-term direct knowledge of the estuarine wetlands, special-status species, and diked baylands in the project area. A statement of my qualifications is attached hereto as Attachment A.

My comments focus on the potentially adverse environmental impacts of proposed changes in the land use designation of the Pedro Point neighborhood. 2-19-0026
Exhibit 8

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Packet Pg. 3447 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 2 Summary of Comments

1. Environmental Baseline: The DEIR provides contradictory information about the vegetation of the Pedro Point field, asserting that it supports “northern coastal scrub”, an upland vegetation type absent in the grassy field, and that it supports wetlands. The field supports seasonal wetlands. The DEIR fails to disclose the importance of these wetlands in terms of the environmental setting of San Pedro Creek mouth wetlands in the Coastal Zone (the field is the last remaining historical floodplain of the lower San Pedro Creek Valley that has not been developed in the Coastal Zone) and the local distribution of ESHA (Environmentally Sensitive Habitat Areas) supporting California red-legged frogs.

2. Biological Impacts to Wetlands and Special-status Species: The DEIR fails to analyze any biological impacts caused by conversion of the existing Pedro Point field to a land use designation of “Coastal Residential Mixed Use development”. The DEIR fails to programmatically assess impacts at a neighborhood-specific level as it did in the 1980 General Plan, and it fails to consider general impacts of residential development on extensive seasonal wetlands and ESHA in and around the field. The proposed land use change for the field is likely to cause significant impacts to wetlands, wildlife, and special-status species for which no feasible mitigation has been identified, and for which no feasible mitigation probably exists.

3. Land Use Impacts. The DEIR fails to analyze land use impacts caused by changing the land use of the field from a general “Commercial” use (1980 General Plan) to a more specific and different “Coastal Residential Mixed Use” designation. This change for the field’s designated land use causes significant impacts (conflicts with) to the City’s own land use policies and numerous Coastal Commission land use policies that cannot be mitigated, and are not mitigated by the vague, programmatic mitigation measures cited in the DEIR.

4. Conclusion. The DEIR fails to disclose important biological resources, and their distribution and relationship to other biological resources and communities in the environmental setting of lower San Pedro Creek. This precludes meaningful public comment and DEIR analysis of significant impacts to biological resources and land use policies that are likely to occur. The DEIR should be recirculated to correct the flawed environmental baseline and defective impact analysis, and should identify reasonable alternatives that either lessen significant impacts, or are otherwise environmentally preferable.

1. Environmental Baseline
The DEIR presents inconsistent and erroneous biological baseline description of the existing conditions of the Pedro Point field and its vicinity. The errors, omissions, and contradictory environmental baseline description results in erroneous conclusions that the project (General Plan) will have no significant biological impacts. Neighborhood-specific assessments of proposed General Plan land use changes are lacking for Pedro Point, its field, and for the DEIR in general. 2-19-0026
Exhibit 8

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Packet Pg. 3448 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 3 Assessment of biological and land use impacts to the Pedro Point neighborhood requires reference to existing physical and biological environmental conditions (2014; approximately the time of the EIR’s notice of preparation), and the existing land use designations from the 1980 General Plan. The existing biological conditions of the Pedro Point field – the last undeveloped lowland open space within the historical floodplain of San Pedro Creek – is inaccurately and inconsistently represented in the DEIR’s figures and text. These errors result in underestimation of significant biological impacts, as discussed below.

1.1 Mapped DEIR Wetlands, Vegetation and Habitats – physical and biological baseline The DEIR provides contradictory and confused (and confusing) information about the existing biological conditions of the Pedro Point field. Figure 3.7-1 (Vegetation; DEIR p. 3.7-3) maps most of the field in the color-code (pale olive green) corresponding with “Northern Coastal Scrub” (an upland vegetation type associated with coastal hillslopes and bluffs), and part of the field color-coded gray as “urban” land use but overlapping with the “wetlands” symbol. This is contradictory and erroneous environmental baseline information. There are in fact no stands of northern coastal scrub vegetation at all within or around the Pedro Point field. The shrubs on the railroad berm are ornamental non-native plantings. No part of the field is “urban” cover type, as misrepresented in the figure; no paved or developed areas with structures exist in the field. Figure 3.1-1 shows the “Existing land use” color-coded gray as “Vacant/Undeveloped”, which is also inconsistent with “urban” land use, but consistent with “wetlands”. The map also misrepresents mixed ornamental, non-native, and native coastal bluff scrub vegetation northwest of the field as “beach/intertidal” habitat. The two major color-coded map units for the Pedro Point field, “urban” and “northern coastal scrub” are incorrect.
2-19-0026
Exhibit 8

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Packet Pg. 3449 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 4 Excerpted section of Figure 3.7-1 of the DEIR “Vegetation” map (above) showing Pedro Point field with paper streets between Dannman and San Pedro Ave. The setting within the Draft Local Coastal Plan (2014) as represented as “Undeveloped San Pedro Ave Site”, is shown in a portion of Figure 4.8 (left).

Only one map symbol (pattern) for the vacant/undeveloped Pedro Point field in Figure 3.7-1 is accurate: “wetlands” classified by the U.S. Fish and Wildlife Service National Wetlands Inventory at coarse scale, as shown also in DEIR figure 3.7-2. The Pedro Point field itself is dominated by non-native grasses and herbaceous broadleaf plants, including seasonal wetland and non-wetland vegetation. Both maps omit the distinct seasonal and perennial wetlands of the drainage swale at the east end of the field, which drain to San Pedro Creek through a series of culverts. The drainage swale wetlands, the wetland connectivity to San Pedro Creek mouth, and the extensive perennial wetlands (Freshwater Marsh) of San Pedro Creek are entirely missing from the vegetation map of Figure 3.7-1.

Other errors describing habitat and vegetation are evident in the DEIR’s descriptions of existing conditions in the coastal zone. For example, the DEIR confuses coastal strand (beaches and dunes) with coastal bluff scrub, and states that the plant sea-rocket (Cakile maritima) is a dominant species of “coastal bluff scrub”. Sea-rocket is a non-native species common on sand beaches and low foredunes (like those 2-19-0026
Exhibit 8

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Packet Pg. 3450 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 5 of Pacifica State Beach), but does not occur at all in coastal bluff scrub in Pacifica or elsewhere, let alone as a dominant species. The description of coastal bluff scrub combines species that simply do not occur together in natural or disturbed environments of Pacifica.

1.2. Wetland classification of the Pedro Point field and vicinity: existing conditions Based on my recent and past site visits, I know that the existing vegetation of the Pedro Point field consists of predominantly annual and perennial, herbaceous, non-native seasonal wetland and upland grassland vegetation. Seasonal wetland grassland occupies a mosaic of depressions, ditches, and swales.

Mesic grassland (seasonally wet but lacking a prevalence of wetland indicator plants) occupies portions of the higher elevation zones of the site, primarily to the southwest corner. The wetland depressions are indicated by seasonally high density of toad rush (Juncus bufonius, FACW, facultative-wet indicator in arid west), co-occuring with European ryegrass (Festuca perenne; syn. Lolium perenne; FAC, facultative wetland indicator in arid west) and buck’s-horn plaintain (Plantago coronopus; FACW, facultative-wet indicator in arid west). Some of the wettest depressions support populations of Lilaea scilloides (flowering quillwort). Flowering quillwort is evident only in the wettest years when pools stay flooded for many weeks or months. Accurate wetland plant identification and measurement of the seasonal wetland patches at this site are possible only during winter to spring months. Desiccation, disturbance (trampling, mowing, discing) eliminates or degrades wetland vegetation and precludes accurate identification in fall and summer. Similarly, accurate assessment of wetland hydrology is feasible only during the rainy season, during and within two weeks following major rainfall events.

The USFWS classification of Pedro Point Field wetlands shows wetlands distributed over approximately all of the site, as shown in DEIR Figures 3.7-1 and 3.7-2. Past and current National Wetland Inventory (“NWI”) maps consistently apply wetland classifications to approximately all of the field. Two current classifications of the field’s wetlands include the codes “PEMah” and “PUSCh”, both “palustrine” (freshwater emergent, non-tidal) seasonal, and consistent with the seasonally flooded hydrology associated with surrounding berms. The “U” (unconsolidated shore) probably is associated with intermittent unvegetated (disced, vegetation disturbed) conditions. The NWI wetland mapping of the field broad-brush treatment of prevailing past wetland distribution, but the precision of the NWI wetland type boundaries is not precise enough for the DEIR to represent as “existing conditions” in 2014 CEQA assessment. In my professional opinion, “wetlands” meeting the jurisdictional criteria for Coastal Commission (“Commission”) policies, and classification as “wetland” under the Cowardin (U.S. Fish and Wildlife Service, USFWS) system, are in fact present and widely distributed over the Pedro Point field today, despite past unauthorized ditching and drainage activities (see wetland history, below).

Despite DEIR’s inclusion of NWI mapped wetlands in some figures, the DEIR fails to apply the NWI wetland mapping and classification (as well any current field reconnaissance observations to update or verify them) to any meaningful biological assessment of potential wetland impacts of land use 2-19-0026
Exhibit 8

1.k
Packet Pg. 3451 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 6 designation changes to the field, and assessment of alternatives. The DEIR fails to assess the extent and distribution of the field’s seasonal wetlands (meeting Cowardin/California Coastal Commission wetland criteria) in relation to land use changes proposed. The DEIR does not consider the accuracy or distribution of the (old) NWI wetland maps based on existing field conditions. Specifically, the DEIR does not analyze whether the field’s wetlands are localized or extensively distributed in the field, so it cannot analyze whether it is even feasible to designate a coastal residential mixed-use development without committing the City’s General Plan to significant wetland impacts, in conflict with its own land use policies and Coastal Act policies.

Further, because of the DEIR’s omissions about wetland impacts, comparison of alternatives will lack relevant information about feasible land use alternatives that may avoid or minimize wetland impacts, and which may be environmentally preferable. Examples of environmentally preferable alternatives consistent with City and Coastal Act policies include existing “Commercial” land use (with and without “Commercial-Recreation” zoning) compatible with low-intensity visitor-serving commercial recreation/tourism-promoting uses; or “Conservation” - all of which are consistent with City policies for tourism destination, avoidance of natural hazards, wetland conservation, and consistency with recreational, scenic values that Coastal Act policies give priority over residential development.

1.3. Wetland jurisdiction and CEQA
The DEIR cites multiple state and federal wetland jurisdictions. With respect to assessment of biological impacts to wetlands, USFWS (NWI, Cowardin wetland classification), California Coastal Act, and California Department of Fish and Wildlife wetland policy definitions are applicable because these are fundamentally based on habitat, hydrogeomorphic features, and ecological functions. In contrast the narrowest federal definition (U.S. Army Corps of Engineers and Environmental Protection Agency; USACE/EPA) under the Clean Water Act is specifically limited to legal wetland definition for jurisdiction over authorization of discharges of earthen fill regulated under Section 404 of the Clean Water Act. The USACE/EPA wetland definition contains federal exemptions and policy disclaimers that are not relevant to biological impact assessment under CEQA, and it is a narrower and more exclusive definition that is likely to underestimate the extent of habitat-based or hydrogeomorphic definitions appropriate for impact assessment.

The California Coastal Act Section 30231 defines a wetland as:
…lands within the coastal zone which may be covered periodically or permanently with shallow water and include saltwater marshes, freshwater marshes, open or closed brackish water marshes, swamps, mudflats, and fens.
2-19-0026
Exhibit 8

1.k
Packet Pg. 3452 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 7 Similarly, the Cowardin (USFWS, NWI) wetland classification uses a general broad definition of wetlands:

Wetlands are lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water.

California Coastal Act jurisdictional wetlands criteria in the California Code of Regulations at 14 14 CCR Section 13577 establish a “one-parameter definition” that only requires evidence of a single wetland parameter to establish wetland conditions, in contrast with federal wetlands criteria under the Clean Water Act:

Wetland shall be defined as land where the water table is at, near, or above the land surface long enough to promote the formation of hydric soils or to support the growth of hydrophytes, and shall also include those types of wetlands where vegetation is lacking and soil is poorly developed or absent as a result of frequent and drastic fluctuations of surface water levels, wave action, water flow, turbidity or high concentrations of salts…
The Commission’s one-parameter definition is similar to the USFWS wetlands criteria, which state that wetlands must have one or more of the following three attributes:
(1) at least periodically the land supports predominantly hydrophytes; (2) the substrate is predominantly undrained hydric soil; and (3) the substrate is nonsoil and is saturated with water or covered by shallow water at some time during the growing season of each year.

In contrast, the U.S. Army Corps of Engineers (USACE) and the Environmental Protection Agency use a three parameter definition for delineating wetlands under Clean Water Act jurisdiction, which is relevant only in context of USACE permit authorization for discharges of fill in jurisdictional waters of the United States. The USACE definition is narrower than those of the Coastal Commission (relevant to LCP) and USFWS (relevant to wetland impact assessment under CEQA, not limited to fill discharges and subject to federal exemptions irrelevant to CEQA).

The City’s wetland policies (Land Use; DEIR p. 3.1-21) cite both USACE/EPA and Coastal Commission wetland definitions. CO-I-5, CO-I-6 cites both, and CO-I-8 cites State (CDFW/CCC) wetlands only. The narrower USACE/EPA definition is relevant only to those land use policy elements that specifically cite it in context of wetland fill permits. The USACE/EPA jurisdictional wetlands are not the proper standard for determining consistency of GPU consistency with Coastal Act wetlands policies, or wetland impacts under CEQA. This should be corrected in the EIR, or else the EIR will not provide accurate conclusions about Pedro Point field land use impacts regarding wetlands in context of CEQA or Coastal Act policies.

1.4. Special-status species and Environmentally Sensitive Habitat Areas (ESHA): California red-legged frogs (Rana draytonii) environmental baseline 2-19-0026
Exhibit 8

1.k
Packet Pg. 3453 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 8 California red-legged frogs (Rana draytonii; CRLF) occur in the freshwater marsh drainage swale bordering the Pedro Point Field along its eastern edge. I reported their presence to the U.S. Fish and Wildlife Service Sacramento Fish and Wildlife Office, Endangered Species Program in 2005. If the DEIR preparers had consulted properly with state and federal wildlife agencies, or local residents, about the local distribution of special-status or other wildlife species, this information would have been available to include in the DEIR. The DEIR, however, failed to disclose the local sub-population of CRLF in the drainage swale bordering the field, and its relationship with the population of the lower San Pedro Creek wetland complex.

I have observed adult red-legged frogs are most often observable basking along muddy or prostrate grass banks near the culverts draining San Pedro Avenue at the southeast corner of the field. The perennial moisture in this swale provides year-round hydration habitat for CRLF, as well as foraging and potential breeding habitat. CRLF breeding is indicated by intermittent local population increases in redlegged frogs here, most notably in 2010. Foraging activities of CRLF likely extend to adjacent nonwetland flats (rich in invertebrate prey) in the field during moist, foggy nighttime and early morning conditions. I am not aware of protocol nighttime surveys for California red-legged frog conducted either in the freshwater marsh swale adjacent to the field, or in the field itself. The vicinity of the freshwater marsh swale and field are a complex of foraging, basking, dispersal, and breeding wetland and upland habitat for California red-legged frogs. It thus also meets criteria for Environmentally Sensitive Habitat Areas (ESHA) under California Coastal Commission regulations. The DEIR fails to include this information about CRLF at and in proximity to the field.

In addition, the DEIR fails to analyze the potential adverse, significant impacts to CRLF from the proposed land use changes. Land use designations that would foreseeably increase the intensity of land use, such as the proposed redesignation to allow residential development or other substantial increases in the built environment, may have significant direct and indirect impacts on CRLF. The proposed residential mixed-use development of the field would likely (a) substantially reduce available nocturnal foraging habitat for CRLF (food and prey base impacts to growth and survival; (b) increase contaminant loads in the drainage swale due to runoff from driveways, roads, and backyard sources of pesticides, petroleum hydrocarbons, solvents, and detergents (reproductive impacts); (c) increase peak flow velocities in the swale during major storm runoff events (juvenile mortality impacts).

Not only has the DEIR not assessed such impacts, it has not identified feasible programmatic mitigation measures. Feasible mitigation for ESHA/California red-legged frog habitat and frog populations must include measures to (a) avoid and minimize “take” of individual frogs, (b) avoid and minimize impacts to CRLF habitat; and (c) provide adequate buffer zones to minimize adverse effects of incompatible adjacent land uses. The spatial structure of CRLF mitigation aligned with the freshwater marsh swale bordering the field may substantially constrain the feasibility of some incompatible land use designations, especially any that increase runoff, contaminants or pesticides, predator pressure on CRLF, 2-19-0026
Exhibit 8

1.k
Packet Pg. 3454 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 9 or reduce the extent or quality of potential productive nighttime foraging habitat. The Bolsa Chica court decision [Bolsa Chica Land Trust v. Superior Court 71 Cal. Ap.4th 493, 507] confirmed that the Coastal Act requires that ESHA be avoided and buffered from development impacts and that providing compensatory mitigation alone is insufficient as ESHA mitigation.

Intermittent breeding habitat of California red-legged frogs in freshwater marsh swale bordering the southeast corner of the field, near roadside culverts. An adult CRLF is shown at the concrete base of foundation culvert on August 20, 2006, after the field ditch connections were breached to the swale north of this pool. CRLF frequently bask in the western muddy or grassy banks of this pool in wet (non-drought) years.

1.5. Wetland context and cumulative impacts: environmental setting of Pedro Point The DEIR also omisrepresents the existing environmental setting and context of the wetlands of the Pedro Point field. The field’s wetlands are represented as completely isolated from any other significant wetlands or potential wetland-dependent endangered species habitats. See Figures 3.1-1, 3.7-1, 3.7-2, and

3.7-3, all of which fail to show the San Pedro Creek mouth wetlands and their riparian wetland habitat, vegetation and hydrological connections with Pedro Point field and its wetlands. The San Pedro Creek stream mouth wetlands, however, are shown as red-legged frog habitat (marsh, creek, and riparian vegetation) in Figure 3.7-1, but without their wetland connections to the Pedro Point field and drainage swale wetlands. The omission of the San Pedro Creek mouth wetlands in the Coastal Zone is either arbitrarily selective or at least inconsistent in the DEIR: the riparian corridor and wetlands upstream of Highway 1, outside the coastal zone, are represented in Figure 3.7-1 and 3.7-4, but not in Figure 3.7-2.

This error of selective omission of wetlands in the project vicinity appears to be due to the DEIR’s failure to critically interpret and update National Wetlands Inventory map with even cursory examination of readily available current aerial or satellite imagery of San Pedro Creek mouth (e.g., Google Earth), or field reconnaissance surveys of the conspicuous restored freshwater marsh there. 2-19-0026
Exhibit 8

1.k
Packet Pg. 3455 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 10 Figure 3.7-2, “National Wetlands Inventory Wetlands”, completely fails to represent the perennial freshwater emergent marsh and freshwater streams of San Pedro Creek mouth as they existed at the time of the DEIR’s notice of preparation, and as they have existed for about a decade. The DEIR cannot uncritically transfer NWI map data without checking for errors of omission due to outdated data layers.

The NWI wetland classification (Cowardin USFWS classification system) provides sufficient clear wetland criteria to identify the obvious wetlands (cattail and tule marsh vegetation 6 to over 10 feet tall with standing water) at the mouth of San Pedro Creek. This marsh is clearly known to the City of Pacifica, which was the local partner in the project that restored it.

The adjacent San Pedro Creek mouth freshwater marsh is very significant as an environmental setting of the seasonal wetlands of the Pedro Point field. Ecological connectivity (wildlife corridors for wetland-dependent wildlife) exists between the creek mouth marsh and the field, provided by the drainage swale wetlands (not currently channelized; infilled with sediment and wetland vegetation) consisting of willow swamp (riparian scrub) and freshwater marsh dominated by broadleaf wetland forbs and grasses.

The environmental setting and potential Project and cumulative impacts to wetlands at the Pedro Point field are related to their hydrogeomorphic setting and historical origins and development. The preagricultural “natural” condition of the field was freshwater nontidal marsh within the floodplain of San Pedro Creek (San Pedro Valley lowlands). The modern field was part of complex of freshwater marsh and swamp (alder-willow) surrounding Lake Mathilda (the freshwater lagoon outlet of San Pedro Creek prior to channelization), behind the barrier beach (San Pedro Beach). The rich organic fine-grained alluvial soils were converted to agricultural cropland (artichoke fields) by draining and ditching in the late 19th century. The field apparently persisted with either low-intensity agricultural use (grazing, haying) into the 1950s or early 1960s when Linda Mar was extensively developed. Some fill was placed on at least portions of the field in recent decades, but differential subsidence in the flat to very gently sloping (<2%) field maintained depressional microtopography (shallow swales, pools) to the present day.

I have observed the Pedro Point field since the year 2000 in all seasons. Wet (saturated to seasonally flooded) depressions in the field persisted for weeks to months, supporting typical seasonal wetlands grasslands dominated by ryegrss, toad rush, buck’s-horn plaintain in winter-spring months. In addition, a regionally rare vernal pool/pond plant, the flowering quillwort (Lilaea scilloides) occurred in local abundance in several pools. In January, 2006, the current landowner and assistants manually excavated diagonal ditches and side-cast fill (ditch spoils) across the field, apparently with the intent of draining the field. In August 2006, mechanical equipment breached wide gaps in the berm between the field and the adjacent drainage swale marsh. These drainage activities were apparently completed without benefit of a Coastal Development Permit or authorization from the U.S. Army Corps of Engineers.

Despite the 2006 drainage ditching and subsequent maintenance and repeated discing of the field, depressional wetlands have persisted and re-emerged (due in part to differential settlement and choking of 2-19-0026
Exhibit 8

1.k
Packet Pg. 3456 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 11 ditches) in the field. The ditching appears to have reduced the duration and extent of wetland hydrology, but significant wetland areas remain widely distributed across most of the field, including the original seasonal wetland plant community.

Excerpt of U.S. Coast Survey map of San Francisco Peninsula, 1869, based on 1850s topography: San Pedro Creek Valley and beach, now Linda Mar. Approximate location of San Pedro Field (Calson/former Archdiocese property) in red shows the relationship of the modern field wetlands to the historical valley floodplain wetland complex.

Parallel horizontal hatched lines indicate freshwater marsh. Stippled shoreline area indicates sandy beach, dune, washover. Fine horizontal hatching is open freshwater (Lake Mathilda; historical Pedro Creek Lagoon, drained for agriculture 19th century). Irregular circles/dots within marsh = wooded freshwater swamp (alder, willow). No scale.

Extensive seasonal flooding of
the Pedro Point Field during the
transition between the historical
agricultural era (derelict or lowintensity agricultural use) and suburban development of Linda
Mar in San Pedro Valley
lowlands (background), likely
1950s-early 1960s. View to
E/SE. The eucalyptus and
Monterey cypress trees at the
fenceline correspond the mature
trees present today along the
drainage swale at the east end of
Approximate
location modern
San Pedro Field flats

SAN PEDRO
VALLEY

FRESHWATER
MARSH

FRESHWATER MARSH
(horizontal hatching)

FRESHWATER SWAMP
2-19-0026
Exhibit 8

1.k
Packet Pg. 3457 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 12 the field. The extensive seasonal pond likely represents flooding patterns prior to partial filling of the wetlands.

Flooding patterns delineate undrained depressions of shallow open water in a matrix of saturated soils in San Pedro Field following heavy rainfall. December 26, 2005. View to N.

Shorebirds (likely sanderlings) forage in the seasonally saturated and flooded field during high tide and storm wave conditions that restrict foraging habitat availability on the adjacent San Pedro (Pacifica State) Beach. December 27, 2005, prior to unauthorized ditching of the field. Red-necked phalaropes also forage in the saturated to flooded field during winter storms.
2-19-0026
Exhibit 8

1.k
Packet Pg. 3458 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 13 January 19, 2006. Manual excavation of drainage ditches in flooded field at the east end of the field. Grass grows above water surface. Water in bare spots can be seen as reflected sunlight on the field; emergent unvegetated mud is dark brown.

2-19-0026
Exhibit 8

1.k
Packet Pg. 3459 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 14 During discing of the field in summer, the berm along the east end of the field was mechanically breached at multiple locations to connect new drainage ditches (excavated in seasonal wetlands of the field) to the large drainage swale occupied by California red-legged frogs, draining to San Pedro Creek through culverts at the northwest end.

August 20, 2006.

Despite new unauthorized ditching and drainage connections of the field, ditches merely reduce the extent and duration of soil saturation and flooding; they do not eliminate wetland conditions in the winter following ditching.

December 27, 2006
Today, wildlife in the seasonal wetlands of the Pedro Point field includes shorebirds, meadowlarks, black-tail deer, tree frogs, small mammals, and raptors, all of which move between the field wetlands, the adjacent drainage swale wetlands, uplands, and the mouth of San Pedro Creek. Sanderlings and red-necked phalaropes occur intermittently in the flooded to saturated fields, particularly during high tides and storm wave conditions that flood the beach.. In summer, meadowlarks inhabit the field some years, particularly when grass and forb vegetation cover is thick. Small mammals, including mice, pocket gophers, and voles, occur frequently in the field (indicated by burrows, runs) and provide a prey base for raptors, including great horned owls (roosting in eucalyptus trees near the field), and red-tail hawks. Deer browse in the field at night, and at times in the morning as well. The marsh swale bordering the east end 2-19-0026
Exhibit 8

1.k
Packet Pg. 3460 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 15 of the field has supported a breeding population of tree frogs (Pseudacris sierra) and a population of federally listed threatened California red-legged frogs (Rana draytonii) most years at least since 2000 (see special-status species, below). The DEIR fails to disclose intermittent red-legged frog populations in the vicinity (and sometimes directly bordering) the field, and the existence of probably nocturnal foraging habitat (for this species spring-fall non-breeding adults) within in the field itself. The DEIR failed to identify these significant wildlife movement and habitat connections between the field and habitats in its wetland setting. The DEIR fails to analyze potentially significant impacts to red-legged frogs using the field that would be affected by proposed conversion to coastal residential mixed use development.

The DEIR’s failure to correctly characterize the wetland environmental setting (the wetland complex comprising the San Pedro Creek mouth wetlands, the drainage swale wetlands, and the historical and existing condition of the Pedro Point field wetlands) prevents the DEIR from accurately analyzing potentially significant cumulative impacts caused by wetland habitat loss, degradation or fragmentation in the lower San Pedro Creek corridor, and the Pedro Point neighborhood.

Given the outstanding biological significance of the field as the only open, level (flatland) space left in the Pedro Point neighborhood, and despite years of being the focus of substantial public concern and comment in scoping and other public meetings, the DEIR’s failure to provide even minimally accurate, consistent baseline environmental description of the field is a very serious defect in the DEIR.

It precludes accurate assessment of potentially significant impacts that are not mitigated at the policy or site-specific level.

1.6. Biological Resource Impact Assessment and Mitigation in the DEIR Despite identifying wetlands occurring potentially throughout the field, the DEIR fails to assess potential adverse, significant impacts to Coastal Act wetlands from the proposed land use designation changes at the Pedro Point Field. The DEIR provides no explanation why converting existing wetlands of the Pedro Point field to residential mixed use development would have no significant biological or land use policy impacts. The DEIR omits any specific reference at all to the Pedro Point field wetlands in discussion of biological impacts.

Further, the DEIR’s cumulative impact analysis must consider that the extent of Coastal Act wetlands in the field was modified by ditching and drainage activities conducted by the landowner and assistants on January 19, 2006, during conditions of saturation and widespread flooding of the field. As far as I am aware, ditching and draining activities of these wetlands occurred without issuance of a Coastal Development Permit or analysis of environmental impacts. The apparently unauthorized drainage of the field probably results in underestimation of the actual extent of proper Coastal Commission jurisdictional wetlands in the field. See wetland history, below. The errors in the DEIR’s environmental baseline, described above, contribute to basic errors in assessment of significant biological impacts and mitigation to wetlands and special-status species.
2-19-0026
Exhibit 8

1.k
Packet Pg. 3461 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 16 The DEIR identifies only two potential general city-wide biological impacts, without areaspecific reference to Pedro Point neighborhood and the specific land use changes proposed in the revised General Plan. Both of these impacts are incorrectly assessed with respect to Pedro Point biological resources, and their proposed programmatic (policy-level) mitigation is infeasible applied to Pedro Point field.

Figure 3.1-2 of the DEIR (p. 3.1-9; “Existing General Plan Land Use”) shows the majority of the Pedro Point field mapped in red (“Commercial”), and apparently one small lot in the northwest corner of the field mapped in light yellow-orange (“low density residential”). The biological impacts of this proposed land use change must be assessed at a programmatic level, commensurate with the level of detail of land use designation change in the programmatic EIR at neighborhood-scale. The DEIR, however, fails to assess biological impacts at this geographic scale even at a programmatic level. It merely assesses biological impacts at a sweeping, vague, city-wide, policy level, omitting neighborhoodlevel biological impacts of specific land use changes proposed (DEIR p. 3.7-48 Impact 3.7-1; p. 3.7-57, Impact 3.7-3). The DEIR also provides only vague, policy-level “mitigation” (pseudo-mitigation; purely speculative policy without reference to physical or biological conditions) for land use change impacts in the aggregate, city-wide:

Impact 3.7-1 Implementation of the proposed General Plan would not have a substantial adverse effect, either directly or through habitat modifications, on candidate, sensitive, or special status species identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service. (Less than Significant)
Impact 3.7-3 Implementation of the proposed General Plan would not have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. (Less than Significant)
The DEIR provides no substantial evidence and no arguments for either impact findings or their level of significance. It is inconsistent with proposed land use changes (coastal residiential mixed-use development) for the field, and the presence of extensive seasonal wetlands and adjacent special-status species populations.

Although the DEIR does not need to assess impacts of land use change at a project-specific level (i.e., it cannot speculate about the design of specific project proposals or their impacts in site-specific detail), it must address biological impacts that are reasonably foreseeable for the type of land uses proposed in the environmental setting under existing conditions. There is only one major land use change proposed in Pedro Point, and the DEIR provides no biological impact or mitigation discussion about it at 2-19-0026
Exhibit 8

1.k
Packet Pg. 3462 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 17 all – not even the cursory programmatic wetland discussion presented in the Draft Land Use plan itself (LUI-30, p. 4-36, Pacifica Draft Land Use Plan, March 2014). The boilerplate, standard wetland permit discussion in the DEIR at p. 3.7-42 has no substantial bearing on impact or mitigation analysis for wetlands at Pedro Point.

Potentially significant biological impacts of proposed residential land use (development) at the Pedro Point Field and adjacent habitats are enumerated below. These are based on a more adequate characterization of the Pedro Point field wetlands, their relationship to San Pedro Creek wetlands, and their wildlife and hydrological attributes described above. None of these potentially significant biological impacts were analyzed in the DEIR.

Coastal Zone Wetland impacts
o Direct filling (loss) of the last coastal zone seasonal wetlands in Pedro Point watershed due to residential development. Lack of available off-site compensatory mitigation area within the coastal zone of the San Pedro Creek watershed (no feasible compensatory mitigation).
o Degradation of remaining coastal zone wetlands (wetland swale east of field) the San Pedro Creek watershed due to hydrological changes; increased impermeable surfaced area, decreased groundwater infiltration, increased storm runoff from drained residential lots within basin (historic floodplain).
o Degradation of remaining wetlands (wetland swale east of field) due to increased contaminant loading from adjacent residential development: pesticides (residential pesticide use and pesticide loading from runoff and drainage), increased petroleum hydrocarbon contaminant loads from street and driveway runoff; increased surfactant runoff to the drainage swale from residential car washing.

Wildlife and Special-status species impacts
o Loss of storm high tide refuge habitat for shorebirds o Loss of meadowlark foraging habitat
o Loss of nocturnal deer browsing habitat
o Loss of raptor foraging habitat (Great Horned Owl, red-tail hawk, kestrel) o Loss of terrestrial foraging habitat for California red-legged frogs o Loss of flood refuge habitat for California red-legged frogs during peak flood events of San Pedro Creek.
2-19-0026
Exhibit 8

1.k
Packet Pg. 3463 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 18 2.0 Land Use Impacts – Coastal Zone
The DEIR proposes to change the land use designation of the Pedro Point field from “Commercial” (Pacifica General Plan, pp. 86 and 90; DEIR Figure 3.1-2) to “Coastal Residential Mixed Use“ (CRMU; DEIR Figure 2.2-1). The DEIR inaccurately states that the new proposed CRMU designation corresponds with an existing “Mixed Use” land use category (Table 3.1-3), but no such independent or category or subcategory of “mixed use” exists in the 1980 General Plan; “mixed use” is simply described as a contingent allowable use of “commercial” land use in the original General Plan (1980 General Plan p. 32-33). The project description is inconsistent, incorrect, and confusing in terms of existing and proposed land uses.

The 2014 Draft General Plan Land Use element states the following with regard to the CRMU designation on p. 4-24: “The Plan retains flexibility for any future development on the vacant site west of the shopping center, which could have residential and small-scale commercial and visitor-oriented uses.

Future development should include a small park and access to the berm and the beach beyond”. Table 4.1 of the Draft General Plan states that residential density with CRMU designation may range between 10- 15 gross units per acre.

The DEIR, in contrast with the original 1980 General Plan, fails to assess even at a programmatic level the area-specific effects of proposed land use designations for the Pedro Point neighborhood, and specifically for the vacant Pedro Point field, in terms of land use impacts (cf. 1980 General Plan, pp. 84- 89). The DEIR gives no reason why the level of specificity for impact assessment should be broader and more programmatic than the level of specificity for individual parcel land use designations like the Pedro Point field, or why the level of neighborhood-specific assessment should be significantly less than that of the 1980 General Plan’s treatment of Pedro Point, especially in the Coastal Zone.

The existing land use designation of the field, “commercial” is compatible with low-intensity, visitorserving commercial recreational land uses that support coastal-dependent (beach and coastal scenic) recreation and associated economic uses, which matches the existing zoning (commercial-recreation) of the field. Low-intensity commercial land uses that do not involve ditching, draining, filling, paving, or construction in the field (open-space and recreational uses, special events, coastal agriculture) are potentially compatible with conservation of wetlands, environmentally sensitive habitat areas, and special-status species, and relevant Coastal Act policies. Proposed Coastal Residential Mixed Use land uses, however, are likely to have significant impacts on Coastal Act land use policies (cited in Draft Pacifica Local Coastal Land Use Plan, March 2014, Appendix A) and Pacifica General Plan policies involving these elements, as discussed below.

The extensive distribution of Coastal Act jurisdictional wetlands in the Pedro Point field, and the presence of California red-legged frog habitat and population in the adjacent freshwater marsh swale, 2-19-0026
Exhibit 8

1.k
Packet Pg. 3464 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 19 both indicate that land use designations for the field must be compatible with ESHA policies of the Coastal Commission. According to the Coastal Commission’s LCP Update Guide: Sensitive Habitats and Natural Resources (April 3, 2007 update), the DEIR and LCP should clearly state that only “resource dependent” development, such as restoration or nature study, is allowed in ESHA, consistent with Coastal Act §30240. No ESHA assessment for the proposed changes in land use designation of the Pedro Point field has been provided in the DEIR, which is likely related to the DEIR’s failure to accurately identify wetlands and special-status species at the site. The DEIR must be revised to include this analysis of potentially significant environmental impacts even at a programmatic level.

The 1980 Pacifica General Plan provided a programmatic analysis of consistency between proposed (commercial) land use designation of the Pedro Point Field and specific Coastal Act policies (1980 General Plan p. 86), including assessment of unimproved coastal access through foot trails (p. 88).

The DEIR for the General Plan update has provided no such analysis for proposed changed land use designation of the field or coastal access impacts. It merely included the Coastal Act policies as an appendix, without analysis of proposed land use designation change impacts. The changed land use designation has potential significant land use policy conflicts (impacts) with Coastal Act land use policies, each of which affects ESHA (wetlands and special-status wetland-dependent wildlife). Some examples are provided below. The DEIR should fully assess at a programmatic level all such potential significant land use impacts, and compare the compatibility (conflict) of existing, proposed and alternative land use designations for the field in terms of Coastal Act policies.

Section 30212 New development projects
(a) Public access from the nearest public roadway to the shoreline and along the coast shall be provided in new development projects except where:
(1) it is inconsistent with public safety, military security needs, or the protection of fragile coastal resources,
(2) adequate access exists nearby, or,
(3) agriculture would be adversely affected.

Pedro Point field has three well-established and persistent foot trails that lead from San Pedro Avenue (the nearest public roadway to the shoreline) to a private beach with long-established open public access.

The foot trails are visible in aerial photographs dating back to at least 1993 (Google Earth images) and reemerge after being temporarily erased by discing, ditching, or mowing. The foot trails are formed by trampling patterns established between physical points of access from the roadway to a stairway from the beach to the historic railroad berm, and to a public path to the beach at the mouth of San Pedro Creek.

Foot trails are frequently used by beach visitors and surfers seeking minimal travel distances to the beach.

The foot trails evidently established long before the current ownership of the property. The foot trails are the most efficient short cuts from San Pedro Avenue to the public shore; alternative routes along public 2-19-0026
Exhibit 8

1.k
Packet Pg. 3465 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 20 roads would nearly double foot trail distance from the public roads to the shore from established access points.

Pedro Point field in relation to public and private ocean shores, and freshwater marsh and stream habitat of San Pedro Creek mouth. 2013 Google Earth image.

Pedro Pt
Field
Private beach
with public
shore access
Pacifica
State
Beach
Freshwater
marsh
2-19-0026
Exhibit 8

1.k
Packet Pg. 3466 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update) Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 21 Foot trail network (2013) of Pedro Point Field, showing connections to levee trail access to private shore with long-established public access. Freshwater wetland drainage swale connecting to San Pedro Creek mouth is shown in dashed blue line. 2013 Google Earth image.

Pedro Pt
Field
2-19-0026
Exhibit 8