Agenda — Pacifica City Council, June 25, 2022 (part 4 of 23)

Mitigation. A specific action taken to reduce environmental impacts. Mitigation measures are required as a component of an environmental impact report
(EIR) if significant measures are identified.

Mitigation Measures. Action taken to avoid, minimize, or eliminate environmental impacts. Mitigation includes: avoiding the impact altogether by not taking a certain action or parts of an action; minimizing impacts by limiting the degree or magnitude of the action and its implementation; rectifying the
impact by repairing, rehabilitating, or restoring the
affected environment; reducing or eliminating the
impact over time by preservation and maintenance
during the life of the action; and compensating
for the impact by repairing or providing substitute
resources or environments.

Mixed Use. Describes a development project which
includes two or more categories of land use such as
residential and commercial, or commercial and professional office and the like For further discussion see the Land Use Element section on Mixed-use centers.

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PACIFICA GENERAL PLAN PUBL,C REVIEW DRAFT G-7

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Packet Pg. 631 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption Mode (transportation). Each form of transportation
is a mode: public transit, bicycling, walking, and
driving.

Mode split (transportation). The proportion of trips
that use each mode of transportation.

Multi-Lane Highways. Highways with posted speed
limits generally between 40 and 55 miles per hour.

They are interrupted by intersections or driveways.

Net Developable Area. The total area of land available for development, not necessarily the total area of a property itself. It does not include open space,
drainage land, regional roads and land used for other
public facilities.

Nitrogen Oxides (NOx). Chemical compounds
containing nitrogen and oxygen; reacts with volatile
organic compounds, in the presence of heat and sunlight to form ozone. It is also a major precursor to acid rain.

Noise Attenuation. Reduction of the level of a noise
source using a substance, material, or surfac_e.

Noise Contours. Lines drawn about a noise source
indicating equal levels of noise exposure. CNEL
and Ldn are the metrics utilized herein to describe
annoyance due to noise and to establish land use
planning criteria for noise.

Open Space. Any parcel or area of land or water
that is essentially unimproved. The General Plan
designates privately-owned rural/grazing lands, and
devoted open space areas as defined by California
planning law.

Overdraft. A groundwater basin is in overdraft conditions when the amount of water being drawn out exceeds the amount of water being recharged.

Overlay District. A zoning designation that may
be applied in addition to the "underlying" zoning
district, to meet a specific, additional goal, such as
to encourage affordable housing or allow flexibility
with parking requirements.

G-8 PACIFICA GENERAL PLAN PUBLIC REVIEW DRAFT
Ozone. A compound cons1stmg of three oxygen
atoms that is the primary constituent of smog. It
is formed through chemical reactions in the atmosphere involving volatile organic compounds, nitrogen oxides, and sunlight. Surface level Ozone can initiate damage to the lungs as well as damage to
trees, crops, and materials. There is a natural layer
of Ozone in rhe upper atmosphere, which shields the
earth from harmful ultraviolet radiation.

Paleontological Resources. The mineralized remains
of prehistoric plant and animal life, not including
human remains or artifacts-also known as fossils.

Park Ratio. The amount of parkland in acres to
1,000 residents.

Particulate Matter (PM-10 and PM-2.5). Particulate
matter in the atmosphere results from many kinds of
dust- and fume-producing industrial and agricultural
operations, fuel combustion, and atmospheric photochemical reactions. PM-10 and PM-2.5 consist of particulate matter that is 10 microns or less in diameter and 2.5 microns or less in diameter, respectively.

PM-10 and PM-2.5 represent fractions of particulate
matter that can be inhaled into the air passages and
the lungs and can cause adverse health effects.

Peak Hour. The busiest one-hour period for traffic
during a 24-hour period. The PM peak hour is the
busiest one hour period of traffic during the evening
commute period. The AM peak hour is the busiest
one hour period during the morning commute.

Pedestrian-oriented Development. Development
designed with an emphasis on the street sidewalk
and on pedestrian access to the building; rather than
an auto access and parking areas.

Pedestrian Priority Zones. Areas in which high
volumes of pedestrian traffic are encouraged and
accommodated along the sidewalk.

Performance Standards. A statement representing a
commitment by a public agency to attain a specified
level or quality of performance through its programs
and policies.

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Packet Pg. 632 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption Planning Area. The land area addressed by a General Plan, including land within the city limits and land outside the city limits that bears a relation to
the City's planning. This area is not all intended for
development; the Urban Growth Boundary shows
the future development area.

Pocket Parks. Parks less than 2 acres in area that
may provide amenities for the immediate area, such
as playlots in residential neighborhoods, or plazas in
commercial and mixed-use areas.

Rare or Endangered Species. A species of animal
or plant listed in Sections 670.2 or 670.5, Title 14,
California Administrative Code; or Title 50, Code
of Federal Regulations, Section 17.11 or Section 17.2,
pursuant to the Federal Endangered Species Act designating species as rare, threatened, or endangered.

Retention Area. A pond, pool, lagoon, or basin used
for the storage of water runoff, which is not pumped
to another location.

Right-of-Way. A continuous strip of land reserved
for or actually occupied by a road, crosswalk, railroad, electric transmission lines, oil or gas pipeline, water line, sanitary storm sewer or other similar use.

Residential Care Facilities. A residential care facility for the elderly is a housing arrangement chosen voluntarily by the resident, the resident's guardian, conservator or other responsible person; where 75 percent of the residents are sixty years of age or older and
where varying levels of care and supervision are provided, as agreed to at time of admission or as determined necessary at subsequent times of reappraisal.

Any younger residents must have needs compatible
with other residents.

Riparian. Characteristic vegetation along waterways,
often described as "riparian corridors."
Seismic. Caused by or subject to earthquakes or
earth vibrations.

Sensitive Receptors. Persons or land users that are
most sensitive to negative effects of air pollutants.

Persons who are sensitive receptors include children,
the elderly, the acutely ill, and the chronically ill.

The term "sensitive receptors" can also refer to the
land use categories where these people live or spend
a significant amount of time. Such areas include residences, schools, playgrounds, child-care centers, hospitals, retirement homes, and convalescent homes.

Shrink-Swell Potential. The extent to which a soil
expands in volume when water is absorbed and
shrinks as the soil dries. Expansive soils, with a high shrink-swell potential, are largely comprised of clays.

Significant Effect. A beneficial or detrimental
impact on the environment. May include, but is not
limited to, significant changes in an area's air, water, and land resources.

Siltation. The process of silt deposition. Silt is a loose sedimentary material composed of finely divided
particles of soil or rock, often carried in cloudy suspension in water.

Solid Waste. General category that includes organic
wastes, paper products, metals, gl~ss, plastics, cloth, brick, rock, soil, leather, rubber, yard wastes, and
wood.

Special Status Species. Any species which is listed,
or proposed for listing, as threatened or endangered
by the U.S. Fish and Wildlife Service or National
Marine Fisheries Service under the provisions of the
Endangered Species Act. It also includes any species
designated by the U.S. Fish and Wildlife Service as a
"candidate" or "species of concern" or species identified on California Native Plant Society's Lists IA, 1 B, or 2, implying potential danger of extinction.

Specific Plan. A plan that provides detailed design
and implementation tools for a specific p_ortion of the area covered by a general plan. A specific plan may
include all regulations, conditions, programs, and/
or proposed legislation which may be necessary or
convenient for the systematic implementation of any
general plan element(s).

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Packet Pg. 633 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption Sphere oflnfluence (SOI). The ultimate service area
of an incorporated city, as established by San Mateo
Local Agency Formation Commission (LAFCo).

Stationary Source. A source of air pollution that is
not mobile, such as a heating plant or an exhaust
stack from a laboratory.

Surface Water. Water found m rivers, streams,
creeks, lakes and reservoirs.

Stormwater Runoff. Surplus surface water generated
by rainfall that does not seep into the earth but flows overland to a watercourse.

Stormwater Management. A coordinated strategy to
minimize the speed and volume of stormwater runoff, control water pollution, and maximize groundwater recharge.

Student Generation Rate. The number of new students that is projected to occur with new housing units.

Subsidence. Subsidence occurs when a large portion of land is displaced vertically, usually due to the withdrawal of groundwater, oil, or natural gas.

Substantial Exterior Structural Modification
(SESM): Any physical improvement which modifies
an existing structure, as defined, to achieve any of the following:
i) a seaward encroachment of the structure; or
ii) removal or replacement of 50 percent or more
of the linear length of the exterior walls,
whether or nor rhe floor area or building
footprint is expanded; or
iii) an addition that includes new floor area at or
below the first storv equal to 50 percent or
more of the structure's total existing floor
area; or
iv) an increase of the existing building footprint
equal to 50 percent or more: but excluding
any of the following:
v) rerri.ovaL replacement, or maintenance of
nonstructural components of exterior walls
such as siding and roofing materials and
windows:
vi) development on any site which is protected
G-10 PAOFICA GENERAL f'LAN PUBLIC REVIEW DRAFT
from coastal erosion by an existing, permitted
shore- line protection structure;
vii) replacement of any structure pursuant to the
provisions of subdivision (g) of Section 30610 of
the Public Resources Code:
viii) the demolition and reconstruction of a singlefamily residence; provided, that the reconstructed residence shall nor exceed either
the floor area, height or bulk of the former
structure by more than 10 percent, and that the
reconstructed residence shall be sited in the
same location on the affected property as the
former structure; or
ix) the reconstruction, repair, or maintenance of any
shoreline protection structure; provided, however, that the reconstructed, repaired, or maintained shoreline protection structure is nor
seaward of the location of the former structure,
and that such modifications do not increase the
height or length of the former shoreline
protection structure by more than 10 percent.

Changes to exterior walls, floor area, height, length,
or building footprint shall be measured cumulatively
from those existing at the site on the dare of
certification of the LCLUP. The cost of
improvements shall nor be used as a basis in
application of this definition or any policy relying
thereupon unless ·expressly s·tated in the policv.

Threatened Species, California. A species of animal
or plant is endangered when its survival and reproduction in the wild are in immediate jeopardy from one or more causes, including loss of habitat, change
in habitat, over-exploitation, predation, competition,
disease, or other factors; or when although not
presently threatened with extinction, the species is
existing in such small numbers that it may become
endangered if its environment worsens. A species
of animal or plant shall be presumed to be rare or
endangered as it is listed in Sections 670.2 or 670.5,
Title 14, California Code of Regulations; or Tide 50,
Code of Federal Regulations Sections 17.11 or 17 .· 12
pursuant to the Federal Endangered Species Act as
rare, threatened, or endangered.

Threatened Species, Federal. A species which is likely
to become an endangered species within the foreseeable

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Packet Pg. 634 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption future throughout all or a significant por- tion of its range.

Total Dissolved Solids (TDS). Total dissolved solids comprise inorganic salts and small amounts of organic matter that are dissolved in water. The principal constituents are usually calcium, magnesium, sodium and potassium and the anions carbonate,
bicarbonate, chloride, sulphate and, particularly in
groundwater, nitrate (from agricultural use).

Toxic Air Contaminant. An air pollutant that
may increase a person's risk of developing
cancer and/ or other serious health effects. Toxic
air contaminants include more than 700 chemical
compounds that have been determined to have
potential adverse health impacts.

Transfer of Development Rights. A mechanism
used to relocate potential development from areas
where environmental or land use impacts could
be severe to other areas more appropriate for
development, and to preserve significant open
space resources.

Transit Oriented Development. A development
or planning concept typified by the location of
residential and commercial districts around a
transit station or corridor with high quality
service, good walkability, parking management
and other design features that facilitate transit use
and maximize overall accessibility.

Transportation Demand Management.

Measures to improve the movement of persons
and goods through better and more efficient
utilization of existing transportation systems (e.g. ,
streets and roads, freeways and bus systems) and
measures to reduce the number· of singleoccupant vehicles utilized for commute purposes.

Trip Generation. The number of vehicle trip
ends associated with (i.e., produced by) a
particular land use or traffic study site. A trip end
is defined as a single vehicle movement.

Roundtrips consist of two trip ends.

Tsunami. A wave generated by abrupt movement
of the seabed, which can occur as an earthquake or
after a significant landslide.

Urban Development Boundary (UDB): The
administrative boundary beyond which urban development is not allowed during the General Plan's first time period. Plan policies provide specific criteria for moving from the UDB, or First Tier, to the Urban
Growth Boundary (UGB, or Second Tier).

Urban Growth Boundary (UGB): The line within
which all urban development is to be contained. The
primary purpose of an UGB is to limit the extent of
urbanization.

Use. The purpose for which a lot or structure is or
may be leased, occupied, maintained, arranged,
designed, intended, constructed, erected, moved,
altered, and/or enlarged as per the City's Zoning
Ordinance and General Plan land use designation.

Vehicle Miles Traveled (VMT). A measure of both
the volume and extent of motor vehicle operation;
· the total number of vehicle miles traveled within a
specified geographical area ( whether the entire coun~
tty or a smaller area) over a given period of time.

View Corridor. The line-of-sight (identified as to
height, width, and distance) of an observer looking
toward an object of significance to the community
(e.g. , ridgeline, river, historic building, etc.).

Walkable. A characteristic of an area in which a variety of housing types, retail uses, parks, schools and other destinations are in close proximity and wellconnected by streets and paths that provide a good pedestrian environment.

Water Recycling. The reuse of tertiary-treated wastewater for landscaping, industrial cooling, irrigation, groundwater recharge, or other uses.

Watershed. The total area above a given point on a
watercourse which contributes water to the flow of
the watercourse; the entire region drained by a watercourse.

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Packet Pg. 635 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption Wetlands. Areas that are permanently wet or periodically covered with shallow water, such as saltwater and freshwater marshes, open or closed brackish marshes, swamps, mud flats, and fens.

Wildlife Corridor. A natural corridor, such as an
undeveloped ravine, that is frequently used by wildlife to travel from one area to another.

Williamson Act. Known formally as the California
Land Conservation Act of 1965, it was designed as
an incentive to retain prime agricultural land and
open space in agricultural use, thereby slowing its
conversion to urban and suburban development.

The pro- gram entails a ten-year contract between
an owner of land and (usually) a county whereby
the land is taxed on the basis of its agricultural use
rather than the market value. The land becomes
subject to certain enforceable restrictions, and
certain conditions need to be met prior to approval
of an agreement.

Zoning Ordinance. Title 9 of the Pacifica
Municipal Code divides incorporated City land
into districts and establishes regulations governing
the use, placement, spacing, and size of buildings,
open spaces, and other facilities.

G-12 PACIFICA GENERAL PLAN PUBLIC REVIEW DRAFT

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Packet Pg. 636 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption

LIST OF ACRONYMS
ABAG: Association of Bay Area Governments
af/y: acre feet/year
-
ADA: Americans with Disabilities Act
ADT: Average daily traffic
AHO: Affordable Housing Overlay zone
ALUC: Airport Land Use Commission
AST: Aboveground Storage T ank
BAAQMD: Bay Area Air Quality Management District
BART: Bay Area Rapid Transit
BAU: Business as Usual
BAWSCA: Bay Area Water Supply and Conservation Agency
BACT: Best Available Control Technology
BCDC: Bay Conservation and Development Commission
BCP: Beach and Commuter Parking
BID: Business Improvement District
BMP: Best Management Practice
C: Conservation
Caltrans: California Department of Transportation
CalGreen: California Green Building Code
CalRecycle: ·california Department of Resources
Recyclip.g and Recovery
CAP: Climate Action Plan
CARB: California Air Resources Board
C/CAG: City/County Association of Governments
of San Mateo County
CCAT: California Climate Action Team
CCC: California Coastal Commission
CCWRP: Calera Creek Water Recycling Plant
CDF: California Department of Forestry and Fire
Protection
CDFG: California Department of Fish and Game
CEQA: California Environmental Quality Act
CFCs: Chlorofluorocarbons
cfs: Cubic feet per second
CGS: California Geologic Survey
CIP: Capital Improvement Program
CLG: Certified Local Government
CMP: Congestion Management Program
CNDDB: California Natural Diversity Database
CNEL: Community Noise Equivalent Level
CO: Carbon monoxide
COG: Council of Governments
CO2e: Carbon Dioxide Equivalent
CRLF: California red-legged frog
CRSMP: Coastal Regional Sediment Management
Plan
C-w-!v1A: Consolidated Waste Management Authority
CZ: Coastal Zone
PACIFICA GENERAL PLAN PUBLIC REVlt\N DRAFT G-13

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Packet Pg. 637 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption dB: Decibel
dBA: Decibel A-Weighted
DNL: Day-Night Average Noise Level
DOF: Department of Finance
DPM: Diesel Particulate Matter
DTSC: Department of Toxic Substances Control
DU: Dwelling Unit
du/ac: Dwelling Units per acre (measure of density)
DWR: Department of Water Resources
EIR: Environmental Impact Report (CEQA)
EMS: Emergency Medical Service
EPA: Environmental Protection Agency
ESHA: Environmentally Sensitive Habitat Area
ESU: Ecologically Significant Unit
FAR: Floor Area Ratio (measure of intensity)
FEMA: Federal Emergency Management Act
FESA: Federal Endangered Species Act
FIRM: Flood Insurance Rate Map
FMMP: Farmland_ Mapping and Monitoring Program
FRA: Federal Responsibility Area
GBO: Green Building Ordinance
GCC: Global Climate Change
GCM: Global Climate Model
GGNRA: Golden Gate National Recreation Area
GHG: Greenhouse Gases
G-14 PACIFICA GENERAL PLAN PUBLIC REVIEW DRAFT
GIS: Geographic Information Systems
GMP: General Management Plan
GP: General Plan
GPOC: General Plan Outreach Committee
GPR: GreenPoint Rated
GPURC: General Plan Update Review Committee
gpcpd: gallons per capita per day (water use)
GWP: Global Warming Potential
HCD: Housing and Community Development
HCM: Highway Capacity Manual
HOR: High Density Residential
HPD: Hillside Preservation District
HSR: High Speed Rail
HHW: Household Hazardous Waste
IPCC: International Panel on Climate Change
ISO: Insurance Service Office
JPA: Joint Powers Authority
JUHSD: Jefferson Union High School District
LAFCO: Local Agency Formation Commission
LCLUP: Local Coastal Land Use Plan
LCP: Local Coastal Program
LOR: Low Density Residential
LEED: Leadership in Energy and Environmental
Design
LID: Low Impact Development
LIVC: Low-Intensity Visitor-Serving Commercial
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Packet Pg. 638 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption Leq: Equivalent Sound Level
Ldn: Day-Night Average Sound Level
LHMP: Local Hazards Mitigation Plan
LOS: Level of Service
LRA: Local Responsibility Area
LUST: Leaking Underground Storage Tank
MCL: Maximum Contaminant Level
MOR: Medium Density Residential
mgd: Million Gallons per day (water or wastewater)
MOE: Measures of Effectiveness
MPO: Metropolitan Planning Organizations
MRP: Municipal Regional Permit
MT: Metric ton (greenhouse gases)
MTC: Metropolitan Transportation Commission
MUC: Mixed Use Center
MUN: Mixed Use Neighborhood
NAAQS: National Ambient Air Quality Standards
NAHC: Native American Heritage Commission
NAICS: North American Industry Classification
System
NCCWD: North Coast County Water District
NCFA: North County Fire Authority
NFIP: National Flood Insurance Program
NFPA: National Fire Protection Association
NMFS: National Marine Fisheries Service
NOAA: National Oceanic and Atmospheric Administration
NOx: Nitrogen oxides
NPDES: National Pollution Discharge Elimination
System
NPS: National Park Service
NWI: National Wetlands Inventory
OC: Office/Commercial
P: Park
PG&E: Pacific Gas & Electric
PM-2.5: Suspended particulate matter 2.5 microns or
less in diameter
PM-10: Suspended particulate matter 10 microns or
less in diameter
ppb: Parts per billion
ppd: Pounds per person per day (waste)
ppm: Parts per million (106) by volume or weight
PPD: Pacifica Police Department
PSD: Pacifica School District
PSP: Public and Semi-Public
RC: Retail Commercial
RHNA: Regional Housing Needs Assessment
ROG: Reactive Organic Gases
ROSA: Residential/Open Space/Agriculture
RP: Regional Park
RSM: Regional Sediment Management
RTP: Regional Transportation Plan
RWQCB: Regional Water Quality Control Board
SA: Special Area
PACIFICA GlNERAL PLAN PUBLIC REVIEW DRAFT G-15

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Packet Pg. 639 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption SamTrans: San Mateo County Transit District
SB: Sandy Beach
SC: Service Commercial
SR: State Route
SCS: Sustainable Communities Strategy
SFGS: San Francisco garter snake
SFO: San Francisco International Airport
SFPUC: San Francisco Public Utilities Commission
SIP: State Implementation Plan (Air Pollution)
SMARA: Surface Mining and Reclamation Act
SMCL: San Mateo County Library
SMCWPPP: San Mateo Countywide Stormwater
Pollution Prevention Program
SOI: Sphere oflnfluence
Sq. Ft.: Square Feet
SR: State Route
SRA: State Responsibility Area
SWMP: Storm Water Management Plan
SWRCB: State Water Resources Control Board
TAC: Toxic Air Contaminant
T AZ: T raffle Analysis Zone
TOM: Transportation Demand Management
TMDL: T oral Maximum Daily Load
TOD: Transit Oriented Development
TRD: Transfer of Development Rights
TWL: Total Water Level
G-16 PACIFICA GENERAL PLAN PUBLIC REVIEW DRAFT
U: Utilities
UDB: Urban Development Boundary
UGB: Urban Growth Boundary
UR: Urban Reserve
USGS: United States Geologic Survey
UST: Underground Storage Tank
UV: Ultraviolet
UWMP: Urban Water Management Plan
V/C: Volume to Capacity Ratio
VC: Visitor-Serving Commercial
VLDR: Very Low Density Residential
VMT: Vehicle Miles Traveled
VOC: Volatile Organic Chemicals
. VPD: Vehicles per Day
WCP: Water Conservation Plant
WWTP: Waste Water Treatment Plant
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Packet Pg. 640 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption

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Packet Pg. 641 Attachment: Attachment C - Redline Edits to May 2022 Draft General Plan (includes only chapters with edits) (5035 : Consideration of Adoption M i l a g r a R i d g e
( G G N R A )
Pacifica
State
Beach
Pacifica
Pier
S h a r p P a r k
G o l f C o u r s e
San Pedro Vall e y
County Par k
S h a r p P a r k
M o r i P o i n t
( G G N R A )
S w e e n e y R i d g e ( G G N R A )

FASSLER AV E TERRA NOVA BLVD

LINDA MAR BLVD

ODDSTAD BLVD

GRAND AVE

ROCKAWAY BE ACH AVE

REINA DEL MAR AVE

CRESPI DR

FAIRWAY DR RIDGEWAY DR

PALOMA AVE

CLARENDON RD

PALMETTO AVE

MANOR DR

AVALON DR

MI LAGR ADR

MONTEREY RD

IVERNESS DR

NELSON AVE

PA ML ETTO AVE

ADOBE DR

BEACH BLVD

HICKEY B LV D
P a c i f i c
O c e a n
Northern
Coastal
Bluffs
(GGNRA)
Sharp
Park
Beach
P e n i n s u l a
Wa t e r s h e d
( S F P U C )
Rockaway
Beach
P e d r o P o i n t
H e a d l a n d s
Devil' s Slide Tunnel

PERALTA RD

ROSITA RD

EVE RGLAD ES DR

M ANZA NI T A DR

LERI D A WAY

R OBERTSRD

SHAR P P A RK R D

BRADFORD WAY

ESPLANADE AV E

E DGEMAR A VE

GAT EWAYDR

FIRECREST AVE

OCEANA BLVD

SHARP PARK RD TALBO T AVE

MOANAW AY
Water
Recycling
Plant
·|þ}35
·|þ}1
MILES
0 1/4 1/2 1 2
Figure 8-X:

Mapped Landslides
Planning Area
City Limits
Mapped Landslide
Source: Department of Conservation, 2022;
City of Pacifica, 2020; San Mateo County, 2020;
Dyett & Bhatia, 2020.

Note: Some landslides outside the Planning
Area boundary are not shown.

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Packet Pg. 642 Attachment: Attachment D - Figure 8-X Mapped Landslides (Revised following Planning Commission hearing) (5035 : Consideration of Figure 8-3b 1.e
Packet Pg. 643 Attachment: Attachment E - Figure 8-3b Debris Flows (Revised following Planning Commission hearing) (5035 : Consideration of Adoption of General Plan Update and
Sharp Park Specific Plan
Final Environmental Impact Report
SCH: 2012022046
May 25, 2022
City of Pacifica

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Packet Pg. 644 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 1 Introduction
This Program Final Environmental Impact Report (EIR) has been prepared by the City of Pacifica (City) in accordance with the California Environmental Quality Act (CEQA). The City is the lead agency responsible for ensuring that the proposed City of Pacifica General Plan Update and Sharp Park Specific Plan (“Plan” or “Proposed Project”) complies with CEQA.

1.1 Purpose
The Final EIR includes the Draft EIR and this document, which includes comments on and responses to comments on the Draft EIR, and minor corrections and clarifications to the Draft EIR.

It is intended to disclose to City decision makers, responsible agencies, organizations, and the general public, the potential impacts of implementing the proposed General Plan and Sharp Park Specific Plan (also referred to as the “General Plan,” “Proposed Plan,” or “Proposed Project”). This program level analysis addresses potential impacts of activities associated with implementation of the General Plan, which are described in Chapter 2: Project Description, of the Draft EIR.

The primary purpose of the Final EIR is to revise and refine the environmental analysis in the Draft EIR, published January 7, 2022 in response to comments received during the public review period.

The extended review period for the Draft EIR (State Clearinghouse No. 2012022046) ran for 58 days, from Monday, January 10, 2022 to March 8, 2022.

This document, combined with the redlined Draft EIR, constitutes the Final EIR on the project.

This Final EIR amends and incorporates by reference the Draft EIR. The Draft EIR, along with the City of Pacifica General Plan, are available at the City’s General Plan Update webpage at the following link:
https://www.planpacifica.org/project-docs
The Draft EIR contains some impacts that are significant and unavoidable despite mitigating policies, specifically impacts to transportation. Irretrievable commitments of non-renewable resources associated with the Project are identified in the Draft EIR for the resource topics of air quality, water consumption, energy sources, and construction-related impacts. Other potentially significant impacts can be avoided or reduced to levels that are less than significant through implementation of the policies identified in the Draft EIR.

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Packet Pg. 645 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) Pacifica General Plan Final Environmental Impact Report Chapter 1: Introduction
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1.2 CEQA Process
Upon publication of the Final EIR, the City Council will hold public hearings to certify the EIR and to consider adoption of the proposed General Plan. Before the City Council may approve the various discretionary actions needed on the proposed Project, it must independently review and consider the information contained in the Final EIR, certifying that the Final EIR adequately discloses the environmental effects of the Plan, that the Final EIR has been completed in conformance with CEQA, and that the decision-making body of the Lead Agency independently reviewed and considered the information contained in the Final EIR. Certification of the Final EIR would indicate the City’s determination that the Final EIR adequately evaluates the environmental impacts that could be associated with the General Plan.

For impacts identified in the EIR that cannot be reduced to a level that is less than significant, the City must make findings and prepare a Statement of Overriding Considerations for approval of the Project if specific social, economic, or other factors justify the Plan’s unavoidable adverse environmental effects.

If the City decides to approve the proposed Project for which the Final EIR has been prepared, it will issue a Notice of Determination.

The City of Pacifica has prepared this document pursuant to CEQA Guidelines Section 15132 which specifies that the Final EIR shall consist of:
• The Draft EIR or a revision of the Draft
• A list of persons, organizations, and public agencies commenting on the Draft EIR • Comments and recommendations received on the Draft EIR • The response of the Lead Agency to significant environmental points raised in the review process
• Any other information added by the Lead Agency
This Final EIR incorporates comments from public agencies and the general public. It also contains the Lead Agency’s responses to those comments. Copies of the Final EIR have been provided to agencies and other parties that commented on the Draft EIR or have requested the Final EIR.

The Final EIR is also available online at:
https://www.planpacifica.org/project-docs.

1.3 New Information in the Final EIR
If significant new information is added to an EIR after notice of public review has been given, but before final certification of the EIR, the Lead Agency must issue a new notice and recirculate the EIR for further comments and consultation. None of the corrections or clarifications to the Draft EIR identified in this document constitutes significant new information pursuant to Section 15088.5 of the CEQA Guidelines.

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The new information added to this EIR merely clarifies and makes insignificant changes to an adequate EIR. Specifically, the new information, corrections, or clarifications presented in this document do not disclose that:
• A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;
• A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance; • A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it; or • The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

As a result, a recirculation of the Draft EIR is not required. Information presented in the Draft EIR and this document support this determination.

1.4 Organization
This document contains the following components:
• Chapter 2 provides master responses to comments raised in multiple comment letters from the Draft EIR. The master responses address comments related to general issues that are common throughout several comment letters. The intent of a master response is to provide a comprehensive response to an issue so that all aspects of the issue are addressed in a coordinated, organized manner in one location and avoid repetition. • Chapter 3 lists all of the agencies, organizations and individuals that submitted written comments on the Draft EIR, reproduces all comments, provides a unique number for each EIR comment in the page margin, and provides numbered responses to comments. • Appendix A contains attachments to the Comments in Chapter 2. • Appendix B contains the redlined DEIR.

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Packet Pg. 648 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 1 2 Master Responses
Numerous comments raised common concerns or questions that are most appropriately answered or clarified in one comprehensive or “master” response. For this Final EIR, the issues listed in Table 2.1-1 are addressed in Master Responses, lettered MR-1 to MR-7. The intent of the Master Responses is to give a single, comprehensive response to the recurring comments to improve readability of the document by avoiding repetition and multiple cross-references. Many of the individual responses refer back to these Master Responses.

Table 2.1-1: Master Response List
Master Response Title Page Number
MR-1 EIR Comments vs. Planning-Related Comments 1
MR-2 Programmatic EIR and Level of Detail Analysis 2
MR-3 Buildout and RHNA 4
MR-4 Undeveloped San Pedro Avenue Sites 5
MR-5 Wildfire 10
MR-6 Environmentally Sensitive Habitat Areas (ESHA) 12
MR-7 Emergency Access 17
MASTER RESPONSE 1: EIR COMMENTS VS. PLANNING-RELATED COMMENTS Some of the comments received during the comment period were expressions of support of or opposition to the content of Proposed Plan, rather than comments on the adequacy of analysis in the draft environmental impact report (DEIR). This response clarifies the City’s legal obligation to address California Environmental Quality Act (CEQA) related comments and describes how the City will respond to General Plan or Specific Plan-related questions or issues raised.

Public Resources Code Section 21091(d) (California Environmental Quality Act (CEQA)) and CEQA Guidelines Section 15088 require that the lead agency evaluate comments received during the noticed comment period and prepare a written response for each comment relating to any significant environmental issues raised in the DEIR. The written responses presented in this final environmental impact report (FEIR) describe the nature of any significant environmental issues raised in the comments and provide a good-faith, reasoned response to each comment. The range of responses includes providing clarification on the DEIR, making factual corrections, explaining why certain comments may not warrant further response, or simply acknowledging the comment for consideration by the decision-making bodies.

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Packet Pg. 649 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 2 At least 10 days prior to certifying an environmental impact report, the City must provide a written proposed response to a public agency on comments made by that agency which conforms with the requirements of CEQA.

As noted above, CEQA only requires responses to comments on the significant environmental issues raised in a DEIR, rather than to comments on the merits of the proposed project or in response to general reference materials submitted in support of comments. However, in recognition of the value of public input and the significant community interest associated with the General Plan update and Sharp Park Specific Plan, City staff will present a summary of General Plan and Specific Plan-related comments received during the public comment period to City decision-makers at public hearings for adoption of the Proposed Plan.

Additionally, to the maximum extent practicable with consideration of the City’s limited staff resources and the timeline for action on the proposed project, City staff will strive to provide thematic responses to all public comments received on issues unrelated to the DEIR. Importantly, all comments received – whether related to the General Plan update and Sharp Park Specific Plan or the DEIR - will be included in the FEIR and become part of the public record.

Consideration of project merits is important and the decision makers in the City of Pacifica will consider all comments regarding the merits as part of deliberations on the proposed project and when making any necessary findings. The Planning Commission and City Council will hold publicly‐noticed hearings to consider action on the project, which will include consideration of the project merits.

MASTER RESPONSE 2: PROGRAMMATIC EIR AND LEVEL OF DETAIL OF ANALYSIS Several comments claim that the DEIR does not provide adequate environmental analysis at the site level.

This master response is prepared to clarify the role of this DEIR and the level of detail of analysis required for a programmatic document.

The Pacifica General Plan EIR is a program EIR, defined in Section 15168 of the CEQA Guidelines as: “[An EIR addressing a] series of actions that can be characterized as one large project and are related either: (1) Geographically; (2) A[s] logical parts in the chain of contemplated actions; (3) In connection with the issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program; or (4) As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental impacts which can be mitigated in similar ways.” The CEQA Guidelines in Section 15618 further provide a discussion of the advantages of a program EIR, which include use as a starting point for environmental review with later activities, use with subsequent EIRs and negative declarations, and noticing for later activities:

Advantages. Use of a program EIR can provide the following advantages. The program EIR can: (1) Provide an occasion for a more exhaustive consideration of effects and alternatives than would be practical in an EIR on an individual action; (2) Ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis, (3) Avoid duplicative reconsideration of basic policy considerations, (4) Allow the Lead Agency to consider broad policy alternatives and program-wide

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Packet Pg. 650 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 3 mitigation measures at an early time when the agency has greater flexibility to deal with basic problems or cumulative impacts, and (5) Allow reduction in paperwork.

Use with Later Activities. Subsequent activities in the program must be examined in the light of the program EIR to determine whether an additional environmental document must be prepared. (1) If a later activity would have effects that were not examined in the program EIR, a new Initial Study would need to be prepared leading to either an EIR or a Negative Declaration. (2) If the agency finds that pursuant to Section 15162, no new effects could occur or no new mitigation measures would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document would be required. (3) An agency shall incorporate feasible mitigation measures and alternatives developed in the program EIR into subsequent actions in the program. (4) Where the subsequent activities involve site specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were covered in the program EIR. (5) A program EIR will be most helpful in dealing with subsequent activities if it deals with the effects of the program as specifically and comprehensively as possible. With a good and detailed analysis of the program, many subsequent activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required.

Use with Subsequent EIRs and Negative Declarations. A program EIR can be used to simplify the task of preparing environmental documents on later parts of the program. The program EIR can:
(1) Provide the basis in an Initial Study for determining whether the later activity may have any significant effects; (2) Be incorporated by reference to deal with regional influences, secondary effects, cumulative impacts, broad alternatives, and other factors that apply to the program as a whole. (3) Focus an EIR on a subsequent project to permit discussion solely of new effects which had not been considered before.

Notice with Later Activities. When a law other than CEQA requires public notice when the agency later proposes to carry out or approve an activity within the program and to rely on the program EIR for CEQA compliance, the notice for the activity shall include a statement that: (1) This activity is within the scope of the program approved earlier, and (2) The program EIR adequately describes the activity for the purposes of CEQA.

A program EIR differs from a project EIR, which is the most common type of EIR and examines the environmental impacts of a specific development project. A project EIR “should focus primarily on the changes in the environment that would result from the development project [and] examine all phases of the project including planning, construction, and operation.” (CEQA Guidelines, Section 15161; In re Bay Delta etc. (2008) 43 Cal.4th 1143, 1169.)
A program EIR can be used as the basic general environmental assessment for an overall program of projects such as the Pacifica General Plan and Sharp Park Specific Plan intended to be developed over a 20-year

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Packet Pg. 651 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 4 planning horizon. A program EIR has several advantages. First, it provides a basic reference document to avoid unnecessary repetition of facts or analysis in subsequent project-specific assessments. Second, it allows the lead agency to look at the broad, regional impacts of a program of actions before its adoption and eliminates redundant or contradictory approaches to the consideration of regional and cumulative effects.

As a programmatic document, this EIR presents a citywide assessment of the potential impacts of the proposed Pacifica General Plan. It does not assess project-specific impacts of potential future projects under the proposed Plan, all of which are required to comply with CEQA as applicable.

MASTER RESPONSE 3: BUILDOUT AND REGIONAL HOUSING NEEDS ALLOCATION (RHNA) Several comments claim that the DEIR underestimates the potential environmental impacts of the General Plan because buildout projections do not use estimates of maximum theoretical buildout or provide capacity to address Pacifica’s Cycle 6 Regional Housing Needs Allocation (RHNA). This master response has been prepared to clarify the purpose and uses of buildout projections in the CEQA process and to correct mischaracterizations in the public comments regarding the adequacy of buildout projections in the DEIR.

Buildout projections represent a forecast of the amount of residential and non-residential development likely to result from implementation of the Proposed Plan and they provide a reasonable basis for quantifying potential environmental impacts of the Proposed Plan. In the DEIR analysis, projected 2040 buildout is used as the basis for technical modeling of air quality and GHG emissions, noise, vehicle miles travelled (VMT), and utilities capacity, as well as for an assessment of public services capacity among other topics.

For the DEIR, a projection of likely buildout of the Proposed Plan was developed based on the realistic potential for development in the Planning Area. As noted on DEIR p. 2-20, buildout is calculated based on assumptions about new residential and non-residential development that could be built under the Plan’s land use designations and their respective densities and intensities, adjusted to match expected demand as assessed through an adjusted regional projection from the 2019 Association of Bay Area Governments 2040 growth forecasts. To identify areas of possible change, vacant and underutilized parcels were identified, and capacity was projected based on economic and market conditions, historical growth trends, and approved development in the pipeline.

Buildout projections were calculated on a parcel basis; however, the assumptions for particular sites do not guarantee that any given site will be developed or redeveloped with that use or assumed density during the planning period, as future development will rely primarily on each property owner’s initiative.

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Packet Pg. 652 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 5 Cumulatively though at the citywide level these projections represent a reasonably foreseeable basis for assessing the environmental impacts that could result from Proposed Plan implementation.

Cal Code Regs. Tit. 14§ 15144 recognizes that drafting an EIR necessarily involves some degree of forecasting and requires that the lead agency “use its best efforts to find out and disclose all that it reasonably can.” Further, the statute allows for the use of projected future conditions that are supported by reliable projections based on substantial evidence in the record.

Therefore, it is unreasonable to assume every parcel in the city will be built out at the maximum permitted under the applicable land use designations. Furthermore, using maximum theoretical buildout as the basis for the CEQA analysis would exaggerate impacts and result in mitigation measures requiring the construction of road and utility infrastructure in excess of what is actually needed to support growth resulting from the Proposed Plan. Therefore, the DEIR correctly used a reasonably foreseeable forecast of buildout under the Proposed Plan as the basis for the environmental analysis.

With respect to the second claim that the buildout projections used in the DEIR are inadequate because they do not accommodate Pacifica’s Sixth Cycle RHNA, the City notes that the Proposed Plan is a technical update to the 2014 Draft General Plan Update prepared previously and that the scope of the project did not include substantial land use changes outside of the Sharp Park Specific Plan area or include community engagement to inform such changes. As described on DEIR p. 1-2, the 2014 General Plan update process began with a visioning phase, initiated by the City of Pacifica in the spring of 2009. This project was carried out almost to adoption, and then put on hold in 2014; work resumed on the General Plan update in February 2019, including the addition of a specific plan for the Sharp Park area. In the summer of 2019, a period of community outreach sought to re-familiarize community members with the Plan Pacifica process and work to date and gather more information to reflect more current community priorities.

At a joint study session on September 3, 2019, the City Council reviewed a limited set of land use changes developed on the basis of community outreach conducted in 2019 and directed City staff and consultants to update the 2014 Draft General Plan accordingly and prepare a Draft EIR. Subsequently, in May 2021 the Association of Bay Area Governments (ABAG) released draft RHNA numbers for Pacifica. These draft RHNA numbers were adopted as final RHNA numbers by the ABAG Board in December 2021. To accommodate these new RHNA numbers, it is likely that Pacifica will need to consider additional land use changes; however, such changes were beyond the scope of the Proposed Project. Rather than start the General Plan and EIR process over again and delay adoption by an additional two years, the City elected to proceed with the Proposed Plan knowing that additional land use changes, community engagement and environmental analysis will be needed for the Housing Element. The updated General Plan will provide a better basis for the subsequent Housing Element update. Furthermore, as noted in the master response

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Packet Pg. 653 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 6 “Level of Detail of Analysis and Programmatic Nature of the Draft EIR,” certification of the DEIR will provide a useful programmatic starting point for consideration of any additional land use changes that may be needed to accommodate the City’s 6th cycle Housing Element update to accommodate its RHNA.

Separately, the City is preparing to initiate its 6th cycle Housing Element update. The Housing Element update and development of the required housing sites inventory will involve extensive community input and be subject to separate CEQA review. At this point, the City has not identified the locations of any new housing sites, so they cannot be analyzed as part of this CEQA process. The Housing Element CEQA document will analyze the cumulative effects of implementing the Housing Element Update – including any associated changes to the land use diagram - in combination with the Proposed Plan. Therefore, this approach does not constitute “piecemealing,” or dividing a large project into separate parts, each of which might have individually minimal environmental consequences.

MASTER RESPONSE 4: UNDEVELOPED SAN PEDRO AVENUE SITES
Nearly two-thirds of the overall total public comments on the DEIR related to two undeveloped properties under different ownership, the 0.92-acre 505 San Pedro Avenue site and the approximately 5.5-acre “undeveloped San Pedro Avenue” site. Several of these comments claim that designating the 505 San Pedro Avenue and undeveloped San Pedro Avenue sites as Coastal Residential Mixed Use in the proposed General Plan would result in significantly greater environmental impacts than other land use designations to be applied, such as Low Intensity Visitor Serving Commercial. Further, commenters claim that the designation is not consistent with the Coastal Act, and that the DEIR did not adequately analyze potential biological, geological, and hydrological impacts associated with development on the site pursuant to the Proposed Project. This Master Response has been prepared to clarify what can be developed on this site under the Proposed Project, to address the mischaracterization of Coastal Act inconsistency, and to address perceived inadequacies in analysis of impacts related to biological resources, geological hazards, and coastal flooding on the site.

The site’s proposed designation would allow for development similar to that currently allowed in the 1980 LCLUP and the existing General Plan. Under the current, adopted General Plan, the site has a Commercial land use designation, which “[i]ndicates the variety of potential commercial uses the City might attract, including visitor-serving commercial, retail commercial, office, heavy commercial and light industrial. The type of commercial use recommended for a site is stated in the General Plan Land Use Description” (Pacifica General Plan, p. 33). Residential uses are also permitted above commercial uses, at a density of up to 1 unit per 2,000 square feet of site area, which translates to approximately 22 units per acre. The Proposed Project introduces a new Coastal Residential Mixed Use (CRMU) designation which would apply to the “undeveloped San Pedro Avenue” site. The proposed CRMU designation would establish a set of permitted uses that is more closely tailored to visitor orientation and to the coastal setting, with building form guidance that would result in small-scale buildings more suited to the neighborhood context, as compared to the existing zoning, which permits a wide range of commercial activities from retail shops and fast food restaurants, to home appliance and furniture sales and veterinary hospitals and clinics. As described in the Land Use Framework section of the Proposed Plan, “the Coastal Residential Mixed Use (CRMU)

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Packet Pg. 654 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 7 designation is intended for sites in the Coastal Zone with residential mixed use development potential, including housing at a range of densities, mixed use with housing over retail, and/or small-scale visitororiented commercial uses such as vacation rental or time-share units. Hotels are not permitted. Coastal access and public open space must also be provided, and environmental resources must be evaluated and protected. Sites may be developed up to an overall density of up to 15 units per gross acre, with clustering and sensitive site planning. Non-residential development may have an FAR up to 0.5 FAR. The total FAR (residential and non-residential) cannot exceed 1.0” (proposed General Plan, p. 4-7).

The proposed CRMU designation for the undeveloped San Pedro Avenue site is complemented with proposed Policy LU-I-29, which provides direction for the zoning standards through which it would be implemented:
“Undeveloped San Pedro Avenue Site. Establish a Coastal Residential Mixed Use zoning district to allow small-scale visitor-oriented commercial uses as a stand-alone project without any residential development, or small-scale visitor-oriented commercial uses with residential development at a density range of three to five units per gross acre. Housing may be clustered, and uses may be mixed, vertically or horizontally.

Residential uses may be constructed attached to or detached from commercial uses, provided the overall site contains both commercial and residential uses. Development must include public coastal access and must provide public open space.

A wetland survey conducted according to the requirements of Coastal Commission regulation 13577 (Title 14, California Code of Regulations) is required to delineate potential wetlands on the site as part of the development application and environmental review process. An assessment of potential geotechnical hazards must also be part of the development application and environmental review process, including assessment of the Ocean Shore railroad berm under hazard and vulnerability scenarios consistent with policies in Chapters 7 and 8.”
Therefore, given that the Proposed Project would permit a more circumscribed set of land uses as compared to the current General Plan with less potential for pollution (as compared, for instance, to heavy commercial and light industrial uses) and a reduced development intensity – up to 5 units per acre and 15 units per acre for the undeveloped San Pedro Avenue and 505 San Pedro Avenue sites, respectively, as compared to the current General Plan which would allow up to 22 units per acre – the City notes that the proposed CRMU designation would likely result in reduced environmental impacts on the site. Further, the DEIR considered alternatives to the Proposed Project which could further reduce or avoid environmental impacts on these sites. On pages 4-12 through 4-32, the DEIR analyzes the impacts of Alternative 2: Conservation and Redevelopment under which the 505 San Pedro Avenue site would be designated Conservation, and a portion of the undeveloped San Pedro Avenue site is designated as a park, as shown in Figure 4.2-3. The purpose of this alternative was to create several mixed use nodes between four smaller centers in a sequence along the Coast Highway and a limited amount of development on the Quarry site, with the great majority conserved as habitat or open space. However, as discussed on page 4-32 of the DEIR, while Alternative 2 would result in fewer environmental impacts overall than the Proposed Project, it would not satisfy project objectives for establishment of a strong City center, integration of the Quarry site into the City’s fabric, and

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Packet Pg. 655 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 8 provision of residential development needed for future housing planning, and it was therefore determined to be infeasible.

Several commenters assert that applying a “Conservation” or “Low Intensity Visitor Serving Commercial” designation to the whole of the undeveloped San Pedro Avenue and 505 San Pedro sites would result in lesser environmental impacts. However, designation of the entirety of these sites as Conservation would limit economic use of the property. Also, specific to the 505 San Pedro site in particular, the site does not have the “large land areas” expected to support recreational uses assumed for sites designated as Low Intensity Visitor Serving Commercial. The Pacifica City Council weighed these considerations and adopted the LCLUP on February 24, 2020, which included both San Pedro Avenue sites with a CRMU designation, as well as the implementing policy LU-I-24.

Some commenters assert that the DEIR did not analyze site-specific impacts. As noted in Master Response 2, the DEIR is a programmatic document. It presents a citywide assessment of the potential impacts of the proposed Pacifica General Plan. Given that the specific details of projects pursuant to the Proposed Project cannot be known at this time, the DEIR does not assess project-specific impacts of potential future projects, for which project-level CEQA review will be required to the extent such projects may result in environmental impacts not considered in the DEIR. Additionally, LCLUP updates are exempt from CEQA because the Coastal Commission LCP certification process is “functionally equivalent” to the CEQA process (State Public Resources Code Sections 21080.5 and 21080.9, and State CEQA Guidelines Sections 15250, 15251(f) and 15265). However, as explained in detail below and throughout the DEIR, the DEIR does analyze at a programmatic level the potential environmental impacts resulting from proposed land use changes for the whole of the Planning Area including the Coastal Zone, and considers whether implementation of the Proposed Project could cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect (in this case, the Coastal Act).

Updates to the General Plan and Local Coastal Land Use Plan (LCLUP) have been conducted in tandem.

All policies and land uses in the LCLUP are in the proposed General Plan. To the extent the General Plan Update proposes any policies beyond those which were sent to the California Coastal Commission for review and certification, a subsequent LCP amendment would be necessary to make the LCP consistent with the General Plan. The Coastal Commission has permitting jurisdiction for certain areas within the Coastal Zone and appellate jurisdiction over many other areas in the Coastal Zone, and projects are required to demonstrate compliance with Coastal Act and/or certified LCLUP policies regardless of whether they are located in the Coastal Commission’s permit jurisdiction, its appellate jurisdiction, or within the City’s permit jurisdiction pursuant to the City’s certified LCP. Importantly, the City would be unable to issue any coastal development permits for areas within its permit jurisdiction in the Coastal Zone until the Coastal Commission has certified that the updated LCLUP (reflective of identical policies in the Proposed Project) is consistent with the Coastal Act.

Commenters stated that that the CRMU designation for this area was incompatible with the following Coastal Act policies that are also related to environmental impacts:

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Packet Pg. 656 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 9 • Cal. Pub. Resources Code § 30221: Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area.
• Cal. Pub. Resources Code § 30222: The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not over agriculture or coastal-dependent industry.
• Cal. Pub. Resources Code § 30240: (a) Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on those resources shall be allowed within those areas.
• Cal. Pub. Resources Code § 30251: The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas. • Cal. Pub. Resources Code § 30253: New development shall do all of the following:
(a) Minimize risks to life and property in areas of high geologic, flood, and fire hazard. (b) Assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs.

Regarding land use compatibility and parks services impacts raised in Coastal Act Policy 30221 and 30221, as described on pages 3.1-12 and 3.12-24-25 of the DEIR, the proposed CRMU designation establishes a set of uses that is more closely tailored to visitor orientation and to the coastal setting, and building form guidance that would result in small-scale buildings more suited to the neighborhood context, compared to the existing zoning, while allowing the property owner some economic benefit to their property. Policy LUI-29, along with OC-I-9 (Parks as Part of Future Development, DEIR p. 3.12-40) adequately address these policies and reduce these impacts to the extent feasible for a programmatic document.

As noted in Master Response 6: Environmentally Sensitive Habitat Areas (ESHA), compliance with applicable federal and State regulations, in addition to policies in the Proposed Project, reduce any potential impacts to ESHA to a less than significant level. Policy LU-I-29 also requires delineation of potential wetlands on the undeveloped San Pedro Avenue site as part of the development application and environmental review process. These regulations and policies, taken together, are compatible with Coastal Act policy 30240.

As noted on DEIR p. 3.9-13, the land use changes in the Proposed Project will not substantially degrade the existing visual character or quality of Pacifica and would not conflict with applicable zoning and regulations

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Packet Pg. 657 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 10 governing scenic views. All existing open space areas are preserved and scenic resources are protected under the Proposed Project. Policies and design guidelines included in the Proposed Project will sensitively govern the formal characteristics of new development to ensure they are compatible with existing neighborhood character and quality. The Coastal Act requires scenic and visual qualities of coastal areas to be considered and protected as a resource of public importance; compliance with these policies and with zoning requirements reduce impacts to less than significant and are not in conflict with Coastal Act policy 30251.

Regarding impacts to Coastal Act Policy 30253, the DEIR adequately analyzes impacts that could result from flooding, seismic hazards, and wildfire (Please see Master Response 5: Wildfire).

The DEIR includes a robust analysis of potential liquefaction impacts on p. 3.6-25 and 3.6-26, noting "The impacts from ground failure, including liquefaction, from development of land uses associated with the General Plan would be addressed through site-specific geotechnical studies prepared in accordance with [California Building Code (CBC)] requirements and standard industry practices. Subsequent development would be required to conform to the current seismic design provisions of the CBC to minimize losses from ground failure as a result of an earthquake. These future projects would also be required to adhere to proposed General Plan policies that contain seismic safety requirements and help strengthen existing code requirements such as referencing known hazard areas that must contain measures to resist ground failure through modern construction techniques. Therefore, the potential impact related to seismically related ground-failure including liquefaction is less than significant." The undeveloped San Pedro Avenue site is in a Seismic Hazard Zone for liquefaction, as shown in Figure

3.6-1. The DEIR notes that on p. 3.6-18 and 3.6-19, "Geotechnical investigations conducted within Seismic Hazard Zones must incorporate standards specified by the California Geologic Society (CGS) Special Publication 117, Guidelines for Evaluating and Mitigating Seismic Hazards".

While the undeveloped San Pedro Avenue and 505 San Pedro Avenue sites are not within a FEMA floodplain (as shown in Figure 3.5-1), they could be adversely affected by flooding due to sea level rise. Prior to experiencing inundation hazards from a higher sea level rise, some developed areas are likely to be subject to changes in flooding hazards as stated on page 3.5-28 of the Draft EIR. Low coastal floodzone areas could expand over time as sea levels rise. The use of maps such as those found in the 2009 California Climate Change report (The Impacts of Sea-Level Rise on the California Coast) are not recommended to be used in place of official FEMA FIRM floodzone maps. The FIRM maps are periodically updated and future maps will likely incorporate the latest findings of sea level rise as it becomes more defined. Nonetheless, the Draft EIR on page 3.5-8 and 3.5-11, identifies the areas within the City that could be subject to increased flooding hazards (i.e., areas of West Linda Mar, lower Pedro Point, Rockaway Beach, West Sharp Park and the Sharp Park Golf Course). Further, the proposed policies including SA-G-4 (Key Coastal Act Policies), SA-G-5 (Sea Level Rise and Best Available Science), SA-I-15 (New Development in Coastal Zone), SA-I-28 (Vulnerability Identification and Mapping), and SA-I-30 (Monitoring Shoreline Change) specifically address the potential hazards of sea level rise and provide the flexibility in making the appropriate adjustments as the science improves to ensure that future development is adequately protected.

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Packet Pg. 658 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 11 Overall, the City notes that the CRMU designation envisions development in a manner that is consistent with the objectives of the Coastal Act, and the DEIR adequately analyzes potential impacts to plan compatibility, biological resources, seismic hazards, and coastal flooding, and makes appropriate determinations on the basis of substantial evidence. Further, the City reiterates that any development on the undeveloped San Pedro Avenue or 505 San Pedro Avenue sites pursuant to the Proposed Project will be required to comply with all applicable federal, State and local regulations and policies, including for biological resources (including the Federal Endangered Species Act, California Endangered Species Act, Section 404 of the Clean Water Act, San Francisco Regional Water Quality Control Board, California Coastal Commission) and hydrological or geological impacts (including the National Flood Insurance Act, California Coastal Act, General Construction Permits and Dewatering Permits, San Mateo Countywide Stormwater Pollution Prevention Program (SMCWPPP), the Multi-Jurisdictional Local Hazard Mitigation Plan, and the California Building Code. Compliance with these regulatory frameworks, coupled with the beneficial impacts of the Proposed Plan policies listed above, reduce impacts to less than significant.

MASTER RESPONSE 5: WILDFIRE
Numerous comments expressed concern that the Proposed Project’s analysis of wildfire risk was inadequate, including inadequacies resulting from alleged map errors or from a failure to consider additional data beyond California Department of Forestry and Fire Protection (CALFIRE) Very High Fire Severity Zone maps, such as Wildland Urban Interface (WUI) mapping. This master response has been developed to address comments from the public regarding these perceived inadequacies in mapping and analysis, to clarify the requirements for analysis of wildfire risk pursuant to CEQA and the sources of data used, and to correct factual errors and misrepresentations presented in those public comments.

The DEIR characterizes wildfire hazards within the Planning Area on pages 3.11-4 through 3.11-6 and 3.14- 1 through 3.14-4, making use of data and information from CALFIRE and from the Multi-Jurisdictional Local Hazard Mitigation Plan (MJ-LHMP) for San Mateo County. The characterization in the DEIR includes a description of vegetation in the Planning Area, a history of wildfire occurrence in the Planning Area, the probability of a fire occurring in the future, and identification of Fire Hazard Severity Zones designated by CALFIRE based on factors such as fuel, slope, and weather. Two maps are included:
• Figure 3.11-2, which shows Very High Fire Severity Zones for Local Responsibility Areas (LRAs), State Responsibility Areas (SRAs), and Federal Responsibility Areas (FRAs) as designated by CALFIRE pursuant to Government Code Section 51175. By law CALFIRE is required to designate these Fire Hazard Severity Zones, land within which is subject to various requirements in the California Building Code for the design and construction of new buildings intended to reduce the risk of loss of life and property, including requirements for building materials, defensible space clearance, and other wildland fire safety practices; and • Figure 3.14-1, which shows Fire Threat, a measure of fuel conditions and fire potential in the ecosystem, representing the relative likelihood of “damaging” or difficult to control wildfire occurring for a given area. Fire Threat is not a risk assessment by itself, but can be used to assess

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Packet Pg. 659 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 12 the potential for impacts on various assets and values susceptible to fire. Impacts are more likely to occur and/or be of increased severity for the higher threat classes.

The data and information referenced in the DEIR, including the data used to prepare the above referenced maps, was the latest and most current available at the time the NOP was released and remains the most current available as of publication of this FEIR. It should be noted that WUI mapping referenced by commenters is an initial step taken by CALFIRE to identify areas where fuels transition from natural vegetation materials to human-improved materials (usually structures). WUI maps are used for a variety of different purposes and in and of themselves do not necessarily identify areas of significant hazard exposure.

WUI maps inform development of Fire Hazard Severity Zones designated by CALFIRE, and the Fire Hazard Severity Zone maps adopted by the State depict only WUI areas that include both a hazard and a housing demographic element (ie an exposure model)[1]. While CALFIRE is currently in the process of updating its mapping to incorporate improved fire science, data and mapping techniques and while that process may ultimately identify new areas where California’s defensible space standards and wildland urban interface building codes are required, updated mapping is not currently publicly available. Therefore, the data and information used in the DEIR represent the latest best available data at time of preparation.

Under CEQA, the DEIR is required to analyze effects from wildfire in two ways. First, the DEIR must analyze if the project would expose people to significant risk of loss, injury, or death involving wildland fires (Appendix G, Criterion IX (g)). Second, if the project is located in or near state responsibility areas or lands classified as very high fire hazard severity zones (Appendix G, Criterion XX(a) through (d)), it must analyze whether the project would impair an adopted emergency response/evacuation plan, exacerbate fire risk, or expose occupants to uncontrolled spread of a wildfire, pollutant concentrations from a wildfire, or post-fire hazards.

Using the latest and best available data, as shown on Figure 3.11-2[2], the DEIR identified that there are no VHFHSZ within the City limit, but that there are Fire Hazard Severity Zones in the Sphere of Influence, which are in areas of State responsibility. Further, using Fire Threat mapping available from CAL FIRE (Figure 3.14-1), as described on p. 3.14-14 of the DEIR, the DEIR identified that beyond CALFIREdesignated Fire Hazard Severity Zones, Pacifica has a substantial risk of wildland fires, with many areas of high threat within the Planning Area. However, as noted in the DEIR, development under the Proposed Plan is expected to occur predominantly in already-urbanized neighborhoods where risk is lower as compared to areas of higher fire threat. While it is possible that development could occur in the proximity of VHFHSZ and in areas that may face higher fire threat shown in Figure 3.11-2 and 3.14-1, there are numerous State regulations – including the requirements of the California Building Code and Public Resources Code - that require landowners to carry out activities such as maintaining defensible space and reducing vulnerability to damage or loss from wildfire, as noted on pages 3.11-11, 3.11-12, 3.14-5, and 3.14- 6 of the DEIR. Any new development occurring in areas that may be designated as VHFHSZ as part of future mapping efforts will be subject to these requirements. Additionally, the MJ-LHMP Annex for Pacifica also includes actions that would reduce the risk of loss or damage due to wildfire in and adjacent to fireprone areas, such as updating its Emergency Operations Plan (Action PAC-8); continuing public education outreach to neighborhoods (Action PAC-14); and Evacuating potential wildfire risk and mitigation strategy

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Packet Pg. 660 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 13 (Action PAC-18) in partnership with North County Fire Authority, as described on DEIR p. 3.14-6. Taken together, these State and local provisions provide a framework for proactively managing and reducing risk associated with wildfire in the Planning Area that is appropriate based on the programmatic nature of the DEIR.

Beyond areas of VHFHSZ, as noted in the DEIR, development occurring in areas of higher fire threat would be also subject to policies in the Proposed Plan that would reduce potential impacts, including development review and consistent inspection (policies SA-I-94 and SA_I-96), public awareness programming (policy SA-I-97), vegetation management policies related to development (policy SA-I-98), plan review in fireprone areas (policy SA-I-95), and coordination with North County Fire Authority and other agencies (SAI-91; SA-I-99; SA-I-102), as described on p. 3.11-24 of the DEIR.

Implementation of these policies together with applicable State and local regulations and measures would minimize fire risk to the maximum extent practicable, and accordingly the DEIR finds that impacts related to wildfire would be less than significant.
[1] Email correspondence with Dave Sapsis, Wildland Fire Scientist, CAL FIRE, dated April 11, 2022 [2] Figure 3.11-2 is based on the “Fire Hazard Severity Zones in SRA” map adopted by CALFIRE on November 7, 2007.

MASTER RESPONSE 6: ENVIRONMENTALLY SENSITIVE HABITAT AREAS (ESHA) Numerous comments expressed concern that the Proposed Project’s analysis of Environmentally Sensitive Habitat Areas (ESHAs) and the potential impacts to the habitat of the California Red-Legged Frog (CRLF), a federally listed Threatened Species, were not sufficiently analyzed or accounted for in the DEIR. These comments are specifically linked to the undeveloped land at/around 505 San Pedro Avenue (“505 San Pedro site” or “site”). This master response has been developed to address comments from the public regarding these perceived inadequacies, and to clarify and correct factual errors, misrepresentations, and assumptions in those public comments.

As defined in Coastal Act Section 30107.5, ESHA is "any 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 and developments." As noted on DEIR Figure 3.7-4, there are known occurrences of the CRLF in Pacifica, including in the vicinity of the 505 San Pedro Avenue site. Additionally, on page 3.7-17 the DEIR notes that portions of the city around Mori Point, coastal bluffs, and Sharp Park Golf Course support both CRLF as well as San Francisco garter snake and likely qualify as ESHA; however, at the time the NOP was released there was no ESHA formally delineated on the 505 San Pedro site. Subsequently, in the course of reviewing whether a Coastal Commission permit was required for development in the Coastal Zone on the 505 San Pedro site, the Coastal Commission conducted a biological study and determined that the whole of the site was ESHA; this information was presented at a hearing on March 2021. Comments allege that the DEIR analysis is inadequate because it did not acknowledge that the Coastal Commission made a determination of ESHA on the 505 San Pedro site; however, the City notes that the property owner has conducted a separate biological study by a qualified expert which concluded

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Packet Pg. 661 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 14 that the development proposed on the site would not result in direct or indirect, temporary or permanent impacts to wetlands, other waters, or any ESHA.1
In any event, irrespective of any prior findings regarding the presence of ESHA on the 505 San Pedro site, any development proposed for the site pursuant the Proposed Plan would be reviewed pursuant to applicable law and required to comply with all applicable federal, state, and local regulations. As noted on pages 3.7-41, these include:
• Federal Endangered Species Act. Pursuant to the requirements of FESA, a federal agency reviewing a proposed project within its jurisdiction must determine whether any federally listed, threatened, or endangered species, or species proposed for federal listing may be present in the project area and determine whether the proposed project will have a potentially significant impact on such species.

In addition, the federal agency is required to determine whether the project is likely to jeopardize the continued existence of any species proposed to be listed under FESA or result in the destruction or adverse modification of critical habitat proposed to be designated for such species (16 USC 1536[3], [4]). Projects that are subject to CEQA and have the potential to significantly impact listed species (as determined in an Initial Study or Environmental Impact Report) must consult with CDFW to get an Incidental Take Permit, without which development cannot legally occur. The permit requires that permit applicants design, implement, and secure funding for a Habitat Conservation Plan or "HCP" that minimizes and mitigates harm to the impacted species during the proposed project.
• California Endangered Species Act. Section 2080 of the California Fish and Game Code prohibits the taking of plants and animals listed under the authority of the California Endangered Species Act of 1984 (CESA). Under CESA, CDFG maintains a list of threatened species and endangered species (California Fish and Game Code 2070). The CDFG also maintains a list of candidate species that CDFG has formally noticed as being under review for addition to either the list of endangered species, the list of threatened species, or the list of “species of special concern,” which all serve as “watch lists.” Pursuant to the requirements of CESA, an agency reviewing a project within its jurisdiction must determine whether any state-listed endangered or threatened species may be present in the project area and determine whether the proposed project will have a potentially significant impact on such species. CESA prohibits the take of any species of wildlife designated by the California Fish and Game Commission as endangered, threatened, or candidate species. CDFW may authorize an Incidental Take Permit of any such species if certain conditions are met, without which development cannot legally occur. Incidental Take Permits allow a permittee to take a CESAlisted species if such taking is incidental to, and not the purpose of, carrying out an otherwise lawful activity. These permits are most commonly issued for construction, utility, transportation, and other infrastructure-related projects. Permittees must implement species-specific minimization and avoidance measures, and fully mitigate the impacts of the project. (Fish & G. Code § 2081 (b); Cal. Code Regs., tit. 14, §§ 783.2-783.8)
1 The Coastal Commission determined that a Coastal Commission permit was required for development at the 505 San Pedro Site, and then denied that permit. The property owner has filed suit to challenge the Coastal Commission’s action. That suit does not affect how the City analyzes the present issues.

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Packet Pg. 662 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 15 • California Coastal Commission. The Coastal Act restricts development within ESHAs to only those uses that are dependent on the resource and requires that ESHAs be protected against significant disruption of habitat values. It also requires that development in areas adjacent to ESHAs and parks and recreation areas be sited and designed to prevent degradation of those areas and to be compatible with the continuance of those habitat and recreation areas. If ESHA is determined to be on a site, the CCC may deny a project’s coastal permit, without which development cannot legally occur.

Further, the Proposed Plan also contains numerous additional policies that in combination with applicable federal, State and local regulations would reduce impacts to special status species and habitat (including ESHA) to a less than significant level. These include policies require written findings that it is consistent with all LCLUP policies (LU-I-3), protecting ESHAs from development (CO-G-11) and requiring sites to conduct a habitat survey to verify ESHA or potential ESHA (CO-I-27; CO-I-31); management of ESHA with specific regulations (CO-I-28) or specific measures (CO-I-26); and protection of California red legged frog during any construction activities (CO-I-35).

Overall, development pursuant to the Proposed Plan would be required to comply with federal and state regulations regarding endangered species, which would require take permits prior to any development occurring. Implementation of Proposed Plan policies listed above would further reduce the potential for impacts to special status species and habitats, and the DEIR correctly determined that associated impacts would be reduced to the maximum extent practicable and would be less than significant. Further, the City notes that there is a disagreement between experts regarding the presence of ESHA on the 505 San Pedro site and the City would have the opportunity to weigh all substantial evidence prior to rendering a future permit decision to authorize development on the site in the future pursuant to the Proposed Project. As such, the Coastal Commission determination of March 2021 does not constitute significant new information which would require recirculation of the DEIR.

MASTER RESPONSE 7: EMERGENCY ACCESS
Several public comments on the DEIR expressed concern that emergency access during a hazard event, especially for wildfire or tsunami evacuation, was not sufficiently analyzed or accounted for in the DEIR or that impact assessment was incorrectly deferred and would be assessed only at a project level. This master response addresses comments from the public regarding these perceived inadequacies, and clarifies and corrects factual errors, misrepresentations, and assumptions in those public comments.

Under CEQA, the DEIR is required to analyze impacts on evacuation in two ways. First, the DEIR must analyze if the project would result in inadequate emergency access (Appendix G, Criterion V (g)). Second, it must analyze if the project would substantially impair an adopted emergency response plan or emergency evacuation plan. The Proposed Project includes policies that complement other existing, adopted plans addressing emergency response and emergency evacuation, including the 2021 Multijurisdictional Local

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Packet Pg. 663 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 16 Hazard Mitigation Plan (MJ-LHMP), the Pacifica All Hazards & Evacuation Plans, and the City of Pacifica Emergency Operations Plan.

As noted on DEIR p. 3.5-45, implementation of the Proposed Project and increases in regional travel passing through Pacifica would increase the amount of vehicular traffic in and around Pacifica and may therefore increase the number of potential emergency access conflicts in the event of a disaster, which could result in a potentially significant impact. However, potential improvements to the roadway network such as the Manor overcrossing project highlighted in proposed policy CI-I-9, would contribute to mitigating the impacts of additional traffic on emergency response times. Furthermore, traffic signal preemption devices on emergency vehicles, as well as emergency sirens, will improve emergency response times in accordance with proposed policy SA-G-9 even in instances of intersection congestion during peak commute periods. Close consultation with Caltrans and the San Mateo County Transportation Authority will help to improve congestion (policies CI-G-7 and CI-G-9) and will ensure that congestion management solutions are implemented with any potential congestion increases. Other Proposed Plan policies improve mobility connections between communities and increase evacuation capacity, such as policy CI-I-1, CI-I-2, CI-I-3, and CI-I-4. The Proposed Project also provides for improved emergency access through policies that provide additional access routes and require new streets and developments meet adopted emergency access standards (CI-I-25, SA-I-94, SA-I-103, and SA-I-104). Policy SA-A-106 also addresses periodic public information programs to raise awareness of the City’s emergency preparedness programs, including evacuation routes. Community evacuation education (SA-I-35) and agency coordination (SA-I-102) also help to ensure inadequate emergency access does not occur. Given the existing framework of adopted plans addressing emergency response combined with the beneficial effects of proposed General Plan policies, implementation of the Proposed Project will ensure that inadequate emergency access does not occur and will result in a less-than-significant impact.

Further, emergency access for individual developments pursuant to the Proposed Project will also be assessed at a project level through the development review process as projects are proposed, consistent with the provisions of the Municipal Code. Project level review required by the City includes site access review for emergency vehicles and traffic control plans as needed that account for emergency vehicles.

The City notes that Proposed Project policies complement numerous other existing plans in place to address natural hazard risk, emergency preparedness, and emergency evacuation. Collectively, these plans together with the proposed General Plan provide an overarching programmatic framework that addresses emergency access and evacuation. These plans include the 2021 Multijurisdictional Local Hazard Mitigation Plan (MJ-LHMP), the Pacifica All Hazards & Evacuation Plan, and the City of Pacifica Emergency Operations Plan. The 2021 MJ-LHMP annex describes important vulnerabilities related to coastal erosion and transportation/accessibility concerns related to landslide along Highway 1. The plan identifies several hazard mitigation action items that will improve emergency access in Pacifica. Such actions include updating the City’s Emergency Operations Plan; taking action to preserve and protect critical transportation infrastructure; considering climate change in infrastructure planning; evaluating potential wildfire risk and mitigation strategies; and developing and delivering business programs and public outreach programs to promote resiliency and community preparedness. The Pacifica All Hazards

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Packet Pg. 664 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 17 and Evacuation Plan grants authority and responsibilities to centralized emergency management and divides the City of Pacifica into 14 evacuation zones, each of which has its own evacuation operations plan, detailing evacuation routes, critical sites, traffic concerns, and refuge areas. This Plan includes specific routes in areas of constrained emergency access. The City’s Emergency Preparedness and Safety Commission is responsible for disaster preparedness training in Pacifica and maintains the Emergency Operations Plan, which ensures an effective and coordinated response to disasters within the city. The City also has a Community Emergency Response Team (CERT) that supplements first-responder police and fire personnel with civilian volunteers to assist with emergency evacuation facilitation in accordance with the City’s existing plans.

Therefore, compliance with the provisions of the Municipal Code and continued implementation of the 2021 Multijurisdictional Local Hazard Mitigation Plan, the Pacifica All Hazards & Evacuation Plans, and the City of Pacifica Emergency Operations Plan in combination with Proposed Project policies would ensure that inadequate emergency access does not occur from the Proposed Project, and that it would not substantially impair an adopted emergency response plan or emergency evacuation plan. As such, the DEIR correctly found that a less-than-significant impact would result.

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Packet Pg. 665 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 1 3 Comments Received
A total of 188 comments, comment letters, and emails were received during the comment period.

Comments and responses to comments are organized by Public Agency comments and responses (section A), Pacifica Organization comments and responses (section B) and Individual/Affiliation comments and responses (section C).

Each letter or summary is identified by a designator (e.g. “Letter A1”). Specific comments within each letter or summary are identified by a designator in the page margin that reflects the sequence of the specific comment within the correspondence (e.g. “A1-1” for the first comment in Letter A1). An index is provided below in Table 3-1. Click the TOC below to jump to a response. (A) Agencies .................................................................................................................................. 15 A1. Amy Dao, BAAQMD, 2/15/2022 ..........................................................................................................16 A2: Will Kanz, CDFW, 3/8/2022 .................................................................................................................21 A3: Dr. Erik Frost, CGS, 2/1/2022 ...............................................................................................................40 A4; Adrianne Carr, NCCWD, 3/8/2022 ......................................................................................................42 A5; Rob Bartoli, San Mateo LAFCO, 3/8/2022 ...........................................................................................44 A6; Julia Koppman Norton, CCC, 3/1/2022 ...............................................................................................46 Pacifica Organizations (B) ............................................................................................................ 47 B1: Judy Heldberg, Pacifica Historical Society, 2/18/2022.........................................................................48 Individuals and Affiliations (C) .................................................................................................... 54 C1: Stan Zeavin, 3/7/2022 ............................................................................................................................55 C2: Maria Martinez-Mont, 2/11/2022 .........................................................................................................62 C3: Lisa Villasenor-Volosing, 3/8/2022 ......................................................................................................63 C4: Remi Tan, 2/26/22 ..................................................................................................................................64 C5: Remi Tan, 2/2/2022 ................................................................................................................................66 C6: Clif Lawrence, 1/30/2022 .......................................................................................................................68 C7: Debra Etienne, 2/14/22 ..........................................................................................................................69 C8: Richard Grassetti, 3/8/2022 ...................................................................................................................72 C9: Bob Boles, 3/7/2022 ...............................................................................................................................73 C10: Christine Boles, 1/27/2022 ..................................................................................................................85 C11: Monica Meagher, 3/8/2022 ..................................................................................................................87

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Packet Pg. 666 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 2 C12: Jewel Walli, 3/5/2022 ...........................................................................................................................89 C13: Christine Boles, 3/8/2022 ....................................................................................................................90 C14: William Leon, 3/3/2022 .....................................................................................................................102 C15: Allison West, 3/8/2022 ......................................................................................................................108 C16: Clifford Lawrence, 2/22/2022 ............................................................................................................111 C17: Deb MacC, 2/14/2022 ........................................................................................................................112 C18: Jim Louderback, 2/28/2022 ...............................................................................................................113 C19: Peter Loeb, 3/5/22 ..............................................................................................................................114 C20: Andre Mettier, 3/8/2022 ....................................................................................................................115 C21: Gary Emich, 3/8/2022 ........................................................................................................................122 C22: Dinah Verby, 3/8/2022 ......................................................................................................................131 C23: Therese Langille, 3/9/2022 ................................................................................................................140 C24: Joanne Gold, 3/9/2022 .......................................................................................................................141 C25: Gary Furlong, 3/7/2022 .....................................................................................................................144 C26: Dina and Robert Horan, 3/7/2022 ....................................................................................................146 C27: Cathy Glenn, 3/7/2022 .......................................................................................................................147 C28: Clif Lawrence, 2/21/2022 ...................................................................................................................149 C29: Nancy Merchant, 3/3/2022 ................................................................................................................150 C30: James Kremer, 2/20/22 ......................................................................................................................151 C31: Bradley Angel, 3/7/2022 ....................................................................................................................167 C32: Andrew Meiman, 3/7/2022 ................................................................................................................172 C33: Richard Campbell, 3/8/2022 ..............................................................................................................173 C34: Richard Grassetti, 3/8/2022 ...............................................................................................................175 C35: Deb Wong, 3/11/2022 ........................................................................................................................206 C36: Patrick Mora, 3/8/2022 ......................................................................................................................208 C37: Allison West, 3/7/2022 ......................................................................................................................210 C38: Peter Loeb, 3/7/2022 ..........................................................................................................................227 C39: Paul Totah, 2/25/2022 ........................................................................................................................229 C40: Adam Mayle, 3/7/2022 .......................................................................................................................230 C41: Adam Mayle, 3/7/2022 .......................................................................................................................235 C42: Sheila Gamble-Dorn, 3/7/2022..........................................................................................................236 C43: Sam Casillas, 3/8/2022 .......................................................................................................................238 C44: Jean Turk, 3/7/2022 ...........................................................................................................................248 C45: Jonathan Cordero, Association of Ramaytush Ohlone, 3/3/2022 ...................................................250

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Packet Pg. 667 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 3 C46: Terrell Watt, 3/8/2022 .......................................................................................................................252 C47: Cindy Abbott, 3/8/2022 .....................................................................................................................318 C48: Paul Tota, 2/25/2022 ..........................................................................................................................323 C49: Christine Boles, 2/28/2022 ................................................................................................................324 C50: Karen Clark, 3/7/2022 ........................................................................................................................365 C51: Gail Benton Shoemaker, 3/1/2022 ....................................................................................................369 C52: Suzanne Moore, 3/3/2022 ..................................................................................................................371 C53: Cherie and Bruce Chan, 3/8/2022 .....................................................................................................374 C54: Christine Boles, 3/6/2022 ..................................................................................................................384 C55: Christine Boles, 3/6/2022 ..................................................................................................................413 C56: Christine Boles, 3/6/2022 ..................................................................................................................414 C57: Christine Boles, 2/17/2022 ................................................................................................................415 C58: Rich Nahass, 2/5/2022 .......................................................................................................................416 C59: Suzanne Moore, 3/5/22 ......................................................................................................................419 C60: Dustin McGahan, 1/18/2022 .............................................................................................................420 C61: Arlene Patton, 3/2/22 .........................................................................................................................421 C62: Clif Lawrence, 1/16/2022 ...................................................................................................................423 C63: Stan Zeavin, 3/2/2022 ........................................................................................................................425 C64: Christine Boles, 1/31/2022 ................................................................................................................427 C65: Patricia McGregor, 1/30/2022 ...........................................................................................................428 C66: Stan Zeavin, 3/8/2022 ........................................................................................................................429 C67: Remi Tan, 1/5/2022 ............................................................................................................................433 C68: Patrick Mora, 3/8/2022 ......................................................................................................................435 C69: Victor Carmichael, 3/8/2022 .............................................................................................................436 C70: Rick Nahass, 2/6/2022........................................................................................................................440 C71: Arlene Patton, 3/2/2022 .....................................................................................................................441 C72: Pete Shoemaker, 2/2/2022 .................................................................................................................442 C73: Erin Macias, 1/20/2022 ......................................................................................................................443 C74: Elizabeth Rubenstein, 1/19/2022 .......................................................................................................447 C75: Peter K, 1/18/2022 ..............................................................................................................................448 C76: David Patton, 2/15/2022 ....................................................................................................................451 C77: Sue Digre, 3/8/2022 ............................................................................................................................452 C78: Sue Digre, 3/8/2022 ............................................................................................................................459 C79: Pete Shoemaker, 2/17/2022 ...............................................................................................................460

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Packet Pg. 668 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 4 C80: Christine Boles, 1/16/2022 ................................................................................................................462 C81: Margaret Goodale, 1/25/2022 ............................................................................................................464 C82: Vicki Sundstrom, 3/8/2022 ................................................................................................................465 C83: Erin Macias, 1/18/2022 ......................................................................................................................472 C84: Rick Nahass, 1/30/2022......................................................................................................................477 C85: Erin Macias, 1/18/2022 ......................................................................................................................482 C86: Christine Boles, 1/20/2022 ................................................................................................................484 C87: Christine Boles, 2/10/2022 ................................................................................................................487 C88: Jim Louderback, 1/16/2022 ...............................................................................................................488 C89: Bill Collins, 2/21/2022 .......................................................................................................................489 C90: Necesse, 1/20/2022 .............................................................................................................................490 C91: Suzanne Buckley, 2/9/2022 ................................................................................................................492 C92: Necesse, 1/20/2022 .............................................................................................................................493 C93: Necesse, 1/19/2022 .............................................................................................................................494 C94: Rick Nahass, 2/20/2022......................................................................................................................496 C95: Mark Hubbell, 3/8/2022 ....................................................................................................................498 C96: Judy Yamahiro, 1/26/2022 .................................................................................................................502 C97: Christine Boles, 1/29/2022 ................................................................................................................503 C98: Christine Boles, 1/7/2022 ..................................................................................................................504 C99: Michelle Pitte, 2/17/2022 ...................................................................................................................505 C100: Shona Keating, 3/8/2022 ..................................................................................................................506 C101: Christine Boles, 1/11/2022 ..............................................................................................................510 C102: Patricia R. McGregor, 2/11/2022 ....................................................................................................511 C103: Alex Strachan, 1/19/2022 .................................................................................................................512 C104: Penelope Keating, 3/8/2022 .............................................................................................................513 C105: Kathi Porter, 1/19/2022 ...................................................................................................................514 C106: Debbie Young Lynch, 1/17/2022 .....................................................................................................515 C107: Ellen Natesan, 3/6/2022 ...................................................................................................................516 C108: John Keener, 2/17/2022 ...................................................................................................................539 C109: Mark Hubbell, 2/21/2022 ................................................................................................................541 C110: Christine Boles, 1/8/2022 ................................................................................................................542 C111: Reina Heinz, 3/8/2022 .....................................................................................................................546 C112: Margaret Goodale, 2/20/2022 ..........................................................................................................552 C113: Margaret Goodale, 2/11/2022 ..........................................................................................................555

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Packet Pg. 669 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 5 C114: Andy Narraway, 3/2/2022................................................................................................................557 C115: Camille Keating, 3/8/2022 ...............................................................................................................558 C116: Henry Ruhnke, 3/8/2022 .................................................................................................................563 C117: Pete Shoemaker, 2/16/2022 .............................................................................................................564 C118: Pete Shoemaker, 1/31/2022 .............................................................................................................565 C119: Michael Vasey, 2/20/2022 ................................................................................................................566 C120: John Sharp, 3/4/2022 .......................................................................................................................570 C121: Margaret Goodale, 3/7/2022 ............................................................................................................571 C122: Stan Zeavin, 3/7/2022 ......................................................................................................................572 C123: Brian Gaffney, ..................................................................................................................................579 C124: Christine Boles, 2/11/2022 ..............................................................................................................613 C125: Nancy Tierney, 3/7/2022 .................................................................................................................618 C126: Lawrence Bothen, 3/7/2022 .............................................................................................................620 C127: Richard Harris, 3/9/2022 .................................................................................................................623 C128: Richard Harris, 3/7/2022 .................................................................................................................625 C129: Jake Scussel, 2/30/2022 ....................................................................................................................627 C130: Laura Sloan, 1/14/2022 ....................................................................................................................629 C131: Danny Estrella, 2/26/2022 ...............................................................................................................630 C132: Kathy Castor, 3/9/2022 ....................................................................................................................637 C133: John Keener, 3/7/2022 .....................................................................................................................638 C134: Breck Hitz, 3/6/2022 ........................................................................................................................641 C135: Christine Boles, 2/11/2022 ..............................................................................................................642 C136: Nick Lusson, 3/8/2022 .....................................................................................................................646 C137: Clifford Lawrence, 3/8/2022 ............................................................................................................647 C138: Andrew, 2/21/2022 ...........................................................................................................................651 C139: Christine Boles, 12/17/21 ................................................................................................................653 C140: Virgilio Jr. L Yap, 1/19/21 ...............................................................................................................654 C141: Remi Tan, 2/26/2022 ........................................................................................................................655 C142: Chuck Gust, 1/21/2022 ....................................................................................................................656 C143: Sue Digre, 3/7/2022 ..........................................................................................................................657 C144: James Kremer, 1/17/2022 ................................................................................................................658 C145: Christine Boles, 2/8/2022 ................................................................................................................659 C146: Christine Boles, 1/31/2022 ..............................................................................................................660 C147: Christine Boles, 2/10/2022 ..............................................................................................................661

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Packet Pg. 670 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 6 C148: Christine Boles, 1/15/2022 ..............................................................................................................662 C149: Christine Boels, 1/13/2022 ..............................................................................................................663 C150: Christine Boles, 1/13/2022 ..............................................................................................................664 C151: Ellen Natesan, 3/7/2022 ...................................................................................................................665 C152: Christine Boles, 1/9/2022 ................................................................................................................666 C153: Mike O’Connell, 1/8/2022 ...............................................................................................................667 C154: Mike O’Connell, 1/10/2022 .............................................................................................................668 C155: Mike O’Connell, 1/11/2022 .............................................................................................................669 C156: Brian Gaffney, 3/8/2022 ...................................................................................................................670 C157: Terry Watt, 3/8/2022 .......................................................................................................................671 C158: Vicki Sundstrom, 2/1/2022 ..............................................................................................................672 C159: Gwendolyn Holden, 2/26/2022 .......................................................................................................673 C160: Ellen Natesan, 1/19/2022 .................................................................................................................674 C161: Arlene Patton, 1/22/2022 .................................................................................................................675 C162: Mark Hubbell, 3/9/2022 ..................................................................................................................676 C163: Paul Totah, 2/27/2022 ......................................................................................................................677 C164: Stan Zeavin, 3/5/2022 ......................................................................................................................679 C165: Christine Boles, 1/10/2022 ..............................................................................................................683 C166: Pez Godsoe, 3/7/2022.......................................................................................................................684 C167: Peter K, 1/16/2022 ............................................................................................................................685 C168: Bill, 1/11/2022 ..................................................................................................................................686 C169: Jackie Rosenheim, 2/21/2022 ..........................................................................................................687 C170: Bryan O’Flynn, 3/9/2022 .................................................................................................................688 C171: Tom Thompson, 3/7/2022 ...............................................................................................................689 C172: Tom Thompson, 3/7/2022 ...............................................................................................................690 C173: Bob Haxo, 3/8/2022 .........................................................................................................................693 C174: James Kremer, 3/8/2022 ..................................................................................................................696 C175: Dan Stegink, 3/8/2022 .....................................................................................................................699 C176: Clif Lawrence, 1/29/2022 .................................................................................................................701 C177: Rick Nahass, 3/4/2022......................................................................................................................702 C178: Christine Boles, 1/11/2022 ..............................................................................................................704 C179: Dawn Zidonis, 1/12/2022 ................................................................................................................705 C180: Irene Davies, 2/14/2022 ...................................................................................................................706 C181: Irene Davies, 1/21/2022 ...................................................................................................................707

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Packet Pg. 671 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 7 Table 3-1: Comment Letter Index
Letter Name Date Agency/ Organization
A1 Amy Dao 2/15/2022 Bay Area Air Quality Management District (BAAQMD) A2 Will Kanz 3/8/2022 California Department of Fish and Wildlife (CDFW) A3 Dr. Erik Frost 2/1/2022 California Department of Conservation, Geological Survey A4 Dr. Adrianne Carr 3/8/2022 North Coast County Water Department (NCCWD) A5 Rob Bartoli 3/8/2022 San Mateo LAFCO
A6 Julia Koppman Norton 3/1/2022 California Coastal Commission (CCC) B1 Judy Heldberg 2/18/2022 Pacifica Historical Society
C1 Stan Zeavin 3/7/2022
C2 Maria Marintez-Mont 2/11/2022
C3 Lisa VillasenorVolosing3/8/2022
C4 Remi Tan 2/26/2022
C5 Remi Tan 2/2/2022
C6 Clif Lawrence 1/20/2022
C7 Debra Etienne 2/14/2022
C8 Richard Grassetti 3/8/2022
C9 Bob Boles 3/7/2022
C10 Christine Boles 1/27/2022
C11 Monica Meagher 3/8/2022
C12 Jewel Walli 3/5/2022
C13 Christine Boles 3/8/2022
C14 William Leon 3/3/2022

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Packet Pg. 672 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 8 Letter Name Date Agency/ Organization
C15 Allison West 3/8/2022
C16 Clifford Lawrence 2/22/2022
C17 Deb MacC 2/14/2022
C18 Jim Louderback 2/28/2022
C19 Peter Loeb 3/5/2022
C20 Andre Mettier 3/8/2022
C21 Gary Emich 3/8/2022
C22 Dinah Verby 3/8/2022
C23 Therese Langille 3/9/2022
C24 Joanne Gold 3/7/2022
C25 Gary Furlong 3/7/2022
C26 Dina and Robert Horan 3/7/2022
C27 Cathy Glenn 3/7/2022
C28 Clif Lawrence 2/21/2022
C29 Nancy Merchant 3/3/2022
C30 James Kremer 2/20/2022
C31 Bradley Angel 3/7/2022
C32 Andrew Meiman 3/7/2022
C33 Richard Campbell 3/8/2022
C34 Richard Grassetti 3/8/2022
C35 Deb Wong 3/11/2022
C36 Patrick Mora 3/8/2022
C37 Allison West 3/7/2022 Pedro Point Community Association C38 Peter Loeb 3/7/2022

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Packet Pg. 673 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 9 Letter Name Date Agency/ Organization
C39 Paul Totah 2/25/2022
C40 Adam Mayle 3/7/2022
C41 Adam Mayle 3/7/2022
C42 Sheila Gamble-Dorn 3/7/2022
C43 Sam Casillas 3/8/2022 Pedro Point Community Association C44 Jean Turk 3/7/2022
C45 Jonathan Cordero 3/3/2022
C46 Terrell Watt 3/8/2022
C47 Cindy Abbott 3/8/2022
C48 Paul Totah 2/25/2022
C49 Christine Boles 2/28/2022
C50 Karen Clark 3/7/2022
C51 Gail Benton Shoemaker 3/1/2022
C52 Suzanne Moore 3/3/2022
C53 Cheri and Bruce Chan 3/8/2022 Pedro Point Community Association C54 Christine Boles 3/6/2022
C55 Christine Boles 2/9/2022
C56 Christine Boles 1/16/2022
C57 Christine Boles 2/17/2022
C58 Rick Nahass 2/5/2022
C59 Suzanne Moore 3/5/2022
C60 Dustin McGahan 1/18/2022
C61 Arlene Patton 3/2/2022
C62 Clif Lawrence 1/16/2022

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Packet Pg. 674 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 10 Letter Name Date Agency/ Organization
C63 Stan Zeavin 3/2/2022
C64 Christine Boles 1/31/2022
C65 Patricia McGregor 1/30/2022
C66 Stan Zeavin 3/8/2022
C67 Remi Tan 1/5/2022
C68 Patrick Mora 3/8/2022
C69 Victor Carmichael 3/8/2022
C70 Rick Nahass 2/6/2022
C71 Arlene Patton 3/2/2022
C72 Pete Shoemaker 2/2/2022
C73 Erin Macias 1/20/2022
C74 Elizabeth Rubenstein' 1/8/2022
C75 Peter K 1/8/2022
C76 David Patton 2/15/2022
C77 Sue Digre 3/8/2022
C78 Sue Digre 3/8/2022
C79 Pete Shoemaker 2/17/2022
C80 Christine Boles 1/16/2022
C81 Margaret Goodale 1/25/2022
C82 Vicki Sundstrom 3/8/2022
C83 Erin Macias 1/18/2022
C84 Rick Nahass 1/30/2022
C85 Erin Macias 1/18/2022
C86 Christine Boles 1/20/2022

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Packet Pg. 675 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 11 Letter Name Date Agency/ Organization
C87 Christine Boles 2/10/2022
C88 Jim Louderback 1/16/2022
C89 Bill Collins 2/21/2022
C90 Necesse 1/20/2022
C91 Suzanne Buckly 2/9/2022
C92 Necesse 1/20/2022
C93 Necesse 1/19/2022
C94 Rick Nahass 1/20/2022
C95 Mark Hubbell 3/8/2022
C96 Judy Yamahiro 1/26/2022
C97 Christine Boles 1/29/2022
C98 Christine Boles 2/7/2022
C99 Michelle Pitte 2/17/2022
C100 Shona Keating 3/8/2022
C101 Christine Boles 1/11/2022
C102 Patricia R McGregor 2/11/2022
C103 Alex Strachan 1/19/2022
C104 Penelope Keating 3/8/2022
C105 Kathi Porter 1/19/2022
C106 Debbie Young Lynch 1/17/2022
C107 Ellen Natesan 3/6/2022
C108 John Keener 2/17/2022
C109 Mark Hubbell 2/21/2022
C110 Christine Boles 1/8/2022

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Packet Pg. 676 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 12 Letter Name Date Agency/ Organization
C111 Reina Heinz 3/8/2022
C112 Margaret Goodale 1/20/2022
C113 Margaret Goodale 2/11/2022
C114 Andy Narraway 3/2/2022
C115 Camille Keating 3/8/2022
C116 Henry Ruhnke 3/7/2022
C117 Pete Shoemaker 2/16/2022
C118 Pete Shoemaker 1/31/2022
C119 Michael Vasey 2/20/2022
C120 John Sharp 3/4/2022
C121 Margaret Goodale 3/7/2022
C122 Stan Zeavin 3/7/2022
C123 Brian Gaffney 3/8/2022
C124 Christine Boles 2/11/2022
C125 Nancy Tierney 3/7/2022
C126 Lawrence Bothen 3/7/2022
C127 Richard Harris 3/9/2022
C128 Richard Harris 3/7/2022
C129 Jake Scussel 2/20/2022
C130 Laura Sloan 1/14/2022
C131 Danny Estrella 2/26/2022 Pedro Point Community Association C132 Kathy Castor 3/9/2022
C133 John Keener 3/7/2022
C134 Breck Hitz 3/6/2022

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Packet Pg. 677 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 13 Letter Name Date Agency/ Organization
C135 Christine Boles 1/10/2022
C136 Nick Lusson 3/8/2022 Protect San Pedro Mountain Operations Team C137 Clifford Lawrence 2/21/2022
C138 Andrew Meiman 2/21/2022
C139 Christine Boles 12/17/202
1 C140 Virgilio Jr. L Yap 1/19/2021
C141 Remi Tan 2/26/2022
C142 Chuck Gust 1/21/2022
C143 Sue Digre 3/7/2022
C144 James Kremer 1/17/2022
C145 Christine Boles 2/9/2022
C146 Christine Boles 1/31/2022
C147 Christine Boles 2/10/2022
C148 Christine Boles 1/15/2022
C149 Christine Boles 1/13/2022
C150 Christine Boles 1/13/2022
C151 Ellen Natesan 3/7/2022
C152 Christine Boles 1/9/2022
C153 Mike O'Connell 1/8/2022
C154 Mike O'Connell 8/3/2021
C155 Mike O'Connell 6/24/2021
C156 Brian Gaffney 3/8/2022
C157 Terry Watt 3/8/2022

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Packet Pg. 678 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 14 Letter Name Date Agency/ Organization
C158 Vicki Sundstrom 2/1/2022
C159 Gwendolyn Holden 2/26/2022
C160 Ellen Natesan 1/19/2022
C161 Arlene Patton 1/22/2022
C162 Mark Hubbell 3/9/2022
C163 Paul Totah 2/27/2022
C164 Stan Zeavin 3/5/2022
C165 Christine Boles 1/10/2022
C166 Pez Godsoe 3/7/2022
C167 Peter K 16-Jan
C168 Bill 1/11/2022
C169 Jackie Rosenheim 2/21/2022
C170 Bryan O'Flynn 3/9/2022
C171 Tom Thompson 3/7/2022
C172 Tom Thompson 3/7/2022
C173 Bob Haxo 3/8/2022
C174 James Kremer 3/8/2022
C175 Dan Stegink 3/8/2022
C176 Clif Lawrence 1/29/2022
C177 Rick Nahass 3/4/2022
C178 Christine Boles 1/11/2022
C179 Dawn Zidonis 1/12/2022
C180 Irene Davies 2/14/2022
C181 Irene Davies 1/21/2022

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Packet Pg. 679 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 15 (A) Agencies

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Packet Pg. 680 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 16 A1. Amy Dao, BAAQMD, 2/15/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A1-1 BAAQMD;
Amy Dao, Sr.

Environment
al Planner
2/16/2
2 The GHG impact analysis should include an
evaluation of the General Plan’s consistency with
the California Air Resources Board’s most recent
Assembly (AB) 32 Scoping Plan and with the
State's 2030, 2045, and 2050 climate goals. The
Air District's current GHG thresholds and CEQA
Guidelines are based on the State's 2020 targets
which are now superseded by the 2030 targets
established in SB 32. The Air District recommends
that cities and counties evaluate such plans based
on whether they would support California’s longterm climate goals of achieving carbon neutrality by 2045, as defined in Executive Order B-55-18,
including reducing GHG emissions in the relevant
jurisdiction to meet an interim milestone of 40
percent below 1990 emission levels by 2030,
consistent with SB 32.

The comment is noted. A clarifying table is thereby
added on DEIR p. 3.4-20 specifying reduction targets
and per capita SB 32 targets. Table 3.4-3 is thereby
added on DEIR p. 3.4-27 to show mass emissions
reductions for each of these targets, as well as the
following clarifying text: "The statewide per capita
goals were developed by applying the percent
reductions necessary toreach the 2030 and 2050
climate goals (40 percent and 80 percent, respectively) to the State’s 1990 emissions limit established under
AB 32. Following this methodology, the table below
shows the maximum mass emissions (i.e., emissions
targets) that the City would need to have to achieve
State reduction targets. As seen in Table 3.4-2, targets for 2040 were calculated based on a linear trajectory
between 2030and 2050, resulting in a target
maximum GHG emissions of 154,433 MTCO2e.In
addition to proving a net reduction in mass emissions
compared to existing conditions, mass emissions
generated by the Project at or below this amount
would constitute a less-than-significant impact on the
environment. Pacifica’s 2014 CAP “assume[ed] that
Pacifica’s emissions have increased since 1990 at the
same rate as for the state of California as a whole,
then Pacifica’s emission levels in 2005 would be
approximately 15 percent above 1990 levels.”
While the Proposed Project falls just short of a 60%
reduction in 2040 without mitigation measures; with
mitigation the Project results in a reduction of 69%
below 1990 levels. Because 2020 existing GHG levels
are approximately 35% below 1990 levels, it can be
reasonably assumed that the Project would meet its
SB 32 target of 40% mass emissions reductions below
1990 levels in 2030.

The following clarifications are added:

DEIR p. 3.4-38: "The Proposed Project would almost
meet SB 32 emissions reduction targets but falls just
short of the 60 percent reduction at 59 percent."
DEIR p. 3.4-52: "Both total and per capita emissions
would achieve the interpolated GHG emissions
reduction target established by the Pacifica CAP and
the AB 32 reduction target of 60 percent mass
emissions reduction below 1990 levels. 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, and the impact would be less than
significant with mitigation."
DEIR p. 3.4-63: "The Proposed Project would result in
GHG emissions of 1.59 MTCO2e per capita in 2040,

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Packet Pg. 681 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 17 Letter Commenter Date Comment Combined Response
Agencies (A)
which meets the CARB Scoping Plan per capita
reduction targets designed to be consistent with SB
32, which are 6.0 MTCO2e per capita by 2030 and 2.0
MTCO2e per capita by 2050. With mitigation, the
Proposed Project meets its SB 32 reduction target for
2040, and it can be reasonably assumed that it would
also meet its 2030 reduction target for 2030, as
described in Impact 3.4-1. "
A1-2 BAAQMD;
Amy Dao, Sr.

Environment
al Planner
2/17/2
2 CEQA requires local agencies to consider
alignment of local plans with federal, state and
local energy and climate policy; thus, the relevant
plans and programs discussed in the General Plan
and DEIR must reflect the most recent
information. Several references to such goals,
plans, rules, and programs in the General Plan
and DEIR are outdated. Air District staff
recommend that the following references be
updated as follows:
• Revise Air District 2010 Clean Air Plan to the
2017 Clean Air Plan;
• Revise California 2020 GHG reduction goal to
California GHG reduction goals for 2030, 2045
and 2050;
• Revise Low Carbon Fuel Standard (2007) carbon
intensity reduction goals of 10% to 20% per 2018
CARB amendments to the regulation;
• Revise AB 32 (2006) to SB 32 (2016), and the
California Climate Change Scoping Plan 2008 and
2014 versions to the 2017 Scoping Plan;
• Revise EPA GHG Regulation of Cars and Light
Duty Trucks covering model years 2012 through
2016 to the model years 2023 through 2026;
• Revise Executive Order 13154 Federal
Leadership in Environmental, Energy, and
Economic Performance (revoked in March 2015)
to Executive Order 13693 Planning for Federal
Sustainability in the Next Decade;
• Revise Draft Plan Bay Area 2050 to Plan Bay
Area 2050 (adopted by MTC/ABAG in October
2021).

This comment is noted. The following edits are made
for clarity:

DEIR p. 3.4-44, 45, 53, 54: "CO-I-53 Transportation
Control Measures. Ensure compliance with the most
current Bay Area Clean Air Plan by implementing the
Plan’s recommended Transportation Control
Measures. The 2010 2017 Clean Air Plan identifies 17
TCMs aimed at reducing vehicle trips and vehicle miles
traveled; increasing access to and support of
alternative modes of transportation; promoting
compact, walkable land use patterns; and increasing
public education and awareness."
On page 3.14-16, "The Scoping Plan must be updated
every five years to evaluate AB 32 policies and ensure
that California is on track to achieve the 2020 GHG
emissions reduction goal California GHG reduction
goals for 2030, 2045 and 2050. In 2014, ARB released
the First Update to the Climate Change Scoping Plan
(First Update), which builds upon the initial scoping
plan with new strategies and recommendations. The
First Update identifies opportunities to leverage
existing and new funds and drive GHG emissions
reductions through strategic planning and targeted
low-carbon investments. This update defines ARB’s
climate change priorities for the next five years and
sets the groundwork for reaching the long-term goals
set forth in California EO S-3-05. The First Update
highlights California’s progress toward meeting the
near-term 2020 GHG emissions reduction goals
California GHG reduction goals for 2030, 2045 and
2050 in the initial scoping plan."
On page 3.4-18, "The updated Scoping Plan includes
various elements, including doubling energy efficiency
savings, increasing the low carbon fuel standard from
10 to 18 20 percent, adding 4.2 million zero-emission
vehicles on the road, implementing the Sustainable
Freight Strategy, implementing a post-2020 Cap-andTrade Program, creating walkable communities with expanded mass transit and other alternatives to
traveling by car, and developing an Integrated Natural
and Working Lands Action Plan to protect land-based
carbon sinks."
On page 3.4-10, "The Global Warming Solutions Act of

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Packet Pg. 682 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 18 Letter Commenter Date Comment Combined Response
Agencies (A)
2006 (AB 32) 2016 (SB 32) required that the California
Air Resources Board (CARB) determine the statewide
greenhouse gas emissions level in 1990 expanded
upon AB-32 to reduce greenhouse gas (GHG)
emissions. AB-32 required California to reduce
greenhouse gas emissions to 1990 levels by 2020, and
SB-32 continues that timeline to reach the targets set
in Executive Order B-30-15, which requires GHG levels
to be reduced by 40 percent below 1990 levels by
2030. SB-32 provides another intermediate target
between the 2020 and 2050 targets set in Executive
Order S-3-05, which requires reducing GHG emissions
to 80 percent below 1990 levels. Based on its 1990-
2004 inventory work, ARB staff set 427 million metric
tons of carbon dioxide equivalent emissions
(MMTCO2e) as the total statewide greenhouse gas
1990 emissions level, and the 2020 emissions limit.

The CARB approved the 2020 limit on December 6,
2007.25 This would be about 9.7 MTCO2e per capita,
based on the Department of Finance’s state
population projection of 44 million."
On page 3.4-16, "In 2006, the California legislature
passed AB 32 (California Health and Safety Code
Division 25.5, Sections 38500 et seq., or AB 32), also
known as the California Global Warming Solutions Act.

AB 32 requires ARB to implement emission limits,
regulations, and other feasible and cost-effective
measures such that statewide GHG emissions are
reduced to 1990 levels by 2020. SB-32 continues that
timeline to reach the targets set in Executive Order B- 30-15, which requires GHG levels to be reduced by 40
percent below 1990 levels by 2030. SB-32 provides
another intermediate target between the 2020 and
2050 targets set in Executive Order S-3-05, which
requires reducing GHG emissions to 80 percent below
1990 levels.

Pursuant to AB 32 SB 32,..."
On page 3-22, "With the passage of Assembly Bill (AB)
32 Senate Bill (SB) 32, the Global Warming Solutions
Act of 2006, the State of California committed itself to reducing greenhouse gas (GHG) emissions to 1990
levels by 2020."
On page 3.4-12, The standards apply to passenger
cars, light-duty trucks, and medium-duty passenger
vehicles, covering model years 2012 2023 through
2016 2026. The standards are designed to achieve a
national vehicle fleet whose emissions and fuel
economy performance improves year over year. The
goal is to reduce CO2 emissions by 960 million metric
tons and save 1.8 billion barrels of oil over the lifetime of the vehicles sold in model years 2012 2023 through
2016 2026.

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Packet Pg. 683 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 19 Letter Commenter Date Comment Combined Response
Agencies (A)
On page 3.4-13, Header: Executive Order 13154
Federal Leadership in Environmental, Energy, and
Economic Performance Executive Order 13693
Planning for Federal Sustainability in the Next Decade
"On October 5, 2009, President Obama issued
Executive Order 13154, which instructs federal
agencies to set or achieve various emissions reduction
and energy and environmental benchmarks by 2015,
2020, and 2030. The order requires agencies to set
GHG emissions reduction targets for 2020 within 90
days, and requires OMB to set a federal government
target for 2020 within 120 days. The order also sets
out required reductions in vehicle fleet petroleum use
and requires increases in water and energy efficiency
and in recycling and waste diversion rates. The order
also mandates adoption of certain contract and
procurement practices designed to promote energy
and water efficiency and environmentally-preferable
products. Now revoked, Executive Order 13693
introduces new requirements and expands on
requirements established by Executive Order 13154.

Such updates include the establishment of new
reduction targets for Scope 1, 2 and 3 GHG emissions
to be achieved by fiscal year (FY) 2025 compared to an
FY 2008 baseline and report annually a comprehensive
inventory and progress towards GHG emission
reduction goals."
On pages 3.4-21, 3.4-57, 4-17, and 4-18, "Draft Plan
Bay Area 2050" will be revised to "Plan Bay Area
2050".

These reference edits do not change any findings of
significance.

A1-3 BAAQMD;
Amy Dao, Sr.

Environment
al Planner
2/18/2
2 Air District staff recommends that the General
Plan include additional feasible measures to
minimize GHGs within the City. Examples of
potential emission reduction measures that
should be evaluated and considered, include but
are not limited to:
• Including electric infrastructure and fossil fuel
alternatives in the development and operation of
the Plan, such as solar photovoltaic (PV) panels,
renewable diesel, electric heat pump water
heaters, and solar PV back-up generators with
battery storage capacity.
• Expanding the requirements for no natural gas
use to all new residential and commercial
construction, with no exemptions for gas cooking
and residential fireplaces
• Prohibiting or minimizing the use of diesel fuel,
consistent with the Air District’s Diesel Free By
’33 initiative (http://dieselfree33.baaqmd.gov/).
• Meeting the vehicles miles traveled (VMT)
requirement under SB 743 per the Calfiornia
The DEIR includes the effects of all of the
recommended measures in the following ways:

Including electric infrastructure and fossil fuel
alternatives in the development and operation of the
Plan, such as solar photovoltaic (PV) panels,
renewable diesel, electric heat pump water heaters,
and solar PV back-up generators with battery storage
capacity:

Proposed policies CO-G-15 (renewable energy); policy
CO-G-16 (energy conservation); CO-I-59 (updated CAP
that will present list of all feasible GHG reduction
measures); CO-I-62 (encourage solar power
generation); CO-I-63 (clean city fleet); CO-I-64 (City
purchasing of renewable energy); Co-I-67 (Energy
efficiency in public buildings); CO-I-69 (outdoor
lighting); and 7-I-8 (generator retrofitting) all achieve the effect of this recommended measure.

Expanding the requirements for no natural gas use to
all new residential and commercial construction, with

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Office of Planning and Research (OPR) Technical
Advisory On Evaluating Transportation Impacts In
CEQA (https://opr.ca.gov/docs/20190122-
743_Technical_Advisory.pdf).
• Requiring installation of electric vehicle (EV)
charging infrastructure and capacity to meet
power requirements of future EV charging needs,
per CalGreen Tier 2 charging infrastructure
requirements
(https://www.dgs.ca.gov/BSC/CALGreen#codes).

Planning for and providing funding for zeroemission transportation projects, including a neighborhood electric vehicle program,
community shuttle/van services and car sharing,
and enhancement of active transportation
initiatives, among others.
no exemptions for gas cooking and residential
fireplaces:

The City is exploring this option as part of a parallel Reach Code initiative.

Prohibiting or minimizing the use of diesel fuel,
consistent with the Air District’s Diesel Free By ’33
initiative (http://dieselfree33.baaqmd.gov/).

Proposed General Plan policy CO-I-63 and CO-I-64
would prioritize clean fuels and electric or hybrid
vehicles to replace and improve the existing city fleet of gasoline and diesel-powered vehicles. This policy
would reduce GHG emissions associated with
municipal operations and
Transportation and achieves the effect of the
recommended measure.

Meeting the vehicles miles traveled (VMT)
requirement under SB 743 per the Calfiornia Office of
Planning and Research (OPR) Technical Advisory On
Evaluating Transportation Impacts In CEQA
(https://opr.ca.gov/docs/20190122-
743_Technical_Advisory.pdf):

Please see response to comment C46-30 for more
information on policies that support SB 743
implementation.

Requiring installation of electric vehicle (EV) charging infrastructure and capacity to meet power
requirements of future EV charging needs, per
CalGreen Tier 2 charging infrastructure requirements
(https://www.dgs.ca.gov/BSC/CALGreen#codes):

Mitigation measure GHG-1 includes requirement of
installation of EV charging infrastructure and achieves the effect of the recommended measure.

Planning for and providing funding for zero-emission
transportation projects, including a neighborhood
electric vehicle program, community shuttle/van
services and car sharing, and enhancement of active
transportation initiatives, among others: Policies CI-G18 (transportation demand management), CO-I-68 (clean city fleet); CI-I-51 (transportation demand
management); CI-I-52 (support of expanded funding
for local transportation services); CI-I-42 (bicycle
education); and MM-GHG-1 (EV charging) address and
achieve the effect of this recommended measure.

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Packet Pg. 685 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 21 A2: Will Kanz, CDFW, 3/68/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A2-1 CDFW; Will
Kanz,
Environment
al Scientist
3/8/22 COMMENT 1: Wildlife Connectivity Issue:

Conservation Element CO-G-10 seeks to protect
environmentally sensitive habitat areas, high value
or high habitat value areas, and wildlife movement
corridors from development that would significantly
disrupt habitat values but does not provide a set of
standards for evaluating these impacts and ensuring
the impacts are reduced to less-than-significant. On
page 3.2-20 of the DEIR it states, “While a wildlife
movement corridor is needed somewhere within
the area designated in Figure 3.7-3; the entire area
would not be designated as a wildlife movement
corridor. Corridors typically range from 100 to 400
feet in width, within which habitat is continuous
and suitable for wildlife movements”. Additionally,
Figure 3.7-3 indicates wildlife corridors are only
needed between Milagra Ridge and Sharp
Park/Sweeney Ridge and the need for identifying
wildlife corridors in the other sensitive habitat is not discussed. Development and road construction or
widening has the potential to significantly impact
wildlife movement due to habitat conversion and
built infrastructure such as roads that can cause
habitat fragmentation, and cut off migration
corridors.

The Proposed Project does not include roadway
widening in any sensitive habitat areas, with the
exception of new roadways as part of Quarry
development. Should any future projects be
proposed, they would be required to assess
biological impacts 1) under CEQA and 2) in
accordance with federal, state, and local
regulations, as well as beneficial policies proposed
in the Proposed Project. Please see response to
comment A2-9 for more information. Proposed
policies that reduce the impact include those that
support critical wildlife habitat and special status
species (LU-G-7 and CO-G-8); Protection of
biological resources through new development,
including avoidance of development in critical
habitat, pre-construction surveys and consultation
with CDFW, biological resource assessments
required within any sensitive habitat areas shown
on Figure 7-3, as well as compensatory mitigation
measures (CO-I-27); protection of any species with
defined or potential habitat (CO-I-28) through
specific habitat survey requirements, development
limitations, or other requirements.

The quote on page 3.7-20 of the DEIR is out of
context, the sentence is thereby amended for
clarification:
"Natural wildlife corridors in Pacifica include
riparian corridors and drainages such as San Pedro
Creek, canyons, ridgelines, and corridors across
valley floors where impermeable barriers (such as
dense urban development, exclusionary fencing,
and heavily traveled roadways) have not yet
eliminated options for wildlife movement and plant
dispersal. An area on the south side of Sharp Park
Road functions as a wildlife corridor between
Milagra and Sweeney Ridges. It is a sensitive wildlife
area because of the link it provides between
populations of CRLF, SFGS, and other plants and
animals. This area has also been identified as part of
the Mission Blue butterfly migration corridor
(National Parks Service, Milagra Ridge, Golden Gate
Recreation Area. U.S. Department of the Interior.

Other wildlife corridors could occur in areas of
potentially sensitive habitat, or areas threatened by
habitat fragmentation, areas with high habitat
value, or critical habitat areas, as shown on Figure

3.7-3. This does not change findings of significance.

A2-2 CDFW; Will
Kanz,
Environment
al Scientist
3/9/22 Evidence the impacts would be significant: Road use can result in wildlife mortality, altered abundances
and diversity of wildlife, and modification of animal
behavior (Trombulak and Frissell 2000).

Additionally, wildlife mortality can occur as a result
See response for A2-1 and A2-3

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of road construction (Trombulak and Frissell 2000).

Road density has been shown to affect habitat
selection in frogs (Vos and Chardon 1998). Both
independently and collectively, these impacts have
the potential to affect public trust resources.

A2-3 CDFW; Will
Kanz,
Environment
al Scientist
3/10/2
2 Recommended Measure 1 – Minimize New Road
Construction:

Limit the construction of new roads and properly
use and maintain existing roads when possible.

When new roads must be constructed or
reconstructed, use practices that minimize
environmental impacts. Restore drainage areas
connected to current roadways to limit
environmental impacts like erosion and diversion of
surface flow. Terrestrial connectivity elements such
as wildlife friendly culverts, directional fencing,
strategically placed median barriers, undercrossings, over-crossings and elevated causeways should be programmed into the Project as design
features or conditions of approval in coordination
with the natural resource agencies.

Site-specific impacts and mitigation measures
would need to be determined during a project EIR
prior to construction. The DEIR includes several
policies that reduce biological impacts from
construction (which also applies to road
construction), including policies that minimize site
disurbance (CO-I-14), protect biological resources
with new development and requirement of preconstruction plan and wildlife surveys, resource assessments, and compensatory mitigation (CO-i26), preconstruction surveys for birds and bats (COI-33 and CO-I-34), and specific measures to protect the California red legged frog and San Francisco
garter snake during construction (CO-I-35). Thus,
the current policies and compliance with existing
regulations reduce impacts to the maximum extent
practicable.

A2-4 CDFW; Will
Kanz,
Environment
al Scientist
3/11/2
2 Recommended Measure 2- Wildlife Connectivity:

The EIR should incorporate a wildlife movement
studies to develop a baseline understanding of the
areas where wildlife movement, crossings, and
mortalities are most prevalent in order to identify
species use and to aid in identifying criteria used to
determine appropriate wildlife corridor widths and
locations where development should not occur. The
studies should be focused in those areas identified
in Figure 3.7-3 as a wildlife movement corridor and
the areas identified as potential environmentally
sensitive habitat areas, and high habitat
value/threatened by fragmentation. CDFW
recommends the study occur over a period of at
least 12 months prior to the approval of any project
relying on the Plan Pacifica Project. The study
should also be utilized to develop project design
and identify areas where wildlife crossing structures
would result in the largest benefit to rare,
threatened, endangered special status, and nonspecial-status species for wildlife connectivity.

Analysis during the 12-month study should also be
utilized to determine the type, size and number of
structures that would be most beneficial to
facilitate wildlife connectivity (new wildlife crossing culverts, modification of existing culverts, elevated
causeways, etc.) in existing developed areas. Upon
completion of any development, wildlife
connectivity structures and movement corridors
should be studied for an additional 6 to12 month
period, at minimum, to determine the effectiveness
of the designs. The protocol for the baseline survey,
post-construction surveys, site selection criteria and
While the importance of identifying and protecting
wildlife migration corridors is recognized in the
Draft General Plan and discussed in the DEIR, the
recommendation to incorporate a longitudinal
study conducted over a period of at least 12 months
into the DEIR is infeasible for two principal reasons.

First, such a study is more appropriately conducted
at a regional or subregional scale and led by an
agency with subject matter expertise such as CDFW,
given that wildlife migration patterns cross multiple
jurisdictional boundaries. Such a study would
necessarily involve coordination between multiuple
jurisdictions and would be beyond the techincal and
financial capabilities of the City of Pacifica to lead.

Second, to implement this recommendation at this
late stage of the multi-year Proposed Project would
require and extensive delay to the timeline and
would incurr significant cost to the City even if the
City had the subject matter expertise to lead such
an effort in the first place. The City notes that CDFW
had multiple opportunities to recommend this type
of study at earlier junctures in the Project -
including most recently during the scoping period
for the DEIR, which ran from August 5, 2020 to
September 14, 2020, but the CDFW did not
previously make this recommendation in their NOP
response.

Nevertheless, the City contiues to recognize the
importance of identifying and protecting wildlife
migration corridors and habitat in and adjacent to
Pacifica and would support regional or subregional
efforts led by an appropriate agency to accomplish

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design criteria for the development of the wildlife
connectivity structures should follow the protocols
outlined in; The California Department of
Transportation (Caltrans), Wildlife Crossings Design
Manual (Caltrans, 2009) and the Federal Highway
Administration Wildlife Crossing Structure
Handbook – Design and Evaluation in North
America, Publication No. FHWA-CFL/TD-11-003
(FHWA, 2011).
this. To underscore the importance of preserving
and protecting wildlife migration corridors, the
following policy will be added to the Conservation
Element of the 2040 General Plan:

Policy X - The City shall advocate for and participate
in a regional or subregional study to identify areas
where wildlife crossing structures would result in
the largest benefit to rare, threatened, and
endangered special status and non-specila-status
species for wildlife connectivity, to be led and
conducted by an appropriate agency.

A2-5 CDFW; Will
Kanz,
Environment
al Scientist
3/12/2
2 COMMENT 2: Fish Passage Assessment Issue:

Multiple potential fish passage barriers and
unassessed locations exist within the Project area.

The Project contains stream crossings within areas
mapped as historic or current watersheds where
anadromous fish are, or historically were found. The
species include but are not limited to Steelhead –
California Central Valley Distinct Population
Segment (DPS) (BIOS; DS-810), Steelhead – Central
Coast DPS (BIOS; DS-806). Section 156 of the Streets
and Highways Code (Senate Bill (SB)-857), which
amended Fish and Game Code section 5901 and
added section 156 to the Streets and Highways
Code which requires in section 156.3, any project
using state or federal transportation funds
programmed after January 1, 2006, the lead agency
shall ensure that, if the project affects a stream
crossing on a stream where fish are, or historically
were found, an assessment of potential barriers to
fish passage is done prior to commencing project
design. For this Project, the City of Pacifica would
need to submit the assessment to the CDFW and
add it to the CALFISH database. If any structural
barrier to passage exists, remediation of the
problem shall be designed into the Project by the
implementing agency. New projects shall be
constructed so that they do not present a barrier to
fish passage. Evidence the impact would be
significant: The decline of naturally spawning
steelhead trout is primarily a result of the loss of
appropriate stream habitat and the inability of fish
to get access to habitat, according to reports to the
Fish and Game Commission and by the CDFW
(CDFW, 1996). Restoration of access to historical
spawning and rearing areas should be incorporated
into the Project design through barrier modification,
fishway installation, or other means (CDFW, 1996).

Recommendations: The EIR should include technical
evaluation of the current status of each crossing
location noted in the California Fish Passage
Assessment Database within the Project limits that
may be barriers to fish passage. If any barriers or
See response for A2-8

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unassessed barriers noted within the Project limits
are found to be exist, remediation of the barrier
should be designed into the Project by the
implementing agency as a Project feature in
consultation with CDFW and other natural resource
agencies.

A2-6 CDFW; Will
Kanz,
Environment
al Scientist
3/13/2
2 Recommended Measure 1 - Fish Passage
Assessment:

To evaluate potential impacts to native fish species
and fisheries resources, City of Pacifica should
submit any fish passage assessments to the CDFW
and add it to the CALFISH database. If any structural
barrier to passage exists, remediation of the barrier
shall be designed nto the Project by the
implementing agency. New projects shall be
constructed so that theydo not present a barrier to
fish passage. When barriers to fish passage are
being addressed, plans and projects shall be
developed in consultation with the CDFW. CDFW
shall be engaged prior to design in early
coordination and at 30% design at minimum.

See response for A2-8
A2-7 CDFW; Will
Kanz,
Environment
al Scientist
3/14/2
2 Recommended Measure 2 - Fish Passage Design
Coordination:

CDFW recommends incorporation into the EIR a
condition of approval to engage with CDFW in early
and continued coordination before design
commences on any fish passage barrier
remediation.

See response for A2-8
A2-8 CDFW; Will
Kanz,
Environment
al Scientist
3/15/2
2 Recommendation Measure 3 - Bridge and Stream
Crossing References:

CDFW recommends utilizing principles outlined in
the California Salmonid Stream Habitat Restoration
Manual, Part XII (CDFW, 2009) and NOAA Fisheries
Service Guidelines for Salmonid Passage at Stream
Crossings (National Marine Fisheries Service
(NMFS), 2001) into stream crossing designs. CDFW
strongly recommends incorporation of freespan
bridge designs that are at minimum 1.25 times
greater than the channel width. Such designs allow
natural stream flow and sedimentation processes to
continue for long term dynamic channel stability.

The DEIR describes fish passages, coordination with
other agencies, and includes policies that would
reduce potential impacts. As noted on DEIR p. 3.7-
50, "The third special status species which occurs in
Pacifica is steelhead, and is known to spawn along
the main stretch of San Pedro Creek in the area
parallel to Linda Mar Boulevard. As such, there are
several specific areas where proposed buildout
could adversely affect this species and its
habitat....For specific development projects under
the Proposed Project, consultation may be required
with USFWS by FESA, and/or with the California
DFW by CESA. Prior to project construction under
the Proposed Project, the applicant would be
required to conduct biological resource
assessments and pre-construction plant and wildlife
surveys at development sites. Compensatory
mitigation would also be required in order to offset
the loss of or alteration to special status species’
habitat."
Policy CO-I-1 applies explicitly to waterways and fish
passage and includes measures to protect and
restore the creek, including removing obstacles to
fish passages (CO-I-1). Policy CO-I-26 requires
engagement with a qualified biologist to assess

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sensitive species, and engagement and CDFW staff
if special status species are found. The policy also
notes that the City will coordinate with the U.S. Fish
and Wildlife Service, National Marine Fisheries
Service, California Department of Fish and Wildlife,
and Regional Water Quality Control Board in
providing project applicants with the best guidance
to avoid impacts to special status species and
habitat areas including creeks, wetland features,
woodlands, or other sensitive natural features. As
described in Master Response 2: Programmatic EIR,
project-specific impacts and mitigation measures
would be determined for projects prior to approval,
in addition to any needed mitigations or design to
reduce or avoid impacts.

A2-9 CDFW; Will
Kanz,
Environment
al Scientist
3/16/2
2 Issue: The Project falls within the Central Coast
North (CC-N) mountain lion subpopulation. The CCN subpopulation has the potential to be impacted by development facilitated by the Project.

Development within sensitive and critical habitat as
defined in Figure 3.7-3 has the potential to cause
impacts during construction and operation by
increasing human presence, traffic, noise, vibration,
air pollutants and dust, artificial lighting, habitat
removal, severing access to or impacting habitat
resources (e.g. streams, dens site, impacts to preybase, etc.), causing disruption during breeding cycles, impacting den selection, forcing animals into
movement paths and areas that could increase their
vulnerability to vehicle strikes, and has the potential to significantly and permanently reduce or
eliminate the existing wildlife movement corridor
necessary for gene flow. Decreased and impeded
connectivity could increase the decline in genetic
diversity of mountain lions in southern and central
parts of the State (Dellingeret al., 2020).

Evidence the impact would be significant: Mountain
lion (Puma concolor) is a specially protected
mammal in the State (Fish & G. Code, § 4800). In
addition, on June 25, 2019, a petition to list the
mountain lion, Southern California/Central Coast
Evolutionarily Significant Unit (ESU) in Southern and
Central California as Threatened or Endangered
pursuant to CESA (Fish & G. Code §§ 2050 et seq.)
was submitted to the California Fish and Game
Commission. Specifically, the petitioners requested
listing as a “threatened species” for the ESU
comprised of the following recognized mountain
lion subpopulations: 1) Santa Ana Mountains; 2)
Eastern Peninsular Range; 3) San Gabriel/San
Bernardino Mountains; 4) Central Coast South
(Santa Monica Mountains); 5) Central Coast North
(Santa Cruz Mountains); and 6) Central Coast
Central. On April 21, 2020, the Fish and Game
Searches of the California Natural Diversity
Database were conducted in June 2021 at time of
DEIR development, as well as in May 2022 to
confirm presence; the mountain lion was not and is
still not identified in the database for the Planning
Area. According to the United States Fish and
Wildlife Service Critical Habitat for Threatened and
Endangered Species data, there is no designated
critical habitat for mountain lions in the Planning
Area. Further, the bulk of development under the
Proposed Project would occur in urbanized, infill
areas of the City, and there would be relatively little development in areas where mountain lions have
the potential to occur. Please also see response to
comment A2-4 for more information on how the
City would support CDFW study of wildlife
movement corridors.

Proposed policies that reduce the impact include
those that support critical wildlife habitat and
special status species (LU-G-7 and CO-G-8);
Protection of biological resources through new
development, including avoidance of development
in critical habitat, pre-construction surveys and
consultation with CDFW, biological resource
assessments required within any sensitive habitat
areas shown on Figure 7-3, as well as compensatory
mitigation measures (CO-I-27); protection of any
species with defined or potential habitat (CO-I-28)
through specific habitat survey requirements,
development limitations, or other requirements
Given the nature of the General Plan as a longrange planning document, these policies are intentionally crafted broadly so that
implementation will continue to be effective even
as species are added to or removed from special
status lists.

As noted on DEIR p. 3.7-41, "Pursuant to the
requirements of the California Endangered Species

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Commission determined that the petitioned action
“may be warranted” and established mountain lion
within the proposed ESU as a candidate species
under CESA (CDFW 2020). As a candidate species,
mountain lion within the proposed ESU now is
granted full protection of a threatened species
under CESA.

Act, an agency reviewing a project within its
jurisdiction must determine whether any statelisted endangered or threatened species may be present in the project area and determine whether
the proposed project will have a potentially
significant impact on such species." CESA prohibits
the take of any species of wildlife designated by the
California Fish and Game Commission as
endangered, threatened, or candidate species.

CDFW may authorize the take of any such species if
certain conditions are met. Without a take permit,
development may not occur.

Additionally, to clarify that mountain lions are
known to occur in the Planning Area, the following
clarification will thereby added to DEIR p. 3.7-21:

Monarch butterflies
Mountain lion
North American porcupine
However, the findings of the DEIR that compliance
with CESA regulations and implementation of
Proposed Project policies LU-G-7, CO-G-8, CO-I-27,
and CO-I-28, the conclusion that impacts would be
less than significant remain valid.

A2-10 CDFW; Will
Kanz,
Environment
al Scientist
3/17/2
2 Recommendations: It is important that the CC-N
subpopulation remain connected to adjacent
mountain lion populations via suitable habitat and
unobstructed sizeable movement corridors.

Permanently conserving and restoring habitat
connectivity and corridors is essential for
minimizing impacts to mountain lions. Gene flow
through maintenance of existing occupied habitat
within improved and additional wildlife corridors
will promote long-term persistence of isolated
subpopulations (Gustafason et al. 2019). It is
important that the CC-N subpopulation remain
connected to adjacent mountain lion populations
via suitable habitat and unobstructed sizeable
movement corridors. Restrictions to mountain lion
movement between the CC-N and CC-C can further
compound this issue absent conservation strategies
to ensure mountain lion movement opportunities.

Please see response to comment A2-9.

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Opportunities to protect and enhance wildlife
connectivity should be incorporated into the EIR.

A2-11 CDFW; Will
Kanz,
Environment
al Scientist
3/18/2
2 COMMENT 4: Monarch Overwintering
The draft EIR does not include impacts to monarch
butterfly overwintering colonies or suitable
overwintering habitat. CDFW is concerned about
the loss of trees and host plants needed for
monarch butterflies. The loss of suitable
overwintering habitat for monarchs will contribute
to extirpation of western monarch populations. If
projects will remove trees used by over-wintering
monarchs, tree planting alone is unlikely to be
sufficient to mitigate impacts to a less-thansignificant level.

Evidence the impact would be significant:

The data gathered from the Western Monarch
Thanksgiving Count show that western
overwintering monarchs are at an alltime critical
low level and have significantly declined to
approximately two percent of their numbers since
1997 (Xerces Society Western Monarch
Thanksgiving Count, 2019). The decrease in Western
Monarch butterflies may be due to the loss of
overwintering habitat and loss of its host plant
(milkweed) (Pelton et al. 2019). According to the
Xerces Society, “Western monarchs use the same
sites each year, even the same trees, and need
intact overwintering habitat, which provides a very
specific microclimate and protection from winter
storms,” (Xerces Society, 2020).

See response for A2-12.

A2-12 CDFW; Will
Kanz,
Environment
al Scientist
3/19/2
2 Recommendations: The EIR should incorporate
protective measures for western monarch
butterflies that includes protecting trees used for
overwintering.

Recommended Measure 1 -Protect, Manage,
Enhance and Restore Monarch Butterfly
Overwintering Sites:
-Conduct overwintering grove habitat assessment(s)
and develop and implement long-term grove
management plans
(https://www.westernmonarchcount.org/).

Management plan actions for groves may include,
but are not limited to:
o Enhance roosting trees within overwintering
groves and within 1/2 mile of groves by planting
native insecticide-free trees (e.g., Monterey pine
(Pinus radiata), Monterey cypress (Cupressus
macrocarpa), coast redwood (Sequoia
sempervirens), coast live oak (Quercus agrifolia),
Douglas-fir (Pseudotsuga menzesii), Torrey pine
(Pinus torreyana), western sycamore (Platanus
racemosa), Bishop pine (Pinus radiata) and others,
as appropriate for location). Avoid the removal of
trees or shrubs within 1/2 mile of overwintering
The DEIR lists the monarch butterfly in Table C-1:

Special Status Species Considered in the Evaluation
of the Planning Area on page A-104 and states that
the potential for the Monarch Butterfly to occur is
medium and that "suitable habitat occurs at the
sound end of Pacifica, but it is not known to support
migratory monarchs." On DEIR page 3.7-29, the
description of Monarch Butterflies states "In
California, the overwintering grounds are
threatened by coastal development as well as
removal of nonnative eucalyptus trees for
restoration of native habitat." The City notes that
any overwintering sites would be identified in
consultation with CDFW as part of the permitting
and approval process for individual projects
pursuant to the Proposed Project, as noted on DEIR
p. 3.7-50: "For specific development projects under
the Proposed Project, consultation may be required
with USFWS by the Federal Endangered Species Act,
and/or with the California Department of Fish and
Wildlife by the California Endangered Species Act.

Prior to project construction under the Proposed
Project, the applicant would be required to conduct
biological resource assessments and pre1.f
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groves, except for specific grove management
purposes, and/or for human health and safety
concerns. The maintenance of trees and shrubs
within a 1/2 mile of these sites provides a buffer to
preserve the microclimate conditions of the winter
habitat.
o Conduct management activities in groves from
March 16-September 14, in coordination with a
monarch biologist, such as tree trimming, mowing,
burning and grazing in monarch overwintering
habitat outside of the estimated timeframe when
monarchs are likely present.
o Enhance native, insecticide-free nectar sources by
planting fall/winter blooming forbs or shrubs within
overwintering groves and within one mile of the
groves
(https://xerces.org/sites/default/files/publications/
18-003_02_Monarch-Nectar-Plant-ListsFS_web%20-%20Jessa%20Kay%20Cruz.pdf). o Avoid the use pesticides within one mile of
overwintering groves, particularly when monarchs
may be present. If pesticides are used, then conduct
applications from March 16-September 14, when
possible. Avoid the use of neonicotinoids or other
systemic insecticides, including coated seeds, any
time of the year in monarch habitat due to their
ecosystem persistence, systemic nature, and
toxicity. Avoid the use of soil fumigants.
o Consider non-chemical weed control techniques,
when possible (https://www.calipc.org/resources/library/publications/non-chem/). o Remove tropical milkweed that is detected, and
replace it with native, insecticide-free nectar plants
suitable for the location
(https://xerces.org/sites/default/files/publications/
18-003_02_Monarch-Nectar-Plant-ListsFS_web%20-%20Jessa%20Kay%20Cruz.pdf). o To assist in maintaining normal migration
behavior, do not plant any type of milkweed within
five miles of the coast from Mendocino County
south through Santa Barbara County, and within
one mile of the coast south of Santa Barbara
County, unless the species of milkweed is native to
the local area.
o Conduct grove monitoring for butterflies during
the Western Monarch Counts each fall and winter.

When possible, report when monarchs arrive and
depart the groves each year
(https://www.westernmonarchcount.org/).
construction plant and wildlife surveys at
development sites. Compensatory mitigation would
also be required in order to offset the loss of or
alteration to special status species’ habitat." In
addition, the following policies apply specifically to
habitat conservation, including policies to support
open space conservation and habitat protection as
well as wildlife and critical habitat, including
potential ESHA (LU-G-7, CO-G-7, and CO-G-11), to
support habitat preservation through requirement
of habitat survey prepared by a qualified botanist or
biologist for any development in sensitive areas
shown in Figure 7-3 (CO-I-31), coordination with
conservation organizations to optimize habitat
protection for public lands (CO-I-42), and
consultation with the CDFW to protect biological
resources with new development (CO-I-26). Other
policies protect against removal of monarch habitat
and prohibit new development that requires fuel
modification within ESHAs (CO-I-30) and
requirement of a Restoration and Monitoring
Proposal for any proposed habitat restoration that
includes a planting plan (CO-I-32).

Therefore, the findings of the DEIR that compliance
with CESA regulations and implementation of
Proposed Project policies Lu-G-7, CO-G-7, CO-G-11,
CO-I-42, CO-I-26, and CO-I-30 would reduce impacts
to less than significant remain valid.

A2-13 CDFW; Will
Kanz,
Environment
al Scientist
3/20/2
2 COMMENT 5: Setback from Streams, Creeks, Ponds,
Lakes, Wetlands, etc.

Issue: The Project DEIR does not include prescriptive
riparian buffers into its zoning updates. “A riparian
buffer is an area along a shoreline, wetland or
stream where development is restricted or
See response for A2-14

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prohibited. The primary functions of the buffer is to
physically protect and separate a stream, lake,
pond, wetland etc. from future disturbances or
encroachment.” If there are no Project setbacks,
there are no protective measures for environmental
sensitive habitat in these areas.

Evidence: Riparian areas provide important
ecological functions for terrestrial and aquatic
ecosystems. More than 225 species depend on
California’s riparian habitat. These species use
riparian habitat for migrating, nesting, feeding and
rearing young.

Each stream, creek, lake, pond, wetland, etc., is
unique and may require a different buffer or
setback. Riparian areas perform many ecological
functions such as enhancing water quality/quantity,
biodiversity, habitat connectivity, and flood
capacity. The stream, lake, pond, wetlands etc.,
conveys runoff, provides groundwater recharge,
supports aquatic plants and animals, as well as
supplies water to trees and plants that thrive in the
riparian zone. Setbacks or buffers are an effective
tool to physically protect and separate stream or
wetlands from future disturbances. If properly
maintained, setbacks or stream buffers can have
significant opportunities to mitigate some of the
effects of development. Setbacks or stream buffers
protect stream function, protect habitat, and
provide additional capacity for flood flow
conveyance. A summary of impacts to aquatic
features from insufficient riparian setbacks include
the following (San Francisco Bay Regional Water
Quality Control Board (RWQCB), 2004):
· Elimination of natural channel, including loss of
wetlands, wildlife, fisheries and riparian areas;
· Increased sedimentation due to construction
activities and land clearing;
· Unmitigated changes in hydrology that upset the
geomorphic equilibrium of streams, causing
destabilization and erosion of channels, and more
frequent flooding;
· Increased pollutant loads associated with urban
activities;
· Impairment of fish habitat from water diversions
and fish passage barriers due to the construction of
in-channel reservoirs and diversion structures, the
sedimentation of channels, and the removal of
vegetation; and;
· Increased pollutant loads associated with
agricultural activities.

In its Watershed Management Initiative, the State
Water Resources Control Board (San Francisco Bay
RWQCB, 2004) identified the major non-point

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source problems within the San Francisco Bay
Region. “Many of which can be partially or fully
addressed through
establishment of setbacks or stream buffers”. The
San Francisco Bay RWQCB prepared a Stream
Protection Policy with the objective for riparian
buffer zones: “Buffer zones shall be maintained or
enhanced to protect stream functions. Examples of
ways in which buffer zones protect stream functions
include: removing agricultural and urban
stormwater pollutants, reducing sediment from
upland sources, stabilizing stream banks, minimizing
changes to the hydrograph by infiltrating
stormwater runoff, metering stream baseflow, and
supporting vegetation which provides nutrients and
shade.” (San Francisco Bay RWQCB, 2004)
Furthermore, the establishment of buffer zones in
moderate to highly disturbed agricultural areas has
been shown to increase aquatic condition and
habitat value (Teels et al., 2006). Increased buffer
widths have also been shown to have a general
positive relationship with terrestrial species
abundance (Marczak et al., 2010).

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A2-14 CDFW; Will
Kanz,
Environment
al Scientist
3/21/2
2 Recommendations: CDFW strongly recommends the
City of Pacifica adopt riparian buffer zones into its
zoning to prohibit development adjacent to
streams, creeks, rivers (including perennial,
intermittent, and ephemeral), wetlands, ponds, and
other environmentally sensitive habitat areas.

Additionally, these buffer areas will help to protect
water quality and habitat for aquatic and terrestrial
species. Because the size of a buffer zone may be
dependent on numerous factors including the size
of the watershed, level of disturbance, and species
that occupy the habitat, CDFW recommends the
City of Pacifica coordinate with CDFW to develop a
detailed and descriptive document that lays out the
guidelines for riparian buffers and setbacks. For
agricultural riparian buffers, CDFW has a California
Landowner Incentive Program
(https://wildlife.ca.gov/Lands/CWHP/Private-LandsPrograms/Landowner-Incentive-Program/Phase-2) that is a voluntary, incentive-based program. It
provides funding to restore marginal or flood-prone
farmland to riparian buffers, disburses annual
incentive funding to assist with costs of habitat
management and the loss of income associated
with idling farmland, and provides technical
assistance to restore and manage riparian buffers.

The comment is incorrect, the DEIR clearly describes
and includes riparian buffers, as well the Proposed
Project's potential impacts: On p. 3.7-45, the DEIR
states "the biological productivity and the quality of
coastal waters, streams, wetlands, estuaries, and
lakes appropriate to maintain optimum populations
of marine organisms and for the protection of
human health shall be maintained and, where
feasible, restored through, among other mean's,
minimizing adverse effects of wastewater discharge
and entrainment, controlling runoff, preventing
depletion of ground water supplies and substantial
interference with surface waterflow, encouraging
wastewater reclamation, maintaining natural
vegetation buffer areas that protect riparian
habitats, and minimizing alteration of natural
streams." Such policies to implement riparian buffer
zones include those to maintain, protect, and
restore Pacifica's creeks, including requirement of
100-foot setbacks from the top of creek banks or
from outer edge of riparian vegetation for
development proposed adjacent to creeks, in
addition to requirement of a biological report
demonstrating hte buffer shall prevent impacts that
significantly degrade the creek (CO-I-1), and
verification and management of ESHA, which would
be establish a minimum of 100 feet from any
sensitive resource (CO-I-27 and CO-I-28). Policy COI-26 addresses consultation with the CDFW if special status species are detected
These conservation buffer policies for sensitive
habitats (including ESHA, wetlands, and other
riparian areas) would apply to new developments
prior to project approval, thus compliance with
these Proposed Plan policies would reduce impacts
to less than significant.

A2-15 CDFW; Will
Kanz,
Environment
al Scientist
3/22/2
2 COMMENT 6: San Francisco Garter Snake
Issue: The DEIR states that there is high potential
for San Francisco garter snake (SFGS; Thamnophis
sirtalis tetrataenia) to be present in the Project area during both the dry and the wet season. However,
the proposed Project does not consider the full
extent of development impacts to upland habitat
for SFGS, a State Fully Protected species.

Construction and maintenance activities in suitable
upland SFGS habitat has the potential to result in
direct and indirect take to SFGS. Indirect take may
occur as a result of upland habitat loss and
degraded site suitability for SFGS to complete all
stages of their life cycle such as through the
construction of roads, installation of fences blocking
suitable habitat and loss of habitat through
development.

See response for A2-16.

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Because of the high probability of presence of the
species within the Project area, the appropriate
avoidance and minimization measures must be in
place to avoid take. As currently stated, CDFW does
not believe the avoidance measures in the DEIR will
avoid all impacts to SFGS. Take of a fully protected
SFGS is prohibited, and CDFW cannot authorize its
take in association with development or
maintenance projects, except under the provisions
of an NCCP.

Evidence the impact would be significant:

Consistent with CEQA Guidelines, Section 15380,
the status of SFGS as an endangered species under
CESA (Fish & G. Code, §2050 et seq.) and as a Fully
Protected species (Fish & G. Code § 5050) qualifies
it as an endangered, rare, or threatened species
under CEQA. SFGS is an endemic snake with a highly
limited range in the San Francisco Peninsula. SFGS
utilize a variety of habitats including upland sites for basking, rodent burrows for shelter and low-lying
marsh for feeding and reproduction (U.S. Fish and
Wildlife Service (USFWS), 1985). In coastal areas,
SFGS may hibernate during the winter in small
mammal burrows (USFWS, 2007). SFGS are
threatened by loss of habitat from agricultural,
commercial, and urban development, illegal
collection by reptile breeders, and decline of their
prey species, California red-legged frog (CRLF, Rana
draytonii) (USFWS, 2007).

Both CRLF and SFGS utilize upland habitat. CRLF can
disperse up to one mile through upland habitat
during the wet season (USFWS, 2002). Habitat loss,
fragmentation, and degradation remain the leading
cause of amphibian and reptile decline (Gallant et
al., 2007; Thompson et al., 2016). Although the
Project proposes to implement avoidance and
minimization measures, it does not avoid the of
potential upland habitat destruction which would
reduce and restrict the range of both SFGS and their
prey species CRLF. Ground disturbing work such as
grading and grubbing necessary for the completion
of development has the potential to result in the
direct take of SFGS utilizing animal burrows and
indirectly impact their habitat availability by
removing the availability of burrows from the site.

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A2-16 CDFW; Will
Kanz,
Environment
al Scientist
3/23/2
2 Recommendation: CDFW recommends the
following avoidance measures are incorporated into
the EIR and included in all projects that are within
suitable SFGS habitat.

Recommended SFGS Avoidance and Minimization:

All projects shall be designed to avoid all impacts to
SFGS within suitable SFGS habitat including but not
limited to wetlands, streams and waterways as well
as associated upland habitat capable of providing
dens and basking habitat as determined by a
qualified biologist, experienced with SFGS, in
coordination with CDFW. Increased no build buffer
zones around wetland and riparian resources shall
be incorporated and the footprint of any new
structures in upland habitat shall be the minimum
necessary. If take of SFGS is likely then the Project
shall not be approved. The lead agency shall
coordinate with CDFW to ensure the Project is
designed to avoid take of a fully protected species.

The DEIR notes on p. 3.7-31 that "SFGS lives in
marshlands that border ponds and sloughs, riparian
cover along streams, and bordering meadows with
scattered brush, and also uses upland habitat for
overwintering and feeding." All federally and state
threatened, endangered, and candidate wildlife
species are protected under the Federal
Endangered Species Act and the California
Endangered Species Act, respectively; the DEIR
states on p. 3.7-51 that "For specific development
projects under the Proposed Project, consultation
may be required with USFWS by FESA, and/or with
the California DFW by CESA. Prior to project
construction under the Proposed Project, the
applicant would be required to conduct biological
resource assessments and pre-construction plant
and wildlife surveys at development sites.

Compensatory mitigation would also be required in
order to offset the loss of or alteration to special
status species’ habitat." In addition to federal and
State laws which would apply to protect the SFGS,
implementation of the following Proposed Project
policies would reduce potential impacts to specialstatus species to a less than significant level, including protection of open space as well as
important and critical habitat (LU-G-7, CO-G-7);
creek protection and restoration (CO-I-1); wetlands
preservation (CO-I-4); preseving biological
productivity (CO-I-38); protection, verification, and
monitoring of ESHA (GO-G-11, CO-I-27, and CO-I28); habitat preservation requiring special survey in areas delinated in Figure 7-3 (CO-I-31); monitoring
requirements for any proposed habitat restoration
or mitigation (CO-I-32); protection of biological
resources with new development (CO-I-26); specific
protection of SFGS during construction activity (COI-26); and requirement of free passage with any fencing or barriers in riparian ESHA or wildlife
corridor (CO-I-29).

While these above policies would reduce impacts to
less than significant, more specificity around
"upland habitat" is included in the following policy:

CO-I-26 ✳Protection of Biological Resources with
New Development. Protect sensitive habitat areas
and special-status species through implementation
of the following measures:
1) Discourage development and/or buildout in
critical habitat of special status species during the
development review process.
2) Pre-construction plant and wildlife surveys:

Project applicants shall engage a qualified biologist
to conduct presence/absence biological surveys for
sensitive plant and wildlife species prior to

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construction adjacent to or within identified special
status communities and other sensitive areas
identified in Figure 7-3 of the proposed General
Plan. If special status species are identified, the
qualified biologist shall consult with the California
Department of Fish and Wildlife (CDFW) and
establish no-disturbance buffers around special
status species to avoid disturbance and direct
impacts to these resources during construction. If
no special status species are detected during
surveys, then construction-related activities may
proceed. Nesting birds, in particular, are protected
by two means; they receive protection under the
Migratory Bird Treaty Act, and nesting raptors (in
the order Falconiformes or Strigiformes) are
protected under the State Fish and Game Code,
§3503.5.
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, upland habitat,
or other sensitive habitat areas shown on Figure 7-3
of the General Plan.
4) Require on-site monitoring of biological
resources by a qualified biologist throughout the
duration of construction activity.
5) Require compensatory mitigation by means of
habitat preservation, restoration, and
enhancement; for the loss of any critical habitat
and/or special status communities.

A2-17 CDFW; Will
Kanz,
Environment
al Scientist
3/24/2
2 COMMENT 7: Loss of Pond Habitat Issue:

Development of a golf course to a residential and
commercial development may result in the
destruction of on-site golf course ponds, which
provide habitat for wetland dependent species and
reduce wildlife connectivity. Evidence the impact
would be significant: Manmade ponds on golf
courses can provide food resources for many
species of waterbirds (White and Main, 2005).

Manmade ponds on golf courses can also provide
suitable habitat for wetland dependent wildlife
including semi-aquatic turtles (Price et al., 2013),
amphibians, and macroinvertebrates (Colding et al.,
2009).

See response for A2-18
A2-18 CDFW; Will
Kanz,
3/25/2
2 Recommendations to minimize significant impacts:

CDFW recommends retaining onsite ponds into the
The Proposed Project does not include changing the
designation of a golf course to residential or
commercial development as show in Figure 2.2-1
General Plan Land Use which designates the Sharp

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Environment
al Scientist
design of the development and incorporating
wildlife corridors with adjacent open space.

Park Golf Course as a Park land use. The DEIR
discusses impacts to ponds specifically at the Sharp
Park Golf Course on p. 3.7-59 and these habitats are
shown in Figure 3.7-2. The DEIR includes multiple
policies to protect sensitive species and habitats
related to the Sharp Park Golf Course and other
sensitive species, including:
(CO-I-4) Wetlands Preservation. Prohibit new
development in existing wetlands except as allowed
under the federal Clean Water Act and the
California Coastal Act. Continue to require formal
delineations wetlands subject to State or federal
regulations prior to any proposed development
project in an area where potential wetlands have
been identified. If impacts on wetlands are
unavoidable, compensation measure should be in
line with the State’s no-net-loss goal regarding
wetlands.
(CO-I-38) Biological Productivity. Maintain—and
where feasible, restore—the biological productivity
and the quality of coastal waters, streams,
wetlands, and lakes in order to maintain optimum
populations of marine organisms and to protect
human health.

Techniques may include:
• Minimizing adverse effects of wastewater
discharge;
• Controlling runoff, preventing depletion of ground
water supplies and substantial interference with
surface waterflow;
• Encouraging wastewater reclamation, maintaining
natural vegetation buffer areas that protect riparian
habitats; and
• Minimizing alteration of natural streams.
(CO-I-27) Verification of ESHA. Prior to any
proposed development in an ESHA or potential
ESHA, require that a habitat survey be conducted by
a qualified botanist or biologist. The habitat survey
will verify whether the site is an ESHA, and
document the extent of the sensitive resources,
document potential negative impacts to the habitat,
and recommend appropriate mitigation measures.

Verification of an ESHA shall be based on the
following considerations:
• Presence of natural communities identified as rare
by the California Department of Fish and Wildlife
(determined by a state rarity ranking of S1 to S3).
• Recorded or potential presence of plant or animal
species designated as rare, threatened or
endangered under State or federal law.
• Recorded or potential presence of plant or animal
species for which there is compelling evidence or
rarity, such as a designation of 1B (rare or
endangered in California or elsewhere) or 2 (rare,
threatened, or endangered in California, but more

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common elsewhere) by the California Native Plant
Society.
• Presence of coastal waterways.
• Integrity of the habitat and its connectivity to
other natural areas.
(CO-I-31) Habitat Preservation. Require a habitat
survey be prepared by a qualified botanist or
biologist for any development proposed for the
following areas, as shown in Figure 7-3.
• Designated Critical Habitat for Endangered or
Threatened Species;
• Potential Environmentally Sensitive Habitat Area
(ESHA);
• High Habitat Value; and
• Wildlife Movement Corridor.

The survey will be used to determine the exact
location of habitat areas and to recommend
mitigation measures that minimize potential
impacts.
(CO-I-26) Protection of Biological Resources with
New Development. Protect sensitive habitat areas
and special-status species through implementation
of the following measures:
1) Discourage development and/or buildout in
critical habitat of special status species during the
development review process.
2) Pre-construction plant and wildlife surveys:

Project applicants shall engage a qualified biologist
to conduct presence/absence biological surveys for
sensitive plant and wildlife species prior to
construction adjacent to or within identified special
status communities and other sensitive areas
identified in Figure 7-3 of the proposed General
Plan. If special status species are identified, the
qualified biologist shall consult with the California
Department of Fish and Wildlife (CDFW) and
establish no-disturbance buffers around avian nests,
bat roosts, and sensitive plants to avoid disturbance
and direct impacts to these resources during
construction. If no special status species are
detected during surveys, then construction-related
activities may proceed. Nesting birds, in particular,
are protected by two means; they receive
protection under the Migratory Bird Treaty Act, and
nesting raptors (in the order Falconiformes or
Strigiformes) are protected under the State Fish and
Game Code, §3503.5.
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, or other
sensitive habitat areas shown on Figure 7-3 of the
proposed General Plan.
4) Require on-site monitoring of biological
resources by a qualified biologist throughout the
duration of construction activity.
5) Require compensatory mitigation by means of

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habitat preservation, restoration, and
enhancement; for the loss of any critical habitat
and/or special status communities.

The City will coordinate with the U.S. Fish and
Wildlife Service, National Marine Fisheries Service,
California Department of Fish and Wildlife, and
Regional Water Quality Control Board in providing
project applicants with the best guidance to avoid
impacts to special status species and habitat areas
including creeks, wetland features, woodlands, or
other sensitive natural features.
(OC-I-17) Sharp Park. Support the continued
operation of golf at Sharp Park Golf Course, and
support development of additional recreational
uses in upland portions of the Park.

The long-term management approach must protect
existing development from hazards; protect and
restore habitat; and maintain public access to and
along the beach.

Compliance with these Proposed Plan policies
combined with the preservation of the Sharp Park
Golf Course as a park would retain the wetlands and
ponds located on-site.

A2-19 CDFW; Will
Kanz,
Environment
al Scientist
3/26/2
2 COMMENT 8: California Red-Legged Frog
Issue: CRLF is known to occur within the Project
range but the DEIR does not identify specific
locations of all known or recorded detections. In
addition, the DEIR does not include sufficient
avoidance, minimization and mitigation measures
to off-set potentially significant effects to CRLF.

Evidence the impact would be significant: CRLF is a
species listed as threatened under the Federal
Endangered Species Act (ESA) and a California
Species of Special Concern (SSC). CRLF require a
variety of habitats, including aquatic breeding
habitats and upland dispersal habitats. Breeding
sites of the species are in aquatic habitats including
pools and backwaters within streams and creeks,
ponds, marshes, springs, sag ponds, dune ponds
and lagoons. Additionally, CRLF frequently breed in
artificial impoundments such as stock ponds
(USFWS 2002). Breeding sites are generally found in
deep, still, or slow-moving water (>2.5 feet) and can
have a wide range of edge and emergent cover
amounts. CRLF can breed at sites with dense
shrubby riparian or emergent vegetation, such as
cattails or overhanging willows, or can proliferate in
ponds devoid of emergent vegetation (i.e., stock
ponds). Habitat includes nearly any area within one
to two miles of a breeding site that stays moist and
cool through the summer; this includes nonbreeding aquatic habitat in pools of slow-moving streams, perennial or ephemeral ponds, and upland
See response for A2-20

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sheltering habitat such as rocks, small mammal
burrows, logs, densely vegetated areas, and even
man-made structures (i.e., culverts, livestock
troughs, spring-boxes, and abandoned sheds)
(USFWS 2017). CRLF populations throughout the
State have experienced ongoing and drastic declines
and many have been extirpated (Thomson et al.
2016). Habitat loss from growth of cities and
suburbs, mining, overgrazing by cattle, invasion of
nonnative plants, impoundments, water diversions,
stream maintenance for flood control, degraded
water quality, and introduced predators, such as
bullfrogs are the primary threats to the species
(Thomson et al. 2016, USFWS 2017). Development
could injure or kill CRLF if they occur on-site,
resulting in a substantial reduction of the
population.

A2-20 CDFW; Will
Kanz,
Environment
al Scientist
3/27/2
2 Recommendations: CDFW recommends the EIR
include additional detection information of known
CRLF detections including those from the following
sources: historical and recent survey data, field
reconnaissance, scientific literature and reports,
and findings from “positive occurrence” databases
such as California Natural Diversity Database
(CNDDB) In addition, CDFW recommends the
following measures are incorporated into the EIR
and included in all projects in suitable CRLF habitat:
· A qualified biologist shall complete CRLF habitat
assessments in accordance with the Revised
Guidance on Site Assessments and Field Surveys for
the California red-legged frog (USFWS 2005) (survey
protocol). Results of the habitat assessment shall be
submitted to USFWS and CDFW for review and
written acceptance prior to starting Project
activities. If after review of the results of the habitat assessment, USFWS or CDFW determines that
surveys are warranted, then surveys shall be
conducted in accordance with the USFWS survey
protocol prior to starting project activities. Results
of surveys shall also be submitted to CDFW for
review and approval in writing.
· If a project may impact CRLF based on the results
of the habitat assessment and any surveys, the
project shall obtain authorization from USFWS for
impacts to the species prior to project start.
· If CRLF is discovered during the habitat
assessment, surveys, or during Project construction,
work shall be delayed/ceased immediately and
contact CDFW and USFWS within 24 hours. In this
event, Project work shall not resume/proceed until
the frog, through its own volition, moves out of
harm’s way and CDFW and USFWS have provided
permission in writing to proceed with the Project.

The Program DEIR identifies both specific locations
of all known or recorded detections and critical
habitat locations for the California Red-Legged Frog
(CRLF) in Figure 3.7-3 Sensitive and Critical Habitat
and 3.7-4 Special Status Species. Figure 3.7-3 shows
the Critical Habitat areas for the CLRF, in
coordination with the most up to date information
provided by USFWS. Figure 3.7-4 shows recorded
detections of the CRLF, sourced from the California
Natural Diversity Database. This represents the best
available evidence for a programmatic EIR. As a
special-status species, the CRLF subject to state and
federal protections. As noted on DEIR p. 3.7-51, "For
specific development projects under the Proposed
Project, consultation may be required with USFWS
by FESA, and/or with the California DFW by CESA.

Prior to project construction under the Proposed
Project, the applicant would be required to conduct
biological resource assessments and preconstruction plant and wildlife surveys at development sites. Compensatory mitigation would
also be required in order to offset the loss of or
alteration to special status species’ habitat." Specific goals and policies to address protecting the CRLF
habitat and other sensitive habitat areas include
policies that protect areas tht support critical
wildlife habitat and special status species (LU-G-7
and CO-G-7), protection of biological resources with
new development (CO-I-26), and explicit reference
to protection of the CRLF and SFGS during
construction (CO-I-35), requirement of habitat
survey in any critical habitat, potential ESHA, high
habitat value, and wildlife movement corridor areas
(CO-I-31).

1.f
Packet Pg. 703 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 39 Letter Commenter Date Comment Combined Response
Agencies (A)
A2-21 CDFW; Will
Kanz,
Environment
al Scientist
3/28/2
2 ENVIRONMENTAL DATA
CEQA requires that information developed in
environmental impact reports and negative
declarations be incorporated into a database which
may be used to make subsequent or supplemental
environmental determinations. (Pub. Resources
Code, §21003, subd. (e)). Accordingly, please report
any special-status species and natural communities
detected during Project surveys to the CNDDB. The
CNNDB field survey DocuSign Envelope ID:

FE837397-619A-404C-ADB9-2F3D70DEF00E form
can be found at the following link:
https://wildlife.ca.gov/Data/CNDDB/SubmittingData#44524420-pdf-field-survey-form. The completed form can be mailed electronically to
CNDDB at the following email address:

[email protected]. The types of information
reported to CNDDB can be found at the following
link:
https://wildlife.ca.gov/Data/CNDDB/Plants-andAnimals.

The comment is noted. Policy CO-I-26 addresses
consultaton with the CDFW if special status species
are detected.

1.f
Packet Pg. 704 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 40 A3: Dr. Erik Frost, CGS, 2/1/2022
A3-1 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/1/22 Earthquake Hazard Zones Numerous potential
earthquake hazards exist within the planning area:
a) Fault Rupture, Liquefaction and Landslide
Hazards The DEIR includes figures depicting the
most up-to-date Earthquake Zones of Required
Investigation produced under the Alquist-Priolo
Earthquake Fault Zoning Act and the Seismic
Hazards Mapping Act. The City may also wish to
provide in the Safety Element links to CGS websites
that will be updated as maps are published and
revised:
https://maps.conservation.ca.gov/cgs/information
warehouse/regulatorymaps/
https://maps.conservation.ca.gov/cgs/information
warehouse/apreports/
https://maps.conservation.ca.gov/cgs/EQZApp/app
/
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response: EIR comments for more
information about GP- or SPSP-related responses.

A3-2 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/2/22 Tsunami Hazards The DEIR includes the most recent Tsunami Hazard Area maps for evacuation planning,
which were updated in 2020. Within the next
couple years, CGS will be completing new Tsunami
Hazard Zones under the Seismic Hazard Mapping
Act. These new Tsunami Hazard Zones will use the
same area of the 2020 Tsunami Hazard Area maps
to delineate the overall hazard zone but will include
within it an additional Engineering Analysis
Subzone, which will be delineated by probabilistic
tsunami hazard analyses. When these new Tsunami
Hazard Zones are released, the City of Pacifica will
be responsible for requiring site-specific
investigations and reviewing investigation reports
for development projects, in the same manner as
the other Earthquake Hazard Zones. CGS will reach
out to the City of Pacifica close to the time
Preliminary Tsunami Hazard Zones are released.

The comment is noted.

A3-3 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/3/22 Geologic Hazards
a) Landslides
The DEIR currently includes a figure depicting the
relative density of existing landslides (“mostly
landslides,” “few landslides,” and “not landslide
prone”) throughout the planning area. The City
should also consider providing a map of specific
landslides. CGS has compiled an inventory of
landslides in the planning area (as shown in Seismic
Hazard Zone Reports 128 and 133), and we
recommend this inventory be shown in an
appropriate figure. The GIS data for this landslide
inventory will be transmitted separately.

The comment is noted. As noted in the Department
Conservation Seismic Hazard Zones mapping
methodology, available at
https://www.conservation.ca.gov/cgs/Documents/P
ublications/SHZR/SHZR_133_San_Francisco_South_
a11y.pdf: "As a part of the geologic data
compilation, an inventory of existing landslides in
the San Francisco South Quadrangle, San Mateo
County was prepared by analysis of shaded relief
maps (various illumination directions) and contour
data, limited field reconnaissance, and a review of
previously published (Harding-Lawson, 1983;
Bonilla, 1988; Jacobs Associates, 1999; Brabb and
others, 2000; Wentworth and others, 1998) and
unpublished geologic-landslide mapping. Landslides
were reviewed using the lidar shaded-relief map
(USGS, 2005), Google Earth Pro DigitalGlobe and

1.f
Packet Pg. 705 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 41 Historical Imagery, and stereo-paired aerial photos.

For each landslide included on the map several
characteristics (attributes) were collected and
compiled in a geodatabase. These characteristics
include recency of activity, type, thickness,
associated geologic unit(s), and the confidence of
interpretation (definite, probable, or questionable).

The completed landslide map was digitized, and the
attributes were entered into a database. Landslides
rated as definite or probable were carried into the
landslide zone..." Methodology indicates that these
inventories are included in Seismic Hazard Zone
mapping, thus, the hazard assessment maps are
adequate.

A3-4 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/4/22 Debris Flows Shallow, rainfall-triggered landslides, described in the DEIR as debris flows, are a known
hazard within the City of Pacifica. The DEIR
mentions debris flow hazards but does not provide
much information on where this hazard exists nor
where it has occurred in the past. CGS recommends
that the Final EIR and Safety Element include debris
flow hazard maps and information prepared by the
USGS (USGS OFR 97-745 E; USGS Professional Paper
1434 including Plate 8). In particular, the City should consider using these references to help identify
existing developments subject to debris flow
hazards and determine what new development
areas should have geotechnical site investigations
prepared prior to project approval.

The comment is noted. A map of debris hazards was
included in the General Plan; it will be added to the
DEIR. This does not constitute new information and
does not change the conclusions of significance.

1.f
Packet Pg. 706 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 42 A4; Adrianne Carr, NCCWD, 3/8/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A4-1 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/8/22 In the Draft EIR, conservation element CO-G-5,
please note that the NCCWD has demonstrated
compliance with the 2020 water use target of 124
gallons per capita per day, having reduced its
potable water use in 2020 to 65 GPCD. There is no
need for the City to work with the District on
meeting this target.

The comment is noted. To further support NCCWD
efforts, including compliance with AB 1660 and SB
606, the following policy is thereby amended:
“Work with the Water District to meet State targets
for reducing per capita urban water use by 10
percent by 2015 and 20 percent by 2020. for
reducing per capita water use by 1annual water use
objectives, consistent with State targets. This does
not change findings of significance.

A4-2 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/9/22 In regards to conservation element CO-I-22, Water Recycling, the District welcomes the continued
support of the City in the implementation and
expansion of NCCWD’s recycled water project. In
addition to expansion of recycled water production,
which will take coordation between the City and the
District, the District seeks coordination with the City to create a commercial recycled water fill station, so
that construction-related dust control activities and
street cleaning activities can be done with recycled
water.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response: EIR comments for more
information about GP- or SPSP-related responses.

A4-3 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/10/2
2 In regards to conservation elelment CO-I-19, Water
Supply, the District would also welcome the City’s
support in the District’s efforts to secure reliable
local water supplies, such as groundwater.

A4-4 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/11/2
2 The District welcomes coordination efforts
proposed by the City in it’s measures CO-I- 20, CO-I21, CO-I-22, CO-I-23, SA-I-13, SA-I-92, and SA-I-108.

A4-5 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/12/2
2 In the dialog under Table 3.13-4 on page 3.13-23,
there are two typos ("mdg" should be "mgd").

The comment is noted. The second and third
sentence of the first paragraph on page 3.13-23 are
hereby amended as follows, "While implementation
of the Proposed Project would
result in a projected population slightly higher than
NCCWD’s projected 2040 population, demand is
estimated to be 2.27 mgd mdg. Water supply in
regular years is expected to be 3.87 mgd mdg,
similar to other years. Based on these calculations,
there will be adequate water supply to provide for
the population under General Plan buildout in a
normal year." This amendment represents a minor
clarification and does not affect the findings of the
DEIR.

A4-6 NCCWD;
Adrianne
Carr, Ph.D.
3/13/2
2 The District supports the City's Sharp Park Specific
Plan policies that reduce impacts 6-I-13, 6-I-14 and
6-1-21 by supporting water conservation and water
recycling.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared

1.f
Packet Pg. 707 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 43 Letter Commenter Date Comment Combined Response
Agencies (A)
General
Manager
with decision-makers in that context. Please see
Master Response: EIR comments for more
information about GP- or SPSP-related responses.

A4-7 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/14/2
2 Please include the NCCWD in the City's emergency
planning and response coordination activities as
described in SA-I-101 and SA-I-102, as the District
does provide essential services during emergencies
and needs to be part of the City's meetings and
drills.

1.f
Packet Pg. 708 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 44 A5; Rob Bartoli, San Mateo LAFCO, 3/8/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A5-1 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/8/22 Please clarify the allowed Urban Reserve density.

Policy LU-I-4 in the DEIR states that the City should
“coordinate with San Mateo County to ensure that
new development in unincorporated areas occurs at
a maximum density of five acres per unit.” Policy
LU-I-4 in the Draft General Plan states that the
development in the Urban Reserve is “maximum
density of 10 acres per unit.” DEIR Policy LU-I-6
states that density for the Urban Reserve is a
“minimum lot area of 10 acres per dwelling unit.”
The response is clarified: "coordinate with San
Mateo County to ensure that new development in
unincorporated areas occurs at a maximum density
of five ten acres per unit." It does not change
findings of significance in the DEIR.

A5-2 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/9/22 For Policy LU-I-4, is it the City’s intent to have the County undertake a master plan for a subdivision of
50 acres or more located in the City’s Sphere of
Influence or it is proposed that the master plan
would be part of the City’s annexation process? In
addition to any City process and entitlements
needed for annexations, LAFCo will need to review
and approve any proposed boundary change.

The comment is noted. The comment is not related
to the adequacy of the DEIR, therefore no further
response is required in the FEIR. However, the
comment addresses the content of the Proposed
Plan and will be shared with decision-makers in that
context. Please see Master Response 1: EIR
Comments for more information about GP- or SPSPrelated responses.

A5-3 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/10/2
2

Page 4 ends

Urban Reserve land use. The section states that
“Sites within the Urban Reserve land designation
that are annexed into the City of Pacifica should
receive a land use designation consistent with the
applicable density prior to annexation.” For parcels
that are annexed to the City, would the parcels
retain the Urban Reserve land designation, or would
they receive a different land use designation?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

A5-4 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/11/2
2 Table 4-1 in the Draft General Plan lists Urban
Reserve as a land use, but does not show a density.

However, Table 4-1 shows Urban Reserve as having
a density of 0.1 or less.

The comment is noted. This change will be made in
the GP errata.

A5-5 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/12/2
2 Policy LU-I-6 in the Draft General Plan states that
the minimum lot area is 1010 acres and appears to
be a typo.

The comment is noted. This change will be made in
the GP errata.

A5-6 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/13/2
2 Page G-10 of the Draft General Plan defines a
Sphere of Influence as “The ultimate service area of
an incorporated city, as established by San Mateo
County.” The Sphere of Influence is established by
San Mateo LAFCo not the County.

The comment is noted. This change will be made in
the GP errata.

A5-7 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/14/2
2 The majority of the General Plan planning area is
served by North Coast County Water District for
water service. LAFCo encourages the City to
continue to engage with the district throughout this
update process, particularly if water service is
The comment is noted. As the comment does not
address the adequacy of the environmental analysis
contained in the DEIR, no further response is
required.

1.f
Packet Pg. 709 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 45 proposed to be expanded beyond the District’s
existing boundaries for potential development.

1.f
Packet Pg. 710 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 46 A6; Julia Koppman Norton, CCC, 3/1/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A6-1 Coastal
Commission; Julia
Koppman Norton
North Central Coast
District Supervisor
California Coastal
Commission
3/1/22 Thank you for the opportunity to provide comments on the DEIR for the City’s General Plan Update and Sharp Park Specific Plan. I’ve attached our prior correspondence on this matter, all of which we would like to be incorporated into the comment record for the DEIR and project. Broadly, and as indicated prior, the General Plan Update and Sharp Park Specific Plan, as well as this associated DEIR, must be consistent with the certified LCP. As the LUP update has been submitted to the Coastal Commission but has not yet been certified, the originally certified LCP is the standard with which the GP/SPSP must be consistent. Once an updated LUP is certified, the GP/SPSP would have to be updated to then be consistent with the updated LCP. As such, generally, it may make the most sense to coordinate timing of the GP/SPSP for after the LUP is certified, given the outstanding nature of the LUP certification.

The comment is noted. As described
on DEIR p. 2-7, "To the extent the
General Plan Update proposes any
policies beyond those which were
sent to the California Coastal
Commission for review and
certification, a subsequent LCP
amendment would be necessary to
make the LCP consistent with the
General Plan."
A6-2 Coastal
Commission; Julia
Koppman Norton
North Central Coast
District Supervisor
California Coastal
Commission
3/1/22 More specifically, policies proposed in the GP/SPSP that correspond to coastal resources cannot contradict the certified LCP and thus Coastal Act. While we understand that the City boundaries extend beyond those of the Coastal Zone, policies that contradict Coastal Act mandates cannot be applied within the Coastal Zone. However, as we understand it, multiple policies proposed in the LUP update are duplicated in the proposed GP update (as denoted by a wave symbol), despite not being certified policies and numerous concerns regarding inconsistencies with the Coastal Act that have been noted to City staff over the years. Thus, policies in Chapter 6 ‘Open Space and Community Facilities,’ Section 6.3 ‘Coastal Access’; Chapter 7 ‘Conservation,’ Sections 7.1-7.3 ‘Water, Biological, Land and Soil Resources’; and Chapter 8 ‘Safety,’ Sections 8.1-8.3 and 8.5-8.6 ‘Seismic and Geologic Hazards, Flooding and Drainage, Coastal Resilience, Fire Hazards, and Public Safety and Emergency Management’ (and any other relevant policies) need to be made fully consistent with the currently certified LCP, and thus Coastal Act – currently, the policies noted as being included in both GP and LCLUP are not certified and thus not in effect in the Coastal Zone at this time. Further, the General Plan update appears to include policies that would only apply in coastal areas, including those pertaining to coastal access, coastal resilience, shoreline development, and allowances for shoreline armoring; these cannot be applied in the CZ as the LCP currently stands. As such, please include the attached past comment letters regarding Coastal Act inconsistencies of proposed LUP policies in the record for this GP/SPSP DEIR. Please note that all in-line edits previously provided to City staff on iterations of the proposed LUP update should also be incorporated as feedback on the overlapping GP update policies.

The comment is noted. it does not
pertain to the merits of the DEIR.

While the LCLUP is not certified,
policies in the plan represent postconsultation comments and in-line edits provided by the Coastal
Commission. Please see response to
comment A6-1 for more information
on how the General Plan will be
made consistent.

A6-3 Coastal
Commission; Julia
Koppman Norton
North Central Coast
District Supervisor
California Coastal
Commission
3/1/22
[email correspondence attached] The correspondence is received.

1.f
Packet Pg. 711 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 47 Pacifica Organizations (B)

1.f
Packet Pg. 712 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 48 B1: Judy Heldberg, Pacifica Historical Society, 2/18/2022 Letter Commenter Date Comment Combined Response
Organizations (B)
B1-1 The Pacifica
Historical
Society
Board of
Directors,
Judy
Heldberg –
President
2/18/22 These comments regarding the Draft Pacifica
General Plan have been approved by the Board of
Directors of The Pacifica Historical Society on
February 8, 2022. In order to be clear with what
changes we propose, we have included here the
entire section of the 2022 Draft Pacifica General
Plan Chapter 7 (Conservation) section 7.6
“CULTURAL RESOURCES AND HISTORIC
PRESERVATION”. Fig. 4. could not be copied, but
comments are included after comments on Table 5.

For clarity, this second copy does not show the
suggested changes and omissions. 7.6 CULTURAL
RESOURCES AND HISTORIC PRESERVATION One
objective of the General Plan is to protect
community assets, including sites with historical and
cultural significance. Cultural resources include
prehistoric or archaeological sites, properties of
cultural or historic significance, or paleontological
sites. Pacifica has a rich history with regional and
statewide significance, as it was home to Native
American villages as well as the first sighting of the
San Francisco Bay by non-indigenous people. The
Sanchez Adobe Historical Site along San Pedro
Creek, which features physical evidence of several
significant periods in California history.

Historic Context
Native Americans had an extensive presence in the
Planning Area. When Europeans arrived, the area
was home to persons speaking the
Costanoan/Ohlone language, and living in and
around two villages: Pruristac, in San Pedro Valley,
and Timigtac, in Calera Valley. In 1769, an
expedition led by Gaspar de Portola, governor of
the Spanish territory covering both Baja and Alta
California, camped in San Pedro Valley and first
sighted San Francisco Bay from a point on Pacifica’s
Sweeney Ridge. Not long after, Mission San
Francisco de Asis (Mission Dolores in present-day
San Francisco) was established, and in 1786 the
Mission developed an outpost in San Pedro Valley,
alongside Pruristac. The Ohlone village was wiped
out by disease in 1791.21 Mexican independence
from Spain was followed by a “secularization”
program, and in 1839 the San Pedro mission
outpost and its rancho, covering the majority of the
Planning Area, was granted to Francisco Sanchez,
who built the adobe house that stands today as the
oldest structure in San Mateo County. Following his
death, the land was divided and the area developed
slowly. In 1905 construction began on the Ocean
Shore Railway, which was to connect San Francisco
with Santa Cruz. The line was never completed, but
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

1.f
Packet Pg. 713 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 49 Letter Commenter Date Comment Combined Response
Organizations (B)
operated as far south as Half Moon Bay until 1921,
supporting a string of stops in present-day Pacifica
including Edgemar, Salada Beach, Brighton Beach,
Vallemar, Rockaway Beach, and Tobin (San Pedro
Terrance-by-the- Sea. The communities surrounding
the railway stops grew slowly until the building
boom following World War II. Pacifica incorporated
as a City in 1957, as the union of these
unincorporated neighborhoods. Native American
Cultural Resources Five Native American
archaeological resources have been found and
recorded in Pacifica, all classified as habitation sites.

Two additional resources contain both Native
American and historic-era archaeological value. The
Sanchez Adobe, operated by the San Mateo County
Historical Association as an historical site, is listed as a State Historical Landmark and is listed on the
National Register of Historic Places. The Sanchez
Adobe Park, site of the Pruristac village and the
outpost or asistencia San Pedro y San Pablo of the
Mission San Francisco de Asis (Mission Dolores),
also is listed in the National Register of Historic
Places and the California Register of Historical
Resources. The San Mateo County Historical
Association recently dedicated (summer 2021) a
new building in Sanchez Adobe Park featuring the
history and lifeways of the local Aramai-Ohlone who
lived in the village of Pruristac. The facility is
specifically designed to accommodate tours of
school groups. The Planning Area is rich with the
types of environments where Native American
cultural resources have been found: permanent and
intermittent streams, productive coastal
environments, and sheltered locations for
permanent habitations, as well as ridgelines,
terraces, spurs and saddles. The Planning Area also
includes a significant amount of alluvial soil, which
in some cases is overlaid by artificial fill, increasing the probability for buried archaeological deposits.

There is considered to be a high likelihood that
unrecorded Native American cultural resources are
present. Contemporary Native American Resources
As part of the General Plan update process, the
Native American Heritage Commission (NAHC)
conducted a record search of the sacred lands file in
2009. The search did not indicate the presence of
additional Native American cultural resources
within the Planning Area. The NAHC response listed
six tribes that may have historic ties to the Planning
Area, and letters of inquiry were sent to the six
tribal representatives; however, no responses were
received.

In 1769, an expedition led by Gaspar de Portola
sighted San Francisco Bay from a point on Pacifica’s
Sweeney Ridge (upper). The Sanchez Adobe, built in

1.f
Packet Pg. 714 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 50 Letter Commenter Date Comment Combined Response
Organizations (B)
1842, is the oldest surviving structure in San Mateo
County. The site was once the Ohlone village of
Pruristac (lower). Historic Resources The Portola
Expedition Camp at San Pedro Creek, the Discovery
Site, and the Sanchez Adobe are State Historical
Landmarks. Tobin Station, one of two remaining
structures from the Ocean Shore Railroad, is a State
Point of Historical Interest. A Master Plan for the
Sanchez Adobe Historical Site, completed in 2007
aims to increase visitation and improve visitors’
educational experience while ensuring that the site
is preserved for future generations. The City has
identified nine local historical landmarks: Sanchez
Adobe; the Little Brown Church; the former San
Pedro Schoolhouse (now City Hall); the 1907
Anderson’s Store building on Paloma Avenue; the
Sharp Park Golf Course club house, from 1932;
Vallemar Station; the former Dollaradio Station; and
two private residences (see Table 7-5). In 2005, the
Pacifica Historical Society began restoration of the
Little Brown Church to establish it as into the
Pacifica Coastside Museum, which opened in 2015.

The Historical Society also owns the last remaining
car from the Ocean Shore Railroad, and has stated
its interest in moving the railcar to be close to the
Little Brown Church, preferably in the parking lot at
Salada Avenue and Francisco Blvd. The City is
considering this as the potential location of the
railcar as part of a Civic Center master plan
discussed by the City Council in 2021. Local historic
landmarks in Pacifica are specifically designated in
the Historic Preservation Ordinance of 1985. They
are listed below in Table 7-5 and also shown in
Figure 7-4 (not shown).

B1-2 The Pacifica
Historical
Society
Board of
Directors,
Judy
Heldberg –
President
2/19/22 Revisions to Table 7-5 with correct headings &
listings:

A) National Historic Landmark – change 1st heading,
this applies only to one site:
- San Francisco Bay Discovery Site
B) National Register of Historic Places –new heading
for 2 items
- San Francisco Bay Discovery Site Remove Little
Brown Church as it is
- Sanchez Adobe not in B) National Register
C) California Historical Landmarks – all O.K.
- Discovery Site
- Sanchez Adobe
- Portola Expedition Camp
D) Local Landmarks Identified in Historic
Preservation Ordinance (1985) – all 9 listings O.K.

Age of buildings: Vallemar Station - 1906; 165
Winona - 1908; 185 Carmel Avenue - 1910
Revision to Figure 7-4:

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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Organizations (B)
• Little Brown Church is not listed on National
Register.
• The line points to the Portola Camp Historic
marker, not the actual campsite (which was on San
Pedro Creek).
• Discovery Site should add “National Historic
Landmark, National Register, and California Historic
Landmark”.
• We think the format of the map is good overall,
but the size of the notations of the sites themselves
is VERY small, so the colors do not show well.

B1-3 The Pacifica
Historical
Society
Board of
Directors,
Judy
Heldberg –
President
2/20/22 Historic Preservation Ordinance
The Historic Preservation Ordinance found at
Chapter 7 of Title 9 of the City’s Municipal Code
protects structures and sites of historic significance
in the City. The ordinance outlines procedures for
designating historic landmarks, describes the permit
process for the alteration, demolition, or relocating
of any historic structure, and includes a section
pertaining specifically to the Little Brown Church. It
also acknowledges the role of the Pacifica Historical
Society in designation of sites and the permit
process.

POLICIES
Policies included in both the General Plan and Local
Coastal Land Use Plan are indicated
Guiding Policies
CO-G-17 CO-G-18
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 of them.

Ensure Mitigation. Require mitigation for any new
development that would adversely affect
archaeological or paleontological resources.

Implementing Policies
CO-I-65 CO-I-66
Historic Preservation Ordinance. Continue to
evaluate development projects for their historical
significance and preservation value, using the
criteria in the Historic Preservation
Ordinance.

Integration of Historic and Cultural Resources with
City Identity. Incorporate historic and cultural
resources into the City’s marketing and branding
efforts. Specific initiatives might include:
• Identifying historic sites in the City’s wayfinding
scheme;
• Giving priority to streetscape and public realm
improvements around historic structures that are
visitor destinations;
• Hosting/supporting events and educational
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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Organizations (B)
programs that feature Pacifica’s history and
promote its relevance; and
• Linking related historical sites through the City’s
open space and trail system.

Public Agency Support for Local Historic Sites. Seek
support from public agencies, such as GGNRA, for
local historic preservation programs for designated
sites.

Two documents have been prepared for San Mateo
County that should guide agency involvement in
Pacifica’s historic resources: the Sanchez Adobe
Historical Site Master Plan
(2007) and the Historic Resource Study for Golden
Gate National Recreation Area in San Mateo County
(2010).

CO-I-68
Resource Impact Mitigation.

Ensure that new development analyzes and avoids
potential impacts to historic, archaeological, and
paleontological resources by:
• Requiring a records review for development
proposed in areas that are considered
archaeologically or paleontologically sensitive;
• Requiring pre-construction surveys and
monitoring during any ground disturbance for all
development in areas of historic or archaeological
sensitivity; and
Implementing appropriate measures as a condition
of project approval—such as avoidance,
preservation in place, and excavation,—to reduce or
avoid impacts.

In the event that historical, archaeological, or
paleontological resources are accidentally
discovered during construction, grading activity in
the immediate area shall cease and
materials and their surroundings shall not be
altered or collected. A qualified archaeologist or
paleontologist must make an immediate evaluation
and avoidance measures or appropriate mitigation
should be completed, according to CEQA
Guidelines. The State Office of Historic Preservation
has issued recommendations for the preparation of
Archaeological Resource Management Reports that
may be used as guidelines.

CO-I-69 CO-I-70
Adaptive Reuse. Promote adaptive reuse of historic
structures—preserving their original design and
character—as an option for preserving sites that are
threatened with demolition or
degradation.

Native American Sites. Work with local Native
American tribes to protect recorded and
unrecorded cultural and sacred sites, and educate

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Organizations (B)
developers and the community-at-large about the
connections between Native American his- tory and
the environmental features that characterize the
local landscape.

Development on archaeologically sensitive sites
requires on-site monitoring by appropriate Native
American consultant(s) and a qualified
archaeologist of all grading, excavation, and site
preparation activities that involve earth-moving
operations.

B1-4 The Pacifica
Historical
Society
Board of
Directors,
Judy
Heldberg –
President
2/21/22 1. (Section 7.6, p. 7-40, para. 1) The word “sites” is too limiting, as “historical significance” is not limited to buildings and specific locations. For example, the
old trees (many planted more than 100 years ago)
of both Sharp Park and Vallemar are an integral part
of what defines these Districts and makes them
both have “historical significance”.

2. (p. 7-40, para. 2) Many descendants of the
original native people of this region object to the
use of the words “discovered” or “Discovery”, as
thousands of people living in the Bay Area already
knew about The Bay when Portola’s Expedition
arrived. This may be a semantic point to most
people, but is a matter of some sensitivity and
significance to present day Ohlone. 3. (p. 7-41, para.
1) Pacific Manor was built in 1948, long after the
demise of the OSRR. 4. (p. 7-41, para. 3)
Unfortunately “spurs and saddles” sounds like
something found on a rancho. Are these common
enough terms of geography to avoid confusion?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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Packet Pg. 719 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 55 C1: Stan Zeavin, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C1-1 Stan Zeavin 3/7/22 Please include the informative Figure 8-5 Fire Hazards and Public Safety Services
document from the 2014 draft. The 2014
mapping is much more realistic and useful
than simply showing fire danger topping at
the city boundary. Pacificans’ safety depends
on accurate information.

The data and information referenced in the DEIR, including the data used to prepare the above referenced maps, was the latest and most current available at the time the NOP was released and remains the most current available as of publication of this FEIR. The 2014 mapping referenced uses data that is out-of-date, and not the adopted SRA CAL FIRE maps, nor the 2008 Recommended LRA Maps. Please see
Master Response 5: Wildfire for more information.

C1-2 Stan Zeavin 3/8/22 Support the above statements by designating and showing Montara and San
Pedro Mountains and foothills on the map as
a designated viewshed from Pacifica State
Beach, Aramai Point and Highway 1.

The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

However, the comment addresses the content of the
Proposed Plan and will be shared with decision-makers in that context. Please see Master Response 1: EIR comments for more information about GP- or SPSP-related responses.

C1-3 Stan Zeavin 3/9/22 Conservation Element ADD:

Grassland/Prairie. Conserve and protect
remnant grassland/prairie for its value as a
carbon sink.

The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

However, the comment addresses the content of the
Proposed Plan and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments for more information about GP- or SPSP-related responses.

C1-4 Stan Zeavin 3/10/22 ES-I-21 Shopping Center Upgrades. Support upgrading existing centers to include
affordable housing.

The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-5 Stan Zeavin 3/11/22 Pacifica Historic Context
>> Change first paragraph: In 1769, an
expedition led by Gaspar de Portola,
governor of the Spanish territory covering
California, followed an Ohlone trail over the
Montara/San Pedro Mountain saddle (later
the Old Coast Road) to San Pedro Valley
where they camped. From the valley, scouts
discovered San Francisco Bay from a atop
Sweeney Ridge.

The comment is noted. The second sentence of the last
paragraph on page 3.8-2 is hereby amended as follows:…
Native Americans once had an extensive presence in the
Planning Area. When Europeans arrived, the area was
home was to people speaking the Costanoan/Ohlone
language, and living in and around two villages: Pruristac, in San Pedro Valley, and Timiigtac, in Calera Valley. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering California, discovered San
Francisco Bay from a point on Pacifica’s Sweeney Ridge, and camped in San Pedro Valley. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering California, followed an Ohlone trail over the
Montara/San Pedro Mountain saddle (later the Old Coast
Road) to San Pedro Valley where they camped. From the
valley, scouts discovered San Francisco Bay from atop
Sweeney Ridge.

This is a minor correction made to clarify and does not affect the findings of the DEIR.

C1-6 Stan Zeavin 3/12/22 >> Update for 2019 completion and opening of new Sanchez Adobe visitors’ center
The comment is noted. The second sentence of the last
paragraph on page 3.8-2 is hereby amended as follows:…
A Master Plan for the Sanchez Adobe Historical Site was

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Individuals (C)
completed in 2007, which aims to increase visitation and improve visitors’ educational experience while ensuring that the site is preserved for future generations. Key
aspects of the Master Plan’s proposed improvements for
the site include educational and interpretive exhibits and activities; expanded public facilities such as picnic areas and restrooms; and improving site characteristics such as signage, security, screening, and interface with San Pedro Creek. The new interpretive center was completed and
opened to the public in October 2019.

C1-7 Stan Zeavin 3/13/22 3.7 Biological Resources
Plant Communities
1990 and 1992 source reports are out-ofdate.
>> Replace “Annual” Grasslands with
“Grassland/Prairie”
CEQA requires analysis of how the project could have
substantial adverse effect on any 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. As noted on DEIR p. 3.7-1 and 23.7-2, "The basis for the
vegetation classification system utilized in this analysis relies on the currently accepted California Department of Fish andVegetation communities are mapped using the
Wildlife List of Vegetation Alliances and Associations (also known as the Natural Communities List). Plant communities generally correlate with wildlife habitat types, and these typically are classified and evaluated using CDFW’s
California Wildlife Habitat Relationship classification system. Figure 3.7-1 shows this data. "Annual Grassland" is the term used in this dataset. Thus, this represents the best available source of data, and no change is needed.

C1-8 Stan Zeavin 3/14/22 >> Include common native and special species plants
A list of these species are included in Appendix C and are listed on page 3.7-21. This comment does not relate to the adequacy of DEIR analysis, thus, no further response is required.

C1-9 Stan Zeavin 3/15/22 Coastal Bluff Scrub (p. 3.7-6) >> ACKNOWLEDGE 30 YEARS OF DUNE
RESTORATION AT Pacifica State Beach. Nonnative iceplant (Carpobrotus edulis) New Zealand spinach (Tetragonia tetragonioides)
have been virtually eradicated and replaced
with appropriate natives grown and planted
by volunteers.

The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-10 Stan Zeavin 3/16/22 >> The brackish water marsh at the north end of Pacifica State Beach was severely
impacted by the widening of State Highway
1 and now contains only willows where
saltmarsh common yellowthroats can be
heard..

The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-11 Stan Zeavin 3/17/22 p. 3.7-14 Beach/Intertidal
>>Add Snowy Plovers, Sanderlings, Willits,
Whimbrels
>> ADD: Pacifica State Beach in the 1970s
hosted nesting Western Snowy Plovers, a
Federally listed threatened species. Since
2003 volunteers have regularly surveyed and
monitored the plovers and have seen only
wintering plovers in declining numbers.

Snowy plover is shown on DEIR p. 3.7-21 to have mediumto-high potential to occur in the Planning Area. ESHA is determined through individual site analysis by a qualified biologist. Any proposed development on land designated
on the Sensitive and Critical Habitat map (Figure 3.7-3) as having potential to include an ESHA requires a site-specific evaluation by qualified biologists. The site evaluation will determine the precise location and extent of sensitive
resources, if any, and establish appropriate development

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Individuals (C)
ESHA is required on the north half of the
beach where plovers roost and feed.
setbacks and standards to ensure that resources are
protected. The entirety of the Pacifica State Beach is
designated as Park land use designation as shown in Figure

2.2-1, which precludes it from development. The General Plan includes multiple policies to protect special status species and identifying ESHAs, including:
(LU-G-7) Open Space Conservation and Habitat Protection.

Protect beaches, oceanfront bluffs, wetlands, riparian
corridors, Environmentally Sensitive Habitat Areas (ESHA), ridgelines, hillside areas adjacent to existing open space, and areas that support critical wildlife habitat and special status species.
(CO-G-8) Coastal Environment and Special Status
Communities. Conserve and protect beaches, sand dunes,
coastal bluffs, and special status communities, particularly the Coastal bluff scrub on the northern bluffs.
(LU-I-2) Land Divisions in the Coastal Zone. Continue to require coastal development permits for all land divisions within the Coastal Zone. Land divisions in the Coastal Zone shall be:
• Designed to minimize impacts to public access,
recreation, and coastal resources.
• Designed to minimize site disturbance, landform
alteration, and the removal of native vegetation for
development or fire safety.
• Prohibited on properties that include any areas that are within or adjacent to an Environmentally Sensitive Habitat Area (ESHA) unless the resulting parcels can be developed without building or requiring vegetation clearance in the ESHA or ESHA buffer, or unless the resulting parcels are set aside for conservation.
• Permitted only in areas with adequate public services to serve development on the resulting parcels.
• Any land division that would result in a parcel that could not be developed in accordance with the policies of this LCLUP is not allowed.
(CO-G-11) Other Environmentally Sensitive Areas. Protect other potential ESHAs, high habitat value areas, and wildlife movement corridors from development that would
significantly disrupt habitat values.
(CO-I-27) Verification of ESHA. Prior to any proposed
development in an ESHA or potential ESHA, require that a habitat survey be conducted by a qualified botanist or
biologist. The habitat survey will verify whether the site is an ESHA, and document the extent of the sensitive
resources, document potential negative impacts to the
habitat, and recommend appropriate mitigation measures.

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Individuals (C)
• Recorded or potential presence of plant or animal species for which there is compelling evidence or rarity, such as a designation of 1B (rare or endangered in California or
elsewhere) or 2 (rare, threatened, or endangered in
California, but more common elsewhere) by the California Native Plant Society.
• Presence of coastal waterways.
• Integrity of the habitat and its connectivity to other natural areas.
(CO-I-28) Management of ESHA. If the area qualifies as an ESHA under the California Coastal Act, the following
regulations apply:
• No new development shall be allowed within primary
habitat areas with the exception of resource-dependent
uses that can be demonstrated to have no significant
adverse impact.
• Buffer areas shall be established around all sensitive resources, providing a minimum of 100 feet, and varying as needed to account for feeding, breeding, nesting, and
other habitat requirements. New buildings in buffer areas shall be allowed only if there are no other feasible
development areas on the parcel. Exceptions to such buffer requirements should be supported by a biological report demonstrating that the adjusted buffer, in combination
with incorporated siting, design or other mitigation
measures, will prevent impacts that significantly degrade the ESHA and will be compatible with the continuance of the ESHA. Buffer adjustments should also be limited to
where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the
buffer would have a greater impact on the ESHA.

Development shall be sited and designed to prevent
impacts that would degrade adjacent habitat areas, taking into account drainage, vegetation, topography, and other considerations.
• Alteration of landforms, removal of vegetation,
impervious surfaces, noise, light, and glare shall be
minimized.
(CO-I-31) Habitat Preservation. Require a habitat survey be prepared by a qualified botanist or biologist for any
development proposed for the following areas, as shown in Figure 7-3.
• Designated Critical Habitat for Endangered or Threatened Species;
• Potential Environmentally Sensitive Habitat Area (ESHA); • High Habitat Value; and
• Wildlife Movement Corridor.

The survey will be used to determine the exact location of habitat areas and to recommend mitigation measures that minimize potential impacts.

C1-12 Stan Zeavin 3/18/22 p. 3.7-18
Environmentally Sensitive Habitat Areas
(ESHA)
Environmentally Sensitive Habitat Areas
(ESHA) are defined by the California Coastal
See response for C1-11

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Packet Pg. 723 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 59 Letter Commenter Date Comment Combined Response
Individuals (C)
Act[1] as “any 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 and developments”
(California Public Resources Code Section
30107.5).

Figure 3.7-3 Potentially Sensitive and Critical
Habitat Area (AND Figure 7-3 Potentially
Sensitive Habitat Area)
>> ESHA is required on the north half of the
beach where plovers roost and feed on
amphipods and kelp flies.

C1-13 Stan Zeavin 3/19/22 >> ADD: Pacifica State Beach, in the 1970s hosted nesting Western Snowy Plovers, a
Federally ESA designated threatened species
and a State of California “species of special
concern.” PSB is identified in the 2007
USWFS Pacific Coast Recovery Plan as
Recovery Unit CA-48. Since 2003, volunteers
have regularly monitored the plovers for
USFWS surveys and have seen only wintering
plovers whose numbers continue to decline.

Snowy plover is shown on DEIR p. 3.7-21 to have mediumto-high potential to occur in the Planning Area. In addition to federal and State (FESA and CESA) regulations, the DEIR presents policies to protect special status species which would pertain to the western snowy plovers habitat once verified by a biologist, including:
(CO-G-7) Wildlife and Critical Habitat. Conserve and protect indigenous threatened, endangered, and other special
status species by preserving critical habitat.

Habitat can be protected by allowing very limited or no development, by identifying habitat areas as top priorities for permanent conservation, and by managing public land to ensure species protection. Critical Habitat in the Coastal Zone is considered Environmentally Sensitive Habitat Area (ESHA).
(CO-I-26) Protection of Biological Resources with New
Development. Protect sensitive habitat areas and specialstatus species through implementation of the following measures:
1) Discourage development and/or buildout in critical
habitat of special status species during the development review process.
2) Pre-construction plant and wildlife surveys: Project applicants shall engage a qualified biologist to conduct presence/absence biological surveys for sensitive plant and wildlife species prior to construction adjacent to or within identified special status communities and other sensitive areas identified in Figure 7-3 of the proposed General Plan.

If special status species are identified, the qualified biologist shall consult with the California Department of Fish and Wildlife (CDFW) and establish no-disturbance
buffers around avian nests, bat roosts, and sensitive plants to avoid disturbance and direct impacts to these resources during construction. If no special status species are
detected during surveys, then construction-related
activities may proceed. Nesting birds, in particular, are protected by two means; they receive protection under the Migratory Bird Treaty Act, and nesting raptors (in the order Falconiformes or Strigiformes) are protected under the
State Fish and Game Code, §3503.5.

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3) Require biological resource assessments be conducted prior to approval for any development within 300 feet of creeks, wetlands, or other sensitive habitat areas shown on Figure 7-3 of the proposed General Plan.
4) Require on-site monitoring of biological resources by a qualified biologist throughout the duration of construction activity.
5) Require compensatory mitigation by means of habitat
preservation, restoration, and enhancement; for the loss of any critical habitat and/or special status communities.

This is a minor correction made to clarify and would not affect the findings of the DEIR.

C1-14 Stan Zeavin 3/20/22 p. 3.7-32
>> ADD to Saltmarsh common yellowthroat:

Also reported at small willow marsh at
northern end of Pacifica State Beach and
Lake Mathilde remnant east of Crespi
Community Center.

The DEIR uses data from the CNDDB database for June
2021. This occurrence was not identified at time of release.

C1-15 Stan Zeavin 3/21/22 p. 3.7-35
ADD: Western pond turtle (Actinemys
marmorata). Ca species of special concern
Observed basking at San Pedro Creek –
(Margaret Goodale personal observation ,
spring, 2019) (ALSO reported from Laguna
Salada)
The DEIR uses data from the CNDDB database for June
2021. This occurrence was not identified at time of release.

C1-16 Stan Zeavin 3/22/22 p. 3.7-39
>> With the completion of the tunnels,
Hickman’s cinquefoil is no longer threatened
by the Devil’s Slide Bypass highway project.

Update.

The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-17 Stan Zeavin 3/23/22 p. 3.7-53
Impact of the General Plan
ADD: Western Snowy Plover as a special
status wildlife species and identify Pacifica
State Beach as ESHA.

See response for C1-13. Snowy plover is referenced on DEIR p. 3.7-21.

C1-18 Stan Zeavin 3/24/22 CO-I-1 Creek Protection and Restoration • “Enforcing restrictions on the planting of
invasive species near creek areas;
• Requiring minimum setbacks from the top
of creek banks for development proposed
adjacent to creeks, in keeping with City
regulations and Best Management
Practices.”
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

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Packet Pg. 725 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 61 Letter Commenter Date Comment Combined Response
Individuals (C)
>> Specify “restrictions” and “minimum
seatbacks”
C1-19 Stan Zeavin 3/25/22 p 3.7-59 CO-I-37 Protection of … During Construction
>> ADD Western Pond Turtles
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-20 Stan Zeavin 3/26/22 p. 3.7-6
>> ESTABLISH ROBUST Habitat Conservation
Plans and Natural Community Conservation
Plan
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-21 Stan Zeavin 3/27/22 p. 3.7-61 (Impact of the General Plan) “…and San Pedro Creek is very close to the
San Pedro Site.”
>> Clearly Identify and add DETAIL ABOUT
THE ”SAN PEDRO SITE”
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-22 Stan Zeavin 3/28/22 CO-I-28 Protection of Environmentally Sensitive Habitat Area (ESHA). Protect all
sensitive species with defined or potential
habitat…
CO-I-29 Verification of ESHA
>> Most endangered or threatened species
have been listed due to habitat limitations
from human encroachment. We CANNOT
further limit their habitat. Remove the
possibility of mitigation. Loss of habitat
cannot be mitigated.

See response for C1-13 for ESHA and sensitive habitat
protection policies.

C1-23 Stan Zeavin 3/29/22 p. 3.7-64
CO-I-46 Shoreline Protection. Continue to
prohibit new development requiring
shoreline alterations.
>> Specify and clarify date of “existing
structures” to be consistent with Coastal Act.

The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

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Packet Pg. 726 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 62 C2: Maria Martinez-Mont, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C2-1 Maria
MartinezMont
2/11/22 I've lived in Pacifica for the past 20 years and my family has lived here for over 40 years. Please do
NOT ALLOW for the changes proposed on Sharp park.

These will create more traffic and if you want
affordable housing why not do it in places that are
open like Fresno or up north past Eureka???? that
part of the valley? Pacifica doesn't have the
infrastructure to handle the traffic anymore, we are
already on top of each other.

Plus we do not want the pollution and over
population. You will kill the heart of Pacifica if you do this. We are a small town not crowded like the
Peninsula or South Bay.

The comment is noted. Traffic congestion is no
longer a required topic of analysis under CEQA.

Thus, no further response is required.

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Packet Pg. 727 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 63 C3: Lisa Villasenor-Volosing, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C3-1 Lisa
VillasenorVolosing
3/8/22 As a Pacifica resident since 2005 and long time
lady golfer and supporter of the Sharp Park Golf
Course and its historical clubhouse, I am
expressing my support for and agreement with
Mr. Richard Harris’ letter dated 3/7/22, regarding
Sharp Park Golf Course is a historical site. I have
reviewed Mr. Harris’ 3/7/22 letter on behalf of
San Francisco Public Golf Alliance, and I agree
with its analysis and its call for Sharp Park to be
listed and designated a Pacifica historic site and
historic resource.

Please see Master Response 1 for more information on
GP-related responses. The comment stated that that
Sharp Park Golf Course itself—and not only the
Clubhouse—should be identified in the General Plan
and EIR as an historic resource. The Golf Course and
Clubhouse are identified as an historic site in the 1980 General Plan, and were identified by Resolution No. 63- 2007 as “historically significant facilities” by the Pacifica City Council.

The fact that the golf course is not identified in the
Draft EIR as an historic resource reflects the language in the zoning code, which only recognizes the Sharp Park
Golf Course Clubhouse. However, given other formal
recognition of the Golf Course by the City, the Draft EIR has been updated to reflect this change. It does not
change findings of significance in the DEIR.

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Packet Pg. 728 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 64 C4: Remi Tan, 2/26/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C4-1 Remi Tan 2/26/22 I was looking at the DEIR exec summary and the housing number is still to low at 900... The DEIR
needs to be completely updated to reflect the
higher RHNA numbers and the increased service
retail that the new housing would support. Also
the DIER needs to be updated to reflect the
increased traffic, pollution, transit, and other
environmental impacts would increase and need
to be accounted for with the higher RHNA
numbers.

Cal Code Regs. Tit. 14§ 15144 recognizes that drafting
an EIR necessarily involves some degree of
forecasting and requires that the lead agency “use its
best efforts to find out and disclose all that it
reasonably can.” Further, the statute allows for the
use of projected future conditions that are supported
by reliable projections based on substantial evidence
in the record.

Consistent with that guidance, DEIR buildout
projections do not use the theoretical buildout of
each parcel to the maximum extent allowed under
zoning because that would not represent a
reasonably foreseeable forecast. Parcel dimensions or
the existence of environmental constraints will likely
preclude many properties from being built out to the
maximum intensity allowed and historical trends in
the city indicated that developments are typically
approved and constructed at densities and intensities
below the maximum. Therefore, it is impossible for
every parcel in the city to be built out the maximum
permitted under zoning. Furthermore, using
maximum theoretical buildout as the basis for the
CEQA analysis would exaggerate impacts and result in
mitigation measures requiring the construction of
road and utility infrastructure in excess of what is
need to support growth resulting from the Proposed
Plan. Therefore, the DEIR correctly used a reasonably
foreseeable forecast of buildout under the Proposed
Plan as the basis for the environmental analysis.

Subsequently, in May 2021 the Association of Bay
Area Governments (ABAG) released draft RHNA
numbers for Pacifica which identified a need for
housing far beyond the realistic capacity of the
Proposed Plan Land Use Diagram. These Final RHNA
numbers were adopted by the ABAG Board in
December 2021. To accommodate these new RHNA
numbers, it is likely that Pacifica will need to consider additional land use changes; however, such changes
were beyond the scope of the Proposed Project.

Rather than start the General Plan and EIR process
over again and delay adoption by an additional two
years, the City elected to proceed with the Proposed
Plan knowing that additional land use changes,
community engagement and environmental analysis
will be needed for the Housing Element. The updated
General Plan will provide a better basis for the
subsequent Housing Element update, as the existing

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Packet Pg. 729 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 65 Letter Commenter Date Comment Combined Response
Individuals (C)
General Plan from 1980 is out of date and
inappropriate for that purpose.

Separately, the City is preparing to initiate its 6th
cycle Housing Element update. The Housing Element
update and development of the required housing
sites inventory will involve extensive community input
and be subject to separate CEQA review. The Housing
Element CEQA document will analyze the cumulative
effects of implementing the Housing Element Update
– including associated changes to the land use
diagram - in combination with the Proposed Plan.

Please see Master Response 3: Buildout and RHNA for
more information.

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Packet Pg. 730 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 66 C5: Remi Tan, 2/2/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C5-1 Remi Tan 2/2/22 The planned housing quantity of 990 units by 2035 is inadequate and does not cover the job creation of
1,470 jobs by 2040 and is also short of the 1,892 RHNA
required housing units to be built by 2031. (See
excerpts from the Jan 2022 Public Comment Draft
General Plan and the ABAG RHNA.) Also given that the
majority of the jobs projected to be created are in the retail and service sectors (which is in line with the
proposed increase in tourism), and these jobs are
typically low paying, we need to add much more
housing and most of this should be affordable
housing.

Please see response to comment C4-1 and Master
Response 3: Buildout and RHNA for more
information on adequacy of buildout projections.

C5-2 Remi Tan 2/2/22 Given the recent astronomical rise in Pacifica real estate values, Pacifica needs to increase housing
quantities beyond the RHNA allocation to stabilize
prices by increase supply to meet demand.. The City
should work with other Bay Area cities and counties
and ABAG to engage a study by an economist that
would analyze job creation and population increase in
the Bay Area and determine the amount of housing
that needs to be built in Pacifica (and the Bay Area)
not only to accommodate the new jobs within
commutable distance and population growth but to
stabilize rising prices by building enough housing so
that demand and supply are equalized.

This comment is not related to the adequacy of the
DEIR. Thus, no further response is required.

C5-3 Remi Tan 2/2/22 This new housing should be accounted for in the new General Plan and should be located near transit stops
and shopping centers to reduce traffic, and not
located on hillsides and toes of hills subject to
landslide, in erosion vulnerable coastal edges, or in
areas prone to flooding or high tide inundation to
avoid loss of life and property due to more severe
weather and sea level rise caused by global warming.

This may require increase in density and height limits
near the transit and shopping centers to
accommodate the housing.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C5-4 Remi Tan 2/2/22 Given the dire rising cost situation with housing, and with all the effort and public input in the new General Plan and subsequent zoning updates, all housing
projects as well as commercial projects should have
as-of-right zoning that minimizes additional public,
planning commission and city council hearings and
meetings to expedite the planning process and the city
should coordinate with the Coastal Commission to
make sure the General Plan and zoning is designed to
make CC approval as of right too
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C5-5 Remi Tan 2/2/22 The city should have an expedited permit process in place and coordinate this expedited permit process
with the Coastal Commission for housing locations in
the Coastal Zone. Housing projects with high
affordability should be top priority in permit
expediting
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see

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Packet Pg. 731 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 67 Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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Packet Pg. 732 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 68 C6: Clif Lawrence, 1/30/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C6-1 Clif
Lawrence
1/30/22 FIRST...WE NEED MORE TIME
The 2015 FEIR references more than 80 days in
that review period. "What's the rush?"
According to 14 CA ADC § 15105, The public review
period for a draft EIR shall not be less than 30 days nor should it be longer than 60 days except in unusual
circumstances. The public comment period was
extended on 2/14/2022 to 3/8/2022.

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Packet Pg. 733 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 69 C7: Debra Etienne, 2/14/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C7-1 Debra
Etienne
2/14/22 I am concerned about Wildland fires in our town. The EIR does not adequately address this risk.

In Figure 3.11-2 under the Fire Hazards and Public
Safety Services Map, only one area is marked as Very
High Fire danger and one very tiny spot is marked as a
High fire danger area. Come on, folks! We all know
Pacifica is covered in groves of Eucalyptus trees and
pine trees. How in the world can you honestly say this
map represents our town’s risk of Wildland fires?
Under the Fire Hazards section, (page 639) the DIER
states, “Pacifica has a substantial risk of woodland
fires, with many areas of high and very high threat
within the Planning Area.” Well, where are they? How
can this statement be made without a map showing
these areas throughout town? Additionally, this
statement is contradicted later as shown below. Why
don’t they contain the same information?
Please see Master Response 5: Wildfire. The DEIR
characterizes wildfire hazards within the Planning
Area on pages 3.11-4 through 3.11-6 and 3.14-1
through 3.14-4, making use of data and information
from CALFIRE and from the Multi-Jurisdictional Local
Hazard Mitigation Plan (MJ-LHMP) for San Mateo
County. The characterization in the DEIR includes a
description of vegetation in the Planning Area, a
history of wildfire occurrence in the Planning Area,
the probability of a fire occurring in the future, and
identification of Fire Hazard Severity Zones
designated by CALFIRE based on factors such as fuel,
slope, and weather. Two maps are included:

Figure 3.11-2, which shows Very High Fire Hazard
Severity Zones for Local Responsibility Areas (LRAs),
State Responsibility Areas (SRAs), and Federal
Responsibility Areas (FRAs) as designated by CALFIRE
pursuant to Government Code Section 51175. By law
CALFIRE is required to designate these Fire Hazard
Severity Zones, land within which is subject to
various requirements in the California Building Code
for the design and construction of new buildings
intended to reduce the risk of loss of life and
property, including requirements for building
materials, defensible space clearance, and other
wildland fire safety practices; and
Figure 3.14-1, which shows Fire Threat, a measure of
fuel conditions and fire potential in the ecosystem,
representing the relative likelihood of “damaging” or
difficult to control wildfire occurring for a given area.

Fire Threat is not a risk assessment by itself, but can be used to assess the potential for impacts on
various assets and values susceptible to fire. Impacts
are more likely to occur and/or be of increased
severity for the higher threat classes. Please see
Master Response 5: Wildfire for more information.

Both CAL FIRE datasets/maps used for analysis,
including VHFHSZ (Figure 3.11-2) and Fire Threat
(Figure 3.14-1), incorporate measures related to
wildfire fuel conditions and fire potential. Policy SA-I98: addresses Vegetation Management, included in Impact 3.14-1.

Analysis in the 2021 MJ-LHMP and the safety
element of the Proposed Project identifies areas of
the city that have constrained emergency access.

Reliance on Highway 1 as a north-south connection
causes challenges for timely fire response, and the
Vallemar, West and East Fairway Park, Rockaway
Beach, and Rockaway neighborhoods in central
Pacifica are beyond four-minute travel distance from
northern San Mateo County fire stations, meaning

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Packet Pg. 734 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 70 Letter Commenter Date Comment Combined Response
Individuals (C)
that a new station would be needed if the central
part of Pacifica were to experience substantial new
development.

Potential improvements to the roadway network
could contribute to mitigating the impacts of
additional traffic on emergency response times.

Furthermore, traffic signal preemption devices on
emergency vehicles, as well as emergency sirens, will
improve emergency response times ven in instances
of intersection congestion during peak commute
periods. The Proposed Project provides for improved
emergency access through policies that promote
mobility connections between communities; provide
additional access routes; require new streets and
developments meet adopted emergency access
standards; and ensure adequate fire, police, and
emergency service in line with any new
development, including in Central Pacifica where
service times do not currently meet NCFA’s
standards, and in areas that have less than two
evacuation routes north of the VHFHSZ (Proposed
General Plan Implementing Policy SA-I-104) Future
development would be required to adhere to all
policies, goals, and standards in the MJ-LHMP,
Pacifica Municipal Code, and CBC, including vehicular
access and emergency access. Implementation of the
following Proposed Project policies will ensure that
inadequate emergency access does not occur, and
will result in a less than significant impact.

C7-2 Debra
Etienne
2/15/22 Further, under the Wildland Fires section, the
document states, “As an urbanized community,
wildfire hazard is minimal in most of Pacifica city limits.

However, areas along the southwestern perimeter
within the Sphere of Influence and in San Pedro Valley
County Park are designated as Very High…..” It then
follows up with, “ Land adjacent to these areas that is within city limits is low and very low density residential development.” Not true.

Using the latest and best available data, as shown on
Figure 3.11-2, the DEIR correctly identified that there are no VHFHSZ within the City limit, but that there
are Fire Hazard Severity Zones in the Sphere of
Influence, which are in areas of State responsibility.

Further, using Fire Threat mapping available from
CAL FIRE (Figure 3.14-1), as described on p. 3.14-14
of the DEIR identified that beyond CALFIREdesignated Fire Hazard Severity Zones described on p. 3.14-14 that Pacifica has a substantial risk of
wildland fires beyond identified VHFHSZ, with many
areas of high threat within the Planning Area.

Development However, as noted in the DEIR
development under the Proposed Plan is expected to
occur predominantly in already-urbanized
neighborhoods where risk is minimal as compared to
areas of higher fire threat, but not devoid. Existing
land uses in the area are shown in Figure 3.1-1,
which uses data from the County Assessors office,
shows that areas surrounding Pacifica's Sphere of
Influence are indeed low density residential. Please
see Master Response 5: Wildfire for more
information.

C7-3 Debra
Etienne
2/16/22 These statements do not accurately reflect the amount of potential danger we face with all of our trees. You
all live here. Look around your backyards and hills.

Both CAL FIRE datasets/maps used for analysis,
including VHFHSZ (Figure 3.11-2) and Fire Threat
(Figure 3.14-1), incorporate measures related to

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Packet Pg. 735 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 71 Letter Commenter Date Comment Combined Response
Individuals (C)
They are covered in Eucalyptus groves and many areas
have Pine trees lining the properties and streets. Have you honestly driven around town and documented all
the thick groves of trees surrounding our homes?
wildfire fuel conditions and fire potential. Thus, they present an adequate means of establishing areas of
fire risk for purposes of DEIR analysis. Please see
Master Response 5: Wildfire for more information.

C7-4 Debra
Etienne
2/17/22 How can we assess our fire danger when we haven’t accurately documented it? Why aren’t these areas
considered in looking at potential fire dangers within
our city limits:
• Oddstad Park where Spindrift Theatre is located off
Crespi — huge groves Hill behind Christian school on
Seville Dr. — huge groves
• Strip of forest behind Park Mall and below Alicante
Drive.
• Hill above/behind Ortega Elementary and downside
of Banyan
• Everglades drive going up the hill, huge grove on
right, below Water tank accessed from Big Sur Dr.
• On hill above Terra Nova HS, long grove.
• Hill above Cabrillo Elementary and below water tanks
off Fassler — lots of trees clustered there
• Corridor between Fassler and Rockaway Beach Ave.
• Hill above Lumber Yard on Hwy One
• South Hill behind Reina Del Mar and between Fassler
• Rifle Range Road has lots of pines lining it and there’s many trees in the Golf Course also
• Hill below Gypsy Hill Road and above Brighton Rd.
• Hill above Good Shepard School
• All the City’s "Green Belt” areas behind homes that
contain many trees. (My elderly neighbor said our City
sold trees for $.01 to residents to encourage planting
in the early days.) Now all those trees are huge.

You get the idea. We are in big trouble if a wildfire
breaks out here where the trees are so close to homes,
business and schools. I can’t find an accurate map that show all these potential fire dangers, even after
contacting Fire Safe San Mateo and writing North
County Fire Authority. Please, think this over and ask
yourself if you or your family members are protected
by this document. I think not. Please take the time to
accurately reflect the Wildland fire hazards in our town before approving this document.

As noted on DEIR p. 3.14-2, fire hazards and threat
are determined using several factors, including fuel
(or vegetation), fire history, topography, and
climactic conditions. Please see response to
comment C7-1 for more information about the maps
assessing fire threat, and Master Response 5:

Wildfire for more information regarding the
adequacy of analysis.

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Packet Pg. 736 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 72 C8: Richard Grassetti, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C8-1 Richard
Grassetti
3/8/22 Hi- Attached find “Attachment C” to my letter
sent earlier today. It was too large a file to be
sent with the earlier letter. Please include it with
our letter.

This comment contains an attachment to comment C34
and is not a comment on the DEIR.

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Packet Pg. 737 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 73 C9: Bob Boles, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C9-1 Bob Boles 3/7/22 This DEIR is a mess: the data it is based on varies from recent to decades ago, it both leaves out
important elements and duplicates others while
providing conflicting information; it meanders
around endlessly while providing platitudes
instead of worthwhile information to determine
impacts and appropriate mitigations to reduce
proposed project impacts to a less than significant
level as required by CEQA.

The adequacy of hazards mapping is described in
response to comment C22-10. Please see response to
comment C123-1 for more information on the
adequacy of impact analysis.

C9-2 Bob Boles 3/7/22 My particular concern while reviewing the DEIR and Draft General Plan was the public utilities that
the city provides: storm drainage, sewer system
collection and treatment, water supply and
waste/recycling.

A. General Comments

1. LU-I-13 “Public Service Priorities. Ensure that
needs generated by development or uses
permitted over the planning period are adequately
served by existing and planned public works
facilities. In the event that existing or planned
public works facilities can accommodate only a
limited amount of new development, services to
coastal dependent land use, essential public
services and basic industries vital to the economic
health of the region, state, or nation, public
recreation, commercial recreation, and visitor
serving land uses shall not be precluded by other
development.”
I see no analysis or discussion in any of the utility
sections that confirms existing sewer, drainage,
water, or waste system capacities or plans to
upgrade/expand capacity to serve the projected
buildout of 990 new units in the General Plan,
much less the 1892 new units required under
RHNA by January 2023, or the recent changes to
state laws which allow ADU’s on virtually any
residential lot and lot splits per SB 9 and 10, along
with current developer proposals for high-rise
residential development and proposed zoning
amendments, annexations, and density bonuses.

These growth projections must be presumed to
have a considerably large error factor, which calls
in question the very basis of the DEIR.

Analysis pertaining to whether the implementation of
the Proposed Project will require or result in the
relocation or construction of new or expanded water,
or wastewater treatment, or storm water drainage
facilities is discussed under criterion 3.13-1, specifically on pages 3.13-16 to 3.13-20. Future water demand in
the NCCWD service area was accounted for through
2045 in the District’s 2020 UWMP, including
development associated with the Proposed Project
buildout, and no new or expanded conveyance
infrastructure beyond that which is already planned
would be required to deliver water to the Planning
Area through 2045. In addition, proposed General Plan
Policy CO-I-63 reduces impact by requiring
implementation of the Project to maximize water
system efficiency.

In regard to wastewater, the dry weather capacity of
the Plant is 7.0 mgd, and the estimated flow under
General Plan buildout is only 2.56 mgd. Therefore,
there is adequate capacity to serve the buildout
population. General Plan buildout will not impact any
existing sewers due to the projected growth of Pacifica over time. Proposed General Plan policies that will
continue to reduce impact include CO-G-5, CO-I-19,
CO-I-20, CO-I-21, CO-22, and CO-I-63 which ensures
that the City maintains adequate wastewater
treatment and sanitary sewer capacity while
maximizing efficiency.

In regard to stormwater, development under the
Proposed Project will incorporate best management
practices from construction and development, meeting
the requirements of the City’s stormwater permit,
regional and state regulations, and Proposed Project
policies. The increasing incorporation of stormwater
management in site planning will further reduce the
need for development of new storm drainage
infrastructure. Such Proposed Project policies to
reduce impact on stormwater facilities include CO-I-9,
CO-I-10, CO-I-11, CO-I-12, CO-I-13, CO-I-14, CO-I-15,
CO-I-16, and CO-I-17. Thus, the stormwater
infrastructure in Pacifica is adequate to provide for the Proposed Project buildout population.

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Packet Pg. 738 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 74 Letter Commenter Date Comment Combined Response
Individuals (C)
Cal Code Regs. Tit. 14§ 15144 recognizes that drafting
an EIR necessarily involves some degree of forecasting
and requires that the lead agency “use its best efforts to find out and disclose all that it reasonably can.”
Further, the statute allows for the use of projected
future conditions that are supported by reliable
projections based on substantial evidence in the
record.

Consistent with that guidance, DEIR buildout
projections do not use the theoretical buildout of each parcel to the maximum extent allowed under zoning
because that would not represent a reasonably
foreseeable forecast. Parcel dimensions or the
existence of environmental constraints will likely
preclude many properties from being built out to the
maximum intensity allowed and historical trends in the
city indicated that developments are typically
approved and constructed at densities and intensities
below the maximum. Therefore, it is impossible for
every parcel in the city to be built out the maximum
permitted under zoning. Furthermore, using maximum
theoretical buildout as the basis for the CEQA analysis would exaggerate impacts and result in mitigation
measures requiring the construction of road and utility infrastructure in excess of what is need to support
growth resulting from the Proposed Project.

As noted in Master Response 3: Buildout and RHNA, at
a joint study session on September 3, 2019, the City
Council reviewed a limited set of land use changes
developed on the basis of community outreach
conducted in 2019 and directed City staff and
consultants to update the 2014 Draft General Plan
accordingly and prepare a Draft EIR. Subsequently, in
May 2021 the Association of Bay Area Governments
(ABAG) released draft RHNA numbers for Pacifica
which identified a need for housing far beyond the
realistic capacity of the Proposed Project Land Use
Diagram. These Final RHNA numbers were adopted by
the ABAG Board in December 2021. To accommodate
these new RHNA numbers, it is likely that Pacifica will need to consider additional land use changes;
however, such changes were beyond the scope of the
Proposed Project. Rather than start the General Plan
and EIR process over again and delay adoption by an
additional two years, the City elected to proceed with
the Proposed Project knowing that additional land use
changes, community engagement and environmental
analysis will be needed for the Housing Element. The
updated General Plan will provide a better basis for the subsequent Housing Element update, as the existing
General Plan from 1980 is out of date and
inappropriate for that purpose.

Separately, the City is preparing to initiate its 6th cycle

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Packet Pg. 739 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 75 Letter Commenter Date Comment Combined Response
Individuals (C)
Housing Element update. The Housing Element update
and development of the required housing sites
inventory will involve extensive community input and
be subject to separate CEQA review. The Housing
Element CEQA document will analyze the cumulative
effects of implementing the Housing Element Update –
including associated changes to the land use diagram -
in combination with the Proposed Project. Therefore,
this approach does not constitute “piecemealing,” or
dividing a large project into separate parts, each of
which might have individually minimal environmental
consequences.

Therefore, the DEIR correctly used a reasonably
foreseeable forecast of buildout under the Proposed
Project as the basis for the environmental analysis.

The DEIR therefore contains a valid and accurate
analysis of the effects that project buildout may have
on utility facilities.

C9-3 Bob Boles 3/7/22 LU-I-13 acknowledges that development may need to be limited and yet gives no analysis how
development may be limited. The Land Use
Diagram Figure 4-3 increases density on a number
of parcels scattered throughout Pacifica. For
example, is the land proposed to be rezoned to
Mixed Use
2 Neighborhood at the corner of Oddstad and
Terra Nova a lower priority than Sharp Park as
implied by LU-I-13 since it is not in the Coastal
Zone? It seems the owner of that property would
have a reasonable expectation based on the new
General Plan zoning density change to Mixed Use
Neighborhood that the property can be developed
to increase density.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response:

EIR comments for more information about GP- or
SPSP-related responses.

While land use designations describe what can be
developed on a gross acre, projects would also be
subject to the Zoning Code, and any other projectspecific requirements that could affect development, such as setback from a creek, siting to avoid sensitive resources, or slope constraints, for example. Individual projects are required to prepare a more precise,
project-level analysis to fulfill CEQA requirements. The lead agency responsible for reviewing these projects
shall determine the level of review needed, and the

1.f
Packet Pg. 740 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 76 Letter Commenter Date Comment Combined Response
Individuals (C)
3/7/22scope of that analysis will depend on the
specifi3/7/21cs of the particular project. Should an
applicant propose to develop in an area with sensitive
resources or potential site-specific impacts or in an an area of known hazards, compliance with policies
requiring additional study would be a requirement for
project approval. Any project requiring discretionary
approval is required to make findings of General Plan
consistency and must demonstrate analytically that the
project is consistent with the General Plan, and how
they comply with applicable policies.

C9-4 Bob Boles 3/7/22 Are we making promises that we cannot necessarily keep and therefore exposing the city to
potential litigation from that property owner if the
city later denies his project based on inadequate
utility capacity for example? How would you know
if three other large projects in Sharp Park might be
submitted the following month which would have
priority and cap capacity? Or is the city then
obligated to expend capital improvement funds we
do not currently have on hand to expand our
pump stations and sewage plant? We need a
thorough evaluation of our capacity and ability to
expand capacity as part of this DEIR. Please
confirm how and when this will be provided.

See response to comment C9-2.

C9-5 Bob Boles 3/7/22 By the way, this property, I believe identified as Park Mall, backs onto San Pedro Creek on the
southern side – isn’t there a new DEIR policy that
requires a 100-foot setback from a creek? Has that
been considered? The parcel next to the creek is
currently zoned agriculture (see below), which per
the Growth Control Ordinance, requires a vote of
the people to alter zoning. Please confirm why this
parcel has been rezoned without this public vote.

The comment is noted. Policy CO-I-1, Creek Protection
and Restoration, would require a 100-foot setback
from the top of creek banks to be incorporated into a
project for any development adjacent to creeks.

According to the City's current zoning code, the parcel is zoned C-1 (Neighborhood Commercial). The
Proposed Project does not make any changes to
zoning; Zoning Code updates are required after
adoption.

C9-6 Bob Boles 3/7/22 2. Pacifica’s Limited Financial Resources for Expansion of Public Services.

The Bibliography on page 6-12 refers to “City of
Pacifica Annual Budget 2011-2012. Available:
http://www.
cityofpacifica.org/civica/filebank/blobdload.asp?Bl
obID=4400, accessed August, 2013.”
Please confirm what recent data and city budget
were used as part of this DEIR and provide detailed
information as to the city’s planning for both
maintenance and expansion of utility
infrastructure and additional land/sites for
infrastructure needed to support actual project
buildout over the next 8 years. We all know from
Pacifica’s current Vision 2025 that the city is broke
and in the next two to three years will not be able
to serve current residents with essential services,
much less future residents. Please identify and
break out economic costs of new infrastructure
The comment is noted. The comment is not related to
the adequacy of the DEIR, therefore no further
response is required in the FEIR. However, the
comment addresses the content of the Proposed
Project and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related
responses.

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needed, including new roads, fire stations, schools,
sewer, water, stormwater systems, etc. required
to achieve full Project buildout including RHNA
housing allocation numbers so the City Council can
make informed decisions as to our actual
economic capacity for growth.

C9-7 Bob Boles 3/7/22 B. Sewage (wastewater) Collection and Treatment I started by reviewing the Department of Public
Works’ Sewage Collection System Master Plan,
which dates to 2012, with a partial Update in 2021.

I was glad to see what appeared to be a
professionally organized document which
described and mapped the components of the
system. One of the goals of the Master Plan and
particularly its Update was to model the system to
assess its capacity with expected growth, and to
point out what elements would need
maintenance, repair or replacement, so that long
term budgeting could be planned.

There are some problems with the Update as its’
projections for future flows are based on early
2021 knowledge of near-term developments
(developments for which applications had already
been made) which even a year later are severely
out of date, and on the assumptions about open
developable land based on “allowable density in
the general plan”, presumably the 1980 General
Plan which is still in effect.

Project Implementation Recommendations on
Page ES-7 of the Sewage Collection System Master
Plan confirms that these growth projections,
including the Sharp Park Specific Plan, are not
included in the current analysis.
“Growth projections assumed herein should be
updated as needed to reflect the City’s General
Plan and Sharp Park Specific Plan updates, which
are currently ongoing, and need to meeting
regional housing needs. Based on the Draft
Regional Housing Needs Allocation (RHNA) Plan for
the San Francisco Bay Area, prepared in May 2021,
the City must plan to accommodate a total of
1,892 new households between 2023-2031 to
meet regional housing needs;” The DEIR is based in
part on these Master Plan documents so it is
likewise subject to a large error factor.

The comment is noted. The comment is not related to
the adequacy of the DEIR, therefore no further
response is required in the FEIR. However, the
comment addresses the content of the Proposed
Project and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related
responses.

C9-8 Bob Boles 3/7/22 1. Please clarify and provide detailed calculations and analysis to show how the Project Buildout
number was obtained, where the various
additional units are proposed to be located, and
confirm the number of additional housing units
possible given our current sewage system capacity.

If additional sewage capacity is needed to meet
The comment is noted. Please see Master Response 3:

Buildout and RHNA for more information on how
buildout was calculated.

Analysis pertaining to whether the implementation of
the Proposed Project will have adequate wastewater
treatment capacity to serve the projects projected

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projected buildout, please confirm how and where
our existing plant might be expanded, which pump
stations would need to be upgraded, at what
projected cost, and how the city is planning to
secure these funds. I see no discussion of this in
the General Plan or DEIR. Please also note that
current development fees for sewage and storm
water improvements have not been updated in
some time and are woefully inadequate.
demands is discussed under criterion 3.13-3,
specifically on pages 3.13-25 to 3.13-26. Based on the
estimated wastewater flow under General Plan
buildout (see response to comment C9-2), there are
adequate wastewater treatment facilities in the City.

Additional Proposed Project policies ensure
compliance with stormwater discharge permits. One
such policy includes CO-I-10 which ensures compliance
with stormwater discharge regulations from new and
existing development. Therefore, the Proposed Project
will not result in the exceeding of wastewater
treatment requirements of the RWQCB.

C9-9 Bob Boles 3/7/22 2. Due to the date of its publication, the Update also makes no mention of the recent Linda Mar
flooding and the massive spills of recent untreated
sewage into the Pacific Ocean in October and
December of 2021. This is the elephant in the
room – the fact that the Equalization Basin hasn’t
done the job it was intended for even with current
demand, much less with any projected growth.

Please provide detailed information and
calculations showing the capacity of the
Equalization Basin and detail any proposed
improvements to increase capacity.

The comment is noted. The Wet Weather Equalization
Basin has a 2.1 million gallon capacity. See response to comment C9-2 regarding whether the implementation
of the Proposed Project would require or result in the
relocation or construction of new or expanded
wastewater treatment or storm water drainage
facilities.

C9-10 Bob Boles 3/7/22 3. Looking at the DEIR section for sewage, and assuming it would be based on the latest
information available, I was astonished to see in
the Environmental Setting section, on page 3.13-5,
under the heading Usage and Capacity, the phrase
“Flows are projected to rise to 3.2 mgd by 2012”,
and that this datum based on the General Plan
Update Wastewater Treatment Service Provider
Form from 2009.

Wait, our new general plan is written in reference
what was supposed to happen starting 10 years
ago? From a study which is 13 years old? This calls
into question the rest of the utility section – how
much of it is actually current and pertinent to
today and the next 20-40 years? Does it need to be
refreshed with current data? If the
recommendations are based on a document
written thirteen years ago, then the document is
fatally flawed and needs to be rewritten.

The comment is noted. The 2021 Collection System
Master Plan Phase 2 was released after publication of
the NOP but will be incorporated into the FEIR. The
second sentence of the third paragraph on page 3.13-5
is hereby amended to read, "Existing base wastewater
flow is estimated to be 1.96 mgd" (Collection System
Master Plan Update, 2021). This amendment
represents a minor clarification and does not affect the findings of the DEIR. In addition, the capacity of the
CCWRP has remained unchanged since cited by the
RWQCB.

C9-11 Bob Boles 3/7/22 4. Another example, on page 3.16-6: table 3.13-2 says it “represents the most recent wastewater
data that was available…”, but the source listed is
the Sewer Collection Master Plan, 2011. Please
update analysis and findings per current source
material from 2012 and 2021.

The comment is noted. The specific flow component
data represents the most recent data available for the
City of Pacifica.

C9-12 Bob Boles 3/7/22 5. Under the Planned Improvements heading, several items are listed that “…the City intends to
undertake…” The list is from 2009. Have these
projects already been done? Are they still
The comment is noted. The first bullet under the
Planned Improvements section on page 3.13-5 is
hereby amended to read, "Ultraviolet disinfection
system improvement project - feasibility study" (City of

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pending? Are there new projects in the works to
increase capacity and provide resilience from
climate change impacts? Please clarify and update
the documents accordingly with current
information.

Pacifica, 2021). This amendment represents a minor
clarification and does not affect the findings of the
DEIR. The following two bullets list projects that are
still pending in the City.

C9-13 Bob Boles 3/7/22 6. Reading on, in the section entitled IMPACT SUMMARY, starting on page 3.13-16, the DEIR
does reference the more recent data in the 2021
Update. But on page 3.13-17, data from BOTH
2006 and from 2021 are referenced! Please review
and clarify that there are no discrepancies
between these references that would impact the
proposed Project or cause confusion for
developers or planning commissioners utilizing
these documents as references for the next 20-40
years.

The comment is noted. The citations referenced
remain accurate and represent the most up to date
data available that can be used for this analysis.

C9-14 Bob Boles 3/7/22 7. CO-I-23 “Wastewater Treatment Capacity.

Continue to monitor wastewater generation rates
so decision-makers are aware of the impacts on
the treatment plant on new development, and
plan for additional capacity in advance of
projected need.” Again there are no details,
enforcement, or budgeting described to
implement this vague policy. Please expand.

The comment is noted. The comment is not related to
the adequacy of the DEIR, therefore no further
response is required in the FEIR. However, the
comment addresses the content of the Proposed
Project and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related
responses.

C9-15 Bob Boles 3/7/22 C. Storm Water System
I was unable to find a Master Plan for the city’s
storm water system. I understand from Public
Works Director Lisa Peterson that a consultant has
been hired and this is being worked on now. I
therefore dug into the DEIR directly. 1. Storm
drains are (briefly) described on pages 3.13-6 and -
7, in the Environmental Setting section, as
comprising 290,000 linear feet of piping and 989
inlets with two pump stations. There aren’t any
hints to the age of the data, but the data points
listed are at least in conformance with the storm
drain description on the city’s website. Creeks are
mentioned as a destination for storm water, but
no mention is made of the open swales and
drainage channels that are an important part of
the storm water system. Isn’t a natural creek that
handles the city’s storm drainage part of the storm
drainage system? Please add this information as
necessary to the DEIR.

Information pertaining to open swales and drainage
channels is located in the Environmental Setting of
both the Hydrology and Flooding and Utilities chapters
of the DEIR. Pages 3.5-1 to 3.5-6 describe the city's
watershed system, as well as each of the major
watershed creeks that drain into the ocean or toward
the San Francisco Bay. The first full paragraph on page

3.13-7 mentions constructed wetland treatment
swales.

C9-16 Bob Boles 2. Further on, on page 3.13-19 in the IMPACT SUMMARY section, the storm drain system is
described again: “The system serves 178 miles of
roads and 986 inlets”. Oops, lost three inlets, but
then again, this data is from 2008 so maybe we
gained 3 outlets in the meantime? It’s curious that,
as there is commonly about one foot of storm
drain piping per foot of road, this would seem to
entail about 940,000 linear feet of piping…but
then I know from personal experience that, at
The comment is noted. The number of stormwater
inlets are edited on page 3.13-9 to 989 inlets. A note is added that storm water analysis may need to be
amended upon completion of the Storm Drainage
Master Plan. These amendments represent minor
clarifications and do not affect the findings of the DEIR.

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least in my own neighborhood, the official storm
drain block books are sometimes blank. It’s not
clear that anyone knows just how big the system
is. Please complete the Storm System Master Plan
and incorporate this important information in the
DEIR and General Plan, even if it needs to be done
as an amendment next year. For now, please add a
note as appropriate in the DEIR and GP that this
information is incomplete and will need to be
amended.

C9-17 Bob Boles 3/7/22 3. The DEIR concludes that the Plan (not sure exactly what plan is being analyzed here;
sometimes a ‘plan’ is referred to, sometimes ‘the
project’) will incorporate best storm water
practices in new projects and doesn’t envision any
changes to the existing infrastructure; therefore,
there will be no environmental impacts. There
seems to be no thought of climate change and its
effect on rainfall. Shouldn’t an Environmental
Impact Report take nature into account? Increased
rainfall intensity should be evaluated and planned
for as part of SB379’s climate change vulnerability
assessments and adaptation planning. Please add
this critical information to the DEIR and GP.

Perhaps the editors should be made aware of the
City’s recent Request for Proposals to Civil
Engineering Consultants for a Storm Water Master
Plan. Among other scopes of work, it calls for this
(emphasis added):
“Deficiencies in the Storm Drain System - Assess
conditions of storm drain infrastructure and
determine capacities of existing storm drain
facilities; include identification of isolated flooding locations, and determination of capacity
improvement needs. Flooding has occurred with
greater frequency in recent years – a trend that
can be expected to continue due to several
factors, such as weather events of greater severity
(related to increased ocean water temperatures)
and sea level rise.”
The comment is noted. The "Proposed Project" refers
to implementation of the General Plan and Sharp Park
Specific Plan. Analysis pertaining to whether the
implementation of the Proposed Project will require or
result in the relocation or construction of new or
expanded storm water drainage facilities as discussed
under criterion 3.13-1, specifically on pages 3.13-16 to

3.13-20. In regard to stormwater, development under
the Proposed Project will incorporate best
management practices from construction and
development, meeting the requirements of the City’s
stormwater permit, regional and state regulations, and
Proposed Project policies. The increasing incorporation of stormwater management in site planning will
further reduce the need for development of new storm
drainage infrastructure. Such Proposed Project policies to reduce impact on stormwater facilities include CO-I9, CO-I-10, CO-I-11, CO-I-12, CO-I-13, CO-I-14, CO-I-15, CO-I-16, and CO-I-17. Thus, the stormwater
infrastructure in Pacifica is adequate to provide for the Proposed Project buildout population.

C9-18 Bob Boles 3/7/22 4. The city engineers seem to know the score, have they reviewed this DEIR prior to recent
publication? Please provide copies of Public
Work’s review and input of these current
documents.

Chapter 7 of the DEIR on pages 7-1 ad 7-2 reflects the
latest contacts on persons and organizations consulted
in order to obtain access to Public Works comments on
their review of the DEIR.

C9-19 Bob Boles 3/7/22 D. Flooding

1. In a subsequent section, on page 3.13-12, the
City’s Flood Damage Prevention Ordinance is
mentioned. That dates to 2017. Can you confirm
whether this ordinance, the DEIR and the draft
Safety Element comply with the requirements of
Government Code Section 65302(g) (2) which I
have copied below for reference. I am still slowly
Government Code Section 65302 refers to the
authority for and scope of general plans. The comment
is not related to the adequacy of the DEIR, therefore
no further response is required in the FEIR. However,
the comment addresses the content of the Proposed
Project and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related

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wading through the General Plan documents, but
have not seen all these items addressed, for
example flooding risk in Sharp Park without the
sea wall, and flooding risk in Fairway Park without
the berm, repeated flooding of Linda Mar as
recently as October and December 2021. What is
the flood history and current flood risk to the Linda
Mar Fire Station #72, which is located very near
San Pedro Creek? What about the Milagra Fire
Station? I believe that area has also had a history
of flooding and sink holes?
responses. Flooding in Linda Mar is described on DEIR
p. 3.5-8: "San Pedro Creek has a history of substantial flooding in the Linda Mar area. The low area of Linda
Mar has pump systems providing drainage to the
ocean, but these systems can be overwhelmed during
high flow/tide events." P. 3.5-9 also describes impacts due to coastal flooding in the Linda Mar area. Please
see response to comment C66-2 for more information
on added dates of historical flooding.

C9-20 Bob Boles 3/7/22 2. SA-I-24 Storm Drainage Impact Assessment. “Require developers to provide an assessment of a
project’s potential impacts on the local storm
drainage system as part of the development
review process. If development is found to have a
negative impact on storm drainage, the City should
require applicable and e!ective mitigation
measures, such as the creation of permanent or
temporary detention or retention basins, provision
of additional landscaped areas and green roofs,
installation of pump stations, and the use of
permeable paving in drive-ways, walkways and
parking areas.”
Please clarify how the city will define “local storm
drainage system”. Would that include all the
downstream storm drains, roads, and pump
stations to the point of treatment?
As described in the second paragraph on page 3.13-6,
Pacifica’s storm drainage system consists of a
collection system and two pump stations. This
drainage system acts to convey drainage to area creeks
or the ocean. Two areas in the City, Linda Mar and
lower Sharp Park, are too low to allow drainage to a
creek or the ocean, and are served by pump stations to
prevent street flooding. The Streets Division of
Pacifica's Public Works Department maintains 290,000
linear feet of storm drain pipes with 989 storm drain
inlets within the City right-of-way and easements.

C9-21 Bob Boles 3/7/22 3. Figure 3.5-1 Hydrology and Flood Zones neglects to show the flow of Big Inch Creek between the
homes on Monterey and Nelson, undergrounding
at Ocean Shore School. This is also an area that
regularly floods from storm water runoff, despite
being on a hillside. The creek banks are also
eroding in several areas, as recently documented
by Christine Boles with extensive photos, videos
and over 30 neighbor testimonials. This data was
shared with Public Works on 12/2/2021.

The comment is noted. Figure 3.5-1, Hydrology and
Flood Zones Map, will be amended to add Big Inch
Creek to the map. This amendment represents a minor
clarification and does not affect the findings of the
DEIR.

C9-22 Bob Boles 3/7/22 4. CO-I-3 Funding for Creek Maintenance. “Establish funding mechanism to require property
owners with land adjacent to creeks to pay
proportionate share of creek improvement
maintenance.”
I strongly object to this requirement as written.

When creeks are part of the local hydrology and
used for drainage, they benefit the entire
community in the watershed, not just the
properties that back onto the creek. Responsibility
for maintenance should be shared by all the
properties within the watershed, which is easily
identified now with Figure 3.5-1 above.

The comment is noted. The comment is not related to
the adequacy of the DEIR, therefore no further
response is required in the FEIR. However, the
comment addresses the content of the Proposed
Project and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related
responses.

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C9-23 Bob Boles 3/7/22 I’d also like to call into question Section 6-12.208 of the PMC “Every person owning property
through which a watercourse passes, or such
person's lessee or tenant, shall keep and maintain
that part of the watercourse within the property
reasonably free of trash, debris, excessive
vegetation, and other obstacles which would
pollute, contaminate, or significantly retard the
flow of water through the watercourse.”
From surveying our neighbors on Monterey Road
and Nelson, not everyone can access the creek
from their back yards due to steep friable banks or
tall retaining walls. This means that large sections
are not maintained. This maintenance should
therefore be the responsibility of public works,
who can access the creek from the large gates at
the cross streets, which residents cannot access.

Again, costs can be shared by all the watershed
properties in a newly created special assessment
district. I also wanted to point out that there was
no disclosure of this maintenance requirement in
our purchase papers when we bought our
property.

The comment is noted. The comment is not related to
the adequacy of the DEIR, therefore no further
response is required in the FEIR. However, the
comment addresses the content of the Proposed
Project and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related
responses.

C9-24 Bob Boles 3/7/22 E. Water

1. “CO-G-5 Water Conservation. Work with the
Water District to meet State targets for reducing
per capita urban water use by 10 percent by 2015
and 20 percent by 2020.” Please revise to include
appropriate targets for FUTURE dates. Were the
water reduction goals listed above achieved in
2015 and 2020? The current data actually shows
water use has increased to its highest level in
2019-2020. What does the water use data show
for 2021-2022?
As stated in the fourth sentence of the second
paragraph on page 3.13-2, "water demand within the
District is projected to decrease to 819 MG (or 2.24
mgd) by 2045, a reduction of 4.4 percent compared to
the 2016-2020 average". In addition, see Table 3.13-4
on page 3.13-23 for estimated future water demand
and supply. Therefore, the existing water allocation is sufficient to meet the needs of the District from the
present through 2045.

C9-25 Bob Boles 3/7/22 2. CO-I-22 Water Storage. “ Support the NCCWD in its efforts to provide adequate emergency water
storage in Pacifica.”
Do we have adequate amounts of water storage?
NCCWD is not currently planning for growth of 990
new units or 1892 new units under RHNA in the
2020 Urban Water Management Plan. Are the
large, heavy water tanks located on hillsides
secure in the event of a substantial seismic event?
This analysis is missing from the public documents
the NCCWD has released to date.

As noted on DEIR p. 3.13-2, "NCCWD system’s 11
storage tanks or reservoirs have a total capacity of

18.25 million gallons, enough to supply the service
area with water for 5.8 days at the District’s average
daily
usage rate of 2.43 million gallons per day (mgd)...water demand within the District is projected to decrease to
819 MG (or 2.24 mgd) by 2045, a reduction of 4.4
percent compared to the 2016-2020 average. This
existing allocation is sufficient to meet the needs of the District from the present through 2045." This indicates that storage will remain adequate with future demand.

As stated in the second sentence of the first paragraph on page 3.13-4, the NCCWD's current Capital
Improvement Plan is focused on pursuing additional
sources of water supply, addressing water storage
deficits by increasing tank size or adding new tanks,
and pipe upgrades. In addition, California Assembly Bill 1823 identifies nine projects essential to the
maintenance of water supply following a major

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earthquake, and
requires that they be carried out. In 2002, the SFPUC
adopted a $2.9 billion capital improvement program to
undertake a system upgrade. The General Plan
proposed policy SA-I-93 also requires a priority place
on water storage facility locations that are the least
impacted by seismic activity and land sliding.

C9-26 Bob Boles 3/7/22 3. The Bay Delta Plan may significantly lower available potable water to Pacifica – where is this
discussed in relation to possible limits to new
housing? What about droughts limiting water
hookups, which is discussed in the NCCWD’s 2020
Urban Water Management Plan? Should that not
be included in the DEIR especially as it relates to
climate change adaptation and resiliency as
required by SB379?
Analysis pertaining to whether the implementation of
the Proposed Project will have sufficient water supplies available to serve the project and reasonable
foreseeable future development during normal, dry
and multiple dry years is discussed under criterion

3.13-2, specifically on pages 3.13-22 to 3.13-25.

NCCWD projects there will be adequate water supply
to provide for the population under General Plan
buildout in a normal year. However, significant
shortfalls are projected in dry year conditions, which if realized would require the District to enact its Water
Shortage Contingency Plan. Numerous uncertainties
exist in the assumptions that drive the projected dry
year shortage estimates, and the District anticipates
revising its water service reliability assessment within the next five years as some of these uncertainties are
resolved. Even so, as implementation of the Proposed
Project would not result in rapid or substantial
population growth that would exceed NCCWD’s
current demand rates, and because proposed policies
concentrate on reducing water use and ensuring
adequate supply, this impact is considered less than
significant.

C9-27 Bob Boles 3/7/22 F. Waste/Recycling

1. ES-I-4 Recycling Center Relocation. Work with
Recology, Inc. to identify a new location for a
recycling yard to free up land for visitor-based
economic development. The current Recology
location is in an area experiencing high erosion of
coastal cliffs. This is an essential public health and
safety issue and it is not discussed at all in the DEIR or General Plan. A new location should be
identified now as part of resiliency planning under
SB379, not at some vague time in the future.

Please provide a discussion/plan for resolving this
issue along with a plan to address the potential
loss of Palmetto Avenue in this location across
from the current Recology site due to projected
Coastal Erosion.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Project and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C9-28 Bob Boles 3/7/22 2. “6-G-6 Adequate Infrastructure.

Manage utility infrastructure and waste
management systems that are adequate to protect
the health and safety of all current and future
Sharp Park residents and businesses.”
First of all, is this item numbered properly? It
seems different than other Guiding or
The comment is noted. Guiding Principles are
renumbered to correspond with the correct GP
Principle in the redlined DEIR. As the remainder of the comment is not related to the adequacy of the DEIR,
therefore no further response is required in the FEIR.

However, the comment addresses the content of the
Proposed Project and will be shared with decisionmakers in that context. Please see Master Response 1:

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Implementation Policies. Secondly this is so vague
it is meaningless. Utility infrastructure in Sharp
Park will need to be moved inland for resiliency
from sea level rise. Please provide a discussion of
when and where infrastructure will be moved, and
identify an inland site for the relocation of Sharp
Park Sewage Pump Station.

The Sharp Park Sewage System serves
approximately 40% of the population of Pacifica,
well beyond the boundaries of Sharp Park. With a
pump failure, waste backup could reach every
corner of the sewer system. Even with triggers and
a plan in place by that time, it would take years to
add details to finish the plans, raise the money,
process the permits through the Coastal
Commission, and actually complete moving the
sewer system landward. By waiting so long to
complete the rebuild the cost could double or
triple what it would cost if done in the near future.

The lack of any current plan to move the pump
station as part of this General Plan or of the Beach
Boulevard Infrastructure Resiliency Project seems
negligent on the part of the city of Pacifica, and is
most certainly not building long term resiliency
from climate change effects of sea level rise and
coastal erosion.

EIR Comments for more information about GP- or
SPSP-related responses.

C9-29 Bob Boles 3/7/22 In conclusion, all public service and utilities impacts should be found to be significant and
unavoidable unless new analysis is provided that
services and utilities can meet the demands of the
full development allowed by the Proposed Project
(much more than 990 units as demonstrated in
detail by Planning Consultant Terry Watt)
The comment is noted. See response to comment C9-

2. C9-30 Bob Boles 3/7/22 I urge you to pull the documents, update them properly and consistently with current data in
consultation with Public Works and Wastewater
divisions, NCCWD and Recology, organize the
documents clearly with proper indexes and tables
of contents and an updated Bibliography;
recirculate them as necessary, and hold public
hearings to study them. These are important
documents and need to be properly prepared and
publicly vetted in a fair and reasonably manner.

We cannot possibly approve a General Plan with
990 new units (or more under RHNA) without a
proper understanding of our infrastructure
capacity as well as the necessary improvements
for climate change resiliency and adaptation.

The comment is noted. See response to comment C9-

2. 1.f
Packet Pg. 749 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 85 C10: Christine Boles, 1/27/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C10-1 Christine
Boles
1/27/22 I would like to officially record my objections to the 45-day public review process given the poor quality of
the documents posted on the Plan Pacifica website
for public review on January 7, 2022 at approximately
10:30pm. Please reference the email to council from
Pete Shoemaker sent on January 23, 2022, which I
have copied below, and which you can see my name
is officially signed on to. I also reference my previous email to you on 1/20/22 with a specific example of
the difficulties I am facing in using these documents
related to Greenhouse gas emissions.

After substantial public outcry, the city made
available searchable word documents on 1/25/22, but
at that point we had already lost 17 out of 45 days of
our already minimal review period the city has
allowed. The fact that the Word documents contain
text but not graphs or other visuals means that they
are still difficult to use and take more of our time as we are forced to go back and forth between
documents and formats. This is unprofessional and an
unnecessary burden to both residents and state and
local agencies tasked with reviewing these
documents.

In fact, I received a phone call from Will Kanz of the
California Department of Fish and Wildlife yesterday
afternoon. Their department is also having issues with
not being able to search documents, and with not
being able to cut and paste from the pdf to prepare
their official comments and responses. He told me he
had sent the city a letter requesting an extension, but that the request was denied. On what grounds what
this request denied? I would like to remind city staff
and Council that the basic purpose of these
documents, as described in the DEIR introduction
Section 1.1, is to “inform decision makers, responsible and trustee agencies, and the general public of the
proposed action and a range of potential
environmental impacts of that action. The EIR process
provides (is supposed to provide) an opportunity to
identify environmental benefits of the Proposed
Project that might balance some potentially
significant adverse environmental impacts.” It is not
only in all of our interests to ensure these documents
are properly prepared and reviewed, but also our
utmost duty as the current stewards of this land we
coinhabit. How can honestly claim at the beginning of
each Council meeting to honor the Ohlone Ramaytush
peoples whose land we profess still belongs to them
without a full and robust review and engagement
process on these most critical environmental
documents. I urge you to pull the documents, fix the
According to 14 CA ADC § 15105, The public review
period for a draft EIR shall not be less than 30 days
nor should it be longer than 60 days except in
unusual circumstances. The public comment period
was extended on 2/14/2022 to 3/8/2022.

1.f
Packet Pg. 750 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 86 pdfs as previously requested, and reset the 45 day
clock.

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Packet Pg. 751 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 87 C11: Monica Meagher, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C11-1 Monica
Meagher
3/8/22 It is clear from the Draft General Plan that the city is mindful of preserving a large amount of open space,
and focusing on dense, high uses for vacant or
undeveloped space. There is also clear thought put
into better utilizing currently developed land. We
appreciate the balance of open space and smart
development.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C11-2 Monica
Meagher
3/8/22 We love and fully support the plans to further
develop Palmetto Avenue into a retail and visitor
destination. We try to spend as much money locally
as possible. This is very easy with the many
restaurant options, local grocery store, and
recently, a few local toy stores. However, this is
difficult for home goods and sundries. We’d love to
see options for sustainable home goods that we can
purchase locally and hope a revitalized Palmetto
Avenue is attractive for retail.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C11-3 Monica
Meagher
3/8/22 It is also clear that Pacifica is car centric. This has become a chicken and egg problem. Since Pacifica
does not invest as heavily in walking, biking, and
transit, people must drive; therefore we are a car
centric town that does not invest heavily in
alternatives. We appreciate the focus beyond cars
and considerations for pedestrians, bicycles, and
transit. We hope the city prioritizes planning for
alternative modes before investing further in car
infrastructure. This will start to shift the balance and allow residents to use alternative modes to get
around town. The Draft General Plan notes that all
studied intersections have crosswalks. However,
there is no crosswalk across Esplanade Avenue at
any point, which makes it very dangerous for the
many pedestrians trying to get to the walking path
to enjoy the view. We hope this is addressed.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C11-4 Monica
Meagher
3/8/22 We appreciate the Existing and Proposed Bike
Network but did notice some discrepancies
between current conditions and what is marked on
the map, especially regarding the north section of
Palmetto (between Ingrid B Lacey and West Avalon)
and Esplanade. There is one “bike path” sign and no
road markings on Esplanade so we are surprised to
see it classified as a bike path. There are many
bikers who use that portion of the road and have
difficulty navigating around parked cars. The path
does not link up to the well created paths along
Palmetto.

We would love to see the path on Esplanade
updated and linked to the rest of the city. We think
many residents would bike around town to shop
locally with safer and connected bike paths. We
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

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Packet Pg. 752 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 88 Letter Commenter Date Comment Combined Response
Individuals (C)
hope Pacifica will look to Berkeley as an example for
safe, usable bicycle paths.

C11-5 Monica
Meagher
3/8/22 It is also clear from the small number of transit trips today that Pacifica can benefit from better
connections to the world-class transit available just
over the hill. The Linda Mar Park N Ride is a great
example of what can be done, but could be
executed better. If a Linda Mar resident wanted to
park and bus to BART, they would have to stop 36
times between Linda Mar and BART. Even someone
from the north end of the city would need 22 stops.

Pacifica should partner with SamTrans to make an
effective connection to BART with fewer stops for
Pacifica residents. Rather than providing more
stops, reduce stops to serve just a few central Park
N Ride locations to make for a fast commute to
BART or Caltrain. Park N Ride facilities can be
located in the major residential areas (Manor, Sharp
Park, Linda Mar) and Limited stop or Rapid bus lines
can be used during commute times to supply buses
just stopping at Park N Ride locations. These same
locations could be used on weekends (with the
addition of Rockway) to provide trolleys or some
festive way for BART or Caltrain riders to access
Pacifica beaches on the weekends. Again,
minimizing stops (rather than expanding services) to
just be in key commercial areas for visitors and
residents. We would happily take our family via
transit down to Linda Mar for a beach day rather
than struggle with parking if there was only one
stop along the way.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C11-6 Monica
Meagher
3/8/22 These suggestions around walking, biking, and
transit align with the Caltrans’ Smart Mobility
Framework for suburban locations. It recommends
the prioritization of transportation projects and
programs that:
- Invest in complete streets and safer walking and
biking conditions
- Increase commute transit service and ridesharing
- Improve connectivity to reduce trip lengths and
increase non-auto trips
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C11-7 Monica
Meagher
3/8/22 In line with the last suggestion, we would like to suggest clearer prioritization. There are many
policies outlined in the Draft General Plan. While we
hope the city is able to realize them all, we must be
mindful of our limited resources (of both time and
money). Can the city work to balance various needs
and make it more clear which policies are priorities?
There should only be a handful in order to be
effective.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

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Packet Pg. 753 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 89 C12: Jewel Walli, 3/5/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C12-1 Jewel Walli 3/5/22 1. Please include some recreation requirements in the approval of new building permits for those
large complexes that are being discussed. We are
a city with no public tennis courts/pickle ball
courts.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C12-2 Jewel Walli 3/5/22 2. In the general plan please include some pickleball courts . Work with the Parks and
Recreation department and start applying for
grants. This sport, most popular in America,
appeals to older adults so there are probably
grants available.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C12-3 Jewel Walli 3/5/22 3. Negotiate with the High School District and go in jointly with a new library. Oceana and Terra
Nova have a lot of unused land (That would work
for some public pickleball courts as well).

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C12-4 Jewel Walli 3/5/22 4. Quit approving buildings (like the church) that have a huge negative impact on the residents
that live there. Would you want a house on Cape
Brenton?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

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Packet Pg. 754 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 90 C13: Christine Boles, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C13-1 Christine
Boles
3/8/22 As mentioned previously in my Comment Letter
#2, detailed maps of projected coastal erosion and
sea level rise are missing from both the DEIR and
General Plan. In fact, the city’s own Existing
Conditions Report from July 2010 showed much
better maps to help decision makers and
developers analyze these conditions, in that they
are more complete. Using less complete
information in subsequent updates leaves the City
vulnerable to confusion and lititgation by
artificially adding perceived value by rezoning to
higher allowed densities.

Please see response to comment 13-3 for more
information about adequacy of sea level rise analysis
and response to comment C69-8 for more information
about adequacy of coastal erosion analysis. Maps of
coastal erosion projections and sea level rise are
included in the 2018 Sea Level Rise Vulnerability
Assessment, referenced on DEIR p. 3.5-10 and 3.6-1.

These maps are also included in the LCLUP, which will
govern permitting and coastal resiliency thresholds for sea level rise and erosion in the Coastal Zone once
certified. Policies in the GP share policies with the
LCLUP and are based on this latest mapping effort.

Maps chosen represent the latest and best available
sources of information; existing conditions reports
from 2010 represent data that is outdated.

C13-2 Christine
Boles
3/8/22 2. In addition, the City’s hired consultant, ESA, in the 2018 Sea Level Rise Vulnerability Assessment
provides even more detailed information about
coastal erosion and sea level rise projections.

There is no link to this document in the DEIR and it
is not listed in the Bibliography. Please add the
references to ensure we are working on the same
information. The copy I have of this report is dated
January 2018 and is labeled DRAFT. Has this report
been finalized with the consultant and approved
by the City Council? Why were these maps not
incorporated into the DEIR and GP Safety Element
when sea level rise and coastal erosion are some
of our greatest hazards, and have already cost the
city greatly in lost housing and fees to tear down
inappropriately built structures?
The 2018 Sea Level Rise Vulnerability Assessment is
referenced on p. 3.5-10 and 3.6-1; the DEIR
incorporates its coastal erosion and sea level rise
projections. A link to the report is found on DEIR 3.5-

10. The reference will be included in errata.

C13-3 Christine
Boles
3/8/22 3. I spoke with one of the report authors at ESA about a year ago to try to understand the map in
Sharp Park in particular. I was confused because
there is no storm flood area shown in the diagram
when I have personally observed major flooding
along Beach Boulevard and the properties across
the street from the ocean in winter storms and
king tide events. I was told that flooding was not
analyzed due to the presence of the sea wall. I
would suggest that this issue needs further
scientific study and mapping to understand the
real hazards in this area and this information
needs to be added to the DEIR.

The comment is noted. Background information using
some of the latest widely accepted scientific research
on climate change and sea level rise, including recent
(2013) work from the Coastal and Ocean Working
Group of the California Climate Action Team (CO-CAT),
was incorporated into the Draft EIR analysis as
provided on pages 3.5-9 and 3.5-10. In 2018, the City
of Pacifica prepared a Sea Level Rise Vulnerability
Assessment using the best available science.

Consistent with the San Mateo County Vulnerability
Assessment, existing and future coastal flooding was
evaluated using the Our Coast, Our Future (OCOF;
produced by US Geological Survey) mapping products,
while future coastal erosion was evaluated using the
Pacific Institute (PI) erosion maps. The Vulnerability
Assessment projected sea level rise scenarios ranging
from 1-2 feet by 2050, and 3-6 feet by 2100. The 6 feet projection is an extreme scenario in which sea levels
rise at a rate about 30-40 times faster than the rate
experienced in the 20th century. Rising sea levels have occurred over the last century and are expected to
continue over the coming century, likely at a rate that

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Packet Pg. 755 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 91 Letter Commenter Date Comment Combined Response
Individuals (C)
exceeds the rates experienced thus far. Modeling has
provided estimates of potential increases in sea levels but as stated on page 3.5-11 of the Draft EIR,
predictions become less reliable as you go further into the future. In addition, different modeling efforts have been conducted to reflect various possible outcomes
resulting in a range of estimates for the amounts of
sea level rise that could be experienced, largely due to the difficulty in determining a more defined predictive value.

Prior to experiencing inundation hazards from a higher
sea level rise, some developed areas are likely to be
subject to changes in flooding hazards as stated on
page 3.5-28 of the Draft EIR. Low coastal flood zone
areas could expand over time as sea levels rise. The
use of maps such as those found in the 2009 California
Climate Change report (The Impacts of Sea-Level Rise
on the California Coast) are not recommended to be
used in place of official FEMA FIRM flood zone maps.

The FIRM maps are periodically updated and future
maps will likely incorporate the latest findings of sea level rise as it becomes more defined. Nonetheless,
the Draft EIR on page 3.5-8 and 3.5-11, identifies the
areas within the City that could be subject to
increased flooding hazards (i.e., areas of West Linda
Mar, lower Pedro Point, Rockaway Beach, West Sharp
Park and the Sharp Park Golf Course). Further, the
proposed policies including SA-G-4 (Key Coastal Act
Policies), SA-G-5 (Sea Level Rise and Best Available
Science), SA-I-15 (New Development in Coastal Zone),
SA-I-28 (Vulnerability Identification and Mapping), and SA-(-30 (Monitoring Shoreline Change) specifically
address the potential hazards of sea level rise and
provide the flexibility in making the appropriate
adjustments as the science improves to ensure that
future development is adequately protected. Any
development in the Coastal Zone is also required to
apply for a Coastal Permit; Coastal Commission
certification will be functionally equivalent to CEQA
analysis for other Coastal Act and LCLUP policies.

C13-4 Christine
Boles
3/8/22 4. In addition, new development cannot be
permitted in the Coastal Zone that relies on a sea
wall or other armoring, which makes it imperative
to redo this modeling without a sea wall in place.

In previous letters I have documented that this is
actually a state requirement for General Plan
Safety Elements for flood areas. As these
properties in the Coastal Zone must be designed
for 100-year life, which is 50 years beyond the
design life of the sea wall currently being
proposed, this modeling is essential to
understanding how building design life criteria can
be met. Specifically, Section 30253 prohibits new
development if it would require a coastal armoring
The comment is noted. Analysis used the best
available data for sea level rise projections. Further, the proposed policies including SA-G-4 (Key Coastal
Act Policies), SA-G-5 (Sea Level Rise and Best Available Science), SA-I-15 (New Development in Coastal Zone),
SA-I-28 (Vulnerability Identification and Mapping), and SA-(-30 (Monitoring Shoreline Change) specifically
address the potential hazards of sea level rise and
provide the flexibility in making the appropriate
adjustments as the science improves to ensure that
future development is adequately protected.

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Packet Pg. 756 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 92 Letter Commenter Date Comment Combined Response
Individuals (C)
structure. New development shall do all of the
following:
(a) Minimize risks to life and property in areas of
high geologic, flood, and fire hazard.
(b) Assure stability and structural integrity, and
neither create nor contribute significantly to
erosion, geologic instability, or destruction of the
site or surrounding area or in any way require the
construction of protective devices that would
substantially alter natural landforms along bluffs
and cliffs.

C13-5 Christine
Boles
3/8/22 5. Below is the map of the Sharp Park Area from
this ESA study, showing considerable threat. I have
roughly overlaid the map with the areas indicated
on Figure 4-3 Land Use Diagram, to be the highest
density allowed, where height is increased to 55’
or more (there was one reference to more than
55’ somewhere that I can’t find now) with the
provision of low-income housing. Note that several
of these overlap these high hazard zones. I believe
the General Plan Safety Element calls for
avoidance of building in high hazard areas.

Please remember that the Coastal Commission
needed to assert jurisdiction over the Coastal
Zone, and overturned the City of Pacifica’s
questionable approval of Coastal Development
Permit Application Number CDP-395-18, which
had been previously green-lighted by the City,
despite numerous objections and appeals by local
residents who had pointed out the obvious
hazards at 1567 Beach Blvd Pacifica. Failing to
provide current information to the public further
endangers Pacificans, misleads developers who
wish to build sustainably in good-faith, and wastes
staff and the public’s time and taxpayer funds. So, I
would question the validity and wisdom of the
current proposed land use maps for this area.

The comment is noted. Please see response to
comment C13-3 for more information about adequacy
of sea level rise analysis and response to comment
C69-8 for more information about adequacy of coastal
erosion analysis. As the commenter notes, the CCC has
project permitting authority in the Coastal Zone, and
several of the policies in the LCLUP require additional project-level review.

C13-6 Christine
Boles
3/8/22 6. I am pretty certain there are restrictions about placing--or concentrating--vulnerable low-income
population in areas of high hazards. If not, there
are moral issues with placing vulnerable residents
in the highest-risk areas. Please confirm and add
appropriate conditions in the Land Use Element to
comply with applicable laws, and explain how
these could possibly be in conformance with the
State’s Environmental Justice goals.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C13-7 Christine
Boles
3/8/22 7. Please also note that Palmetto Avenue is
threatened by sea level rise on the southern end. I
have seen no discussion of the possible need to
move the road and infrastructure inland. This
should be discussed now before new high-density
construction is allowed on the inland side of
Palmetto.

Please see response to comment C137-1

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Individuals (C)
C13-8 Christine
Boles
3/8/22 8. As previously mentioned in Comment Letter #4, our sewage infrastructure will eventually need to
be moved inland. Our sea wall consultant GHD
specifically said that the sea wall would not
protect us long term, it is only being designed with
a 50-year life to buy us time for more wholistic and
long-range resiliency planning. An alternate site for
the Sharp Park Sewage Pump Station that serves
the entire northern section of Pacifica must be
identified now as part of this General Plan.

Perhaps the city’s Salada parking lot would be a
good location, but that is also zoned Mixed Use
Center. This property has also recently been
approved as part of the Civic Center Remodel as
required parking for those buildings, so perhaps
we need to find an alternate site?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C13-9 Christine
Boles
3/8/22 9. SA-I-26 Tsunami Evacuation Zone. For new
development in the tsunami evacuation zone,
require use of low impact engineering techniques,
such as elevating structures above projected water
levels, to mitigate impacts to people and
structures.

My understanding from my limited experience
with the Coastal Act is that new development is
not strictly prohibited in Tsunami Evacuation zones
or areas with or projected flooding from sea level
rise or seasonal rains, but that the structures and
roads must be adaptable and allow the water to
pass through. Their ground floor levels also need
to be raised above projected sea level rise. These
requirements and basic protections are missing in
the DEIR, and are also conspicuously absent from
the consultant’s pretty renderings of what Sharp
Park development might look like under this
General Plan.

These basic requirements will completely change
the relationship of the buildings to the street and
require long handicapped ramps that require
considerable space (1 foot of length for every inch
of rise) and will therefore limit the amount of
buildable space. This seems negligent on behalf of
our planning consultant to not have raised this
issue in the planning process.

The comment is noted. All development will comply
with California Coastal Act regulations. New
development in Coastal Zones will adhere to proposed
policy SA-I-15 which states that the Proposed Project
will continue to enforce provisions of the California
Coastal Act requiring new development within the
Coastal Zone to:
• Minimize risks to life and property in areas of high
geologic, flood, or fire hazard;
• Assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding
area or in any way require the construction of
protective devices that would substantially alter
natural landforms along bluffs and cliffs;
• Not accelerate the need for a shoreline structure or
increase the likelihood of a future seawall beyond the
existing development’s expected life; and
• Not violate required setback provisions.

Small improvement projects are exempt, including
improvements that would increase height, bulk or
floor area by less than ten percent.

C13-
10 Christine
Boles
3/17/22 10. SA-G-3 Sea Level Rise Adaptation. Establish policies to minimize the risk to persons and
property posed by potential sea level rise.

Please confirm what measures this General Plan
establishes to minimize risk. These measures that
affect basic life safety cannot be deferred under
CEQA.

Proposed Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take on an
ongoing basis as the Proposed Project is implemented
and the DEIR has correctly considered the effects of
implementing these policies, including any beneficial
effects they would have in reducing potentially
significant impacts of the Proposed Project. The Draft
EIR on page 3.5-11, identifies the areas within the City that could be subject to increased flooding hazards

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Individuals (C)
(i.e., areas of West Linda Mar, lower Pedro Point,
Rockaway Beach, West Sharp Park and the Sharp Park
Golf Course). Further, the proposed policies including
SA-G-3 (Sea Level Rise Adaptation), SA-I-22 (Sea Level
Rise Model), and SA-I-35 (Sea Level Rise Surveys),
specifically address the potential hazards of sea level rise and provide the flexibility in making the
appropriate adjustments as the science improves to
ensure that future development is adequately
protected.

C13-
11 Christine
Boles
3/8/22 11. Chapter 3.9 of the DEIR discusses visual
resources. As a licensed architect, I am considered
as a professional expert in commenting on these
issues. Visual Resources Figure 3.9-1 from the DEIR
is copied below for reference.

Please note the area circled in red, the coastal
view corridors identified in Sharp Park. As you are
well aware, the current design for the new Sharp
Park sea wall recently approved by the City Council
as a hybrid option of hard armoring with sand
nourishment will entail an approximately 5’ high
sea wall above the existing road. Please clarify how
this will protect these scenic resources which will
no longer be able to be seen from the sidewalk or
the surrounding roads by the majority of the
population.

Without expensive and regular sand nourishment
the city’s consultant, GHD, said the sea wall would
need to be 8’ high. I believe GHD also said that
even with these heights the proposed hard
armoring will not protect the area from future
projected storm surge and wave overtopping, so
flooding will still be an issue. Please confirm. Is
there additional drainage planned for the area?
I’m anxiously waiting for Public Work’s drainage
study due to be completed later this year.

The sea wall and coastal armoring is a LCLUP-related
issue; construction of the sea wall is beyond the scope of the DEIR. The comment is not related to the
adequacy of the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed Plan and will
be shared with decision-makers in that context. Please
see Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C13-
12 Christine
Boles
3/8/22 12. Highway One is also identified on the map as a scenic route. I have seen no analysis or visual
simulations in the DEIR that show how the views
from Highway One may be impacted by the
rezoning of tall structures in Sharp Park along
Palmetto and Francisco. Please provide these
simulations so that the impacts of the rezoning to
Mixed Use Center can be properly evaluated.

The DEIR analyzes scenic resources within state scenic
highways on pages 3.9-22 through to page 3.9-24. As
mentioned on page 3.9-23 'Sharp Park lies to the west
of Highway 1, screened by large trees. No historic
buildings, ridgelines, views of the ocean, or other
scenic resources are visible from Highway 1 where it
traverses the Planning Area. Policies in the Proposed
General Plan also apply to the Sharp Park Specific Plan area.' Due to the topographical differences between
the highway and its immediate surroundings, the
potential future taller buildings along Palmetto would
not have a significant impact of view from Highway 1.

Additionally, simulations are not required for CEQA.

Guiding Policy CD-G-7 ensures viewsheds from
Highway 1 and Sharp Park Road are preserved and
enhanced through scenic corridor plans (CD-I-22),

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roadway design or modification that minimizes visual
impacts to views from scenic routes (CD-I-26). The
DEIR also has regulations and policies that would
further reduce impact on scenic resources on pages

3.9-23 and 3.9-24.

C13-
13 Christine
Boles
3/8/22 13. The importance of Highway One View
Corridors is also written in the DEIR on page

3.9.21. As essential parts to Pacifica’s identity, I
would expect to see a real analysis of visual
impacts with simulations from multiple
viewpoints. The increased height limits and new
zoning right up next to the freeway at Manor Plaza
should also be evaluated with visual simulations.

This is the first view that most visitors get of
Pacifica coming down the hill and is particularly
important to the city’s image.

14. Furthermore, on page 3.9-22 somehow
without any visual analysis, the impact on visual
corridors has been declared to be less than
significant. Please explain in detail how this
conclusion was reached.

The DEIR analyzes scenic resources within state scenic
highways on pages 3.9-22 through to page 3.9-24. No
historic buildings, ridgelines, views of the ocean, or
other scenic resources are visible from Highway 1
where it traverses the Manor Plaza section of the
Planning Area. Due to which any potential future
development at Manor Plaza would not have a
significant impact of view from Highway 1.

Additionally simulations are not required for CEQA.

C13-
14 Christine
Boles
3/8/22 15. Page 3.9-5 of the DEIR states
There are no renderings provided in the Sharp Park
Specific Plan of the relationship between these tall
new buildings along Francisco and Palmetto to all
the one- and two-story existing homes in the area.

Please provide this analysis and renderings so the
visual impacts can be understood. I remember
Mayor Mary Bier commenting at a Council
Meeting when the renderings were presented that
she would want to see those as well as they
directly affect her constituents.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C13-
15 Christine
Boles
3/8/22 16. Page 3.9-6 of the DEIR states......

Again these important view corridors may be lost
due to both the sea wall and the more bulky and
tall strucutres proposed under this General Plan
Land Use Element. Can you confirm that this is in
compliance with CEQA for Visual Resources, and
with the Coastal Act, see pae 3.9-10 of the DEIR?
Please see response to comment C13-30.

The sea wall is a LCLUP-related issue; construction of
the sea wall is beyond the scope of the DEIR as it not
part of the Proposed Project. The comment is not
related to the adequacy of the DEIR, therefore no
further response is required in the FEIR. However, the
comment addresses the content of the Proposed Plan
and will be shared with decision-makers in that
context. Please see response to comment C13-3 for
more information about coastal flooding and sea level
rise.

C13-
16 Christine
Boles
3/8/22 17. Would there not be some lost economic
benefits in Sharp Park if the ocean, which is one of
the major draws of the area, was no longer visible?
Has this financial analyis been done as part of the
GP update or sea wall project? I have not seen this
information.

Economic analyses are not required under CEQA. The
comment is not related to the adequacy of the DEIR,
therefore no further response is required in the FEIR.

However, the comment addresses the content of the
Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

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C13-
17 Christine
Boles
3/8/22 18. Under Impacts and Mitigation Measures on
page 3.9-14 somehow, without this detailed visual
analysis, it has been determined that impacts are
less than significant. Please provide actual
information to back up this statement to avoid a
CEQA challenge.

The DEIR analyzes scenic vistas on page 3.9-14
through 3.9-22. As mentioned on page 3.9-14 'A
number of the Proposed Project’s policies provide
long-term protections for scenic vistas in Pacifica while also creating opportunities for development in
already-developed areas of the city; these policies
include the continuation of the Hillside Preservation
District program and Design Guidelines and Review for
development projects (including Guiding Policies CDG-4 and CD-G-5; and Implementing Policies CD-I-4; I7; I-11; I-12; I-13; I-14; I-15; I-16; and I-17).' As well as 'Future redevelopment projects and development of
vacant lots within and adjacent to already-developed
neighborhoods will be subject to regulation and
review mechanisms to ensure there is no substantial
adverse effect on scenic vistas.' Implementation of
these policies and regulations, as well as additional
ones mentioned on pages 3.9-19 through 3.9-22, will
decrease the impact of the Proposed Project to a less
than significant level. Additionally simulations are not required for CEQA.

C13-
18 Christine
Boles
3/8/22 19. Further down on page 3.9-14 it talks about
landscape screeing as a method to protect visual
resources. I believe there are other General Plan
and Municipal Code regulations that prohibit the
use of landscaping to hide an otherwise
unacceptable structure. I don’t have time to find
references, but this was discussed in my letters
regarding the Vista Mar Project. Landscaping
obviously does nothing to help blocked ocean
vistas from buildings so this line of argument is
flawed.

The comment is noted. Section 3.9 does not mention
the use of screening to hide an otherwise
unacceptable structure. This comment is not related
to the adequacy of the DEIR, thus no further response
is required.

C13-
19 Christine
Boles
3/8/22 20. There is one image in the DEIR on page 3.9-17 that shows ocean views being blocked by buildings
even 35’ in height at the city’s property at 2212
Beach Boulevard. Does this indicate that at this
site the height must even be reduced beyond
current zoning limitations? Please clarify. Note
that this image and the others after it in the DEIR,
were taken from a higher elevation, not street
level on Palmetto, so they should be redone.

The DEIR analyzes scenic vistas on page 3.9-14
through 3.9-22. As shown in Figure 3.9-7, increasing
building heights does not substantially impacts views
of the ocean as compared to existing zoning (35').

Figures 3.9-8 through 3.9-9 in the DEIR show that by
implementing policies such as 5-I-67 along with
additional design standards/guidelines specified in the SPSP, the impacts will be reduced to a less than
significant level.

C13-
20 Christine
Boles
3/8/22 21. Page 3.9-22
Doesn’t this mitigation measure contradict the
basic concept in the Land Use Diagram to allow
heights up to 55’ in this area. I am very confused.

The DEIR analyzes scenic vistas on page 3.9-14
through 3.9-22. As described on DEIR p. 3.9-13, "While
the Proposed Project eliminates the existing single
height limit in the city with height limits that vary by zone, future development will be subject to regulation
and review mechanisms to ensure there is no
substantial adverse effect on scenic vistas...The land
use changes in the Proposed Project will not
substantially degrade the existing visual character or
quality of Pacifica and would not conflict with
applicable zoning and regulations governing scenic
views. All existing open space areas are preserved and

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scenic resources are protected under the Proposed
Project. Policies, zoning designations and design
guidelines included in the Proposed Project will
sensitively govern the formal characteristics of new
development to ensure they are compatible with
existing neighborhood character and quality The
Coastal Act requires scenic and visual qualities of
coastal areas to be considered and protected as a
resource of public importance, and the Sharp Park
Specific Plan includes design standards to minimize
impacts to these areas.

Figures 3.9-4 through 3.9-9 in the DEIR show that by
implementing 3-G-3, 3-I-2, 3-1-35 and 4-G-4 policies
along with additional design standards/guidelines
specified in the SPSP, the impacts will be reduced to a less than significant level.

C13-
21 Christine
Boles
3/8/22 22. The Coastal Commission also brought up their concerns about visual impacts of increased heights
in their comment letter to the NOP sent on
September 9, 2020. I have copied the letter here
below. Please provide a response to their
comments.

As described on DEIR p. 3.9-18, the Sharp Park Specific Plan proposes land use and corresponding density and
intensity changes along Palmetto Avenue, Francisco
Boulevard, and Eureka Square. The intent of these
changes is to support development of additional
housing, including affordable housing; create a
balanced mix of residential options and compatible
commercial land uses; improve the public realm and
streetscape to promote commercial activity and
walkability; and create a defined commercial center
for Pacifica. To accommodate desired densities and
intensities, the Specific Plan allows for additional
building heights of up to 45 feet for Mixed Use
Neighborhood land uses and up to 55 feet for Mixed
Use Center land uses.

As described in the Environmental Settings, there are
three designated coastal view corridors in the
Planning Area, looking down Paloma Avenue, Salada
Avenue, and Clarendon Road to the ocean. The
vantage point at the top of the bluff where the
Horizons West Apartments are located offers views of
the ocean and the surrounding city, though it is not a
protected view. Between existing buildings and trees,
glimpses of the surrounding hillsides to the east can
be found along Palmetto Avenue. East-west oriented
streets provide views of both the ocean and hillsides.

Views of other important community landmarks, like
the Pacifica Beach Park, the Pacifica Municipal Pier,
and the Sharp Park golf course exist along Beach
Boulevard.

All development under the Proposed Project is
required to comply with existing General Plan and
Local Coastal Land Use Plan policies related to
protected views, particularly new buildings along
Palmetto Avenue with frontage on the coastal view
corridors of Paloma Avenue, Salada Avenue, and
Clarendon Road. While the Sharp Park Planning Area is
mostly flat, there are some points of

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elevation around Hilton Way. From Hilton Way, the
undeveloped portion of the 2212 Beach Boulevard site
provides a more expansive viewshed to the ocean. At
the corner of Palmetto Avenue
and Hilton Way looking south, views to Mori Point and
other southern hills are visible. Pacifica’s existing
height limit of 35 feet begins to obstruct these views
should all buildings reach their existing height
maximum, as shown in Figure 3.9-3 and Figure 3.9-6.

Because the Sharp Park Specific Plan allows for
additional heights up to 55 feet, new development has
the potential to further impede views.

However, the Sharp Park Specific Plan includes several
urban design standards and guidelines would reduce
impacts to these viewsheds, including setbacks, upper
stepbacks above the second
floor, and policies directing site design at the 2212
Beach Boulevard site to preserve part of the viewshed.

Thus, the impacts of taller buildings on scenic
resources are less than significant.

C13-
22 Christine
Boles
3/8/22 23. In this letter, the Coastal Commission also
asked for a thorough geotechnical analysis of the
area in this
letter. I also asked for that information in a public
hearing about the Sharp Park Specific Plan in 2021.

Do we know that the area’s soils and ground water
table can even support a 55’ high building? Please
add this analysis to the DEIR to ensure this
proposed project even feasible.

The comment is noted. As described in on p. 3.6-37,
geotechnical investigations would be required to
thoroughly evaluate site-specific geotechnical
characteristics of subsurface soils and bedrock to
assess potential hazards and recommend site
preparation and design measures to address any
hazards which may be present. These measures are
enforced through compliance with the CBC to avoid or
reduce hazards relating to unstable soils and slope
failure. In addition, Policy SA-I- 8 of the proposed
General Plan strengthens these precautions by
requiring geotechnical studies subject to review by
City staff, which identify any geologic hazards affecting proposed project sites in Coastal and Hillside zones,
any necessary mitigation measures, and a statement
of the site’s suitability for the proposed development
and whether or not it will be safe from geologic hazard for its expected life."
C13-
23 Christine
Boles
3/8/22 24. From page 3.9-22 of the DEIR
This statement is in error. The Little Brown Church
is visible from Highway One, as is the adjacent
Salada lot. This is why the Pacifica Historical
Society has chosen the Salada lot facing Francisco
as the ideal location for the refurbished Ocean
Shore Railroad Car. Please revise this section as
required per actual analysis of what is visible from
Highway One.

Due to its location, taller buildings would not obscure this view to LBC. This is a minor correction made to
clarify and does not affect the findings of the DEIR.

The following change is thereby made: "No historic
buildings, ridgelines, views of the ocean, or other
scenic resources are visible from Highway 1 where it
traverses the Planning Area. The historic Pacifica
Coastal Museum is visible from Highway 1, but it
fronts the freeway, and no development would occur
in front of the structure that would obsctruct views to this resource."
C13-
24 Christine
Boles
3/8/22 25. I also asked previously in my comment letter #4 whether NCCWD currently has the fire capacity
to serve 5 story buildings in this area as they will
require different equipment than needed for 3
story buildings. Please confirm. If new equipment
Analysis pertaining to whether the implementation of
the Proposed Project will impair implementation of or
physically interfere with an adopted emergency
response plan or emergency evacuation plan is
discussed under criterion 3.11-6, specifically on pages

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is needed, please confirm the city has the financial
resources to make these basic infrastructure
improvements before this General Plan and Sharp
Park Specific Plan are adopted

3.11-21 to 3.13-23. The Safety Element of the General
Plan provides policies that address conformance with
local emergency response programs and continued
cooperation with emergency response service
providers. For example, proposed Sharp Park Specific
Plan policy 6-I-4 states that the plan will "Work with
PFD to ensure fire services have the capacity to serve
four- and five-story buildings prior to construction of buildings of that height."
C13-
25 Christine
Boles
3/8/22 26. I have not had a chance to review the Historical Preservation section of the GP or DEIR, but I would
like to see some explanation of how these
important resources are protected in the Sharp
Park Specific Plan. Several sites along Palmetto
that are being rezoned to Mixed Use Center
currently house these vibrant buildings and
gardens that are important to the community and
that are well used, and that speak to our history as
a town. Here are three for example. Wouldn’t the
economic value added by increasing density to 5
stories entice developers to tear down these
treasures that contribute to this unique and
desirable shopping area now?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C13-
26 Christine
Boles
3/8/22 27. Traffic and Parking Exceptions
Many residents complain that parking is very
difficult in this area now, especially on sunny days,
which are more numerous now with limate
change and reduction in coastal fog. Page 3.14 of
the DEIR talks about parking in Sharp Park and yet,
it only mentions observations, not a real study that
was done. Please confirm.

This comment is noted. Parking is not a topic of
required analysis under CEQA. The comment is not
related to the adequacy of the DEIR, therefore no
further response is required in the FEIR. However, the
comment addresses the content of the Proposed Plan
and will be shared with decision-makers in that
context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related
responses.

C13-
27 Christine
Boles
3/8/22 Dyett and Bhatia’s contract, it seems a parking
study of the area was an optional service. Was the
option taken and the additional fees for this
important study approved? I have not seen that
study in the DEIR documents. Please provide it so
we can understand these impacts under CEQA.

C13-
28 Christine
Boles
3/8/22 28. Page 3.4.31 of the DEIR under Energy and
Greenhouse Gases says that reduced parking
requirements in Sharp Park are being used to
actively discourage cars in the area. While I
applaud the goal, the fact is that we do not
currently have any reasonable public
transportation in the area. Please show where this
proposed policy was discussed at community
meetings to get input on the SPSP. I have
informally polled community members on the
subject on Facebook and local residents are livid
that reduced parking requirements are even being
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

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considered. Be prepared for pushback from the
community on these assumptions.

C13-
29 Christine
Boles
3/8/22 At this point, with all these unanswered questions about the Sharp Park Specific Plan, I would really
question whether this is the best location to focus
most of the the city’s attention and funding for
redevelopment as part of the General Plan. The
new sea wall for this area also has major hurdles
to clear before it can even be considered, and
even if it somehow clears the environmental and
technical review by the Coastal Commission,
funding sources for such an expensive project are
uncertain at best. I strongly suggest that the city
expand its focus for this General Plan for
redevelopment and increased density to include
other areas of town that are less burdened.

For example, I am really puzzled why the Fairmont
Area has not been included in this plan for
increased density as it is on a high value transit
corridor on Highway 35 which does not impact
already burdened traffic in the rest of town. This
area has already been identified in Plan Bay Area
2050 as a Priority Development Area, which I
understand means that local and state funding
grant opportunities are available for
redevelopment. See below.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

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C13-
30 Christine
Boles
3/8/22 In my opinion, the very first step needed now in this process is to update our DEIR sections about
safety, including landslides, sea level rise, coastal
erosion, fire, flooding, greenhouse gases, etc. so
we understand our hazards. Vulnerability
assessments as required by SB379 must also be
prepared for the entire city, not just the coast, to
understand our changing environment with
climate change.

All hazard analysis and description of potential
impacts required under CEQA is present in the DEIR,
including landslides (Impact 3.6-1), erosion (Impact

3.6-2), wildfire (Impact 3.11-4 and 3.14, 1-4), flooding (Impacts 3.5, 3-4), and greenhouse gases (Impacts 3.4,
1-4). Please see response to comment C22-10 for
more information about adequacy of hazards mapping
and data sources; C69-8 for information about coastal
erosion; C13-3 for more information about sea level
rise and flooding, and Master Response 5: Wildfire for
wildfire analysis adequacy. The San Mateo County MJLHMP, incorporated by reference in many DEIR sections, includes information on how climate change
may exacerbate hazards in accordance with SB379.

Regarding sea level rise and climate change, the City of Pacifica received a Local Assistance Grant from the
California Coastal Commission (CCC) and California
Coastal Conservancy, which provided funding to the
City of Pacifica to hire a consultant to conduct
technical analyses and prepare a vulnerability
assessment and adaptation plan. The City Council
approved and adopted Coastal Resiliency Policies in
2018. These policies are included as part of Chapter 8, Safety, and in Chapter 6, Coastal Resiliency, of the
LCLUP.

C13-
31 Christine
Boles
3/8/22 Then we need to update the DEIR for the actual
scale of the Proposed Project under this General
Plan, which must consider the 1892 units allocated
to us under RHNA at a minimum. We can
simultaneously begin work on the Housing
Element update which is due by January 2023 so
we can get to work to find appropriate sites for
these units, about half of which need to be
affordable and out of harms way. Then we can
have a General Plan that can comprehensively
guide us for the next 20-30 years.

Please see Master Comment: Buildout and RHNA for
more information on RHNA numbers and adequate
description of project buildout

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C14: William Leon, 3/3/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C14-1 William Leon 3/3/22 Today, March 3, 2021, I dropped of my comment letter and attachments to the letter. It's addressed to you and was received at the front desk; I was told it
would be stamped received and dated. I have
attached digital copies of the letter and the
attachments that I dropped off. Please confirm that
you received the letter and attachments.

No response necessary. Comment followed by 128
pages of Appendix items.

C14-2 William Leon 3/3/22 RE: City of Pacifica General Plan Update (GPU) and Local Coastal Land Use Plan (LCLUP) and 2022 Draft
EIR for the GPU Comments
Dear Mr. Murdock, I am writing to point out specific
areas where information in the LCLUP and General
Plan Update are inconsistent and/or missing, and
need to be corrected for the public and decision
makers to understand the impacts of the Project.

1. Sensitive and Critical Habitat
• GPU Figure 7-3, Potential Environmentally Sensitive
Habitat Areas
• 2022 Draft EIR Figure 3.7-3 Sensitive and Critical
Habitat
• 2020 LCLUP Figure 4-3, California Coastal
Commission, Staff Report 2-18-21 CDP Application 2-
19-0026 In reviewing these Figures, I noticed
inconsistency and omissions with areas described in
the Figures as:

A. Potential Environmentally Sensitive Habitat Areas
(ESHA)
B. Critical Habitat: California Red-legged Frog
C. Other Sensitive Areas:

1. High Habitat Value/Threatened by Fragmentation

2.Wildlife Movement Corridor

2. Inconsistencies:

A. Neither GP Figure 7-3 nor 2022 Draft EIR Figure

3.7-3 show California Red-legged Frog listed under
Critical Habitat as shown in Figure 4-3 at Laguna
Salada (Sharp Park Golf Course) and Mori Point
(GGNRA).

The EIR used best available from State and federal
sources. Figure 3.7-3 of the DEIR uses data
established under Critical Habitat for Threatened
and Endangered Species, U.S. Fish & Wildlife
Service. This figure also shows potential
Environmentally Sensitive Habitat Areas (ESHA)
and Wildlife Movement Corridor areas. Figure 3.7-
4 of the DEIR shows where Special Status Species
habitat may be located, which shows the CRLF
habitat at Laguna Salada and parts of Mori Point,
and is not a federally-established Critical Habitat.

The DEIR contains policies to address impacts in
the event that sensitive species are discovered
during construction or pre-construction as
outlined in Master Response 6: ESHA and other
State regulations, like from the California Coastal
Commission, would apply.

C14-3 William Leon 3/3/22 B. Neither GP Figure 7-3, 2022 Draft EIR Figure 3.7-3 or Figure 4-3 show 1) Sensitive and Critical Habitat at the undeveloped field adjacent to San Pedro Avenue,
or 2) the unnamed Waterway that runs from San
Pedro Avenue and eventually connects to San Pedro
Creek. Instead, GP Figure 7-3 and 2022 Draft EIR
Figure 3.7-3 show the undeveloped field adjacent to
San Pedro Avenue designated as Urban and NonUrban Land with Little or No Habitat Value. Figure 4- 3 shows no designation of either Potential ESHA or
Critical Habitat for the undeveloped field adjacent to
San Pedro Avenue.

Figure 7-3 of the General Plan and Figure 3.7-3 of
the DEIR uses data established under Critical
Habitat for Threatened and Endangered Species,
U.S. Fish & Wildlife Service. This figure also shows
potential Environmentally Sensitive Habitat Areas
(ESHA) and Wildlife Movement Corridor areas.

Figure 3.7-4 of the DEIR shows where Special
Status Species habitat may be located, which
shows the CRLF habitat at the vacant San Pedro
site. This is not a federally-established Critical
Habitat.

C14-4 William Leon 3/3/22 3. Omission of Potential ESHA and Critical Habitat Information Possessed by the City.

Neither GP Figure 7-3 nor 2022 Draft EIR Figure 3.7-3
nor the narrative discussions within the documents
Please see Master Response 6: ESHA for more
information on how compliance with federal,
state, and local regulations, in addition to
Proposed Plan policies, reduce impacts to less than

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consider the studies, statements and the decision of
the California Coastal Commission (“CCC”), which
found the undeveloped area adjacent to San Pedro
Avenue to contain ESHA and the unnamed waterway
to be considered as Waters of the United States.
significant, regardless of the final determination.

The Army Corps of Engineers has not made a final
determination of environmental significance to the
site.

C14-5 William Leon 3/3/22 Furthermore, this CCC delineation showed that the adjacent watercourse that runs along the western
edge of the undeveloped San Pedro Avenue site
constitutes areas of both federal and state wetlands,
with the state wetlands spanning the full length of
the watercourse, thus comprising the entire length of
the San Pedro Avenue property’s western boundary.

See Pages 6-12: California Coastal Commission, Staff
Report 2-18-21, CDP Application 2-19-0026:

See response for C14-4
C14-6 William Leon 3/3/22 Both the Coastal Act and the LCP, as guidance, emphasize the need to protect sensitive habitats
within the coastal zone, including wetlands and
environmentally sensitive habitat areas (ESHAs). In
communication with the City of Pacifica, Coastal
Commission staff expressed concerns going back
over a decade with regard to potential impacts of
development on the habitats located on and
adjacent to undeveloped San Pedro Avenue site,
indicating that any proposed development at the
undeveloped San Pedro Avenue Site should consider
measures to avoid or reduce potential impacts on the
adjacent unnamed watercourse, which most likely
would meet the one-parameter definition of
wetlands under the Coastal Act, and stating that a
one-parameter wetland delineation should be
conducted (see comments in Exhibit 6).

Despite the CCC recommendation to conduct a oneparameter wetland delineation at an earlier stage in the process, a delineation undeveloped San Pedro
Avenue site and adjacent drainage channel was not
prepared for this project until November 2019, after
the City of Pacifica had already approved a local CDP
for the portion of the project located in their CDP
jurisdiction. This delineation showed that the
adjacent watercourse that runs along the western
edge of the undeveloped San Pedro Avenue site
constitutes areas of both federal and state wetlands,
with the state wetlands spanning the full length of
the watercourse, thus comprising the entire length of
the western boundary, undeveloped San Pedro
Avenue site. On the northern end of the property,
the federal and state wetlands encompass an
approximately 0.096-acre arroyo willow thicket that
partially extends onto the undeveloped San Pedro
Avenue site and takes up approximately 0.048-acres
at the northern border of the(see delineation
undeveloped San Pedro Avenue site of these features
in Exhibit 5). The federal and state wetlands present
onsite include arroyo willow thicket, perennial rye
See response for C14-4

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Packet Pg. 768 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 104
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Individuals (C)
grass fields, small-fruited bulrush marsh, smartweed
patch, the flow channel, and the wetted watercourse
channel.

During an initial assessment of the project-related
biological information, Commission staff ecologist Dr.

Lauren Garske-Garcia identified for the Applicant
that the Commission typically applies a minimum
wetland buffer of 100 feet. Examining the site-
specific circumstances associated with the property
known at that time, Dr. Garske indicated that the
minimum possible justifiable wetland buffer, if
appropriately mitigated, would be 50 feet from the
edge of the arroyo willow thicket and 25-feet from
the remainder of the state wetlands that comprise
the entire length of the drainage channel along the
property’s western edge. The Applicant submitted
revised plans in response to this feedback; however,
the revised plans did not adhere to these buffer
minimums and continued to propose development
within this already reduced buffer area.

After further research in response to the Applicant’s
updated submittals and, while Commission staff and
the Applicant were in further discussions regarding
the ESHA and wetland buffers, interested parties
provided information documenting the presence of
California red-legged frog in the watercourse area.

California red-legged frog (Rana draytonii; “CRLF”) is
a California special-status species and a federally-
listed threatened species due to loss and degradation
of habitat, predation, and human disturbance. CRLF
are known to occur in San Pedro Creek, which is
connected to the unnamed watercourse by a culvert
on the northern end of the parcel, near the arroyo
willows. As such, Dr. Garske-Garcia, along with
consulting reports that she reviewed, considered the
site in question to have moderate potential for CRLF
upland habitat and watercourse use, which extends
the full length of the property along the western
edge (see Exhibit 5). However, Dr. Garske-Garcia also
recognized the degraded state of the undeveloped
San Pedro Avenue site and adjacent watercourse as
relatively unfavorable when compared to nearby
habitats, and no published record had appeared
documenting CRLF at this location.

Subsequently, Commission staff received
documentation from multiple Pacifica residents,
including from a San Francisco State University
ecologist, in April 2020 demonstrating positive
observation of more than one CRLF, including time-
stamped photographs from various dates in April
showing as many as five CRLF at the same location at
one time (see Exhibit 9). In addition, Commission
staff received letters written by local biologist Peter

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Packet Pg. 769 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 105
Letter Commenter Date Comment Combined Response
Individuals (C)
Baye (dated May 4, 2005 and July 7, 2014) that
report ongoing observations of CRLF at the location
over a sustained period of time (see Exhibits 7 and 8).

Altogether, this evidence points to the watercourse
area adjacent to the San Pedro Avenue site as being
used by CRLF more than just a single frog passing
through, and the information provided to the City of
Pacifica and the CCC indicates that undeveloped San
Pedro Avenue site is used as CRLF aquatic and/or
dispersal habitat. While the Applicant’s consultant
argued that the location is unlikely to provide
“consistent, stable long-term habitat for [CRLF] over
time,” CRLF does not have to carry out its full life
cycle in the watercourse area itself for the area to
have ecological value for this sensitive species. Dr.

Garske-Garcia consulted with California Department
of Fish and Wildlife (CDFW) and U.S. Department of
Fish and Wildlife (USFWS) on this matter, and CDFW
confirmed that the information received by the CCC
in April was valid, including the species identification.

USFWS did not have the 2005 Peter Baye record
available digitally but indicated it was likely available in their hard files; however, USFWS staff was not
surprised by the recent observations and provided
information on recent CRLF observations from
nearby San Pedro Creek.

In short, the watercourse running adjacent to the San
Pedro Avenue site constitutes part of a larger habitat
corridor for CRLF. In addition, the watercourse
adjacent to the San Pedro Avenue site likely also
supports several other species as a habitat corridor,
as it remains green throughout the seasons and
compared to adjacent parcels, and connects to San
Pedro Creek, the shore, the Pacific Ocean, a large
open space to the west, and a major forested area.

Although there have been recent development
encroachments, the watercourse provides a
connection across the landscape capable of
supporting species including birds and small
mammals. The Coastal Commission consistently finds
this type of important and vulnerable habitat to be
an ESHA due to the rarity of the physical habitat and
its important ecosystem functions, including that of
support for sensitive species, as found in this case by Dr. Garske-Garcia. Thus, the drainage channel
adjacent to this site is considered ESHA under the
Coastal Act. In addition, per Dr. Garske-Garcia’s
advice (see Exhibit 11,Page 11), Commission staff
also concluded that the arroyo willow thicket, as well
as the small-fruited bulrush marsh both constitute
ESHA, and would recommend a buffer of 50 feet at
these locations as well. Coastal Act Section 30240
and LUP Policy 18 prohibit non-resource dependent
development within ESHA, prohibit any development
in ESHA that would significantly disrupt habitat

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Packet Pg. 770 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 106
Letter Commenter Date Comment Combined Response
Individuals (C)
values, and prohibit any development in areas
adjacent to ESHA that would significantly degrade
those ESHA areas. In addition, Coastal Act Section
30231 protects the biological productivity of coastal
streams and wetlands. According to Lief Gould, the
USFWS biologist for this region, the USFWS would
typically recommend a 300-foot dispersal corridor
around similar occupied CRLF habitat. Considering all
this and applying a 300-foot corridor (i.e., where the
area within the corridor constitutes ESHA due to its
CRLF habitat functions), Dr. Garske-Garcia
determined that the subject property is all ESHA, and
that no level of precaution could avoid the loss of
habitat with the proposed project. Even if the 300-
foot corridor were centered on the watercourse, it
would extend across and beyond the subject parcel.

In addition, Dr. Garske-Garcia believes that the 300-
foot corridor is the minimum that is acceptable for
protecting this ESHA as required by the Coastal Act
and that a reduced corridor width is not appropriate.

The undeveloped San Pedro Avenue site is in ESHA, is
development which is not a resource-dependent,
would significantly disrupt habitat values. As a result, development of undeveloped San Pedro Avenue site
was found inconsistent with Coastal Act Section
30240. In addition, and for similar reasons, the
proposed project is also inconsistent with Coastal Act
Section 30231 and 30233.

C14-7 William Leon 33/3/22 In short, the portion of the San Pedro Avenue site within the Commission’s permitting jurisdiction is all
ESHA and undevelopable for the proposed range of
uses and structures. Although some provisions in the
LCP allow for reductions to habitat buffers in the
event that the buffer renders the site undevelopable,
in this case it is the actual ESHA area that is affected by development (and not the buffer from it), and the
City has approved development in the portion of the
property that is within its jurisdiction and subject to the LCP. The CCC found that there is no location on
the part considered in undeveloped San Pedro
Avenue for development, outside of ESHA and
sufficient to protect the habitat, as required by the
Coastal Act. And, as such, there aren’t siting and
design conditions available to the Commission to
correct this Coastal Act inconsistency. Therefore, the
CCC found the proposed project inconsistent with
the Coastal Act’s sensitive habitat protection
requirements cited above, requiring project denial.

At this point however, these buffer
recommendations are moot since the entirety of the
site constitutes ESHA and are constrained regarding
allowable development because of that
determination. Considering all of the facts present, I
hereby request that the City of Pacifica correct and
See response for C14-4

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Packet Pg. 771 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 107
Letter Commenter Date Comment Combined Response
Individuals (C)
update its relevant documents, in both the GPU, the
LCLUP and the 2022 Draft EIR, to accurately reflect
what is currently known about the location and
designation of places with Sensitive and Critical
Habitat and Potential Environmentally Sensitive
Habitat Areas. Especially, as it relates to the
undeveloped lands and waterway adjacent to San
Pedro Avenue in Pedro Point.

1.f
Packet Pg. 772 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 108
C15: Allison West, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C15-1 Allison West 3/8/22 I have lived in Pacifica for 19 years and over 5 in Pedro Point. The unique natural beauty, access to
the ocean, views of surrounding hills, mountains
and valleys, access to coastal and hillside trails,
along with the natural habitat seen in the Pedro
Point neighborhood, make this a special place to
live.

For decades, the issue of the land use designation of
the San Pedro Ave Field (“Field” and formerly called
the Pedro Point Field or Calson Field) has come
before the City. For over a decade the PPCA, on
behalf of the residents in this area, has made
consistent efforts to help educate the City Council,
Planning Commission, and your office about the
proposed land use designation and its detrimental
impact to our neighborhood. I am writing to state
my urgent and vehement objection to the
GPU/DEIR’s proposed new land use designation of
“Coastal Residential Mixed Use” (CRMU) for the
undeveloped Field site in the Pedro Point
neighborhood.

I also incorporate by reference each of the impacts
and concerns noted in my comment letter to you in
my role as the President of the Pedro Point
Community Association. Below are just a few of the
significant impacts and concerns:

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C15-2 Allison West 3/8/22 1. Traffic/Parking/Pedestrian Risks Our neighborhood is a magnet to those who love
the beach to surf, relax, grab a coffee, burger, or
other delights as they enjoy the hiking trails and
beach. Except, our neighborhood is not equipped
right now for those who drive to Pedro Point. Our
area becomes congested with increased street
parking (all the way up to my house (across from
the cat clinic) and a substantial increase in
pedestrian traffic. We have no sidewalks; the roads
are in places uneven, and this creates more hazards
as we navigate our way around cars and the
increase in foot traffic.

The change to CRMU and any potential building in
the Field would make the traffic and parking
untenable for the residents. Adding another 100+
vehicles during the workweek would create traffic
issues of monumental proportions just to get to
Highway 1. Importantly, the issue related to the
emergency vehicles struggling to make their way on
our narrow one lane San Pedro Ave creates safety
concerns that the City has neglected to address. On
top of this, the increased traffic would also have
The comment is noted. Congestion is not a required
topic for CEQA analysis and the DEIR correctly analyzed and mitigated VMT impacts on pages 3-40 to 3-43. As
discussed in Impact 3.2-4, project level review required by the City includes site access review for emergency
vehicles and traffic control plans as needed that
account for emergency vehicles. Thus, new
development would be required to comply with
Municipal Code requirements for emergency access to
the site and LHMP and Emergency Plan
implementation will reduce impacts to the maximum
extent practicable. In addition, new development
would be subjected to policies listed under Impact 3.2- 4 as well as the existing programmatic framework to
reduce impacts of evacuation to less than significant
level. See also Master Response 7: Emergency Access
for more information about evacuation.

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Packet Pg. 773 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 109
Letter Commenter Date Comment Combined Response
Individuals (C)
related air quality issues that the City has failed to
note as an impact.

C15-3 Allison West 3/8/22 2. Significant adverse aesthetic impact:

From my porch and front room, I can see the Field
which provides me, my son, and our community
with beautiful, scenic views. There is a natural flow
of seeing trees, the open space, the wildlife there,
and we enjoy seeing our neighbors walking in and
around the Field each day. We moved here because
we and those who visit us enjoy seeing the scenic
views of the surrounding hillsides and use the easy
access footpaths to get to the beach. The proposed
CRMU designation would not only ruin the aesthetic
enjoyment of the field for my family, but for our
neighbors and visitors to our community as well.

Any foreseeable development would absolutely
degrade the existing visual character of the
neighborhood.

The DEIR analyzes scenic vistas on page 3.9-14 through

3.9-22. Typically, scenic vistas would include mountain ranges, ridgelines, or bodies of water as viewed from a highway, public space, or any other area designated
for the express purpose of viewing and sightseeing.

The view from the commentator is not a scenic vista
(not along a coastal view corridor, have any prominent
ridges or prominent landforms as seen on Figure 3.9-
1).

The land use changes in the Proposed Project will not
substantially degrade the existing visual character or
quality of Pacifica and would not conflict with
applicable zoning and regulations governing scenic
views.

The DEIR also has regulations and policies that would
further reduce an already less than significant impact
on scenic vistas on pages 3.9-19 through 3.9-22.

C15-4 Allison West 3/8/22 3. Significant adverse biological impact:

Like most who live on Pedro Point or those who
come to visit here, my family has long enjoyed the
diversity of wildlife we’re able to observe in and
around the Pedro Point field. Walking the
neighborhood by the Field we can see a variety of
birds and walk by the Red Legged Frog habitat
which was confirmed by the California Department
of Fish and Wildlife (please review the California
Coastal Commission rejection of the Rhodes
project). We have seen coyotes, deer, mountain
lions and a wonderful variety of birds. All
development from the proposed CRMU designation
would irrevocably harm the wildlife, the natural
habitat, and our enjoyment of this treasured
neighborhood environmental asset.

The San Pedro site (field) is not considered to be a
federally-protected Critical Habitat. Occurrences of
red-legged frog on the site are noted in Figure 3.7-4.

Please see Master Response 6: ESHA for more
information about how compliance with federal, state,
and local regulations, in addition to Proposed Project
policies, reduce impacts to less than significant. Please also see Master Response 4: Undeveloped San Pedro
Ave Sites and Master Response 2: Programmatic EIR
for more information on how site-specific biological
study would reduce potential impacts. Please also see
response to comment C159-1.

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Letter Commenter Date Comment Combined Response
Individuals (C)
C15-5 Allison West 3/8/22 4. Significant adverse flooding impact:

The Field is designated by the City as a tsunami
evacuation area. The Field sits at the lowest part of
Pedro Point which means it is a catch basin from the
rain runoff. My neighbors have provided pictures
showing that the field turned into a lake during the
October atmospheric river event.

As shown on Figure 3.5-1, page 3.5-3 of the DEIR, the
site is not in a FEMA identified special flood area,
however it is subject to localized floods as noted on
page 3.5-8 ‘The broadest mapped flood hazard areas
are located along San Pedro Creek, covering much of
the Linda Mar area north of the creek extending down
to the coast. A broad 0.2 percent annual chance flood
area is mapped at the confluence of the main stem
with the North Fork of the San Pedro Creek.’ Please
see also response to comment C13-3 for more
information about coastal flooding and sea level rise.

The Proposed Project would allow for mixed use
development, in event of development of the site, it
would be subject to regulations to prevent loss
life/property in the event of a tsunami. In addition to new policies, including SA-I-26, SA-G-2 SA-I-15, that
will further reduce the risk to less than significant and therefore the analysis in the DEIR is valid. See response to comment C13-9 regarding California Coastal Act
Regulations.

The comment also mentions that the field in Pedro
Point acts as a catch basin from the rain runoff. This
does not mean the development cannot take place
here. If development were to happen, the building/s
would have to follow several measures including - SA-I17, SA-I-19, SA-I-20, SA-I-22, SA-I-23, SA-I-25, SA-I-39, SA-I-40, SA-I-88, to decrease impact to a less than
significant level.

C15-6 Allison West 3/8/22 In conclusion, my family urges you to change the proposed land use designation for the Pedro Point
field from CRMU to Conservation (C) which is most
consistent with the current state of the
undeveloped property. A Conservation designation
would also address the many DEIR deficiencies
noted by the PPCA and their expert advisors and be
in compliance with CEQA and Coastal Act policies. It
would therefore be not only the most responsible
solution, but also the most expedient solution to
help move the GPU and DEIR approval process
forward.

Thank you in advance for considering our comments
and I urge you to preserve open spaces like the
Pedro Point Field, and for maintaining Pacifica’s
beautiful, natural assets to ensure our City’s future
as desirable coastal destination and a safe place for
all of us to live.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

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Packet Pg. 775 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 111
C16: Clifford Lawrence, 2/22/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C16-1 Clifford
Lawrence
2/22/22 Our DEIR Material Hazards does not include
reference to the Mussel Rock Landfill which
continues to present risk to nearby West Fairmont
properties in Pacifica and Daly City. By its
proximity it is a threat to all lower properties,
regardless of the municipal line. How do we justify
ignoring this obvious threat?
The Mussel Rock Transfer Station is located outside of
the City's jurisdiction. AS described in Impact 3.11-1, "Hazardous materials are regularly used, transported,
and disposed of in Pacifica.... these activities are subject to a variety of local, State and federal regulations.

Hazardous materials would be required to be
transported under DOT regulations. Future
development under the Proposed Project would be
subject to regulatory programs such as those overseen
by the Regional Water Quality Control Board and the
Department of Toxic Substances Control. San Mateo
County has substantial regulations concerning
hazardous materials under its Toxic Programs; for
example, all businesses in San Mateo County must
submit a Business Plan for the safe storage and use of
chemicals if the business handles and/or stores a
hazardous material equal to or greater than the
minimum reportable quantities. Compliance with
federal, State and local regulations, combined with
Proposed Project policies outlined below, will reduce
the potential for a significant adverse effect on the
environment, due to upset and accident involving the
use, transport, and disposal of hazardous materials, to a less than significant level.

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Packet Pg. 776 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 112
C17: Deb MacC, 2/14/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C17-1 Deb MacC 2/14/22 Increasing residential use is of importance to me.

I'd like to see the GP provide for an increase in
Medium Density Residential zoning, and for
policies to immediately encourage ALL residential
building to be multi-unit. For example in a
proposed development of 10 homes, 20 percent
would have common walls, ie: duet homes,
resulting in more open space for that immediate
development and for the public generally. I do not
want to see a gated community anywhere in
Pacifica. Maybe the GP should include that
exclusion.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C17-2 Deb MacC 2/14/22 Hillside Preservation design guidelines need to include additional emergency egress routes, even
if they exist on easements limited to emergency
use, which are otherwise open, wild space,
drainage routes etc. Fire safety exit routes must
be aggressively included in hillside planning
design.

The comment is noted. As discussed in Impact 3.2-4,
project level review required by the City includes site access review for emergency vehicles and traffic
control plans as needed that account for emergency
vehicles. Thus, new development would be required to
comply with Municipal Code requirements for
emergency access to the site and LHMP and
Emergency Plan implementation will reduce impacts to
the maximum extent practicable. In addition, new
development would be subjected to policies listed
under Impact 3.2-4 as well as the existing
programmatic framework to reduce impacts of
evacuation to less than significant level. Please see
Master Response 7: Evacuation Routes for more
information regarding emergency access.

C17-3 Deb MacC 2/14/22 I'd like to see the work focused on Sharp Park be reproduced in the Park Mall area of Pacifica.

Sharp Park's plan is a good one, Let's do it again,
modified as necessary, in another underdeveloped area of our town The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

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Packet Pg. 777 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 113
C18: Jim Louderback, 2/28/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C18-1 Jim
Louderback
2/28/2
2 Hi, given that the UN’s latest climate report
released today shows that sea rise is irreversible
and will inundate low lying land -
https://www.bbc.com/news/scienceenvironment-60525591
And that during a Tsunami, low-lying areas of
Pacifica are at extreme risk. This website for San
Mateo county -
https://www.conservation.ca.gov/cgs/tsunami/m
aps/san-mateo – at CA.Gov shows the hazard
areas in Pacifica, and particularly around Linda
Mar Beach.

In both situations, the field on San Pedro Avenue,
in between the Pedro Point neighborhood and
the Pedro Point Shopping Center should not have
anything built on it. I believe the plan is in error in how it treats this property. It will likely be flooded
during climate change over the next 10-20 years
and at any time with a Tsunami just slightly worse
than what we experienced on January 25th In
fact, our own city map shows that this is
extremely likely as well -
https://www.cityofpacifica.org/civicax/filebank/b
lobdload.aspx?BlobID=2499
Because of that, I would like to formally lodge a
comment to have this area excluded from any
building.

As shown on Figure 3.5-1, page 3.5-3 of the DEIR, the
site is not in a FEMA identified special flood area,
however it is subject to localized floods as noted on
page 3.5-8 ‘The broadest mapped flood hazard areas
are located along San Pedro Creek, covering much of
the Linda Mar area north of the creek extending
down to the coast. A broad 0.2 percent annual
chance flood area is mapped at the confluence of the
main stem with the North Fork of the San Pedro
Creek.’.

The Proposed Project would allow for mixed use
development, in event of development of the site, it
would be subject to regulations to prevent loss
life/property in the event of a tsunami. In addition to new policies, including SA-I-26, SA-G-2 SA-I-15, that
will further reduce the risk to less than significant
and therefore the analysis in the DEIR is valid. See
response to comment C13-9 regarding California
Coastal Act Regulations.

See response to comment C13-3 for more
information about coastal flooding and sea level rise.

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Packet Pg. 778 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 114
C19: Peter Loeb, 3/5/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C19-1 Peter Loeb 3/5/22 I reviewed the Pacifica General Plan Draft Environmental Impact Report (DEIR) released on Jan.
7, 2022, State Clearing House number 2020089010.

Subsequent to that DEIR, another DEIR was released
on Feb. 1 4, 2022. This new DEIR had a new State
Clearing House number, 2012022046, but with the
same publication date of Jan. 7. I compared the 2
DEIRs and there are differences between the
documents. The newer one now has a 12-page Table
Of Contents which the previous DEIR did not have.

The text of the newer DEIR is searchable; this was not
true of the previous DEIR. There are other differences
between the 2 documents. For example, the first DEIR
had a repeated section on Wildfires and the second
DEIR eliminates that section repeat. There may be
other differences but I don’t know because I can’t
compare two thousand-page documents, especially
when the text in one is not searchable.

In my attempt to compare the 2 documents, I
discovered that the earlier version is no longer on the city of Pacifica’s Plan Pacifica web site,
https://www.planpacifica.org/project-docs. I had
previously downloaded the earlier version of the
DEIR, so it is saved on my computer.

The result is that there are now 2 DEIRs for the
Pacifica General Plan and they are different. Which
DEIR should we be commenting on? If we should be
commenting on the DEIR released on Feb. 14, then
the comment period should be restarted from that
date. If we are commenting on the first DEIR, then my
comment is that document is unusable as published
and should be revised and recirculated. Furthermore,
the first DEIR appears to no longer be available
through the city’s web site. This means that the only
DEIR that we can review and comment on is the one
released on Feb. 14 (still with a Jan. 7 publication
date). This alone seems to require a new public
comment period.

Thank you for your comment. Per public request
the comment period was extended until March 8,
2022 to allow for additional public review time.

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Packet Pg. 779 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 115
C20: Andre Mettier, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C20-1 Andre
Mettler
3/8/22 Pacifica General & Sharp park Plan comments
Note: Quote from the paper are in black
My comments are in green
Questions are in red
The General Plan Must Be Internally Consistent.

This requirement means that the general plan
must fully integrate its separate parts and relate
them to each other without conflict.
“Horizontal” consistency applies both to figures
and diagrams as well as general plan text. It also
applies to data and analysis as well as policies.

The General Plan Must Be Long-Range.

I will try to point out a few inconsistencies and
follies towards that goal to encourage
reconsideration of the outlines
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-2 Andre
Mettler
3/8/22 Manor Drive Overpass! I really have a problem
with this one!
Quote: The Manor Drive overcrossing is planned to
be widened and coordinated signal control is
recommended to be added at the intersections of
Manor Drive with Oceana Boulevard and Palmetto
Avenue. This project includes a new on-ramp to SR
1 from Oceana at Milagra Drive. Table 5-6 And
here the projections for the project showing
NEGATIVE IMPROVEMENTS AFTER COMPLITION!!…
Quote Page 115 The intersections of Manor Drive
and Oceana Boulevard, and West Manor Drive and
Palmetto Avenue, and Paloma Avenue and Oceana
Boulevard may need to be modified in terms of
traffic control (traffic signalization), efficiency
(widening of the overcrossing to provide shoulders
and flaring curb returns without changing the
existing number of lanes), and Highway 1 access
(adding the Milagra Drive on-ramp). The City’s
planned improvements to the two intersections as
well as the overcrossing and Milagra Drive onramp as part of the Manor Drive overcrossing project will allow traffic to flow through the area in
a much better manner, by remaining on the
intended streets and reducing the diversion to side
streets and neighborhoods.

HELLO? Table 5-6 shows that the situation is
getting worse after the “improvements” but on
page 115 it says the traffic will flow much better..

Maybe someone can explain why we would go
through years of agony and huge expenses just to
arrive in a worse situation because I think it is a
costly stupid mistake to take on such a project but
The comment is noted. Congestion is not a required
topic of analysis under CEQA. However, the comment
addresses the content of the Proposed Plan and will be
shared with decision-makers in that context. Please see Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

1.f
Packet Pg. 780 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 116
Letter Commenter Date Comment Combined Response
Individuals (C)
maybe you can clarify a few questions.. · How long
will the project take? 2-3 years and totally destroy
the passage for that time?
· Since no lanes will be added how will the traffic
flow be improved?
· Signaling appears to be the answer, but the
bridge will still only hold 4-5 cars max if either end
is on red. Since we quite often have at least 20 or
more cars on Palmetto lined up going south to
make a left turn and sub sequentially quite a few
another left on Oceana to go north both lights
would have to be on green at the same time to
clear the bridge otherwise only 4 cars will make it
through the light IF the bridge is clear. Now if the
bus that is going east on the bridge trying to make
a right turn into Oceana he won’t be able to do
that because the light for the northbound Oceana
traffic is necessarily on red and the turning radius
does not allow the bus to turn till the fist or first 2 cars north bound have cleared that area which the
bus driver can indicate to the drivers to do now.

But with a red light in their way they will refuse to
do that since they are afraid of traffic fines which
this paper also encourages in order to support the
stated objectives. This is just one other problem
for just this scenario. Please keep in mind that now
all other flows on Manor, Palmetto and Oceana are
shut down. After the light change the people
picking their kids up at Ingrid Lacy school who
want to go up to Fairmont are in the same
situation having a need for clean passage, In the
meantime everyone else on Manor going east or
west and Oceana is waiting. I’d like to see an
engineering flow chart for the two intersection for
pm traffic. PLEASE. I believe in this case human to
human interaction is more productive than AI
imposed traffic rules & orders · Who is going to be
served by the new entrance to SR1 the Milagra
Drive onramp? How much traffic will be eliminated
on Manor?
C20-3 Andre
Mettler
3/8/22 Bicycles
Bicycle paths/trails, bicycle storage, bicycle
parking, bicycle safety and priority for bicycles
sounds all very good and healthy and progressive.

But who pays for it and what is the real benefit to
the whole community In a world of unlimited
resources anything can get paid for, but if we
already have instituted all kind of extra fees and
special tax assessments just to provide basic
services to operate like the fire department,
shouldn’t we ask how all this gets paid for and
what all of us get out of it except feeling good
when we vote for it?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

1.f
Packet Pg. 781 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 117
Letter Commenter Date Comment Combined Response
Individuals (C)
Is there anywhere a cost benefit analysis available.

C20-4 Andre
Mettler
3/8/22 CI-I-65 Parking Enforcement. Continue to make
parking enforcement a priority at public visitor
parking areas.

Since they have a hunch that their plans might
have some problems, they have to be enforced at
additional expenses
Are those tickets really the best 1000s of ways to
promote a cool and friendly city by the ocean?
Because that’s what it would take just to carry the
expense of a control officer..

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-5 Andre
Mettler
3/8/22 Public Traffic
In fact, only 14 percent of Pacifica’s employed
residents work locally. Page 105 Only about 1.5
percent of trips beginning or ending in Pacifica are
made using public transportation
CI-G-17 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. In particular,
advocate for the expansion of public transit
services and facilities to improve public access and
recreation opportunities along the coast. Reality
versus wishful thinking!
Could you please ask these consultants to come to
Pacifica from their place of business in Sacramento
with public transit for the next meeting at city hall
and tell us all in person why they would advocate
for such hair brained ideas?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-6 Andre
Mettler
3/8/22 Conclusion
Hiring the same urban planners for millions of $$
that have destroyed the historic and individual
character of other small cities as an alibi of “doing
something” is a grotesque and counterproductive
top down, one template fits all approach!
Monetizing “ a problem” does not necessarily solve
it, just makes it lucrative for a few.

What we are looking at is a typical, non
enthusiastic, bureaucratic and unimaginative
approach to a government imposed decree that
will stifle local and individual life in its core. The
study is presented by some principals hiring some
just out of school graduates to fill in an industry
produced template to fulfill an imposed
requirement to the detriment of us all I think we
should sue the planners for shoddy work and the
state agencies for imposing the requirement to
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

1.f
Packet Pg. 782 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 118
Letter Commenter Date Comment Combined Response
Individuals (C)
produce it and asking them to pay for the plans
themselves, present us with the options and let us
vote to see if we want to accept it! Amen
C20-7 Andre
Mettler
3/8/22 Sharp Park Specific Plan is a sham too; please see following pages for easy to notice inconsistencies
in the plan.

We like our quaint little neighborhood with
relatively easy beach parking. <> The alternatives
presented in SPSP demand another suburban mall
with overregulated parking, and congestion for
which we have to go in eternal debt to make it
possible and pay off . More money for the city
along with more expenses with a net zero benefit
financially BUT at huge environmental and social
costs for the community! = Another bridge to
nowhere messing up the scenery!
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-8 Andre
Mettler
3/8/22 LAND USE & HOUSING
What’s planned and what we are supposed to get
vs what we like! And this is what it looks like when
they say Ensure development honors the area’s
character, history, and coastal locale.
— Promote development of housing in mixed-use
settings, which accommodates residents of all
incomes, family types, and life stages. (page15)
Nobody would mistake that as a place in Tracy
since it has soooo much P-Town character?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-9 Andre
Mettler
3/8/22 The Sharp Park Specific Plan emphasizes a peoplescaled approach to development which will translate into a walkable, friendly, safe, and
appealing pedestrian realm. How did they get here
and where did they (the visitors and residents
living on the 5th floor penthouse) park if they are
allowed to come in with a car? Remember there
will not be any parking access from Palmetto only
on the side streets. What all the most popular,
quaint “downtown” areas with character have in
common is that they are low rise (max. 2 stories)
like in Bolinas, Burlingame, San Mateo ,etc. with a
variety of building styles <> NOT 4 or 5 story
monsters built to the property line trying to
suggest open space by having big window fronts as
demanded, looking like Santana Row So this this is
more what we like and want!
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-10 Andre
Mettler
3/8/22 3-G-12 Housing Opportunity. Support
development of a diverse range of housing
opportunities suitable for people of all incomes,
abilities, and stages of life. By charging
Development impact fees, Park In-Lieu Fee
(Quimby), Sharp Park Specific Plan Parking In-Lieu
fee up to $40,260 per space? <> That will make it
more affordable for all incomes? Really
This comment is noted. The comment does not relate
to the adequacy of the DEIR, thus no further response
is required.

C20-11 Andre
Mettler
3/8/22 MOBILITY & PARKING
Did they explain how an arterial like Palmetto with
2 bus routes will work/co-exist as a pedestrian
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of

1.f
Packet Pg. 783 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 119
Letter Commenter Date Comment Combined Response
Individuals (C)
zone?
General plan
-Arterials In Pacifica, arterials are classified as
roadways that are wider, accommodate higher
volumes of traffic, (4.1-Page 51) The main arterials
in the Sharp Park Specific Plan Area include
Palmetto Avenue, Oceana Boulevard, and Paloma
Avenue to the west of Highway 1.
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-12 Andre
Mettler
3/8/22 Parking?
Page72 The in-lieu fee, if approved for a
development project, would allow a waiver of offstreet parking requirements for an individual development and require payment of a per-space
fee (initially adopted at $40,260 per space and
indexed to increase annually) that would allow the
City to provide centralized off-street parking
facilities. Centralized parking facilities are another
strategy to “right size” parking and to achieve
other planning goals such as minimizing the
number of curb cuts along pedestrian
thoroughfares.

Could anybody point me to the suggested location
of the “centralized” parking facility please?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-13 Andre
Mettler
3/8/22 Figure 4-8:

Existing Parking, shows current weekday parking
mostly AND weekend parking full around the pier!
BUT the report concludes that as of 2021,
Pacifica’s current parking standards result in an
oversupply of parking relative to demand in Sharp
Park. The high cost of parking construction and
maintenance drives up the cost of housing and
reduces the supply of affordable housing. To
balance these parking issues, “right sizing,” or
converting the parking provisions to a more
appropriate or optimum level, helps to strike a
supply-to demand balance.

And again how many more million $ will they need
tell us exactly what right sizing means. And where
we put it!
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-14 Andre
Mettler
3/8/22 Table 4-4 Retail; Eating and Drinking
Establishments:

Three parking spaces for each 1,000 square feet of
gross leasable space. That will fill up about 3 tables
at a restaurant; all the other patrons are
encouraged to use the bicycle Is a hot date in biker
shorts on a cold, foggy July evening gonna be the
new thing or will the UBER driver have to use the
arterial roadway through the pedestrian zone to
drop guests off in a more conventional attire?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-15 Andre
Mettler
3/8/22 4-I-20 On-Street Parking Supply Management.

Manage on-street parking supply with an ongoing
strategy to generally have 15 percent of on-street
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of

1.f
Packet Pg. 784 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 120
Letter Commenter Date Comment Combined Response
Individuals (C)
spaces available for short-term parking to meet
needs of commercial patrons. When parking
availability falls below this threshold, consider first limiting free parking periods, then implementing
paid parking, and then pursuing other parking
supply management strategies, including addition
of public lots or structures. Figure 4-8 shows we
are already at 85% or above?! Where are the
additional lots again? Also, we need to hire 1-2
parking control officers, NO?
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-16 Andre
Mettler
3/8/22 2212 Beach Boulevard Uses.

Prioritize full-service hotel use at the 2212 Beach
Boulevard site. For any non-hotel project,
emphasize land uses that are of interest to visitors
and generate revenues for the City.

And all these visitors are getting there to the
attraction by taking Paloma Ave to the beach? The
Paloma Ave that is dedicated to get bicycle and
pedestrian improvements? Oh, Maybe Clarendon?
Uuups, that is another bicycle and pedestrian
heaven we cannot pollute with cars AND one way
the wrong way.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-17 Andre
Mettler
3/8/22 Page 143 …to the extent that bicycle and
pedestrian improvements reduce the need for
parking in the Specific Sharp Park Specific Plan
Area, it would be appropriate to spend fee
revenue on bicycle and pedestrian infrastructure
improvements. But then we hear that This new
residential development, when it occurs, as well as
new development elsewhere in the city, will
contribute to park impact fee revenue. If the
envisioned development does not materialize as
expected, associated impact fee revenue may not
be received by the City.

Do they take into consideration that
pedestrian/bicycles are commonly short distance
transportation <> trying to attract out of town
(car) business? So the whole concept that
pedestrian improvements reduce the need for
parking is just another assumption/wishful thinking
without any basis/foot notes. They pile one wishful
thought on top of the other into a circular, absurd
compilation to prove their assumptions possible.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-18 Andre
Mettler
3/8/22 Promote the addition of curb bulb-outs at street corners and midblock crossings to calm traffic,
plant street trees, and heighten pedestrian
visibility and comfort. And who will maintain/pay
for these doggie toilets?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

C20-19 Andre
Mettler
3/8/22 Page 137 – figure 7-12 shows a map of the outline of the storm flood & flood prone zone as well as
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the

1.f
Packet Pg. 785 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 121
Letter Commenter Date Comment Combined Response
Individuals (C)
the envisioned coastal erosion by 2100, 80 years
from now – Right smack overlapping the Sharp
Park Development. And what is the solution
according to the paper?
These maps are not a substitute for site-specific
erosion analyses but do show important
information necessary to make general planninglevel decisions about the vulnerability of portions of the Sharp Park Specific Plan Area.

How many more millions do they want to tell us
that a billion $ sea wall will be the solution in order not only just build our future under water
financially but actually and that we can fund it
with… Development impact fees Park In-Lieu Fee
(Quimby) Sharp Park Specific Plan Parking In-Lieu
fee up to $40,260 per space, Or maybe a special
lien/assessment on each lot in town for a million
$$ Sounds like a great way to bankrupt the whole
city when we get sued down the road because we
encouraged someone to build there and are
therefore liable for the losses. Can we get flood
insurance? How much per year? What have we
learned from Esplanade Ave?
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

1.f
Packet Pg. 786 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 122
C21: Gary Emich, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C21-1 Gary Emich 3/8/22 It's encouraging to see that after more than 40 years the Pacifica General Plan is being updated. Thank you
for overseeing this effort.

Below are my comments regarding the draft Pacifica
General Plan.

Preface
The purpose of the following comments, related
specifically to the Pedro Point Basin also known as the Pedro Point Field (PPF), is to:
1) Document the numerous sections throughout the
Pacifica General Plan Update (PGPU) that are
contradictory and do not adhere to Section 1.2,
General Plan Requirements, that stipulate: "the
general plan must fully integrate its separate parts
and relate them to each other without conflict"
(underline added). Refer to Part A - Sections Not
Integrated / Conflicting within the PGPU (below).

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

Please see Master Response 1: EIR Comments for
more information about GP- or SPSP-related
responses. Please also see Master Response 4:

Undeveloped San Pedro Ave Sites.

C21-2 Gary Emich 3/8/22 2) Highlight the sections of the PGPU that repeatedly and consistently underscore the inappropriateness
and unsuitability of the proposed PPF Coastal
Residential Mixed Use designation based on factors of
tourism, critical habitat, liquefaction and flooding.

Refer to Part B - Factors Documenting the
Inappropriateness and Unsuitability of the PPF as
Coastal Residential Mixed Use (below).
3) Demonstrate, based on the PGPU's Land Use
definitions and descriptions, that the PPF should be
designated as either Visitor-Serving Commercial or
Low-Intensity Visitor Serving which is in keeping with
the California Coastal Commission's original March
24, 1980 certification of the PPF as Commercial
Recreation (see Background section immediately
following). Refer to Part C - Arguments for
Designating the PPF as Visitor-Serving Commercial or
Low-Intensity Visitor Serving (below).

Please see Master Response: San Pedro Avenue
Site, which addresses how CRMU is a compatible
land use with Coastal Act policies, and how
compliance with federal and state regulations, as
well as policies in the Proposed Project, reduce
impacts to sensitive species (see also Master
Response 6: ESHA), liquefaction, and flooding risks
to less than significant levels.

C21-3 Gary Emich 3/8/22 Background As reflected in the "Pedro Point Basin" section of the Pedro Point Community Association's
(PPCA) webpage (www.pedropoint.org/the-pedropoint-field), on March 24, 1980, the California Coastal Commission certified the PPF in the existing Local
Coastal Land Use Plan as Commercial Recreation (low
density, visitor-serving, commercially-viable
recreational uses). The Coastal Commission further
stated: "The designated land use for this area is
commercial with emphasis on coastal related and/or
visitor-serving uses... this small, ocean side
commercial center could be rejuvenated and
expanded to become an attractive visitor destination,
as well as provide for neighborhood retail needs.

Small scale, rustic design and ample landscaping
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

1.f
Packet Pg. 787 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 123
Letter Commenter Date Comment Combined Response
Individuals (C)
throughout the commercial development would
complement the existing attractive design elements in
the Pedro Point area. Adequate public access through
the development to the shoreline and a general
orientation to coastal related/visitor-serving uses
within the project would be appropriate in this
location. Given these criteria, commercial use of this
portion of the neighborhood is consistent with
the....policies of the Coastal Act." Also, as reflected in the "Pedro Point Basin" section of the PPCA webpage,
Pedro Point residents historically, repeatedly and
consistently have voiced their opinion and sentiments
pertaining to zoning changes and developments in the
PPF, e.g.
* 1995 Pedro Point Community Plan wherein
residents registered strong support for preserving a
major portion of the PPF in some form of open space,
* 2011 Letter "In Opposition to the Proposed Land
Use Designation Change" wherein the PPCA rejected
Pacifica's Draft General Plan Use (GPU) proposed land
use designation change, and recommended that it
adopt Commercial-Recreational , the designation
most similar to the existing land use.
* 2011 Letter "In Support of Commercial-Recreational
Use" wherein the PPCA voted for the PPF to retain its
current zoning of Commercial-Recreational which is
intended for land use that would remain in a primarily
undeveloped state but would allow for limited
commercial establishments supporting recre3eational
uses.
* In 2014, the PPCA unanimously voted to pool their
resources to hire experts and an attorney citing
deficiencies in the City's draft GPU and draft
Environmental Impact Report. The proposed land use
change did not pass; and the approved land use
designation remained Commercial- Recreational.

C21-4 Gary Emich 3/8/22 Part A - Sections Not Integrated / Conflicting within the PGPU
1) PGPU - page 2-5 and page 4-24
The photo in the lower right hand corner (showing
Pedro Point) on page 2-5 is captioned: "With its scenic setting along Highway 1, south of San Francisco,
Pacifica has potential for more tourismbased retail."
The photo on page 4-24 (depicting the residential
homes on Pedro Point sitting above Pacifica State
Beach) is captioned:
"The scenic Pedro Point neighborhood overlooks
Pacifica State Beach." Both photos and captions
create visions of a Pedro Point that lures tourists to a "visitor-serving, commercially-viable, recreational
use" destination and are inconsistent with the
proposed Coastal Residential Mixed Use designation.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

1.f
Packet Pg. 788 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 124
Letter Commenter Date Comment Combined Response
Individuals (C)
C21-5 Gary Emich 3/8/22 2) PGPU- page 2-7
"Tourist-oriented retail districts often succeed by
providing a unique mix of small-scale "boutique"
stores that offer arts, craft and other goods or
services with a distinctive local flavor....Pacifica could potentially focus on beach/coastal-related businesses,
drawing on its very name to help establish a strong
identity" (underline added).

This section likewise argues for maintaining the PPF's
original land use designation of CommercialRecreational (visitor-serving, commercially-viable, recreational uses) and, again, is inconsistent with the proposed Coastal Residential Mixed Use designation.
3) PGPU - Section 2.5 - Economic Development
Strategy - page 2-11
The first Guiding Policy under this section is ES-G-1,
Leverage Assets (page 2-12): "Leverage Pacifica's
coastal location...focusing on increasing tourism
facilities, including shops...and hiking trails."
Implementing Policies, ES-I-4, Increase Tourism (page
2-13): 1)" focus on attracting ...a visitor's center or other key attraction, tourism-based shopping...and 2)
"brand" and market Pacifica's parks, open spaces,
beaches and other natural amenities."
Implementing Policies, ES-I-34, Expanded Commercial
Recreation (page 2-17): "develop low-intensity
outdoor commercial recreation uses on sites near
Pacifica State Beach" (underline added)."
Implementing Policies, ES-I-35, Preserve the
Experience of the Natural Environment (page 2-17):
"ensure that new development projects do not
disrupt view corridors ..or otherwise interfere with
residents' and visitors' experience."
Implementing Policies, ES-I-36, Appropriate Site
Design (page 2-7): "ensure development projects
adjacent to protected natural areas are designed to
minimize impacts on those areas by employing low
impact development techniques." (As discussed later,
the waters along the south and east perimeters of the
PPF are home to a number of California Red-Legged
frogs.)
Thus far, all Implementing Policies of the PGPU noted
above support maintaining and arguing for the
retention of the PPF as a "visitor-serving,
commercially-viable, recreational uses" area and run
counter to any possible argument in support of new
residential units as the proposed Coastal Residential
Mixed Use designation would permit.

Further, despite the repeated and numerous
examples of the importance and viability of keeping
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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the PPF as a "visitor-serving, commercially-viable,
recreational use area," Figure 4-3, Land Use Diagram
(page 4-6), abruptly departs with a non sequitur by
listing the PPF as Coastal Residential Mixed Use
instead of the more appropriate Visitor-Serving
Commercial. Visitor-Serving Commercial (page 4-9) is
defined as "intending to foster and protect areas that
attract and cater to visitors, including...a visitor
attraction such as an interpretive center or
conference center..retail and services, commercial
recreation or other compatible uses. Whereas,
Coastal Residential Mixed Use (page 4-8) is defined as
....mixed-use with housing and retail and/or smallscale visitor-oriented commercial uses such as retail, vacation rental and time-share units...Sites may be
developed up to an overall density of up to 15 units
per gross acre (which in the case of PPF would be up
to 75 units).

This conflicts with and is not integrated with the
numerous other sections of the PGPU that advocate
and encourage development of areas such as the PPF
as visitor-serving areas.

C21-6 Gary Emich 3/8/22 4) PGPU - Section 6.2-Trail System - page 6-17 and Section 6.3 - Coastal Access - page 6-25
With the acquisition of the Colt Property, the PGPU
states (page 6-17): "it should be possible to construct a trail west of Highway 1 to extend the Coastal Trail
from its current terminus [at Ace Hardware]
southward through the Pedro Point Headlands to
connect with the Devil's Slide Trail."
Implementing Policies, OC-I-38 New Development
and Coastal Access (page 6-26): "Require that new
development along the coastline provide public
access from the nearest public roadway to the
shoreline and along the coast, and be designed to
minimize impacts to public coastal access and
recreation.

Ensure that impacts are mitigated through the
dedication of access or trail easements or the
provision of improvements to other public access
points."
Implementing Policies, OC-I-41, Impediments to
Public Access (page 6-26): "Prohibit restrictions on
public parking that would adversely affect public
access to beaches, trails, or other recreational lands
along coast."
As anyone who has attempted to find parking at
either the north or south end of the San Mateo
County's Devil's Slide Trail knows parking is at a
premium. Currently, there is only parking space for 15
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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vehicles immediately north of Ace Hardware that
allow for access to the Headlands; they are always
filled. And, the entire east side of San Pedro Avenue
across from Grocery Outlet is marked as "No Parking."
This existing situation is not in alignment with these
two Implementing Policies.

C21-7 Gary Emich 3/8/22 Section 3.3 Hillside and Coastal Development (page 3- 10), calls for: "the protection and enhancement of the
coastal environment, including its visual resources. As shown in Figure 4-8, Land Use, Pacifica /Southwest
(page 2-23), there are three "visual resources" on
Pedro Point. They are the old railroad berm north of
the PPF (site #25), at the Shelter Cove overlook (site
#26) and on the Pedro Point Trail in the headlands
(site #27).

Finally from page 4-27 regarding the PPF: "Future
development should include a small park and access
to the berm and the beach beyond. Completion of the
Devils Slide Tunnel project has provided the
opportunity to create a new trailhead and trails
through open space land on the headlands."
With authorization to build up to 75 residential units
on the PPF under the proposed Coastal Residential
Mixed Use designation, it is highly unlikely the two
Implementing Policies could be actuated, that the
three "visual resources" could be enhanced or that a
small park could be created with access to the berm
and the beach beyond. Designation of the PPF as
Visitor-Serving Commercial or Low-Intensity Visitor
Serving could ensure "dedication of access or trail
easements" (including but not limited to additional
trailhead parking for the Pedro Point Headlands
section of the Coastal Trail) as well as creation of a
"visitor attraction such as an interpretive center" and allow for the enhancement of the three "visual
resources."
Please see Master Response 4: Undeveloped San
Pedro Avenue Sites for more information about
development on this site.

C21-8 Gary Emich 3/8/22 Part B - Factors Documenting the Inappropriateness and Unsuitability of the PPF as Coastal Residential
Mixed Use
1) Tourism
As demonstrated above, developing PPF as a
residential site is inappropriate; and it conflicts with the PGPU, Section 1.4 Plan Themes and Key Initiatives
(pages 1-12 and 1-13) which calls for: "Creating 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
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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assets, creating more attractive places in visitororiented districts [and] marketing.

C21-9 Gary Emich 3/8/22 2) Critical Habitat
Figure 7-3, Sensitive and Critical Habitat (page 7-19)
showing California Red-legged Frog habitat
egregiously and erroneously does not designate the
PPF as sensitive habitat. There is a significant
population of California Red-legged frogs living in the waterway that begins at the intersection of Grand
Avenue and San Pedro Avenue and flows along the
eastern perimeter of the PPF. Guiding Policies, CO-G7: Wildlife and Critical Habitat (page 7-25) mandates:
"Conserv[ing] and protect[ing] indigenous,
threatened, endangered, and other special status
species by preserving critical habitat. Habitat can be
protected by allowing very limited or no
development, by identifying habitat areas as top
priorities for permanent conservation, and by
managing public land to ensure species protection
(underline added).

Permitting up to 75 residential units on the PPF is a
far cry from "allowing very limited or no
development" and is completely contrary to the cited
Guiding Policy above.

Critical habitat is an official designation made by the CDFW. The CDFW has not determined the PPF to be
an area of critical habitat as of the publication of
this DEIR. Please see Master Response 4:

Undeveloped San Pedro Ave Sites for more
information on policies that further limit
development through zoning, as well as additional
required biological study. Please also see Master
Response 6: ESHA.

C21-
10 Gary Emich 3/8/22 3) Liquefaction
Figure 8-1, Seismic Hazard Zones (page 8-4) shows a
very significant part of the PPF in a liquefaction zone.

As stated on page 8-5: "Medium liquefaction
potential exists in many low-lying neighborhoods,
including...parts of Pedro Point." And Figure 8-2,
Liquefaction Potential Zones (page 8-6) actually
classifies parts of the PPF at a very high risk of
liquefaction. And despite Implementing Policy, SA-I-2
(page 8-11) which clearly states: "Prohibit
development in areas of...high or very high
liquefaction risk, the PGPU ignores this policy in its
proposed designation of the PPF as Coastal
Residential Mixed Use. Simple common sense
questions the feasibility and sensibility of building
residential units in a liquefaction zone.

The comment is noted. The DEIR includes a robust
analysis of potential liquefaction impacts p. 3.6-25
and 3.6-26, noting "The impacts from ground
failure, including liquefaction, from development of
land uses associated with the General Plan would
be addressed through site-specific geotechnical
studies prepared in accordance with CBC
requirements and standard industry practices.

Subsequent development would be required to
conform to the current seismic design provisions of
the CBC to minimize losses from ground failure as a
result of an earthquake. These future projects
would also be required to adhere to proposed
General Plan policies that contain seismic safety
requirements and help strengthen existing code
requirements such as referencing known hazard
areas that must contain measures to resist ground
failure through modern construction techniques.

Therefore, the potential impact related to
seismically related ground-failure including
liquefaction is less than significant."
The undeveloped San Pedro Avenue site is in a
Seismic Hazard Zone, as shown in Figure 3.6 The
DEIR notes that on p. 3.6-18 and 3.6-19,
"Geotechnical investigations conducted within
Seismic Hazard Zones must incorporate standards
specified by the California Geologic Society (CGS)
Special Publication 117, Guidelines for Evaluating
and Mitigating Seismic Hazards". Policies addressing
use of maps include Policy SA-I-1: "Fault Zone. New

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development shall be sited and designed to
minimize risks from seismic events. Buildings for
human occupancy shall avoid surface traces of
active faults, consistent with the Alquist-Priolo
Earthquake Fault Zone Act and other relevant state
laws. (See the Seismic Hazards map, Figure 8-1). "
C21-
11 Gary Emich 3/8/22 4) Flooding
Figure 8-4, Flood Zones (page 8-15) designates the
entire PPF as a Tsunami Evacuation Area.

Implementing Policy, SA-I-26 Tsunami Evacuation
Zone (page 8-18) states: "For new development in the
tsunami evacuation zone, require use of low impact
engineering techniques, such as elevating structures
above projected water levels, to mitigate impacts to
people and structures." Suffice it to question whether
a tsunami evacuation area is conducive or suitable for
building new residential dwellings.

As shown on Figure 3.5-1, page 3.5-3 of the DEIR,
the site is not in a FEMA identified special flood
area, however it is subject to localized floods as
noted on page 3.5-8 ‘The broadest mapped flood
hazard areas are located along San Pedro Creek,
covering much of the Linda Mar area north of the
creek extending down to the coast. A broad 0.2
percent annual chance flood area is mapped at the
confluence of the main stem with the North Fork of
the San Pedro Creek.’.

The Proposed Project would allow for mixed use
development, in event of development of the site, it
would be subject to regulations to prevent loss
life/property in the event of a tsunami. In addition
to new policies, including SA-I-26, SA-G-2 SA-I-15,
that will further reduce the risk to less than
significant and therefore the analysis in the DEIR is
valid. See response to comment C13-9 regarding
California Coastal Act Regulations.

C21-
12 Gary Emich 3/8/22 Part C - Arguments for Designating the PPF as VisitorServing Commercial or Low-Intensity Visitor Serving The current Pedro Point residential area (excluding
the PPF and Shelter Cover), consists of about 250
single family residences and sits on approximately 55
acres (or fewer than 5 homes per acre). Most homes
have a partial, if not full, view of the Pacific Ocean and Pacifica State Beach. For decades, the open-space PPF
has been utilized by residents for recreation, as an
impromptu dog park and for passage to Pacific State
Beach as well as to the Coastal Trail.

As proposed, the designation of the PPF as Coastal
Residential Mixed Use would allow up to 75
residences to be constructed. This would increase the
total number of homes on Pedro Point by over 25% ,
all squeezed together in an area less than 10% the
size of the entire rest of the community. Such a highdensity infusion of homes in this relatively small parcel of land is completely out of character with the
rest of the Pedro Point Community.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C21-
13 Gary Emich 3/8/22 PGPU - Section 4.2 - Land Use Framework page 4-8:
"[the designation of Coastal Residential Mixed Use]:
"is intended for sites...with housing and retail, and/or small scale visitor-oriented commercial uses such as
retail, vacation rental, or time-share units. Residential uses are allowed in the same building as commercial
Please see Chapter 3.9 for more information on
impacts to visual resources. As described on DEIR p.

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uses above the ground floor [vertical mixed-use]."
Vertical mixed-use structures, including potential for
a large number of vacation rental and time-share
units, fundamentally would change the existing core
character of Pedro Point from one of single family
residences to one of a much higher density apartment
/ condo nature. And, if allowed, it would violate the
previously cited Implementing Policy, ES-I-35, which
states: "ensure that new development projects do not
disrupt view corridors...or otherwise interfere with
residents' and visitors' experience." Figure 4-8 (page
4-23) clearly depicts the view looking north from the
PPF as a "View Corridor." Allowing vertical mixed-use
structures in the PPF would effectively obstruct,
either partially or totally, the view of the ocean and
Pacifica State Beach for nearly half the residents on
Grand and Livingston Avenues and for a good number
of those on Sterling and Stanley Avenues.

Reinforcing the Coastal Commission's original 1980
vision for this parcel of land:
"The designated land use for this area is commercial
with emphasis on coastal related and/or visitorserving
uses... this small, ocean side commercial center could
be rejuvenated and expanded to become an
attractive visitor destination, as well as provide for
neighborhood retail needs. Small scale, rustic design
and ample landscaping throughout the commercial
development would complement the existing
attractive design elements in the Pedro Point area.

Adequate public access through the development to
the shoreline and a general orientation to coastal
related/visitor-serving uses within the project would
be appropriate in this location. Given these criteria,
commercial use of this portion of the neighborhood is
consistent with the....policies of the Coastal Act."
This description aptly describes a blend of the PGPU's
Visitor-Serving Commercial and Low-Intensity VisitorServing Commercial designation, both descriptions found on page 4-9. Visitor-Serving Commercial: [this]
designation is intended to foster and protect areas
that attract and cater to visitors, including...a visitor attraction, such as an interpretive
center...commercial recreation, or other compatible
uses. Low-Intensity Visitor-Serving Commercial: [this]
designation allows uses that create public access to
the coastal setting and are adaptable to changing
environmental conditions: ...concession stands,
warming huts, outdoor event sites and similar
uses....the long-term goal of transition to recreationoriented land uses." ensure there is no substantial adverse effect on
scenic vistas...The land use changes in the Proposed
Project will not substantially degrade the existing
visual character or quality of Pacifica and would not
conflict with applicable zoning and regulations
governing scenic views. All existing open space
areas are preserved and scenic resources are
protected under the Proposed Project. Policies,
zoning designations and design guidelines included
in the Proposed Project will sensitively govern the
formal characteristics of new development to
ensure they are compatible with existing
neighborhood character and quality The Coastal Act
requires scenic and visual qualities of coastal areas
to be considered and protected as a resource of
public importance.

The DEIR also has regulations and policies that
would further reduce an already less than
significant impact on scenic vistas on pages 3.9-19
through 3.9-22.

C21-
14 Gary Emich 3/8/22 Conclusion The PGPU's proposed designation of the PPF as Coastal Residential Mixed Use:

Habitat, liquefaction, and flooding are adequately
addressed in the DEIR. Please see response to

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* Is inconsistent with and contradicts other sections
of the PGPU that recommend different utilizations of
properties such as the PPF,
* Ignores the decades long sentiment of Pedro Point
residents who repeatedly have resisted changing the
land use designation from the original vision
articulated by the Coastal Commission,
* Does not acknowledge the inappropriateness and
unsuitability of this parcel as residential mixed use
based on factors of tourism, critical habitat,
liquefaction and flooding, and
* Would forever change the very fiber and unique
characteristic of Pedro Point.

I strongly recommend the draft PGPU land use
designation for the PPF is changed to either VisitorServing Commercial or Low-Intensity Visitor Serving in the final PGPU. Thank you for the opportunity to
share my comments
comment C21-10 for more information on
liquefaction impacts and coastal flooding. Please
Master Response 4: Undeveloped San Pedro
Avenue Sites, for more information about required
project-level analysis on the site, including for
biological resources.

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C22: Dinah Verby, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C22-1 Dinah
Verby
3/8/22 These are my comments on the General Plan (GP)
Update and associated Draft Environmental Impact
Report (DEIR). (I apologize for the helter-skelter
organization, but I worked on different parts over
time, and did the best I could to piece it together.)
Since I haven’t had time to review the complete
documents in depth, my comments primarily focus on
the Land Use, Open Space and Conservation Elements
of the GP and the Biological Resources section of the
DEIR, particularly as they relate to the Pacifica Quarry, which is located in the Coastal Zone.

I. General Comments:
• As others have commented, there are numerous
mis-labeled Guiding and Implementing Policies in the
DEIR. Many policies identified as mitigation for
impacts in Table ES-3 and elsewhere do not match the
correspondingly numbered policies in the GP. (Please
refer to comment and Excel spreadsheet from Pete
Shoemaker showing the many mislabeling errors.)
Since so many citations in the DEIR are inaccurate, the impact analysis is unreliable and it cannot be
determined whether the impacts are truly mitigated.

Please update and correct the DEIR so that it
accurately tracks the GP and recirculate the DEIR.

The comment is noted. Policies in the executive
summary will be noted in errata, however, policies
are listed in full in each of the Impacts chapters, so
analysis remains adequate and does not change any
findings of significance.

C22-2 Dinah
Verby
3/8/22 • The color-coded maps in the GP and DEIR are
difficult to interpret (especially the land use maps).

Many shades of colors are so close to each other that
one can’t determine what the true land use
designation is. For example, in GP Figure 4-7 (GP page
4-20) the color for “Conservation” is nearly
indistinguishable from that for “Open
Space/Agriculture/Residential.” The accompanying
text in the GP is often vague and does not describe the land areas with sufficient specificity. In other
instances, the text conflicts with the maps. (See “Map
Errors” below) Since the maps seem to be the primary
tool for guiding land use decisions, they should be as
precise and accurate as possible. Suggestion: Is it
possible to use another method such as assessor
parcel nos. and maps to identify the proper
designations?
Map edits will be made for clarity; they do not
change any findings of significance in the DEIR. Maps
are shown at the appropriate level for a
programmatic document; site-specific analysis would
occur on a project-level basis.

C22-3 Dinah
Verby
3/8/22 Map Errors: There are apparent errors in the following maps in the GP and DEIR.

Figure 3.7-4 in DEIR: Special Status Species: The map
legend does not match the map markings with regard
to California Red-legged Frog (CRLF) Habitat. These
areas are marked with red diagonal lines on the map,
whereas the legend uses a red and white dotted
pattern (which doesn’t appear anywhere on the map
that I can find). Please correct the legend so that it
corresponds with the diagonal markings on the map.

The comment is noted; the map legend will be
revised. This map change clarification does not affect
findings of significance.

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C22-4 Dinah
Verby
3/8/22 Figure 6-1: Parks and Open Space System (GP Page 6- 3)/DEIR Figure 3.12-2:

Rockaway Quarry: The GP at page 6-11 states that
portions of the Quarry are designated in Figure 6-1 as
“Partial Conservation with Development,” where
conservation areas should be determined based on
habitat needs and site conditions. However, Figure 6-1
contains no such designation. The Quarry uplands and
Calera Creek are shown as “Other Protected Open
Space,” while the remaining parts of the Quarry have
no discernable color code. The same error exists in the corresponding Figure 3.12-2 in the DEIR. Oddstad Park:

GP Page 6-3, Figure 6-1 (Figure 3.12-2 in DEIR)
indicates that District, Neighborhood and Pocket Parks
should be dark green. However, Oddstad Park is
shown as greenish-yellow. Please correct this so that it is solid dark green.

Cattle Hill & Pedro Point Headlands: Shows GGNRA as
the owner of the city-owned Cattle Hill property and
the Pedro Point Headlands (PPH). PPH is owned by the
City of Pacifica and the State of California (California Coastal Conservancy). It is uncertain whether GGNRA
will take title to either of these areas. Proposed
Changes: Delete “GGNRA” under Pedro Point
Headlands. Separate the cityowned Cattle Hill
property from GGNRA property on Sweeney Ridge.

These changes should be made on this and other maps
throughout the GP and DEIR, including: GP Figure 6-2
Trail System (GP page 6-16/DEIR Figure 3.12-3); GP
Figure 6-3 Coastal Access Trail (GP page 6-21); GP
Figure 6-4 Schools and Community Facilities (GP page
6-28/DEIR Figure 3.12-1) See also maps in the Land
Use, Conservation elements and many others that I
don’t have time to list.

Map edits will be made for clarity; they do not
change any findings of significance in the DEIR.

C22-5 Dinah
Verby
3/8/22 Figure 6-2 Trail System (GP Page 6-16/DEIR Figure

3.12-3):

Pedro Point Headlands: Shows "Pedro Point Trail” as a
proposed trail or trail improvement. The restoration
efforts of the Pacifica Land Trust Stewards have
completed the trails as mapped. Please mark the trails
as “Existing Trails.” Also, the completed Devil's Slide Trail should be shown as an "Existing Trail” rather than a proposed trail.

The comment is noted; the map text will be revised.

This map change clarification does not affect findings
of significance.

C22-6 Dinah
Verby
3/8/22 Figure 7-3 Sensitive and Critical Habitat (GP Page

7.19/DEIR Figure 3.7-3):

These maps fail to show the entire habitat of the
California Red-legged Frog (CRLF). Habitats in the
Coastal Zone such as Mori Point, the Quarry, and
Pedro Point are omitted. Additional habitats are
shown in DEIR Figure 3.7-4, page 3.7-24 and should be
included in Figure 7-3.

Official critical habitat is designated by the US Fish
and Wildlife Service. The locations this commenter
mentions are shown in DEIR p. 3.7-4, which shows
special status species occurrences.

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C22-7 Dinah
Verby
3/8/22 Typos:

GP Page 1-14: under “Non-Residential Development
and Employment” heading: “7,6310 jobs” should be
7,310 jobs.

GP Page 4-30 Table 4-3: There is a citation to footnote 4 which does not exist. Footnotes 1 and 2 do not
correspond to this table, and appear to belong with
Table 4-2.

GP Page 6-5, Table 6-1, footnote 4: “at 202
population” should presumably be “at 2020.”
GP Page 6-11, right column: “Harmony@1” is now
known as “Ohlone Point.”
The comment is noted. The text changes are
incorporated in the General Plan errata. They do not
relate to adequacy of DEIR analysis.

C22-8 Dinah
Verby
3/8/22 DEIR Page 3.7-18, Table 3.7-3: “Pacific” Ocean
misspelled. Under SOURCE: “Pacifica” misspelled.

DEIR Page 3.7-50: footnotes out of order and not
properly numbered.

DEIR Page 3.7-57: first full paragraph starting with
“Additionally” duplicates most of previous paragraph.

This comment is noted. The following edits are made
for clarity:

DEIR p. 3.7-18, Figure 3.7-3:The comment is noted;
the map text will be revised. (There is no Table 3.7-3) DEIR Page 3.7-50: The footnotes will be renumbered.

DEIR Page 3.7-57: "Additionally, if development or
any land use changes are to occur in or around a
river, stream, or lake then the project proponent
would be required at a minimum, to submit a
Notification of Lake or Streambed Alteration to
CDFW. Through consultation with CDFW, a Lake or
Streambed Alteration Agreement as per the
California Fish and Game Code Section 1600-1616
would be required. Typically, no new grading or
development at any site is allowed within 20 feet of
the edge of riparian vegetation or top of bank,
whichever is further from the creek centerline, as
delineated by a qualified, City-approved biologist."
These edits do not change any findings of
significance.

C22-9 Dinah
Verby
3/8/22 Hillside Preservation District:

I support the addition of new parcels to HPD, as shown
on Figure 4-4 (GP Page 4-12). I oppose the removal of
the Quarry flatlands from HPD, because this area is a
Potential Environmentally Sensitive Area as shown in
Figure 3.7-3 of the DEIR. It is therefore unsuitable for development and should be designated
“Conservation,” as explained below. Furthermore, it is
difficult to tell whether Figure 4-4 accurately lists all of the existing HPD parcels. Please carefully compare
Figure 4- 4 to the Zoning Maps to make sure that all
HPD lands are included.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

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C22-
10 Dinah
Verby
3/8/22 Create New Overlay Districts in Hazard Areas: I haven’t had the time to delve into the Safety Element in detail, but I will generally comment that the data and maps
regarding hazards such as fire, landslides, sea level rise and flooding are out of date and do not accurately
reflect current conditions. As a result, the DEIR
impacts analysis cannot be relied upon, since the
actual risks from these hazards is not disclosed in the GP. I understand that it is possible to create overlay
designations in the GP to mitigate against these
hazards and to protect valuable biological resources.

Examples are prohibiting new subdivisions, limiting
development to one unit per legal lot of record, and
requiring development to be transferred where
possible through mechanisms such as a Vehicle Miles
Traveled (VMT) exchange program and an updated
Transfer of Development Rights (TDR) program for
areas with inadequate evacuation routes and
hazardous conditions. Please update the GP to include
such overlay designations and also update the data to
reflect current conditions.

Risks of hazards are adequately described in the
DEIR, and the mapping uses the best and latest
available data to characterize hazards.

The DEIR characterizes wildfire hazards within the
Planning Area on pages 3.11-4 through 3.11-6 and

3.14-1 through 3.14-4, making use of data and
information from CALFIRE and from the MultiJurisdictional Local Hazard Mitigation Plan (MJLHMP) for San Mateo County. The characterization in the DEIR includes a description of vegetation in the
Planning Area, a history of wildfire occurrence in the
Planning Area, the probability of a fire occurring in
the future, and identification of Fire Hazard Severity
Zones designated by CALFIRE based on factors such
as fuel, slope, and weather. The data and information
referenced in the DEIR, including the data used to
prepare the above referenced maps, was the latest
and most current available at the time the NOP was
released and remains the most current available as of
publication of this FEIR. Please see Master Response
5: Wildfire for more information.

The most up-to-date mapping is represented in
Figure 3.6-1. The Landslide Zone data was released
by the Department of Conservation in 2021, the
authoritative source for mapping Zones of Required
Investigation. As noted in the map methodology, "As
a part of the geologic data compilation, an inventory
of existing landslides in the San Francisco South
Quadrangle, San Mateo County was prepared by
analysis of shaded relief maps (various illumination
directions) and contour data, limited field
reconnaissance, and a review of previously published
(Harding-Lawson, 1983; Bonilla, 1988; Jacobs
Associates, 1999; Brabb and others, 2000;
Wentworth and others, 1998) and unpublished
geologic-landslide mapping. Landslides were
reviewed using the lidar shaded-relief map (USGS,
2005), Google Earth Pro DigitalGlobe and Historical
Imagery, and stereo-paired aerial photos. For each
landslide included on the map several characteristics
(attributes) were collected and compiled in a
geodatabase. These characteristics include recency
of activity, type, thickness, associated geologic
unit(s), and the confidence of interpretation
(definite, probable, or questionable). The completed
landslide map was digitized, and the attributes were
entered into a database. Landslides rated as definite
or probable were carried into the landslide zone..."
Background information using some of the latest
widely accepted scientific research on climate change
and sea level rise, including recent (2013) work from
the Coastal and Ocean Working Group of the

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California Climate Action Team (CO-CAT), was
incorporated into the Draft EIR analysis as provided
on pages 3.5-9 and 3.5-10. In 2018, the City of
Pacifica prepared a Sea Level Rise Vulnerability
Assessment using the best available science.

Consistent with the San Mateo County Vulnerability
Assessment, existing and future coastal flooding was
evaluated using the Our Coast, Our Future (OCOF;
produced by US Geological Survey) mapping
products, while future coastal erosion was evaluated
using the Pacific Institute (PI) erosion maps. The
Vulnerability Assessment projected sea level rise
scenarios ranging from 1-2 feet by 2050, and 3-6 feet
by 2100. The 6 feet projection is an extreme scenario
in which sea levels rise at a rate about 30-40 times
faster than the rate experienced in the 20th century.

Rising sea levels have occurred over the last century
and are expected to continue over the coming
century, likely at a rate that exceeds the rates
experienced thus far. Modeling has provided
estimates of potential increases in sea levels but as
stated on page 3.5-31 of the Draft EIR, predictions
become less reliable as you go further into the
future. In addition, different modeling efforts have
been conducted to reflect various possible outcomes
resulting in a range of estimates for the amounts of
sea level rise that could be experienced, largely due
to the difficulty in determining a more defined
predictive value.

Flooding. Flood mapping utilizes the latest and best
available data from FEMA.

C22-
11 Dinah
Verby
3/8/22 Consider Designation of a proposed Greenbelt
(Multiple benefit resilience buffer): For vacant parcels with hazards and/or valuable biological resources that
would constrain development, utilize a VMT exchange
program or Purchase/Transfer of Development rights
program to generate funding to purchase
undeveloped properties from willing sellers within the
Greenbelt area at the edge of the community.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

C22-
12 Dinah
Verby
3/8/22 II. Rockaway Quarry (aka Pacifica Quarry):

The proposed land use designation of Visitor-Serving
Commercial in the parts of the Quarry known as the
Flatlands and the Pit or Pad is inconsistent with the
fact that these areas have been identified as Potential Environmentally Sensitive Habitat Areas (ESHA), as
shown in Figures 7-3 of the GP and 3-7.3 in the DEIR. It is also internally inconsistent with many Guiding and
Implementing Policies articulated in the GP update for
protection of such areas. The level and intensity of
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

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development contemplated in the Preferred Plan is
incompatible with Coastal Act policies and seems
unlikely to be approved by the Coastal Commission.

C22-
13 Dinah
Verby
3/8/22 It appears in many instances that the GP and DEIR are relying on old, outdated data with regard to the
biological assessments. Furthermore, analysis of the
biological impacts is improperly deferred with a
general statement that “any development of the
Quarry site will require detailed evaluation of
biological resources to ensure that sensitive habitat
and wetlands are protected.” (GP Page 4-22) Other
than an oblique acknowledgement at GP Page 4-22
that the development footprint “could be smaller than
the area designated” due to the existence of “sensitive habitat and wetlands,” there is no analysis of welldocumented current conditions and biological resources, such as the existence of seasonal and
emergent wetlands in the Flatlands and Pit sections of
the Quarry, which are habitat for threatened and
endangered species such as the San Francisco Garter
Snake (SFGS) and the California Red-Legged Frog
(CRLF).

The General Plan and DEIR make use of best available
evidence from reputable federal and State
governmental sources at the time of publishing.

Project-specific analysis does not represent a
deferral; please see Master Response 2:

Programmatic EIR for more information on
requirements of program-level EIRs.

C22-
14 Dinah
Verby
3/8/22 Furthermore, the DEIR improperly fails to analyze the impacts of the pending Quarry Reclamation Plan
submitted in 2020 and revised on February 14, 2022.
(A separate DEIR for the Reclamation Plan is presently
circulating for public comment.) While the existence of the Reclamation Plan is mentioned at Page 3.15-1 of
the DEIR, there is no cumulative impacts analysis of
this known, anticipated development. Of special note
is the fact that the Reclamation Plan proposes to
create mitigation wetlands and a CRLF mitigation pond
in the middle of the Quarry Flatlands – the very area
designated “Visitor-Serving Commercial.” The
Reclamation Plan also contemplates creation of a
Conservation Easement over some portion of the
Flatlands, which would preclude any development in
that area.

This comment raises two issues: plan consistency,
and cumulative impacts. The Quarry Reclamation
Plan does not include the development of any
buildings or change in use of the Quarry site. Any
future development on the Quarry site will require
an application to the City of Pacifica and a public
review process. The end result of the Quarry
Reclamation Plan is a safe site that is suitable for
reuse in accordance with City of Pacifica land use
regulations. The General Plan is the guiding
document, and proposes a Visitor-Serving
Commercial designation on the Quarry site. A land
use designation is implemented through more
specific zoning. While the Visitor Serving land uses
applies broadly to the area, zoning implementation
could provide different standards to the subsection
of this area. Thus, analysis of the Draft DEIR is valid and adequate.

Regarding cumulative impacts: A cumulative impact
would occur if there was a greater amount of
development resulting than what was anticipated in
the General Plan or in the DEIR's cumulative analysis.

As stated previously, the Quarry Reclamation Plan
does not include development of any buildings or
change in use of the Quarry site. Thus, there is no
additional cumulative impact not analyzed under the
DEIR.

C22-
15 Dinah
Verby
3/8/22 Based on all the above considerations, the appropriate designation for the entire Quarry and Flatlands area is “Conservation.” It would be a substantial waste of City time, money and resources to pursue a strong
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with

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commercial center in the Quarry. Accordingly, the City
should strongly consider adopting some form of
Alternative 2 identified in the DEIR, which involves the greatest amount of conservation and the least amount
of development in the Quarry.

More specific comments are detailed below, with
references to the Plan documents.
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

C22-
16 Dinah
Verby
3/8/22 Wetlands Missing or outdated data; deferred analysis Policy CO-I-4 in the Conservation Element of the
General Plan (GP) “prohibits new development in
existing wetlands except as allowed under the federal
Clean Water Act and the California Coastal Act.”1
Figure 3.7-2 of the DEIR contains a National Wetlands
Inventory Map dated 2021, but footnote 10 notes that
“many smaller wetlands do not appear on the map”
and subsequent projects may be subject to “sitespecific wetland delineations that identify the location and extent of federal, state and locally jurisdictional wetlands and other waters.”2 One area where
wetlands are not shown is the Rockaway Quarry,
located in the Coastal Zone where seasonal wetlands
have served as habitat for threatened and endangered
species including the San Francisco Garter Snake
(SFGS) and the California Red-Legged Frog (CRLF). The
existence of the wetlands along Calera Creek as well as in other parts of the Quarry, including a drainage ditch immediately west of Highway 1, was acknowledged in
the 2013 FEIR for the CalTrans State Route 1/Calera
Park Highway widening project (which ultimately was
not built). Refer especially to the U.S. Fish & Wildlife Service’s Biological Opinion No. 81420-2009-F-1328
which confirmed these areas to be habitat for the
SFGS and CRLF.

More recent wetlands & habitat studies were done by
the current owner of the Quarry and are on file with
the City as part of the Rockaway Quarry Reclamation
Plan (as revised on Feb. 14, 2022), for which a Draft
EIR is currently circulating for public comment. Figure 4 of the Reclamation Plan depicts “Wetlands
Potentially Subject to Corps Jurisdiction” which exist
throughout the Flatlands. Here is a link to those
documents:
https://www.cityofpacifica.org/depts/planning/propos
ed_pacifica_quarry_reclamation_pr oject.asp
The DEIR uses the best available evidence from
credible government sources, such as the National
Wetlands Inventory and the U.S. Fish & Wildlife
Services, at the appropriate scale of a Programmatic
EIR for a General Plan. Quarry wetlands delineations
were released after the Impacts to specific sites
would be analyzed as part of a Project EIR. Please see
response to comment C22-13 for more information
on how specific zoning and project-level analysis
would be required. Please see also response to
comment A2-3 for more information about Proposed
Project policies that reduce the impact.

C22-
17 Dinah
Verby
3/8/22 Missing Cumulative Impacts Analysis
Other than a couple of acknowledgements in the GP
that the Quarry needs reclamation work, I can find no
analysis of the actual pending Reclamation plan, which
proposes filling the wetlands west of the creek and
creating new mitigation wetlands in the middle of the
Quarry flats, as well as a conservation easement.

Though not yet approved, it is an anticipated project
that is not analyzed in the GP or DEIR (at least not in Please see Master Response 2: Programmatic EIR.

Please see response to comment C22-14.

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what I’ve read so far). Absent this analysis, there is no factual basis for the DEIR’s conclusion that the
Project’s impacts are less than significant.

C22-
18 Dinah
Verby
3/8/22 Special Status Species and Potential ESHA
GP Figure 7-3 in the Conservation Element3 and DEIR
Figure 3-7.3 entitled “Sensitive and Critical Habitat,”4 show that the entire Quarry – including the Flatlands
and the area known as the Pit or Pad, are “Potential
Environmentally Sensitive Habitat Areas” (Potential
ESHA) that should be protected from development
under GP Conservation Policies CO-G-7 and CO-G-11.5
GP Land Use Policy LU-G-7 additionally provides for
protection of critical wildlife habitat and special status species.6
Missing or outdated data DEIR Figure 3.7-4 entitled
“Special Status Species” shows the federallythreatened California Red-Legged Frog (CRLF) to be extant in the Quarry Flatlands.7 Furthermore, the DEIR
states that the endangered San Francisco Garter Snake
(SFGS) “…are presently known to occur…in the Pacifica
Quarry,” citing a 2005 study by Swaim Biological
Consulting. 8 A more recent study by Swaim concluded
that the entire Quarry including the Flatlands was
habitat for the CRLF and that no developable footprint
could be identified under Coastal Commission rules.

See “STATUS OF THE SAN FRANCISCO GARTER SNAKE
(THAMNOPHIS SIRTALIS TETRATAENIA) AT PACIFICA
QUARRY, SAN MATEO, CALIFORNIA” Revised Feb. 27,
2007 by Swaim Biological, Inc.] (copy attached).

The Swaim report is quoted extensively in more recent
studies in the pending Quarry Reclamation Plan on file
with the City, which are not mentioned in the GP or
DEIR. That work, if approved, would place wetlands
and a CRLF mitigation pond in the middle of the
Quarry flatlands, which would presumably preclude
most if not all development in that area. Contrast the
above-noted conservation policies with GP Figure 4-3
“Land Use Diagram,” which shows the Quarry flatlands
and Quarry Pit/Pad as Visitor-Serving Commercial.9
The Quarry Reclamation Plan was published after
release of the NOP; thus, the DEIR used the best
available public information at the time. The
Reclamation Plan DEIR includes potential significant
impats as well as mitigation measures, but does not
conclude that development would not be able to
occur, as the commenter suggests. This represents a
difference of expert opinion, which is allowed under
CEQA.

While the Quarry Reclamation Plan is a projectspecific plan, the Proposed Project is programmatic and includes an appropriate level of analysis. Please
see Master Response 2: Programmatic EIR. As a
programmatic document, this EIR presents a citywide
assessment of the potential impacts of the proposed
Pacifica General Plan. It does not assess projectspecific impacts of potential future projects under the proposed Plan, all of which are required to
comply with CEQA as applicable.

3.7-3 and Figure 3.7-4 indicate that there are
potential Environmentally Sensitive Areas (ESHAs)
within the Quarry site. Any development proposed
on the Quarry site would be required to comply with
federal, state, and local regulations, in addition to
the policies described in response to comment As-16.

C22-
19 Dinah
Verby
3/8/22 Inconsistency
GP Fig. 4-7 ‘Pacifica, Central” shows the same.10
Similarly, the Land Use Element describes the Quarry
as Pacifica’s “most prominent potential development
site” and designates the Flats and Pad for hotels,
visitor attractions and retail uses. The Economic
Sustainability Element contains similar statements.

Table 4-3 in the Land Use Element entitled “NonResidential Buildout Under the General Plan” projects 448,400 sq. ft. of new development in the Quarry,
which is more than 78% of all the projected VisitorServing Commercial development citywide.11 Further, Policy CD-I-1 of the Community Design
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

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Element states: “Rockaway Beach will be the visitororiented center. Its charming coastal character will be strengthened by new development and the district will
be extended with a connective street pattern onto the
flat portion of the Quarry site. It may gain a new,
defining feature such as a destination hotel or
conference center.”12 Continuing with that theme,
Policy CI-I-6 of the Circulation Element provides for
new streets in the Quarry.13
C22-
20 Dinah
Verby
3/8/22 Deferred Analysis
Policy LU-I-25 of the Land Use Element is to “enable
the responsible development and environmental
conservation of the Quarry site.”14 It goes on to say
that “any development of the Quarry site will require
detailed evaluation of biological resources to ensure
that sensitive habitat and wetlands are protected; as a result, the footprint of development could be smaller
than the area designated.”15 Again, while noting that
reclamation work must occur, there is no analysis of
the impacts of the actual Reclamation Plan. Instead,
analysis of the biological resources is deferred to the time of a future development, which means that the
amount of allowable development in the Quarry
remains unknown. This in turn means that there is no
basis for the DEIR’s conclusion that the Project impacts are less than significant.

Please see Master Response 2: Programmatic EIR.

The Reclamation Plan does not propose a land use;
please also see response to C22-14.

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C23: Therese Langille, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C23-1 Therese
Langille
3/9/22 I am writing to express my opposition to the GPU update and DEIR’s proposed land use designation
change of the undeveloped field along San Pedro
Avenue in Pedro Point. I request that you do NOT
change the land use designation to Coastal
Residential Mixed Use (CRMU). My reasonings are
numerous, but here are some of the most important:

This field is in a flood plain, as evidenced by the many photographs presented to you. Rain waters flood
down from the Pedro Point Headlands on to San
Pedro Avenue and on to the undeveloped field. This
field will eventually be underwater from projected
sea level rise. There is strong scientific evidence that supports this fact. Homes should NOT be built below
sea level. Just look at the home along that East Coast
that are constantly flooded at high tides.

The field supports crucial wildlife habitat for so many species. On our daily neighborhood walks, we see
great heron and red tailed hawks resting in the trees
and catching their prey on the field. We see snakes,
red-legged frogs and other species in their native
habitat. Where will they go if there is no open space
for them? Pacifica must be a good steward of its
ecology and environment. Like it or not, Pedro Point
has become a free parking area for surfers. Adding
construction and homes to the field along San Pedro
Avenue will NOT stop the surfers/visitors from
coming, but will just impede vehicular and pedestrian
traffic even further for the residents of the area.

The comment is noted. Land use designation
changes and vehicular congestion are not required
topics in the DEIR analysis, thus, no further
comment is required.

As shown on Figure 3.5-1, page 3.5-3 of the DEIR,
the site is not in a FEMA identified special flood
area, however it is subject to localized floods as
noted on page 3.5-8 ‘The broadest mapped flood
hazard areas are located along San Pedro Creek,
covering much of the Linda Mar area north of the
creek extending down to the coast. A broad 0.2
percent annual chance flood area is mapped at the
confluence of the main stem with the North Fork of
the San Pedro Creek.

The Proposed Project would allow for mixed use
development, in event of development of the site, it
would be subject to regulations to prevent loss
life/property in the event of a tsunami. In addition
to new policies, including SA-I-26, SA-G-2 SA-I-15,
that will further reduce the risk to less than
significant and therefore the analysis in the DEIR is
valid. See response to comment C13-9 regarding
California Coastal Act Regulations. Please also see
response to comment C13-3 for more information
about sea level rise.

The comment also mentions that the field in Pedro
Point acts as a floodplain. This does not mean the
development cannot take place here. If
development were to happen, the building/s would
have to follow several measures including - SA-I-17,
SA-I-19, SA-I-20, SA-I-22, SA-I-23, SA-I-25, SA-I-39,
SA-I-40, SA-I-88, to decrease impact to a less than
significant level.

Please see Master Response 6: ESHA for more
information about how regulations and policies
reduce impacts to less than significant, and Master
Response 4: Undeveloped San Pedro Ave Sites for
more information about Coastal Act consistency
and project-level requirements.

C23-2 Therese
Langille
3/9/22 Pacificans have been accused of burying our heads in the sand for our denial of climate change in the press
lately. We can do better! There are other great
opportunities to utilize the undeveloped Pedro Point
field that can be a win-win for everyone involved.

The easiest solution to address these issues is to
change the land use designation for the Pedro Point
field to one that is closest to it's current state, which is Low-Intensity Visitor-Serving Commercial (LIVC).

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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C24: Joanne Gold, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C24-1 Joanne Gold 3/9/22 My husband, Ed Gold, and I are 23 year residents of the Pedro Point neighborhood and are writing to
submit comments on City of Pacifica General Plan
Update (GPU) and 2022 Draft Environmental Impact
Report (DEIR). As active and involved members of
the community, we’re very pleased that the
Planning Commission and City Council are
committed to updating the General Plan as guiding
document for Pacifica’s vibrant future. Thank you
for your efforts.

However, we’re writing to state our strongest
possible objection to the GPU/DEIR’s proposed new
land use designation of “Coastal Residential Mixed
Use” (CRMU) for the undeveloped San Pedro
Avenue site in the Pedro Point neighborhood. We
have gone on record many times over more than a
decade to cite our personal objections to a CRMU –
or any residential land use designation – for this
property (known locally as the “Pedro Point field”).

We have also personally supported the Pedro Point
Community Association (PPCA) - both as donors and
as community organizers - to help submit
comments objecting to this designation from legal
and environmental experts. Therefore our
comments in this letter incorporate by reference
the 2022 DEIR/GPU comment letters prepared by
the PPCA, and those prepared on behalf of the PPCA
which were submitted separately by CEQA
consultant Richard Grassetti, attorney Brian
Gaffney, and Coastal Ecologist Dr. Peter Baye. These
experts have provided specific details of how a
proposed change of the existing land use of the
Pedro Point field to CRMU is reasonably likely to
cause direct and indirect significant adverse impacts
and would conflict with CEQA and Coastal Act
policy.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C24-2 Joanne Gold 3/9/22 For us personally, there are many reasons a CRMU designation for the Pedro Point field would cause
significant and direct negative impacts – here are
just a few:

1. Significant adverse aesthetic impact:

Our home directly overlooks the Pedro Point field
which provides us with beautiful, scenic views
we’ve enjoyed every single day for the past 23
years. From our windows we can also see scores of
our neighbors walking in and around the field each
day. Like us, they all enjoy the grassy open space to
observe wildlife, exercise pets (and kids), take in
scenic views of the surrounding hillsides, and use
long-worn footpaths to get to the adjacent Linda
Mar Beach. The proposed CRMU designation would
not only ruin the aesthetic enjoyment of the field
Please see Chapter 3.9 for more information on
impacts to visual resources. As described on DEIR p.

3.9-13, "While the Proposed Project eliminates the
existing single height limit in the city with height
limits that vary by zone, future development will be
subject to regulation and review mechanisms to
ensure there is no substantial adverse effect on
scenic vistas...The land use changes in the Proposed
Project will not substantially degrade the existing
visual character or quality of Pacifica and would not
conflict with applicable zoning and regulations
governing scenic views.

All existing open space areas are preserved and
scenic resources are protected under the Proposed
Project. Policies, zoning designations and design

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Packet Pg. 806 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 142
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for my husband and I, but for our neighbors and
visitors to our community as well. Any foreseeable
development would certainly degrade the existing
visual character of the neighborhood.

2. Significant adverse biological impact:

Like most who live on Pedro Point or those who
come to visit here, our family has long enjoyed the
diversity of wildlife we’re able to observe in and
around the Pedro Point field. From California Redlegged Frogs (CLRF), to San Francisco Garter Snakes, to deer and coyotes, and a myriad of nesting and
foraging birds - over the years we’ve encountered a
veritable guidebook of native wildlife species (and
have gone on record to document endangered
species observed with the California Coastal
Commission, such as CLRF). Foreseeable
development from the proposed CRMU designation
would irrevocably harm the wildlife, the natural
habitat, and our enjoyment of this treasured
neighborhood environmental asset.

3. Adverse Parking/Traffic Conditions & Pedestrian
Safety Hazards:

We love to walk and ride bikes in and around our
neighborhood. But the increased street parking and
vehicular traffic along San Pedro Avenue in the past
several years has made these outings more and
more hazardous. Reasonably foreseeable
development under the proposed CRMU
designation would literally choke our streets,
making this main thoroughfare un-navigable, and
present significant adverse hazards for both
emergency access and pedestrians (there are no
sidewalks!). The increased traffic would also have
related air quality and greenhouse gas emission
impacts.
guidelines included in the Proposed Project will
sensitively govern the formal characteristics of new
development to ensure they are compatible with
existing neighborhood character and quality .The
Coastal Act requires scenic and visual qualities of
coastal areas to be considered and protected as a
resource of public importance.

The DEIR also has regulations and policies that
would further reduce an already less than
significant impact on scenic vistas on pages 3.9-19
through 3.9-22. There are no alleged deficiencies
with the EIR analysis as the EIR used best available
from State and federal sources.

Figure 3.7-3 of the DEIR uses data established under
Critical Habitat for Threatened and Endangered
Species, U.S. Fish & Wildlife Service. This figure also shows potential Environmentally Sensitive Habitat
Areas (ESHA) and Wildlife Movement Corridor
areas. Figure 3.7-4 of the DEIR shows where Special
Status Species habitat may be located, which shows
the CRLF habitat at Laguna Salada and parts of Mori
Point, and is not a federally-established Critical
Habitat.

Parking and congestion are not significant impacts
under CEQA.

C24-3 Joanne Gold 3/9/22 Lastly, in reviewing the GPU Land Use map (section 4-6, p. 67) we note that it appears the one main
property in the entire City of Pacifica being
proposed for the new CRMU designation is the
privately-owned, undeveloped San Pedro Avenue
field. It seems as if this property and its landowner
have been singled out for special treatment. The
GPU should be a guiding document for the
development and policy making decisions of the
entire community, not just for the benefit of a
single landowner.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C24-4 Joanne Gold 3/9/22 In conclusion, we urge you to change the proposed land use designation for the Pedro Point field from
CRMU to Conservation (C) which is most consistent
with the current state of the undeveloped property.

A Conservation designation would also address DEIR
deficiencies noted by the PPCA and their expert
advisors, and be in compliance with CEQA and
Please see reference to Master Response on
Emergency Access and respond to the comments on
traffic, such as noting VMT was studied.

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Packet Pg. 807 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 143
Letter Commenter Date Comment Combined Response
Individuals (C)
Coastal Act policies. It would therefore be not only
the most responsible solution, but also the most
expedient solution to help move the GPU and DEIR
approval process forward. Thank you in advance for
making the smart decision to preserve open spaces
like the Pedro Point field, and for valuing Pacifica’s
natural assets as a way to ensure our city’s future as
a vibrant and desirable coastal destination.

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Packet Pg. 808 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 144
C25: Gary Furlong, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C25-1 Gary Furlong 3/7/22 I am writing to you in regards to my objection to the General Plan Update and Draft Environmental Impact
Report's proposed land use designation change of the
undeveloped field in Pedro Point from Commercial
Recreation to Coastal Residential Mixed Use. My name
is Gary Furlong and I have lived on Pedro Point for
almost 22 years. My husband, David Costa, has lived
here for about 37 years. We have seen dramatic
change to the Pedro Point neighborhood; most of it
good. I object to what is being proposed for this
neighborhood primarily for four reasons:
(1) It will damage and completely change the nature of
the Pedro Point neighborhood.
(2) It will be dangerous for this neighborhood and the
city will bear the responsibility for that.
(3) It will be environmentally unsound and foolish.
(4) The owner of the field bought the property
knowing its designation and I resent a land use
designation change, that the neighbors object to,
simply to enrich someone who bought property based
on changing its nature.

1. Pedro Point is a real neighborhood in the best sense of those words. People know each other, socialize
together and look out for each other. We have
potlucks, parties and communal events together. To
add a staggering number of new homes, while
removing a green space, will change the basic nature
of the neighborhood. I walk almost daily throughout
Pedro Point and my walks certainly take me around
the field, which serves as a communal area for
socializing, as it has done for decades now. I have
greatly enjoyed my chance encounters with various
wildlife as I walk by the field (including what appeared to a heron that was a bit lost, as it was standing in the field!). Over the many years of its use by the
neighborhood, it has become the unofficial heart of
the neighborhood for catching up on the local news
and visiting with friends, as well as for people walking their dogs and children learning to ride bikes. It should be obvious that reasonably foreseeable development
allowed by the proposed new land use designation of
the General Plan Update will ruin my enjoyment of
this established neighborhood character.

2. There is one road into our neighborhood; just one
road. When I moved here there was only limited
beach traffic, especially since at that point, San Pedro Road didn't serve as an exit for some of the beach
parking. That was also before almost half of the
parking lot at our retail center became beach parking.

Now days, particularly on sunny days, the traffic going into and out of Pedro Point is almost unbearable and
it's getting worse. Frequently San Pedro road is almost impassable due to great number of people parking
there to use the shopping center, the beach, or who
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Project and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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Packet Pg. 809 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 145
Letter Commenter Date Comment Combined Response
Individuals (C)
actually live in the neighborhood. This traffic,
especially the beach going part of it, has increased
significantly every year for years now and will only get worse. If there is a need to suddenly evacuate the
neighborhood, such as a forest fire, our one single
road will not be up to the current challenge. I cannot
imagine what it would be like if many new homes are
built on the field, making traffic significantly worse.

3. The field is environmentally sensitive. Others will
have commented on the presence of endangered
species. I will limit myself to pointing out that we're currently in a drought, as we have been for some time
now. However, during our regular weather cycle this
field is marshy and can be prone to flooding. This was
before numerous additional houses were built on the
hillside, which will further increase the runoff when
our weather cycle returns to a more normal, wet
winter. In addition to the runoff that is to be expected, many of these new homes also have been built with
pumps that are pumping water out from around their
foundations, further adding to the water that will flow down to the field. An environmentally sensitive field
that is prone to being marshy during normal weather
years, not a great choice for cramming in dozens of
homes.

4. I believe that everyone has the right to expect a
decent return on their investment as long as it is a
reasonable expectation. However, the current owner
bought this property knowing its land use designation
so I feel that the city has no responsibility to help
them make a profit by insisting on a land use
designation change, especially one that will be
harmful both to the neighborhood and the
environment.

C25-2 Gary Furlong 3/7/22 I believe that one of the highest duties of a city, and its land use designation, is to protect the nature of its
neighborhoods and the lives of its residents. I believe that this land use designation change will do just the
opposite; as I mention above, is should be obvious
that reasonably foreseeable development allowed by
the proposed new land designation of the General
Plan Update will destroy the valued character of the
neighborhood and my enjoyment of it. It's almost
seems as if this particular parcel of land has been
singled out for special treatment.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

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Packet Pg. 810 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 146
C26: Dina and Robert Horan, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C26-1 Dina and
Robert Horan
3/7/22 We are writing to object to the General Plan
Update and Draft Environmental Impact Report's
proposed land-use designation change for the
undeveloped San Pedro Avenue site (the "Pedro
Point Field"). As we understand it, the proposal
would change the designation of the Pedro Point
Field from “Commercial Recreation” to “Coastal
Residential Mixed Use.” For the sake of brevity,
rather than repeat facts presented by and
arguments and proposals made on behalf of the
community by the Pedro Point Community
Association and its counsel and consultant, as well
as the additional arguments, facts and proposals
presented by Sam Casillas, we incorporate them
as though fully set forth herein.

As the Pedro Point neighbourhood has
demonstrated over the years, this community
stands ready to provide the legal and financial
resources (and person-power) necessary to
protect our neighbourhood from ill-conceived
and/or unlawful decisions regarding the Pedro
Point Field. Accordingly, we respectfully urge all
decision makers to please carefully consider the
points made by the PPCA and its lawyers and
consultants, and Mr. Casillas, and work with the
community to appropriately designate the Pedro
Point Field in a manner that protects the
environment and is consistent with applicable law
(including the Coastal Act), neighbourhood
concerns, and science.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

EIR Comments for more information about GP- or
SPSP-related responses.

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Packet Pg. 811 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 147
C27: Cathy Glenn, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C27-1 Cathy Glenn 3/7/22 I'm writing to state my objection to the General Plan Update (GPU) and Draft Environmental Impact
Report (DEIR)’s proposed land use designation
change of the undeveloped San Pedro Avenue site in
Pedro Point (ie: the Pedro Point field) from
“Commercial Recreation” (CR) to a new “Coastal
Residential Mixed Use” (CRMU) designation.

The comment is not related to the adequacy of
the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed Plan and
will be shared with decision-makers in that
context. Please see Master Response 1: EIR
Comments for more information about GP- or
SPSP-related responses.

C27-2 Cathy Glenn 3/7/22 In reviewing the DEIR, I know that the City has concluded that the GPU would not create significant
visual impacts related to 1) views of hillsides, 2)
degradation of existing visual character, or 3) glare
affecting day or nighttime views. As a local resident,
I disagree with these Draft EIR conclusions for the
following reasons:

My family has lived on Pedro Point for almost 30
years. Our front windows overlook the field, the
berm and the ocean. The view of the grassy field is
very relaxing and the wild life that we see in there
on a regular basis is just wonderful.

My biggest concern about the field being designated
Coastal Residential Mixed Use is the increase in
traffic and parking that will overtake the Point. Right now we are inundated with beach parkers every
sunny day. It is taking its toll on our roads and on our residents safety. The roadways are crumbling, have
bigger and bigger pot holes and the parking is
ridiculous. People park where ever there is space
whether it is a parking space or not. Just crossing
San Pedro Road can be an adventure and is getting
more and more dangerous. Adding more residents
will just exacerbate the problem. We have had to
call the police to have parkers ticketed for blocking
our driveways. Unless the City is willing to put the
money into fixing our infrastructure, this will be an
on going problem. My children grew up using the
field for play and for access to the beach. I would
like to see this continue for the next generation of
Pedro Point children.

In addition, reasonably foreseeable development
under a CRMU designation would degrade the
existing visual character and be out of scale with the
existing structures in the surrounding neighborhood.

I have lived here for almost 30 years and the small
town look and feel of this neighborhood are an
integral part of our community.

Please see Chapter 3.9 for more information on
impacts to visual resources. As described on DEIR
p. 3.9-13, "While the Proposed Project eliminates
the existing single height limit in the city with
height limits that vary by zone, future
development will be subject to regulation and
review mechanisms to ensure there is no
substantial adverse effect on scenic vistas...The
land use changes in the Proposed Project will not
substantially degrade the existing visual character
or quality of Pacifica and would not conflict with
applicable zoning and regulations governing scenic
views. All existing open space areas are preserved
and scenic resources are protected under the
Proposed Project. Policies, zoning designations
and design guidelines included in the Proposed
Project will sensitively govern the formal
characteristics of new development to ensure
they are compatible with existing neighborhood
character and quality The Coastal Act requires
scenic and visual qualities of coastal areas to be
considered and protected as a resource of public
importance.

The DEIR also has regulations and policies that
would further reduce an already less than
significant impact on scenic vistas on pages 3.9-19
through 3.9-22.

In regards to your comment on traffic and parking
issues, parking and congestion are not a topic of
required analysis under CEQA. The comment is
not related to the adequacy of the DEIR, therefore
no further response is required in the FEIR.

However, the comment addresses the content of
the Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C27-3 Cathy Glenn 3/7/22 I'm also concerned about new sources of light and glare from exterior and interior lighting that would
be introduced by reasonably foreseeable
development under the General Plan Update’s new
The DEIR analyzes new sources of substantial light
or glare on pages 3.9-29 through 3.9-31. The
proposed project was found to have a less than
significant impact. As mentioned on page 3.9-13

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Packet Pg. 812 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 148
Letter Commenter Date Comment Combined Response
Individuals (C)
land use designation for the field. My nighttime
environment would be negatively impacted, as the
additional lighting and glare would be visible from
my home and take away the peaceful darkness of
the evening. As it is now, we can see the ocean in all
of its glory day and night, but we won’t be able to
watch the waves crash onto the rocks and see the
beautiful waterfalls that they create.
of the DEIR 'New development under the
Proposed Project is not expected to create new
sources of light or glare that could substantially
affect day or nighttime views in the area.' The
DEIR also mentions proposed general plan policies
that would further reduce an already less than
significant impact on pages 3.9-30 and 3.9-31.

C27-4 Cathy Glenn 3/7/22 For each of these reasons, I believe this project will result in a significant adverse visual impacts. The
simplest solution to address these issues is to
change the land use designation for the Pedro Point
field to one that is closest to it's current state, which is Low-Intensity Visitor-Serving Commercial (LIVC).

The comment is noted. Please see to response to
comments C27-2, C27-3 and C27-4.

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Packet Pg. 813 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 149
C28: Clif Lawrence, 2/21/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C28-1 Clif
Lawrence
2/21/22 Good evening. My name is Clifford (Clif) Lawrence. Our First U.S. President was born on this date 290 years
ago. He commended us to remain mindful of the
importance of the role of "Citizen". We are all here this evening as concerned citizens, and as such honored.

Next I wish to express my thanks for the recent upgrade revisions to the Draft General Plan and Draft EIR
documents. These indexes and search friendly
capabilities have opened a window of opportunity to
identify what IS and what IS NOT there. Tonight I
thought I would share with you somethings you might
not have known about our 2022 Draft EIR. More
specifically some nerdy things about its Bibliography...

First...there are 193 references. The oldest 1974. The
newest 2013. There are no references in the
Bibliography newer than 2013. In fact, the 2022
Bibliography is IDENTICAL in substance to the version
made public in 2014. There are at least 5 references
with NO DATE. There is even one document referenced
by year as 3013. Mind you, I accept I may have made
some errors in the creation of this profile. But then I was a little rushed compared to the years utilized by
our high paid consultants.

We spent a lot of money on these consultants in 2021
and 2020. Somehow they managed to add 300+ pages
to the 2014 DEIR without a single change to the
Bibliography. How is that?
References will be updated to reflect the latest
data used in analysis. This does not change any
findings of significance in the DEIR.

C28-2 Clif
Lawrence
2/21/22 There is another matter of concern. The word
"contingency" only appears ten times in the one
thousand pages of the DEIR. Twice in reference to
water. Eight times regarding access for emergency
vehicles. Should I conclude, there is no contingency for the eventual loss of infrastructure under Beach Blvd? Is there no contingency for the potential erosion loss of
Palmetto Ave at the South Canyon? How much longer
will it take emergency vehicles to get to West Fairmont, if they can't use Palmetto Ave? In conclusion I ask you this question. Since you are not only Planning
Commissioners, you are Pacifica Citizens. As Citizens,
how do you grade this DGP and DEIR? Are you also
concerned? What have we paid for "The Emperor's
Clothes?" I thank you for your time.

Planning for critical infrastructure is not a
required topic of analysis under CEQA, but it is
addressed in the MJ-LHMP and in policies SA-I35 and SA-I-36. Please see response to C47-3 for more information about coastal erosion and sea
level rise mapping, and Master Response 7:

Emergency Planning for more information on
adequacy of evacuation planning.

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Packet Pg. 814 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 150
C29: Nancy Merchant, 3/3/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C29-1 Nancy
Merchant
3/3/22 In West Sharp Park, the failing shoreline protection (aka “seawall”) has not been reinforced, and the vulnerable
infrastructure behind it has not been moved, yet
instead of prudently scaling back on allowable
development to mitigate existing and future inevitable
risks, these planning documents recommend increased
intensity and also promoting the tallest buildings
Pacifica has ever allowed. Some of these four- to fivestory buildings, suggested for affordable housing, would be located north of San Jose Avenue, which is a mere
block away from the most vulnerable section of
shoreline in West Sharp Park. This does not meet the
standards for sustainable development – and, if built,
would pass the buck to those who have risked their
livelihoods to live or try to build a business based on the city’s lack of transparency.

Issues related to coastal protection are addressed
in the LCLUP. The LCLUP is not included for
analysis under CEQA.

C29-2 Nancy
Merchant
3/3/22 The Land Use and Housing sections in all three
documents don’t even mention sea level rise. The
ocean has visibly encroached in the last 30 years in
spite of (or perhaps even because of) shoreline
protections. Each month the City Council adopts the
Continuation of Proclamation of Local Emergency of the
Pacifica Coastline from Westline Drive to the End of
Beach Boulevard. Sea level rise is probably the most
significant influence affecting land use in Pacifica. Yet, hazards appear not to have been considered at all in
determining acceptable land uses.

Please see response to comment C13-3 for more
information about coastal flooding and sea level
rise.

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Packet Pg. 815 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 151
C30: James Kremer, 2/20/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C30-1 James
Kremer
2/20/22 Initially, I want to address elected and city officials, and the senior staff (Planning Commissioners, City
Council, and Planning Staff). I expect that understaff will deal with the public comments that are received, collating and responding. Some of my
comments are at a different level however, and I
hope this helps them get noticed.

You all know that the released documents were
technically flawed: Table of Contents not linked to
pages (EIR with no TOC, text not searchable).

Releasing WORD versions was very little help,
since altered pagination required adjusting all
notes to apply to PDF (not easily searchable K). All
together too much time lost bouncing around
trying to keep track so my notes will be accurate…
This inefficient effort multiplied by all the persons
in Agencies, NGOs, and the public.

More importantly, it seems clear to me that no
one proof-read the document. Consider: there are
two sections 3.14 (p. 721 & 750) nearly identical†;
one paragraph I saw begins with a phrase then
abruptly begins again with the same words; a table
I missing; plans are mentioned to replace the
pedestrian walkway over Hwy 1 by Eureka Square
(OC-I-31, p6-20), which was completed more than
2 years ago; and perhaps understandable,
“Rockaway Point” is mentioned repeatedly to in
the GP despite acknowledgement in one place of
the new name Aramai Point; oh, & many obvious
typos. I’d think that at some point city staff, if not
the Dyatt & Bhatia authors, would subject each
part to a final read-through. Public/outside review
should NOT be a kludge mechanism to do this
basic task. († note: This duplication was removed,
and non-standard pagination corrected in the
revised DEIR released later.)
The comment is noted. Clarifications will be noted in
a redlined version of the DEIR; these do not change
findings of significance.

C30-2 James
Kremer
2/20/22 O.K. Here are general issues I hope will receive consideration –
Process. There is a expectation from some in the
public that all comments received will be logged,
given perfunctory dismissive responses by staff,
and PC and CC will approve as is. Since substantive
changes cannot be made later without
recirculating, this seems to imply the city views
these documents acceptable as is. That seems to
leave only legal challenge as a path to achieving
improved documents. Is that your understanding?
I think you may get a chance to resurrect this
process. Should become apparent from the critical
The comment is noted. Adequacy of the DEIR is
expressed in responses to comments as part of the
FEIR.

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Packet Pg. 816 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 152
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Individuals (C)
reviews that major changes must be made, I want
to suggest that an extended review will probably
save time. Here is what I mean:

After all the input from this hasty round of review
is collated, and if crucial changes are made,
perhaps the product will be closer to what might
be called a First Draft, one that is worthy of careful
review. My idea is that THAT is the time to actively
engage citizen volunteers again. Many are
interested. A “Call” from the city for citizen
volunteers to actually read whole sections might
be wellreceived – free labor (!) that would find
more improvements. With such a collaboration, a
2nd Draft can emerge, worthy of the recirculation
review that is deserved.

C30-3 James
Kremer
2/20/22 Missing content – Decarbonization, Electrification and Reach Codes should be major topics for a
responsible plan, yet seem to be glossed over or
missing. I know some Councilors are aware of this
regulatory “wave”! I applaud the mention of
decarbonization in control measure EN1 (Table

3.3-5 p 3.3-32) but am disappointed there are
rampant code errors that make it impossible to
look into how seriously this initiative is being
considered here or in the GP. I found Guidance
policies related to this topic (EN1: CO-G-13, -51, -
59) but code CO-G-13 in GP (p7-34) states an
entirely different policy from that in the EIR; a
different code# for -51 (=”CO-I-57” GP p7-39) ;
different code# for CO-I-59 (=CO-I- 62 in EIR pE133, & CO-I-57 in GP p7-39). Oh my. Just pecking around, the same numbers are different words,
and the same words are different numbers.

Repeatedly. (This turns out to be a general
problem not just with decarbonizing.)
These are mainly errors of haste and lack of
proofreading, but I want to emphasize the lack of
discussion in text body of they key words that
appear in policies, which seems strong evidence
that this topic is not being taken seriously in our
future planning. This is a major, significant
omission. A missed opportunity – or obligation!
The comment is noted. All text in the DEIR analysis
references policies that are described in full in
analysis chapters. Discrepancies in numbering will be
addressed in errata.

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Packet Pg. 817 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 153
Letter Commenter Date Comment Combined Response
Individuals (C)
C30-4 James
Kremer
2/20/22 Change from historical emphasis. In a number of places HPD discussions focus on esthetics, scenic
views. There are hardly any mention of hillside
restrictions in terms of public safety with
landslides, water runoff, and wildfire risk, to which
we should add then environmental risk to wildlife
corridors. While the esthetic emphasis is
commonly appreciated, the near exclusion in this
new doc of explicit mention of the importance of
restricting any development on hillsides as a
function of slope is, dare I say, unacceptable. This
appears to be a conscious shift in emphasis, which
has no basis in public guidance, and strikes me as
city over-reach.

This can be seen clearly in the explicit new
definitions of zoning categories. The lengthy
wording from the 1980 G.P. emphasizing
environmental preservation in various categories
has been omitted in all cases. Seems to be a
conscious shift of guidance. I strongly recommend
the original wording be added back in.

Specifically, wording has been omitted from new
zone definitions that in 1980 consistently included
phrases such as, “will be determined by the
existing conditions on the site, such as slope,
geology, soils, access, availability of utilities,
availability of adequate sewage and highway
capacity, public safety, visibility, and
environmental sensitivity.” (see all these 1980
categories: OSR, VLDR, LDR, MDR, & HDR)
Steep slopes and CEQA-required impacts to the
environment, including landslides, water runoff, and
wildfire risk, are analyzed under the DEIR.

Landslides and slope failure are described on p. 3.6-
13 and analyzed under Impact 3.6-1. On p. 3.6-26,
the DEIR notes, "The impacts from landslides on
development of future land uses associated with the
Proposed Project would be addressed through sitespecific geotechnical studies prepared in accordance with CBC requirements and standard industry
practices, which would specifically address landslide
hazards located in landslide hazard areas.

Development would conform to the current design
provisions of the CBC to mitigate losses from
landslides. Proposed developments would also
adhere to the hillside development requirements
contained in the proposed policies as well as the
existing regulations in the Hillside Preservation
District to resist landslides through modern
construction design and slope stabilization
techniques. General Plan Policies SA I-2 and I-9
maintain restrictions on hazardous areas including
those in the Hillside Preservation District, while
Policy SA I-8 requires that proposed development in
hillside areas undertake geotechnical studies which
analyze erosion and landslide potential. Policy LU-I14 extends the Hillside Preservation District on the zoning map to ensure that all steep and sensitive
terrain is subject to these regulations. Given State
and local regulations, including those in the Proposed
Project, the potential for adverse landslide impacts
due to the implementation of he
Proposed Project at the regional and local level is
considered less than significant."
Water runoff impacts are analyzed as part of Impact

3.5-3. As noted on p. 3.5-29 and 3.5-30, compliance
with MS4 NPDES Draining control requirements,
Provision C.3 in the NPDES permit, compliance with
the County's SMCWPPP, and adherence to the City's
stormwater guidelines would control stormwater
volume. Compliance with these regulations reduces
potential impacts to less than significant.

Slopes and wildfire risk are described in Impacts 3.14-

2. "Rugged ridges" and vegetation are described on
DEIR p. 3.14-14, which also describes the “very high,”
“high,” and “moderate” fire threat levels within the
City", also shown in Figures 3.11-4 and 3.14-1. All
new development must consider fire protection
systems and equipment, defensible space, and
vegetation management consistent with
requirements in the CBC, NCFA guidelines, and the
Pacifica Municipal Code. Continued compliance with

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Packet Pg. 818 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 154
Letter Commenter Date Comment Combined Response
Individuals (C)
existing programs and standards as well as Proposed
Project policies would reduce potential fire hazards
to a less than significant level. Please see Master
Response 5: Wildfire for more information.

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Packet Pg. 819 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 155
Letter Commenter Date Comment Combined Response
Individuals (C)
C30-5 James
Kremer
2/20/22 Vague intent and enforceability. Many policies I read struck me as platitudes, with giant loopholes
of active facilitation via variances. Many in the
public feel variances are being used to bypass
reasonable regulations, city and state. I observe at
city meetings when officials question staff
recommendations, staff responses are often
tangential even dismissive, and then
Commissioners or Councilors acquiesce. It would
be desirable to formally stipulate in policy or
regulation that variances are to be used rarely
under well constrained conditions. Too bad this is
necessary.

The commenter's assertion that "policies are
platitudes" are untrue. Proposed Project policies are
not intended to act as mitigation measures; rather,
they are policy statements indicating actions the City
will take on an ongoing basis as the Proposed Project
is implemented and the DEIR has correctly
considered the effects of implementing these
policies, including any beneficial effects they would
have in reducing potentially significant impacts of the Proposed Project. As a programmatic document, this
EIR presents a citywide assessment of the potential
impacts of the proposed Pacifica General Plan. It
does not assess project-specific impacts of potential
future projects under the proposed Plan, all of which
are required to comply with CEQA as applicable.

As a program EIR, the preparation of this document
does not relieve the sponsors of specific projects
from the responsibility of complying with the
requirements of CEQA. As noted, individual projects
are required to prepare a more precise, project-level
analysis to fulfill CEQA requirements. The lead
agency responsible for reviewing these projects shall
determine the level of review needed, and the scope
of that analysis will depend on the specifics of the
particular project. Should an applicant propose to
develop in an area with sensitive resources or
potential site-specific impacts or in an area of known
hazards, compliance with policies requiring
additional study would be a requirement for project
approval. Any project requiring discretionary
approval is required to make findings of General Plan
consistency and must demonstrate analytically that
the project is consistent with the General Plan, and
how they comply with applicable policies. Please see
Master Response 3: Buildout and RHNA for more
information.

C30-6 James
Kremer
2/20/22 I suppose all this is my “Executive Summary”(!). I have compiled detailed comments and sent all of
them to the City email for public comment. I
expect staff will be the only one who sees the bulk
of them. I am sending only this to Planning staff
and city officials. FYI, should you want to explore,
my detailed comments there include sections on:

I. Philosophy - big picture concerns that don’t
translate easily into discrete modifications
II. General Comprehensibility - Suggestions to
improve the overall structure of the docs, for
easier use, especially important for the G.P. as a
forward reaching, useful resource.

III. Specific comments:
• Itemized specifics with substantive problems, in
page order
• Focus: 3.7 Biological Resources - I spent extra
time on this
The comment is noted. This comment does not
contain CEQA-related comments.

1.f
Packet Pg. 820 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 156
Letter Commenter Date Comment Combined Response
Individuals (C)
IV. BIBLIOGRAPHY, problems with sources and
citations
V. Typos and picky nits
At a later date I will submit comments on the
General Plan, with similar sections.
-------------- This is the END of introductory
comments also sent directly to City officials. -------- ------
C30-7 James
Kremer
2/20/22 I. Philosophy - EIR
Confusion about “the plan.” The DEIR considers
multiple plans. The SPSP is “the” plan, previously
chosen to proceed and the basis for EIR impact
analysis. In this context, considering the Quarry as
an “alternative” is confusing. Why consider only
one? Indeed, is it not the case that the City is
proceeding with Huele to consider that option
too? So the whole framework for the EIR seems to
me to be a “straw man.” Artificial, and perhaps
inaccurate. oes anyone really believe we won’t
consider both Palmetto and the Quarry? I do
understand the need for a “no action” alternative.

On p E-6, “Additional elements may be included as
well”. If this were to be considered, it could not
happen only in the GP, for surely the EIR must
include all appropriate details. So both the GP and
the EIR would have to be re-circulated for agency
and public comment? Wow. Seem unlikely; why
say this?
The CEQA Guidelines require EIRs to describe a
reasonable range of potentially feasible alternatives
to a proposed project or program. That is, the EIR
needs to analyze those alternatives that will help
decision-makers make reasoned choices. The range
of alternatives shall include those that “would
feasibly attain most of the basic objectives of the
project but would avoid or substantially lessen any of
the significant effects of the project” (CEQA
Guidelines, Section 15126.6(a)). “Feasible” means
that the alternatives “are capable of being
accomplished in a successful manner within a
reasonable period of time, taking into account
economic, environmental, legal, social and
technological factors" (CEQA Guidelines, Section
15364). The alternatives contain different land use
categories, densities, and intensities along Palmetto
and at the Quarry site. The differences between the
alternative concepts are described on p. 4-2:

Alternative A, Strong Center at Quarry Site,
establishes one major mixed-use and visitor-oriented
center for Pacifica, and a series of commercial nodes
throughout the city; while Alternative B, MultiCentered, West Sharp Park Emphasis, creates a smaller visitor-oriented node at the Quarry Site and a
civic and mixed-use district in West Sharp Park.

Alternative C assumes very little development on the
Quarry Site, and more intensive transit-oriented
development at several nodes. The General Plan and
Specific Plan most closely resemble Alternative B,
which becomes the Alternative 2:"Proposed Plan".

This Alternative is evaluated in full in the DEIR
analysis chapters, 3.1-3. Policies in these elements
that may reduce environmental impacts for CEQArequired analysis areas are found in this DEIR, as applicable.

C30-8 James
Kremer
2/20/22 Sequence of LCLUP with GP+EIR. The EIR & GP
acknowledge the linkage to the an updated LCLUP.

The current plan is to approve the EIR, GP and
SPSP now, then go back change then when the
LCLCP is done. This seems badly out of order.

Many of the Policies have the icon implicating
consistency with LCLUP. It is my understanding
that the “Certification Draft” has not been
accepted even for review by the CCC, having
instead been rejected as insufficiently responsive.

Would the whole process not be expedited if an
The City of Pacifica started an LCLUP update in 2009
and continued its work through 2014. Between 2014
and 2018, the update work paused. Work on the
LCLUP update resumed in 2019 with a series of five
community meetings and study sessions with the
Planning Commission and City Council. On February
24, 2020, the City Council considered the PostConsultation Draft LCLUP and approved transmittal of the LCLUP to the California Coastal Commission for
review and certification. The LCLUP was transmitted
to the Coastal Commission on June 12, 2020.

1.f
Packet Pg. 821 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 157
Letter Commenter Date Comment Combined Response
Individuals (C)
acceptable LCLUP were to be accepted, or at least
under review by the CCC at this point in time? If
this process for the EIR and perhaps GP are
delayed for significant revision, it really makes
sense to back off and do this in the right order. It
really begs the question in any action can be taken
based on an “approved” GP without a current LUP.

No one knows, right?
Although the LCLUP is a separate planning document,
the LCLUP policies and relevant narratives are
included in the General Plan Update to ensure
coordination between the two documents. The City
has prepared a draft of the LCP Update in 2019,
approved by the City in 2020, and which is currently
under review for certification by the California
Coastal Commission. To the extent the General Plan
Update proposes any policies beyond those which
were sent to the California Coastal Commission for
review and certification, a subsequent LCP
amendment would be necessary to make the LCP
consistent with the General Plan.

C30-9 James
Kremer
2/20/22 What is the future of these docs after approval.

The format and constraints for review of the initial
documents suggest that the city was not
interested in public review. When final and
approved, however, it seems to me that not even
the GP will be read through by many people.
(Certainly not the EIR.) So what should be the goals
in finalizing them:

I suggest they must be tractable as working
documents for future reference. Details that
clearly fell below the threshold of necessity in
these versions become super critical: Searching;
Crosscomparing and checking; Accuracy and
consistency; Clear and well documented
explanation. I must believe that staff appreciates
that improvement in this vein is a good idea. But
the apparent strategy to not allow serious review
with intent to make changes now is confusing and
alarming. If not now, when? I see lip-service to the
only real goal but hasty pressure to getting it done.

We will find this to be a serious mistake.

Constructive action, not words, is needed.
[Note, after the DEIR release of revised version
2/14/22: This doc is more navigable. It IS different
however, and it should have been identified as a
different version, or release date – something!
Changing the name of the file is unreliable and
having no distinguishing phrase somewhere in the
revision is unacceptable.]
The comment is noted. There are no significant
differences among the DEIRs filed with the State. Per
public request for extension and ease of use, a DEIR
with interactive table of contents was added and
submitted to the State Clearinghouse on February
14, 2022. While a duplicated wildfire chapter was
removed to reflect a usable TOC, there are no other
differences between the document.

C30-
10 James
Kremer
2/20/22 Loopholes for enforcement. For all Policies
suggested to reduce Impacts (DEIR p 3.7-56 ff),
such as:

LU-G-7 Open Space Conservation and Habitat
Protection.

CO-G-7 Wildlife and Critical Habitat. Conserve and
protect indigenous threatened, endangered, and
other special status species by preserving critical
habitat.

These are example of vague wording, more
platitudes than enforceable policies. The city has
shown willingness to not look carefully at claims
Critical habitat is an official CDFW designation; the
undeveloped San Pedro Ave sites are not within
critical habitat. Please see Master Response 6: ESHA
for more information, as well as response to
comment A22-21.

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Packet Pg. 822 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 158
Letter Commenter Date Comment Combined Response
Individuals (C)
that projects impact critical habitat for the CRLF, if
the developer offers conflicting assertions. This
may seem snarky of me, but I worry that these
policies are being overlooked as if the city wants to
approve a project. Example: the city decides a
project does not need CEQA review, then
professional testimony submitted by outside
experts is dismissed in favor of the project’s claim.

Yet I understand it is legally required that such
case be resolved by requiring an EIR. Some
variances are judgment calls, but I have trouble
understanding how these evasive actions are
permitted. Lapses like this look to the public like
pro-developer bias, and can result in justified legal
action.

C30-
11 James
Kremer
2/20/22 How about a POLICY on Variances? Policies that
are vague and superficial compromise future
efficacy because they do not provide clear
guidance to future staff and governors. It may be
that Guidance Policies can be platitudes, but
Implementation must not be. This concern led me
to seek the word “variance” in the EIR. (thank you
for a searchable doc! J) This word appears on only
2 pages. Unsurprisingly, none offers guidance that
this tool should be rarely used. In the GP, the word
never appears.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

Pacifica City CouncilJune 25, 2022

Pacifica City Council
June 25, 2022