Agenda — Pacifica City Council, June 25, 2022 (part 5 of 23)

C30-
12 James
Kremer
2/20/22 II. General comprehensibility – EIR Hierarchical structure of headings is impossible to follow. I
looked at Ch. 3, sec 3.4 “Energy and GHGs” trying
only to follow the structure of the layout, i.e.
outline levels indicated by the font style.

There are SEVEN levels, indicated by font
size/bold/italics/ALL CAPS or Upper-Lower case. I
daresay it is IMPOSSIBLE for a reader to know
where a section falls in the structure of the
presented information – am I going down deeper
or rising up? – and if up, by one level or more? Of
course this is essential to comprehend the points
being made in the intended context. Ideally, this
would be made more apparent by successive
indenting, but with 7 levels, the prose paragraphs
become too narrow! Yet it is straightforward to fix:

MS WORD offers “Outline Numbered” that
remains clear with many levels. A full seven layers
gets messy, but that is rarely encountered and at
least it is clear: 1.1.1.1.1.1.1. Without this or
something else explicit, readers have NO CHANCE
of discerning the relative hierarchy of the content.

To preclude this is unacceptable, an impediment
to readers’ understanding. WORD will add these
prefixes and update them automatically (I think; at
least it will show where they all are in Outline
view, and can then be added to text).

The comment is noted. Clarifications will be noted in
a redlined version of the DEIR.

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Packet Pg. 823 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 159
Letter Commenter Date Comment Combined Response
Individuals (C)
Names in headings are repetitive and thus unclear.

See e.g. Sec. 3.7 BIOL, (e.g p3.7-49 pdf=p 537)
starting below “SUMMARY OF IMPACTS” (& the
same applies throughout all elements). Each
individual “Impact” has only that word as a
heading, so they all look identical (in the layout,
but also in the TOC eventually). This is also true for
subsequent headings that are recurrent (I made a
TOC for 3.7 and the Headings are very repetitive,
minimally informative.) This prevents readers from
knowing where they are, or when scanning, from
keeping track. This is counter-productive and
awkward. Even if it is difficult to make the text for
all lower subheadings unique, at least do so with
heading level numberings that are included in the
body of the document. E.g. “Impact 3.7-1” should
be the Heading 4 for that item.

Placement of Figures and Tables inconvenient. In
my experience, cited graphics should always be
placed after text references. This helps the reader,
knowing to look down for the info. I encountered
some places were this was backwards. When the
text is finalized, this could be changed throughout
the documents relatively easily.

C30-
13 James
Kremer
2/20/22 III. Specific comments - EIR
-POLICIES wording do not agree within the EIR and
between it and the GP. In a significant number of
items, the same code is followed by different
statements. They have to be consistent. In some
cases, the same code ID is used for different and
unrelated policies. In one case just in the DEIR, a
specific policy is cited throughout the DEIR with 2
different ID codes. For example:

LU-I-14 “Hillside Preservation. Update the Hillside
Preservation District and the zoning map to ensure
that all steep and sensitive terrain is subject to
these regulations. The Hillside Preservation map
(Figure 4-4 of the proposed General Plan) should
be used as a guide.” [p E-15, E-78, E-104, E-142,

3.9-21.]
LU-I-12 “Hillside Preservation. Update the Hillside
Preservation District on the zoning map to ensure
that all steep and sensitive terrain is subject to
these regulations. The Hillside Preservation map
(Figure 4-4 of the General Plan) should be used as
a guide.” [p E-68, 3.1-27, 3.7-57, 3.12-36, 3.14.19.]
The comment is noted. Clarifications will be noted in
a redlined version of the DEIR.

C30-
14 James
Kremer
2/20/22 Policy CO-I-54 Climate Action Plan is referred to, and 5 bullets propose future goals to be done.

Why are these actions deferred? Baseline
inventory of sources, projected emissions by city
operations, feasible reduction measure sand –
most of all - an implementation plan – all these
Please see response to comment C125-7 for more
information on GHG, the CAP, and mitigation
measures.

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Packet Pg. 824 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 160
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Individuals (C)
seem appropriate PARTS of the planning process
that the GP is about.

These would properly be done ahead and
included, so they only need updating into the
future. To put this off obviates our chance to get
ahead of the curve! (Same policy also on p.3.3-35
(p317) in Table 3.3-

5. C30-
15 James
Kremer
2/20/22 -p.3.1-19 (p 217) Confusing process sequence. in Impact Summary: “following the adoption of the
proposed project the proposed project, the
specific plan in zoning ordinance, as well as other
safety policies and regulations, will be amended to
ensure consistency with the proposed project.”
The EIR seems to take total precedence. It must be
approved and then the rest brought into
compliance. But the construction of this EIR is
weird, and so how can this work? Citizens have NO
IDEA of what is happening, given the preeminent
1000 pg document they can’t review or
understand?
To clarify: The Proposed Project refers to the General
Plan and Specific Plan. Adopted policies, specific
plans, programs, the zoning code, and other
implementing tools will be amended to conform to
the adopted General Plan. Following adoption of the
General Plan, the specific plans and Zoning
Ordinance, as well as other City policies and
regulations, will be amended to ensure consistency
with the General Plan, which is the guiding
document.

C30-
16 James
Kremer
2/20/22 -Assertions stated but not explained. Policies listed in EIR & GP as reducing the impact significance are
stated but not these assertions are not explained
and justified. Inability to search text in PDF as
released badly complicates finding place where
this might be explained, but in the GP where text
can be searched also came up empty for any
discussion that might offer justification. Example: I
sought to understand how the Policies in Table ES3 in DEIR were explained with respect to their benefits claimed in the EIR. I followed one
example, policy LU-G-2. This policy is stated in
Table ES-3 of DEIR (p E-134, pdf p 14) but search
fails to return any mention elsewhere. Of course, it
is there, but very hard to find because the search
works only in the headings and tables – of the EIR
only– not in the explanatory text. Interestingly,
each specific policy is also listed verbatim in the
GP, yet a text search there for the Policy also
comes up empty. I was unable to find any
explanatory justification there either.

The comment is noted. A DEIR with interactive table
of contents was made available on the Plan Pacifica
website on February 14, 2022.

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Individuals (C)
C30-
17 James
Kremer
2/20/22 -sec 3.14 “p6” (real p. 778) Incorrect statement.

Local Hazard Mitig Plan: states “Pacifica’s …SMC
MHMP…updated 2021…identifies City’s hazards”.

That doc’s draft Fire Hazard map was empty and
DID NOT identify any hazard in the City as
incorrectly stated here; and despite being shown
that the map in the draft, this map was NOT
updated in the final MHMP. I’ve heard that the
MHMT is just a tool to facilitate funding. OK, but it
is incorrect to cite that error here. Later
substantive discussion (p. 781ff) refers repeatedly
to the MJ-LHMP which had minimal discussion of
Fire Hazard due to the vacuous Map, so these
should be checked for similar inaccuracy.

A clarification is made as follows: "Per the 2021 MJLHMP, Pacifica had no population or structures within very high wildland severity zones. At this time, CAL FIRE does not provide mapping data for high or
moderate fire risk zones in LRA."
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. 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.

C30-
18 James
Kremer
2/20/22 -sec 3.9, p3.9-11 (pdf p586) Misleading statement of HPD intent. Although sec 3 is “Visual Resources”
the justification for HPD in that ¶ is NOT limited to
that benefit, as the paragraph now reads. The text
of the HPD code states: [Intent is to:] “b. Help
protect people and property from all potentially
hazardous conditions particular to hillsides”. This
really should be be identified as the primary goal
of HPD and certainly not omitted entirely. The
paragraph as written does not represent the
emphasis of the HPD intent accurately. This is
misleading, even in a section on Visual Resources.

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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Letter Commenter Date Comment Combined Response
Individuals (C)
Note: Land Use sec. p4-13 (p74) does state this
better referring to Ch 3 & 8.

C30-
19 James
Kremer
2/20/22 3.7 BIOLOGICAL RESOURCES -EIR - I focused on this • Missing content. No mention of wildlife friendly
fencing, requested in NOP (EIR p 489).

Wildlife friendly fencing is addressed as policy CO-I31.

C30-
20 James
Kremer
2/20/22 >> CRLFrog, which is specifically mentioned in
NOP, has many errors and discrepancies:
• Inconsistent spelling: “red legged frog” is
misspelled, this spelling does not appear
elsewhere in sec. 3.7, it is often spelled “redlegged frog” or “Red-Legged Frog”. Citations have to follow source., but the doc should be consistent
This is a minor correction made to clarify and does
not affect the findings of the DEIR.

C30-
21 James
Kremer
2/20/22 • Inconsistencies between Figs, & between Figs
and text & Factual assertions
Fig. 3.7-3, p3.7-17 Figure errors: (Note: in G.P. Fig
7-3, p7-19, EXACTLY SAME MAP figure but
“Pacific” is not misspelled!?)
a) Pacific Ocean misspelled;
b) CRLF habitat not shown in Sharp Park Golf
Course, & other places yet specifically mentioned
elsewhere.
c) Missing source specification. CRLF has been
widely discussed in Golf Course preservations, and
is shown in GGNRA public info signs for the area.

Fig. 3.7-4, p3.7-23 (p512) Another depiction of
habitats, including CRLF
a) CRLF habitat shows differently from Fig. 3.7-3,
here with many specifics.
b) Key box does not match symbol on map.

KEY BOX: Zone marking in map (1 or many)
≠
p 3.7-50 (p538) Inconsistency. Text of the EIR
asserts the presence of CRLF in Sharp Park and
Mori Pt, BUT these habitat are not shown in Fig.

3.7-3 p.7-17 (p506) Table 3.7-1 is missing although
this Table is cited 3 times in Ch. 3.7. Perhaps the
mention of CRLF on p3.7-21 (PDF p509) is
intended? but it is not a real table, and not
identified as it. E.g. see mention on p3.7-33 (PDF
p521) where the table appears in a list “SpecialStatus Plants & animals.” The comment is noted; Fig. 3.7-3 shows critical
habitat, an official designation made by CDFW. Figure

3.7-4 shows occurrences of special status species.

Other map clarifications will be made in the redlined
version.

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Individuals (C)
C30-
22 James
Kremer
2/20/22 IV. BIBLIOGRAPHY - EIR
Citation of Sources are mostly incomplete. (This
comment applies to the GP also, and was included
in those comments as well.)
This is so pervasive and important, I feel I need to
justify my criticism. The convention employed in
GP & EIR would be unacceptable in any peerreviewed journal, or in agency funding proposals.

While abbreviated citations may be included inline
in text or figures (e.g.: Kremer and Nixon, 1975),
every one should appear later in a list complete
with details for the full source (e.g. document title,
date, authors, journal or agency). In all these docs,
however, abbreviated parenthetic citations are not
fully cited later, and the list of references does not
even include items cited in the body of the
document at all. This is not only unconventional,
but unacceptable, as the actual source of
fundamental information is not knowable.

Specifically:

Throughout the GP &EIR footnotes are given in
text, or for Tables and Figures, that do not specify
the actual source in sufficient detail. Example:
neither “Source: Dyett & Bhatia, 2021” in Table 1-1
(p1-4), or “San Mateo County, 2019” for map
Figure 7-4 (p7-43) gives the specific actual source.

If D&B have a document that the map was based
on, that exact document should be cited whether
inline, by footnote, or later in an itemized list of
citations. The citation is not in the Bibliography,
anywhere I looked, certainly not for Ch. 3.7 Biol.

Res.

A citation “IPCC, 2018” may be barely adequate,
although probably not, since certainly the IPCC
published more than one document in a given
year, so the one being cited is unknowable. But
“City of Pacifica, 2012” is insufficient–what does
this even refer to? Similarly, reference to “Dyett
and Bhatia, 2019” are simply not sufficiently
informative. This general problem compromises
virtually ALL tables and figures, and many text
footnotes.

Notice that “City of Pacifica, 2012” is listed twice in GP REFERENCES on p R-1 & only for sec 2.

Economic Sustainability and sec 4. Land Use but
not for sec 7. Conservation where Table 7-5, p7-42
(pdf p213) uses this phrase. How can the same
vague citation be adequate for these different
topics?
So, “REFERENCES” in the GP and “BIBLIOGRAPHY”
Ch 6 in the EIR include some that were used but
not cited elsewhere? The source information for
all the maps and tables and footnotes appear only
inline (where it is insufficiently specific). Adding
full citations for all to the appropriate sections of
The comment is noted. Please see Chapter 6 of the
Final EIR for clarification of citations in the
Bibliography. The City notes that Dyett & Bhatia is
the primary source for data or information when
listed is the source in maps and tables per MLA
standards. The comment does not pertain to the
adequacy of the environmental analysis.

The comment is noted; footnotes in text will be
updated accordingly in the Bibliography. Dyett &
Bhatia citation means that D&B was conducted map
and figure compilation and analysis. Bibliography
references will be updated to reference in-line
citations.

As noted on DEIR p. 3.5-10, the DEIR uses sea level
rise analysis from the 2018 Sea Level Rise
Vulnerability report. 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 an updated
methodology from 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 2100.25 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." This information is noted in a footnote but
will be updated to in the bibliography.

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Individuals (C)
both (probably all 3) documents is needed.

However, it is more confused. Some in the final list
ARE cited in the text body. See p 3-1-16 ftnt 2 is
“San Mateo County, San Mateo County General
Plan General Land Use Background Chapter, Page

7.1” and this exact citation appears in BIBLIO
including the partial italicization and BOTH have no
year. Repeatedly, however, “San Mateo County,
2021” or “County of San Mateo, 2009”, or other
years iare given as a source for figures (3.1-1, 3.1-
3, ) in this and other sections (3.2-1, …). Which one
is in BIBLIO, which are not? Not using “best
available data”? No recent references are cited for
especially time-sensitive technical Sections (3.4,

3.5, 3.6 & 3.7). I compiled all citations from the
entries in the Ch. 6 (p849-862). There are no
references since 2013. Oh my. While it is true that
inline footnotes and “Source” blocks in Figures and
Tables are not even included in the lest in EIR Ch.
6, they almost all are cited in an inadequately. I
didn’t include them in my graph. Climate sources
are especially inadequate. For Climate, an
especially time-sensitive topic for current range of
predictions of sea-level rise, the most recent
reference is 2014. The most recent IPCC
publication is the 4th Assessment Report in 2007
that was “accessed July, 2013” (p6-3) Another IPCC
doc from 2008 is a Synthesis for the 2007 report
(p6-4). The 5th Assessment Report (2014) was not
cited, and 6th Report some of which was dated
2021 are not either. Old forecast data are not
useful basis for planning. I am aware that we want
to pay special attention to explicit guidelines that
the State Coastal Act gives on sources acceptable
for risk assessments. I’m not sure what their
current positions are.

Citations with problems: (just the ones I stumbled
across…)
Sec 3.5 Hydrology & Flooding p6-4
• typo: year is not 3013! Coastal and Ocean
Working Group of the California Climate Action
Team (COCAT), State of California Sea Level Rise
Guidance Document, also available online
http://www.opc.ca.gov/webmaster/ftp/pdf/docs/
2013_SLR_Guidance_Update_FINAL1.pdf, March
3013 update.
• Listed twice. Coastal Environments, Tsunami
risks in the City of Pacifica, California: A
probabilistic approach, final Report by Hany
Elwany June 2007
• Stops mid citation (p6-6, pdf p853] Cowardin,
Carter, Golet and LaRoe. Classification of Wetlands
and…
• Out of order. Last 5 references cited in Biol. Res
bibio p6-11 (pdf p 858) Larson…Sparling
• No date, citation incomplete (& out of order).

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Individuals (C)
USFWS 5-year review of San Francisco garter snake
• Not the title in BIBLIO. “Sec 3.6 Geology Soils &
Seismic Risk” p3.6-1 (pdf p446) Not the title in
BIBLIO. “Geology & Seismicity” is there p6-11 (pdf
p858), AFTER Biol. Res (sec 3.7) So the section is
out of place in BIBLIO.

C30-
23 James
Kremer
2/20/22 V. Typos & Nit-picks - EIR
-p. E-2 typo: “the proposed General Plan includes
seven the seven elements”
p. 1-9 Intro (pdf p157) Redundant sentence.

TIMEFRAME ¶ has 3 sentences, the last of which is
redundant.
p. 3.1-4, Fig. 3.1-1 (p. 202) Map drafting error.

Beach fill pattern does not agree with that used on
Linda Mar Bch?
p 3.1-12 (p 210) Misleading assertion. LUP is not
technically under CCC review; last correspondence
in the public record the CCC says the document is
NOT suitable for consideration since the city has
not responded to the earlier CCC requests &
stipulations.
p 3.1-14, Fig 3.1-3, (p 212) Map drafting error.
“Sandy Beach” is not indicated at Pac St Bch.?! (&
this is the fill pattern used in the Fig. 3.1-1 but
This comment is noted. The following edits are made
for clarity:

DEIR p. E-2: "The proposed General Plan includes
seven the seven elements required by state law,
including, Land Use, Circulation, Housing,
Conservation, Open Space, Noise, and Safety.

Additional elements may be included as well, at the
discretion of the city. Optional elements for the
proposed General Plan include Economic
Development and Community Design."
DEIR p. 1-9: For analytic purposes in this EIR, the year 2020 is the base year (existing conditions), while the
year 2040 is the horizon year (future conditions)
when the proposed Pacifica General Plan will be fully
implemented. In cases where current data is not
available, the default is to use the latest known data

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Individuals (C)
incorrectly noted)
-- Possible Map error. Ridgelines seem
incomplete? Are there none in Milagra, North
Pacifica, or south near the southern border?
p 3.1-17 (p 215). Impact Criterion 2 of Significance
is worded unclearly. This may be “boiler plate” but
the terminal phrase is ambiguous. “…adopted for
the purpose…effect;” Who adopted? – the City or
the other agency?
sec 3.14 Wildfire - entire section repeated nearly
ver batim, starting real PDF p751 & 776. 2nd is a
bit different & looks like it is the right one?
sec 3.14 non-standard section numbering: pages
omit the section, i.e “1,2,3,4...). Should use 3.14-1,
etc.
sec 3.14 “p2” (real p. 751) Typo: Fig (Fire Threat)
should be 3.14-1 not 3.14-2 . This Fig. ref is correct
in the redundant section following (p776).
sec 3.14 “p7” (p. 779) Ungrammatical sentence
under SIGNIF CRITERIA: “Implementation…have an
impact..if located…in zones, it would:” =run-on
sentence
p3.3-56 (p 336) Footnote 2 dated “2012” is either
very old, or a typo for 2021 the previous note. This
affect the next citations too, both of which are ibid
and referring to the same very old ref..
p3.4-5 GHGs (p340) Poorly worded 1st sentence of
¶2: “remains under debate” is a poor choice of
words. Better to say “remains subject to poorly
understood uncertainty, so predictions must
consider a range.” This is not debate, it is science.
p3.4-7 (p342) The first 2 of 3 bullet points are
nearly irrelevant for Pacifica. This is someone’s
copied boiler-plate - is that what we paid for?
p3.4-23 (p358) Both footnote citations are
incorrect. FN34 does not agree with Biblio citation
p6-2,
(p849) in title or year; FN34 year disagrees–“US D
of E 2014” is shown as 2013 in Biblio (p6-3)
(p1013) http://www.afdc.energy.gov/fuels/
to depict the baseline (i.e., existing conditions). The Proposed Project
covers approximately a 20-year planning period, and
the year 2040 represents the last year of the plan
when projects/programs are anticipated to be fully
implemented.

DEIR p. 3.1-4, Figure 3.7-3:The comment is noted;
map edits will be made for clarity.

DEIR p. 3.1-12: 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.

DEIR p. 3.1-14, Figure 3.1-3:The comment is noted;
map edits will be made for clarity.

DEIR p. 3.1-17: This text has been directly taken from
CEQA, therefore no change required.

DEIR p. 3.14-1: The comment is noted. This issue was
resolved in the updated DEIR uploaded made
available on the Plan Pacifica website on February 14,
2022.

DEIR p. 3.14-1: The comment is noted. The issue with
numbering of the figure was resolved in the updated
DEIR uploaded made available on the Plan Pacifica
website on February 14, 2022.

DEIR p.3.14-7. The comment is noted.

DEIR p. 3.3-56: References will be updated to reflect
the latest data used in analysis.

DEIR p. 3.4-5: GCC is now generally accepted;
however, the precise extent and speed of change to
be expected, and the exact contribution from human
sources, remains under debate.

DEIR p. 3.4-7: The comment is noted.

DEIR p. 3.4-24: References will be updated to reflect
the latest data used in analysis.

References will also be updated to reflect the latest
data used in analysis. These edits do not change any
findings of significance.

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C31: Bradley Angel, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C31-1 Bradley Angel 3/7/22 Comments on Draft Environmental Impact Report for the Pacifica General Plan and Sharp Park Specific Plan
An Environmental Impact Report is supposed to
evaluate the potential impacts of the City of Pacifica’s General Plan and the Sharp Park Specific Plan. While
the Draft EIR contains a lot of information and
provides some good analysis, parts of it are deficient
and fail to fully evaluate some potential negative and
significant impacts of the two plans.

As 21-year Pacifica residents, homeowners and
taxpayers, we agree with the broad goal of the
general planning process to “create economic
development,” “support sustainable practices,” and
“preserve open space.” Very importantly, the plan
must protect our quality of life as the City strives to increase tourism and economic development. The
City must do better than it has it recent years to
protect the quality of life and preserve what makes
Pacifica a great place to live.

Open Space Preservation and Trail System Expansion
– and becoming a tourist destination We strongly
support Open Space Preservation. However, we have
concerns about the draft plan’s reference to “allowing
limited development” in areas that should remain
open space. The ocean, beaches and hills of Pacifica
are integral to our community’s identify. Our open
spaces and environment need to be preserved in
reality, not just in words in an EIR or plan.

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.

C31-2 Bradley Angel 3/7/22 Since the pandemic, the beach and area along Beach Boulevard have seen an enormous increase in
visitation by people coming to our community.

Unfortunately, the City has not kept up with the
resulting litter, illegal dumping, parking congestion,
and increased traffic including on neighborhood
streets including where we live. The EIR must address
and provide solutions for these negative and
significant impacts.

The comment is noted. Litter, illegal dumping,
parking congestion, and increased traffic are not
required topics of 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.

C31-3 Bradley Angel 3/7/22 Sustainable Development and Practices, including better zoning to protect the health and well-being of
residents We fully support green building and
sustainable development. We also support planning
that takes into consideration the reality of rising sea levels caused by climate change. Rising sea levels
need to be considered in all planning and permit
decisions.

The comment is noted. See response to comment
C13-3 for more information about coastal flooding
and sea level rise
C31-4 Bradley Angel 3/7/22 Pacifica should also work to reduce greenhouse gas emissions.

The comment is noted. As the comment does not
address the adequacy of the environmental analysis
contained in the DEIR, no further response is

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required. Analysis of GHG impacts are discussed in
DEIR Ch 3.4
C31-5 Bradley Angel 3/7/22 Rising Sea Levels and Beach Boulevard area development including Hotel Concept We applaud the
City for generally taking the threat posed by sea level rise caused by climate change seriously, but
unfortunately not seriously enough. As the State of
California’s scientists project that sea levels may rise up to 7 ½ feet by the end of the century (California
Coastal Commission) it is an invitation to economic
disaster and makes no sense to propose a hotel at the
site of the former wastewater treatment plant. Beach
Boulevard frequently is flooded, with waves
increasingly crashing into the street and even onto
the properties of Beach Boulevard homes. The City
should explore a more appropriate use of that
property such as a modest ocean-front seafood
restaurant or food-truck space that would not have
the size, footprint or infrastructure that a hotel would have.

The comment is noted. Please see response to
comment C13-3 for more information about coastal
flooding and sea level rise.

C31-6 Bradley Angel 3/7/22 In west Sharp Park, the failing shoreline protection (aka “seawall”) has not been reinforced, and the
vulnerable infrastructure behind it has not been
moved. Instead of proposing to scale back 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 five-story 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.

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.

C31-7 Bradley Angel 3/7/22 Sharp Park Specific Plan Visualization The visualization developed by consultants of what
Palmetto and adjacent buildings might look like is a
portrayal of ugly, box architecture with zero
architectural and cultural appeal. We totally oppose
the idea for tall, multi-story buildings higher than
what is currently in existence. We do not need, and
do not want, four or five story buildings in our
neighborhood. We do not want high density
buildings. This would completely change the character
of the neighborhood in a terrible way, adding
eyesores, blocked views, and congestion.

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.

C31-8 Bradley Angel 3/7/22 Affordable Housing and Diversity Pacifica needs substantially more truly affordable
housing. As home prices and rental prices in Pacifica
continue to soar, our community is becoming yet
another San Francisco area community that is no
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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longer accessible to low income and working class
people and families. Proposing building more housing
without rent control will make the goal of a
sustainable and affordable community impossible to
achieve. The goal of population diversity is truly at
risk. Pacifica already lacks racial diversity, and the cost of housing is an enormous obstacle to a truly diverse
community.

Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C31-9 Bradley Angel 3/7/22 Land Use, Appropriate Zoning, Code Enforcement, Environmental Reviews
The Plan must ensure that the City start properly
managing and properly regulating land use. For
example, an active Recology facility is located on our
residential street, Pacific Avenue and has been a
source of concern for many residents. City staff was
unable to provide us with copies of any use or
operating permit the facility might have – and we
were told there were none. It also appears that the
Recology facility never underwent any environmental
review despite emissions into the environment and
despite being located on a residential street.

There has been little to no oversight of their
operations despite their operations frequently
constituting a nuisance and emitter of pollutants into
our neighborhood. Up until a few years ago, Recology
regularly had their trucks line up in front of our
homes. The trucks would illegally idle their engines,
and the facility manager curiously claimed she was
not aware of the laws restricting and regulating idling.

It was only after we documented the idl ing, filed
complaints with the Bay Area Air Quality
Management District, complained directly to the
facility manager, and threatened to take legal and
public action to shut the facility that the idling
stopped. Where was the City?
However other problems continued, including noxious
odors from operations inside their facility and on the
public sidewalk. In the last two months the problem
has improved somewhat due solely to our complaints
to the City and Bay Area Air Quality Management
District. Recology often has used the public sidewalk
as a place they use for their business operations.

Employee and company vehicles have often been
parked partially on the sidewalk, forcing pedestrians
to walk in the street – clearly a safety hazard. Last
year Recology had a truck sized container on Palmetto
just south of Pacific Avenue for many months,
blocking the view for motorists when turning from
Pacific onto Palmetto. Did Recology apply for and
receive a permit to leave this on the public street for months? I am sure residents are not allowed to use
the public street and block the public sidewalk for
their own purposes as an ongoing practice.

The comment is noted. The City implements a
variety of local, State and federal regulations
designed to address the use, transportation, and
disposal of these materials. Although such activities
are relatively well regulated and monitored,
accidental release due to accidents, misuse or
natural disasters (e.g., earthquakes) could occur.

Additional residential, commercial, and industrial
development resulting from buildout of the
Proposed Project would likely increase the amount
of hazardous materials transported, used or
disposed of in the City. Although a number of
businesses in the Planning Area routinely store,
handle, and transport hazardous substances, the
use of these hazardous materials is controlled and
permitted by San Mateo County’s Toxic Programs
and regulations, and otherwise ensures that risks
associated with the use of hazardous materials in
the community are minimized.

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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In addition, Recology was able to get away with not
maintaining the corner landscaping on Palmetto and
Pacific Avenue. For almost a year it was essentially an abandoned, weed covered lot, despite Recology’s
promise to the city to maintain the lot as part of
neighborhood improvements in exchange for the
public relations signage. It was only after we
complained to the Mayor and City Council that the
company finally cleared the weeds. It is obvious the
city looks the other way when it comes to Recology,
favoring a big corporation over the health and wellbeing of residents.

C31-
10 Bradley Angel 3/7/22 The Draft EIR fails to address the reality of these types of situations and identify potential and actual
significant negative impacts.

The City’s Plan and Zoning ordinance should learn
from these problems and prohibit industrial activities
on residential streets and require environmental
reviews for businesses that have the potential to
impact the community and environment.

As shown in the Proposed Land Use Diagram, no
areas of industrial use are proposed as part of the
General Plan; however, commercial service uses or
other commercial uses may use or transport
hazardous materials. CEQA requires analysis of how
implementation of the proposed Pacifica General
Plan and SPSP could create a significant hazard to
the public or the environment through reasonably
foreseeable upset and accident conditions involving
the release of hazardous materials into the
environment (Impact 3.11-2).

As noted, The City implements a variety of local,
State and federal regulations designed to address
the use, transportation, and disposal of these
materials. although such activities are relatively
well regulated and monitored, accidental release
due to accidents, misuse or natural disasters (e.g.,
earthquakes) could occur. Additional residential,
commercial, and industrial development resulting
from buildout of the Proposed Project would likely
increase the amount of hazardous materials
transported, used or disposed of in the City.

Although a number of businesses in the Planning
Area routinely store, handle, and transport
hazardous substances, the use of these hazardous
materials is controlled and permitted by San Mateo
County’s Toxic Programs and regulations, and
otherwise ensures that risks associated with the use
of hazardous materials in the community are
minimized. Furthermore, the proposed Plan
includes several policies, set forth below, that have
been developed to ensure a safe environment for
its residents, visitors, and businesses. Policies in the Proposed Plan that also reduce impacts include
enforcement of NDPES permits (SA-I-19) and
protection against oil and hazardous substance
spills (CO-I-18).

C31-
11 Bradley Angel 3/7/22 To show that it is serious about protecting community health and sustainability while supporting businesses
and economic development, the City should work
with Recology to relocate the Pacific Avenue facility to 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

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Packet Pg. 835 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 171
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a more appropriate location.

As the City Plan calls for increased economic
development, this must be accompanied by proper
environmental review, proper permitting processes
with opportunities for public participation,
enforcement against violations of permits or other
laws, and appropriate siting of businesses to avoid
negative impacts on the health and well-being of
residents.

Recreational Opportunities and Activities for Youth
We support increased opportunities, activities and
facilities for the youth of our community.
under the proposed Plan, all of which are required
to comply with CEQA as applicable.

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C32: Andrew Meiman, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C32-1 Andrew
Meiman
3/7/22 We have lived on Pedro Point for 17 years, raising our kids here, and enjoying all the natural beauty and
outdoor recreation that Pacifica, and Pedro Point in
particular, provides. Unfortunately, the GPU and the
Draft EIR threaten those very items that make the
Point special. We disagree with the Land Use
designation change for the Pedro Point Field to
Coastal Residential Mixed Use (CRMU). It will
negatively impact the quality of life for us and our
family in many ways.

Additionally, as long-term residents of Pacifica who
plan to live here the rest of our days, I don't want the City, or my community, to be stuck with the costs and
impacts of a housing development built on a wetland
next to a rising sea.

We fully support the comments of Pedro Point
Community Association and the many other
community members from the neighborhood and
beyond that recommend a more appropriate land use
designation such as Low-Intensity Visitor Serving
Commercial.

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.

T. Please see Master Response 6: ESHA for more
information on how implementation of the
Proposed Project will have a less than significant
impact on wetlands, which are classified ESHA
under the Coastal Act. Please see Master Response
4: Undeveloped San Pedro Ave Sites for more
information on how compliance with federal, state,
and local regulations, as well as Proposed Project
policies, reduce the impact to less than significant.

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C33: Richard Campbell, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C33-1 Richard
Campbell
3/8/22 Planning for a City that the State wishes to grow by nearly 2,000 homes (i.e., the Regional Housing
Needs Allocation) necessitates careful consideration
of a wide variety of environmental issues, including
water supply. The City must take into consideration,
and provide itself the flexibility, to limit water
consumption for new development so that it does
not over-build relative to available water supply.

The DEIR correctly used a reasonably foreseeable
forecast of buildout under the Proposed Project as
the basis for the environmental analysis. The
adequacy of buildout and more information about
why RHNA estimates were not included can be
found in Master Response 3: Buildout and RHNA.

C33-2 Richard
Campbell
3/8/22 The City’s environmental review of the General Plan should involve a review of NCCWD’s Urban Water
Management Plan (UWMP), which NCCWD. The City
environmental review should reflect a consideration
of projected water supplies in NCCWD’s recently
updated 2020 UWMP, released in June of 2001, as
part of this new General Plan.

See response to comment C9-26.

C33-3 Richard
Campbell
3/8/22 In the draft General Plan, the City indicates it will undertake a planning and community engagement
process to update the Housing Element and
accommodate its 6th Cycle Regional Housing Needs
Allocation (RHNA 6) of 1,892 housing units following
adoption of the other required elements of the
General Plan. Adoption of a Housing Element to
reflect RHNA 6 must occur by January 31, 2023. The
City must do more now to link the available supply
of water, and projected water shortages discussed
in the 2020 UWMP, to the Housing Element under
development as well as the current 5th Cycle RHNA
(RHNA 5) currently in effect.

Please see response to comment C33-1.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. Please see Master Response 3:

Buildout and RHNA for more information.

C33-4 Richard
Campbell
3/8/22 NCCWD acknowledged in its 2020 UWMP (pg. 3)
that:

This Plan provides information specific to water
management and planning by the District. However,
water management does not happen in isolation;
there are other planning processes that integrate
with the UWMP to accomplish urban planning.

Some of these relevant planning documents include
relevant city and county General Plans, District
Water Master Plans, recycled water facility plans,
integrated resource plans, Integrated Regional
Water Management Plans, and others.

This Plan is informed by and helps to inform these
other planning efforts. In particular, this Plan
utilizes information contained in General Plans,
climate action plans, local hazard mitigation plans,
and local and regional water resource plans to the
extent data from these plans are applicable and
available. (Emphasis added.)
Yet, the City does not acknowledge this 2020
UWMP, nor address water supply, or even make
The DEIR acknowledges and references NCCWD's
2020 UWMP. See response to comment C9-26.

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mention of NCCWD. NCCWD has it right: The City
must integrate water management to effectively
accomplish urban planning. To not do so,
particularly as we head into year three of a
megadrought of unknown duration, is the definition
of arbitrary and capricious decision-making.

Whether the City acts in an arbitrary and capricious
manner is measured by what the City knew at the
time the General Plan (and the Housing Element) is
adopted. And the City is aware of the possibility of
significant shortfalls in water supply from the 2020
UWMP. Thus, the availability of adequate waters
supply to accomplish the City’s land use and
housing goals must be addressed as part of its
environmental review.

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C34: Richard Grassetti, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C34-1 Richard
Grassetti
3/8/22 Grassetti Environmental Consulting (GECo) is
submitting this comment letter on behalf of the Pedro
Point Community Association (PPCA). As Principal of
GECo, I have prepared these comments based on my
40 years of experience preparing and reviewing
California Environmental Quality Act (CEQA)
documents. A copy of my CV is attached.

Summary of Findings
The PPCA requested a thorough evaluation of the
potential effects of the General Plan Update (“GPU” or
“the Project”) on the undeveloped San Pedro Avenue
Site (“the Site” or “San Pedro Avenue Site”). This letter identifies deficiencies in the General Plan Update Draft EIR (“DEIR”) with respect to the Site. It is based on my reading of the proposed GPU and DEIR, as well as a
review of sensitive resources and hazards from
available sources. General deficiencies are described
first, followed by some specific comments on the
adequacy of technical analyses. Under CEQA, the GPU
DEIR must focus not only on the direct impacts, but
also on the secondary effects that will follow from
adoption of the General Plan update (CEQA Guideline
15146). The City is not relieved from considering
reasonably foreseeable impacts of the Project on
specific parcels, including the Site here. Given the
voluminous information provided by experts on the
undeveloped San Pedro Avenue Site, including
extremely detailed evidence presented in the California Coastal Commission 2020 Staff Report on the Rhodes
Mixed Use Development (“CCC Staff Report”) proposed
for the Site, this GPU and DEIR must consider that
information, submitted herewith. The land use
designations are the heart of the General Plan. Because the General Plan serves as “the constitution for all
future developments” within the City once a land use
for a site is designated, applicants have certain
development rights. Therefore it is essential that the
City of Pacifica (“City”) fully consider environmental
values and constraints prior to re-designating parcels, not after a parcel is redesignated. This GPU fails to do that, and, as detailed below, the DEIR fails to
adequately or accurately assess impacts of the
proposed re-designation of the undeveloped San Pedro
Avenue Site.

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.

The DEIR does consider impacts resulting from a
land use change designation; impacts related to
flooding, biological resources, and others are
adequately analyzed in the DEIR. Please see Master
Response 4: Undeveloped San Pedro Ave Sites for
more information.

C34-2 Richard
Grassetti
3/8/22 Inadequacy of Project Description
The DEIR must present a clear and stable project
description. The DEIR’s project description is
inadequate because it fails to narratively or graphically identify which specific areas/parcels would be redesignated or changed by the Project. Instead, the DEIR focuses solely on general buildout numbers, as if site
conditions were uniform throughout the City.) This
The Proposed Project land use is shown in Figure

2.2-1. The existing Project Land Use is shown in
Figure 3.1-1. Comparison of these two maps shows
land use designation changes. The Proposed Project
provides concentrated and compact development
primarily in already developed areas, with policies
to provide more linkages and enhanced connectivity
within and between those areas. As noted on DEIR

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failure makes it very difficult for the reader to
understand how various areas of the City would be
affected by implementation of the proposed Project.
p. 3.1-20, the “Proposed Project includes new land
use designations that replace older and more
generic land use designations in the same or nearby
areas; the new land use designations accommodate
more diverse housing types, densities, and
commercial developments, primarily in alreadydeveloped areas. There are three mixed use classifications to create areas where housing and
active commercial uses may be integrated.” As
shown in Table 2.4-2, approximately 76 percent of
new units are projected to occur in these new
mixed use classifications, shown in Figure 2.2-1. The
remaining units would be accommodated in smaller
vacant “infill” lots found primarily in the West Sharp
Park, East Sharp Park, Westview-Pacific Highlands,
Rockaway, and Pedro Point neighborhoods; these
vacant parcels are shown on the existing land use
map, Figure 3.1-1. Given environmental factors such
as slope and sensitive species, there are some
constraints on the development potential of these
sites.

C34-3 Richard
Grassetti
3/8/22 DEIR Land Use Chapter 3.1 does include a very smallscale map of existing land use designations, which, critically shows the undeveloped San Pedro Avenue
Site land use designation as “Commercial” but omits
consideration that the Site is zoned “Commercial
Recreation”. The General Plan states, “The land directly west of the Pedro Point Shopping Center was identified
as a commercial recreation site in the previous General Plan, and has been zoned for general commercial
uses.” By failing to include this information, the DEIR does not serve its informational disclosure
requirement. The public should not be forced to ferret
out information and connect the dots to understand
the Project and its impacts. This combination of
incomplete and incorrect information renders the DEIR
Project Description useless as the basis for determining impacts of the proposed GPU. Given the limited
number of sites proposed for designation changes in
the GPU, the DEIR should clearly identify them
narratively and graphically, and include
Zoning is a tool to implement land use; any rezoning
would occur after the Proposed Plan is adopted.

Omission of zoning descriptions thus do not
represent a withholding or inadequacy.

Additionally, 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.

C34-4 Richard
Grassetti
3/8/22 Further, the DEIR project description compares the Project to the existing plan, but does not provide the
necessary information on existing on-the-ground
conditions from which to conduct the impact
assessment. With limited exceptions, CEQA does not
permit plan-to-plan analyses. Per the CEQA Guidelines
(Section. 15126.2) “In assessing the impact of a
proposed project on the environment, the lead agency
should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published, or where no notice of preparation is published, at the
time environmental analysis is commenced.”
The DEIR does include existing, on-the-ground land
use; these uses are shown in Figure 3.1-1. The
commenter does not provide an example of a "planto-plan" analysis. All "Environmental Settings" chapters describe existing, on-the-ground
conditions for each of the corresponding chapters.

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C34-5 Richard
Grassetti
3/8/22 In order to adequately evaluate environmental
impacts, the DEIR must identify which parcels are
undeveloped, what their existing physical condition is, and how conditions would change with reasonably
foreseeable development allowed under the proposed
Project. The actual impacts would be the difference
between the existing undeveloped state and full
development of a site under the new designation.

The DEIR describes and maps vacant and
undeveloped land on DEIR p. 3.1-2 through 3.1-4. As
noted in Master Response 3: Buildout and RHNA,
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 nonresidential 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. 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.

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

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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. All settings sections in
the DEIR describe how implementation of the
Proposed Project could generate significant impacts
over current conditions and describes federal, state,
and local regulations and policies to reduce those
impacts.

C34-6 Richard
Grassetti
3/8/22 Inadequate Project Objectives
The DEIR’s stated Project Objectives (pp. 2-9 and 2-10) are so general and vague that they cannot be
effectively used to fulfill their primary purpose, namely to guide development and assessment of an adequate
range of alternatives.

The assertion that the project objectives are vague
is unfounded. As described in CEQA, "A clearly
written statement of objectives will help the lead
agency develop a reasonable range of alternatives
to evaluate in the EIR and will aid the decision
makers in preparing findings or a statement of
overriding considerations, if necessary. The
statement of objectives should include the
underlying purpose of the project and may describe
project benefits." These objectives informed
development of reasonable DEIR alternatives as
described in Chapter 4.

C34-7 Richard
Grassetti
3/8/22 This deficiency is reflected in the Alternatives chapter (p. 4-2), which substitutes three different “criteria” for use in developing and selecting project alternatives
(although those criteria are similarly vague and
generic).

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

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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 visitororiented center for Pacifica, and a series of commercial nodes throughout the city; while
Alternative B, Multi-Centered, 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".

C34-8 Richard
Grassetti
3/15/2
2 Inadequacy of Impact and Mitigation Discussion
The DEIR fails to disclose that the undeveloped San
Pedro Avenue Site is currently zoned commercial
recreation, with a floor area ratio (FAR) of 0.2, which means that total development footage cannot exceed
20% of the site area. This current designation promotes non-intensive recreational use of the Site, retaining
most of the Site in open space. If, for example, a 2-
story recreational facility were constructed, only 10%of the San Pedro Avenue Site would be disturbed, and
sensitive resources and environmental hazards on the
remainder of the Site could be avoided.

The GPU would re-designate the Site as Coastal
Residential Mixed Use, which would allow housing or
commercial uses at an FAR of 0.5 (DEIR Figure 2.1-2 and table 2.3-
1). That FAR does not include roads or parking, which
could result in further environmental impacts. The DEIR fails entirely to address potential Project impacts at this Site, and never even mentions the Site in its impact
analyses.

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.)
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.

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C34-9 Richard
Grassetti
3/8/22 For most topics, the DEIR only provides overgeneralized statements of impacts, lists plan policies, and then assumes – without explanation - that the
policies would effectively reduce all impacts to lessthan-significant levels, without any analysis of the prepolicy impact or the actual applicability and effectiveness of the policies to the impact. In contrast, for traffic, the DEIR does conduct an intersectionspecific assessment. This shows that it is possible for the DEIR to conduct a site-level analysis for the areas where changes in land use are proposed. The DEIR
should be revised to conduct those analyses for all of
the resource categories.

The commenter's assertion is unfounded. 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. The commenter
does not cite specific examples in this comment of
where analysis is inadequate. As noted in CEQA
Guidelines Article 10, 15142, qualitative analysis is
permitted: "An EIR shall be prepared using an
interdisciplinary approach which will ensure the
integrated use of the natural and social sciences and
the consideration of qualitative as well as
quantitative factors."
The DEIR includes an adequate environmental
setting description. It describes the existing local
and regional physical environment, as it existed
when the notice of preparation of the EIR was
published in September 2020. This specific
comment does not highlight any specific examples
of inadequate environmental settings.

The DEIR adequately addresses Project impacts for
each of the required topics under CEQA. The DEIR
analyzes the impact of the policies by focusing on
where and what type of development the plan
would allow. Then it also considered the beneficial
impacts of the policies and the extent to which they
would reduce or avoid impacts in conjunction with
existing regulations. 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.

Impacts on intersections does not represent a sitespecific analysis; it analyzes effects of cumulative buildout under the Proposed Plan and projects
future traffic flows. Air quality, Energy and GHG,
Noise, and Public Utilities all take this similar
cumulative Citywide approach.

C34-10 Richard
Grassetti
3/8/22 In short, the DEIR fails to go through CEQA’s required steps of first disclosing impacts and whether those
impacts are potentially significant, and only then
discussing proposed mitigation measures including
their feasibility. As the court stated in Trisha Lee Lotus v. Department of Transportation:
“The purposes of Section 21801 are that there be some
evidence that the alternatives or mitigation measures
in the EIR were considered by the decision-making
agency and, as the Supreme Court stated in a similar
situation, that there be a disclosure of the analytic
The commenter's allegation that the DEIR did not
adequately analyze impacts is untrue. Each of the
analysis chapters in the DEIR include an
environmental settings section, which describes onthe-ground conditions. Impacts analysis focused on how where and what type of development the plan
allows might lead to significant impacts for CEQArequired topics. Then, it also considered the beneficial impacts of the policies and the extent to
which they would reduce or avoid impacts in
conjunction with existing regulations. Proposed

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route the…. agency traveled from evidence to action.”
And, “The EIR does not, however, include any
information that enables the reader to evaluate the
significance of these impacts.” (p.13) “Caltrans
compounds this omission by incorporating the
proposed mitigation measures into its description of
the project and then concluding that any potential
impacts from the project will be less than significant. As the trial court held, the “avoidance, minimization,
and/or mitigation measures”, as they are characterized
in the EIR, are not “part of the project”. By compressing the analysis of impacts and mitigation measures into a
single issue, the EIR disregards the requirements of
CEQA.” (p. 15).

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.

C34-11 Richard
Grassetti
3/8/22 Here, the proposed changes in land use designations would cause the loss of biological resources,
recreational resources, and flood storage from the Site.

The DEIR must first disclose and analyze those impacts, determine the significance of each impact, and then
discuss whether and how general plan policies and
mitigation would reduce the impact. The applicability
of policies must be identified, as well as their
effectiveness. If policies are assumed to be mitigation, then they must be presented in a manner that assures
their implementation on any particular site.

Please see also responses to Comment C34-17 and
C46-46. 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.

Please also see response to comment C34-11 for
more information about policies that reduce the
impacts.

The DEIR analyzes impacts to potential biological
resources in Chapter 3.7, flooding in Chapter 3.5,
and parks, public services, and facilities in Chapter

3.12. Please see Master Response 4: Undeveloped
San Pedro Ave Sites for more information on.

C34-12 Richard
Grassetti
3/8/22 California courts have made it clear1 that cities are not obligated to implement all of the General Plan’s
policies applicable to a site, therefore the GPU’s
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

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proposed policies cannot be assumed to mitigate for
development of a site under the GP.
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. Some objective policies require
implementation, such as those that require specific
studies, or that would be implemented through
zoning changes.

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, projectlevel 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.

C34-13 Richard
Grassetti
3/8/22 Further, applicable measures must be included in a Mitigation Monitoring and Reporting Program. At a
planning level, a more effective, enforceable,
monitorable, mitigation would be to change the
undeveloped San Pedro Avenue Site land use
designation to Open Space or retain the 0.2 FAR
Commercial-Recreation designation, rather than the
proposed intense 0.5 FAR designation.

The comment is noted. Mitigation measures will be
included in an MMRP. The commenter's opinion on
site-specific mitigation measures is noted; however,
programmatic-level impacts are assessed in the
DEIR; not site-specific impacts. Please see response
to comment C30-5 and C34-12 for more
information, as well as Master Response 2:

Programmatic EIR, and Master Response 4:

Undeveloped San Pedro Avenue Sites.

C34-14 Richard
Grassetti
3/8/22 However, given CEQA’s requirement to compare
impacts of a project (or plan) to existing on-the-ground conditions, impacts of development even at an FAR of

0.2 must be assessed, and mitigated to the extent
feasible. This is particularly important given CEQA’s
infill exemptions. It is likely that, for some of the sites, no additional CEQA review will occur, and the impacts
will not be addressed at all. This DEIR’s lack of detailed analysis would allow the City to play a shell game in
deferring analysis that may never occur, and thereby
fails to meet CEQA’s purpose of full disclosure.

Please see Master Response 3: Buildout and RHNA
for more information on the adequacy of buildout
projections.

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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. These projects may, however,
use the discussion of impacts in this EIR as a basis of their assessment of these regional, citywide, or
cumulative impacts. Please see comment C34-12 for
more information on project-level review in areas
with known sensitivities or hazards. 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.

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C34-15 Richard
Grassetti
3/8/22 In summary, the DEIR fails to address the impacts of land use changes proposed under the GPU because it
concludes that GPU policies would mitigate any
undisclosed impacts. In essence, the DEIR claims that
the Project would mitigate itself – despite the fact that there may be significant unmitigable impacts of
implementing the proposed land use designations on a
given site, as is the case for the undeveloped San Pedro Avenue Site.

The DEIR analyzes effects implementation of the
locations, proposed land uses, land uses and
buildout estimate under proposed under the
Proposed Plan. Please see Master Response 3:

Buildout and RHNA for more information. Each of
the analysis chapters in the DEIR include an
environmental settings section, which describes onthe-ground conditions. Impacts analysis focused on how where and what type of development the plan
allows might lead to significant impacts for CEQArequired topics. Then, it also considered the beneficial impacts of the policies and the extent to
which they would reduce or avoid impacts in
conjunction with existing regulations. 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.

Please see response to comment C34-12. 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, projectlevel 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.

C34-16 Richard
Grassetti
3/8/22 A City may approve a project if it “substantially complies” with the planning policies– full compliance is not required. This means that assuming full
implementation of policies is a best-case scenario, not a likely scenario as required for CEQA review.

Please see response to comment C34-12
C34-17 Richard
Grassetti
3/8/22 Also, many of the plan policies are couched in language such as “to the extent feasible”, “strive to”, “study”, “consult with”, ‘coordinate with” and similar vague,
non-committal terms that fail to assure that mitigation will be implemented or, if implemented, will be
successful in reducing a project’s impacts to a lessThe DEIR identifies the potential environmental impacts that could result from implementation of
the Proposed Project and discusses the effects that
existing regulations and Proposed Project policies
would have in reducing or avoiding those impacts.

In cases where compliance with existing regulations

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thansignificant level. There are numerous examples of
this in the Plan, including Policies CO-G-3, CO-I-1, CO-G4, CO-I-19-23, SA-I-29, SA-I-109, SA-I-12, and many, many more. In addition, as can be seen in these
examples and many others, in many cases, the City
relies on policies that assume mitigation by other
agencies and jurisdictions over which it has no control. and implementation of Proposed Project policies
would not reduce a potentially significant impact to
a less than significant level, the DEIR recommends
feasible mitigation measures and makes a finding of
significance after implementation of mitigation.

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. Further,
the City notes that subsequent projects pursuant to
the Proposed Project will be required to conducted
separate project-level CEQA review to the extent
they may result in impacts not considered in the
DEIR.

Please see response to comment x for more
information on agency responsibility.

C34-18 Richard
Grassetti
3/8/22 Under CEQA mitigation measures must include
performance standards, rather than just aspirational
goals or deferred studies. The DEIR must also translate these policies to enforceable measures before it can
consider any potentially significant impacts to have
been mitigated to less than significant.

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. Please see response to comment C34-12.

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, projectlevel 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 and any required mitigation 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.

C34-19 Richard
Grassetti
3/8/22 The City is required to comply with SB379 as stated in Chapter 1.2, General Plan Requirements: “Climate
Change Adaptation and Resiliency Legislation (SB
The comment is noted. Please see Master Response
1 for more information on GP-related responses.

Climate change and requirements for SB379 are

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379)…requires the safety elements of general plans to
be reviewed and updated to include climate adaptation
and resiliency strategies.” SB379 further requires the
identification of hazard zones that can serve as
mitigation areas for said hazards. Despite this
requirement, the GPU and the DEIR fail to identify any
properties in Pacifica for such mitigation. It is also
insufficient to only set “Coastal Resiliency Policies” but not designate appropriate resiliency sites/areas; areas like the undeveloped San Pedro Avenue Site would
qualify to be designated as hazard mitigation sites due to its many hazard vulnerabilities and ESHA
designation.
included in the MJ-LHMP, incorporated by
reference into the Pacifica GP. 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).

Impacts to sensitive communities, including ESHA,
are described on p. 3.7-49, Impact 3.7-1. The DEIR
describes special status wildlife in the Planning
Area. All federally and state threatened species are
protected under the Federal Endangered Species
Act and California Endangered Species Act,
respectively. For specific development projects
under the Proposed Project, consultation may be
required with USFWS by FESA, and/or with the
California DFW by ESA. 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. Specific provisions of the Coastal
Act, as implemented within the Local Coastal
Program, as they relate to wetlands and other ESHA
are described in the section on Local Ordinances
Plans and Policies. Please see Master Response 6:

ESHA for more information on ESHA on this site.

C34-20 Richard
Grassetti
3/8/22 In addition to rendering the DEIR inadequate, these omissions subvert the basic purpose of planning, which
is to plan so that appropriate land uses can be located so as to avoid or minimize environmental impacts.

Rather than plan for sensitive sites such as the
undeveloped San Pedro Avenue Site, as detailed below,
the City is proposing to adopt non-protective land uses (at the Site, Coastal Residential Mixed Use) and then
use general policies (full compliance with which is not mandatory) relying mostly on deferred studies to
reduce impacts. This approach (and the underlying
DEIR) is inadequate because it uses magical thinking - in theory, the plan policies reduce all impacts to less than significant in spite of on-the-ground evidence to the
contrary – rather than evidence-based analyses.

Please see response to comment 34-12.

C34-21 Richard
Grassetti
3/8/22 Criteria of Significance/Topics Addressed
As detailed in specific comments below, the DEIR fails
to focus its impact analysis to reasonably foreseeable
types of impacts. Instead, the impacts are just the same questions in the standard Initial Study checklist. This is an EIR, not an Initial Study. This DEIR is required to
identify and focus on impacts of importance, not the
items in the CEQA Initial Study checklist. For example, impacts and mitigation measures should be called out
for each special-status species that may be affected by buildout of the plan.

This claim of inadequate analysis is unsubstantiated.

Potential impacts for each of the three special
status species in Pacifica are described on DEIR p.

3.7-49 and 3.7-50. 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

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status species’ habitat. Individual special status
species requirements for steelhead (CO-G-9; CO-I-1)
California red legged frog and San Francisco garter
snake (CO-I-37; CO-I-44) are included in the General
Plan.

C34-22 Richard
Grassetti
3/8/22 Specific Comments
We have reviewed the Land Use, Hydrology, Geology,
Recreation, and Alternatives sections of the DEIR with
respect to CEQA adequacy. Our comments on those
sections are summarized below. We understand that
biological resources issues are addressed under
separate cover in an expert letter from Dr. Peter Baye, coastal ecologist. The general issues of lack of adequate impact/mitigation analyses, as detailed above, apply to all sections; some representative specific examples of
these deficiencies that appear in the sections that we
reviewed in detail are presented below.

Please see comments C34-12 and C134-1 for more
information on the general adequacy of analysis in
the DEIR. Specific examples referenced will be
addressed below in response to comments C23-23,
24, and 25.

C34-23 Richard
Grassetti
3/8/22 Biological Resources
As noted in a letter submitted separately by Dr. Peter
Baye, the site is valuable habitat for a number of
special status species. In addition, habitat values and flooding hazards for the adjoining Rhodes development
site, which extend onto the San Pedro Avenue Site, are
presented in painstaking detail by expert technical
specialists in the California Coastal Commission’s Staff Report for the proposed development of that site (CDP
Application 2-19-0026, dated 2/18/2021), which was
never referenced or considered in this DEIR. Willful
omission of this critical information on its face renders this DEIR invalid.

This DEIR does not accurately disclose the San Pedro
Avenue Site’s conditions as part of the environmental
setting, disclose project impacts, nor discuss the
effectiveness of plan policies as mitigation. For
example, Figure 3.7-3 in the Biological Resources
chapter shows this Site as having no sensitive or critical habitat values, yet evidence by Dr. Peter Baye as well
as that provided by the Coastal Commission’s expert
biologists shows that it does have sensitive species and habitats. The CCC Staff Report for the adjacent Rhodes
project site considers that entire site to be an
Environmentally Sensitive Habitat Area (“ESHA”), and
similar habitat exists on the San Pedro Avenue Site,
making it likely that that Site also would be ESHA.

Similarly, the DEIR focuses on the National Wetlands
Inventory while excluding detailed wetlands mapping
of this Site, thereby rejecting on-the-ground analyses in favor of large-scale remote mapping (see Figure 3.7-2).

The CCC Staff Report on the Rhodes site further
identifies the undeveloped San Pedro Avenue Site as
“likely wetlands” (see Figures 1a and 1b, on p. 134 of
the CCC Staff Report).

Similarly, as described in the CCC Staff Report, a
California Red Legged Frog (“CRLF”) was found in the
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.

Please see Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro Ave Sites for
more information on how compliance with federal,
state, and local regulations, in addition to Proposed
Plan policies ,reduce impacts to less than significant, regardless of the final determination.

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drainage separating the undeveloped San Pedro
Avenue Site from the Rhodes site, and would clearly
have important habitat on the San Pedro Avenue Site
(see CCC Staff Report Figure 2, on p. 134). Further,
given that the frog was found at the upstream end of
the drainage on the Site, and likely traveled up that
drainage to the point where it was encountered, it is
likely that a much greater portion of the San Pedro
Avenue Site is CRLF habitat than shown on that figure.

C34-24 Richard
Grassetti
3/8/22 The lower portion of San Pedro Creek also has been found to be habitat for the special-status tidewater
goby (see Baye report referencing Sutter and Kinziger,
2019). This habitat may be adversely affected by
contaminated runoff that would result from
development of the undeveloped San Pedro Avenue
Site. This impact also must be addressed in the DEIR.

The tidewater goby is mentioned in Table C-1 (page
A-98) of the DEIR and states that the potential for
the tidewater goby to occur in the Planning Area is
low. The tidewater goby is a Special Status species,
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. In addition to
State and federal species and habitat protection
laws, the General Plan includes multiple policies to
address biological resources and habitat protection
which would apply to potential tidewater goby and
wetland habitat which include:
(CO-I-1) Creek Protection and Restoration.

Maintain, protect, and restore Pacifica’s creeks,
including San Pedro, Calera, Sanchez, and Milagra
creeks, as environmental and aesthetic resources.

Actions will include, but are not limited to:
• Continuing restoration efforts along San Pedro
Creek to improve conditions for steelhead by
removing obstacles to fish passage, placing rock
weirs to facilitate fish passage, and by monitoring
the effectiveness of these projects;
• Partnering with local organizations, such as the
San Pedro Creek Watershed Coalition, Go Native,
the Pacifica Land Trust, and others, on restoration
efforts;
• Exploring opportunities to collaborate with other
agencies and organizations on stream restoration
and riparian habitat restoration along Sanchez and
Calera creeks;
• Enforcing restrictions on the planting of invasive
species near creek areas;
• Identifying and working with property owners to
take advantage of unique opportunities where
human active use (e.g., through trail development)
would enhance creek appreciation without
disrupting ecological function;
• Requiring a minimum of 100-foot setbacks from
the top of creek banks, or from the outer edge of
riparian vegetation, where it exists, for
development proposed adjacent to creeks, in
keeping with City regulations and Best Management
Practices. Exceptions to such buffer requirements
should be supported by a biological report

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demonstrating that the adjusted buffer, in
combination with incorporated siting, design or
other mitigation measures, shall prevent impacts
that significantly degrade the creek. 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 creek.
(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.
(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-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.

Verification of an ESHA shall be based on the

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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
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);

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• 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-G-7) Wildlife and Critical Habitat. Conserve and
protect indigenous threatened, endangered, and
other special status species by preserving critical
habitat.

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

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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.

If the tidewater goby was found as part of a projectlevel EIR analysis, then these policies would mitigate habitat impacts to the greatest extent practical.

Therefore, potential impacts to Sensitive Species or
Critical Habitat will be fully mitigated with
implementation of the General Plan.

C34-25 Richard
Grassetti
3/8/22 Finally, the proposed site designation fails to meet CCC policies, as summarized in the 2020 Staff Report for the denied Rhodes Project (emphasis added):
“In short, the portion of the 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
Commission finds that there is no location on the site
that is 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 Commission finds the
proposed project inconsistent with the Coastal Act’s
sensitive habitat protection requirements cited above,
requiring project denial.”
Given the evidence already provided to the City that
much, if not all, of the undeveloped San Pedro Avenue
Site is environmentally sensitive habitat and likely
qualifies as an ESHA, the DEIR must investigate to what extent those conditions exist on the Site. It is entirely possible that the whole Site is ESHA, and therefore
should be designated as such in the General Plan.

Alternatively, designating it for residential mixed-use development likely assures a significant environmental
impact will occur, and the DEIR must disclose those
potential impacts. It should be noted that this is not a disagreement among experts, as the DEIR provides NO
evidence supporting its finding that the proposed land
use designation for that Site would not result in a
significant impact, and the City is in receipt of
substantial
evidence to the contrary.

Please see Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro Ave Sites for
more information.

CEQA permits differing opinions of expert and
competing evidence; if the site is determinedto
qualify as ESHA, then potential site-specific impacts
and/or mitigation measures would be analyzed as
part a Project EIR for when a development proposal
is brought forth. The DEIR for the General Plan
(which is not a Project EIR for the site in question)
includes a comprehensive list of policies to protect
ESHA habitats.

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C34-26 Richard
Grassetti
3/8/22 Land Use Environmental Setting
Chapter 3.1, overall: The list of General Plan Policies that purportedly reduce impacts fails to describe how
or to what degree impacts are reduced. Please add this
analysis for Impacts 3.1-1, 3.1-2, and 3.1-3, considering that not all General Plan policies are required to be
implemented by the City.

Each of the analysis chapters in the DEIR include an
environmental settings section, which describes onthe-ground conditions. The comment does not provide an example of how analysis under the
impacts listed is deficient. Required topics of
analysis under CEQA for Land use and Housing
include the following:

Criterion 1: Physically divide an established
community. As described on DEIR p. 3.1-9, the
Proposed Project does not physically divide any
established community. Rather, by allowing for
compact and concentrated development in alreadyurbanized neighborhoods, increasing opportunities for housing and economic development, and
improving linkages, the Proposed Project provides
improved connections to and continuity with
surrounding neighborhoods. Thus, no division of a
community would occur. Policies listed in the DEIR
describe how this concentrated development will
occur; this impact is less than significant.

Criterion 2: Implementation of the Proposed Project
would not conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding or
mitigating an environmental effect. As described on
DEIR p. 3.1-26, The Proposed Project does not
contain policies that conflict with the San Mateo
County General Plan. The City’s LAFCO-approved
Sphere of Influence overlaps with County land south
of the City limits on the slope of San Pedro
Mountain. The Proposed Project calls for
coordination between the City and the County to
ensure that development of unincorporated county
land that is in the City’s Sphere of Influence is
developed at a maximum density of five acres per
unit. For developments over 50 acres or for the site
of Shamrock Ranch, the Proposed Project aims to
guide potential development outside the City limits
but inside its Sphere of Influence with a master
planning process, potential annexation into the
city, and an amendment to the General Plan.

Through this master planning and annexation
process, any discrepancy between the County
General Plan and the Proposed Project will be
rectified.

Criterion 3: Induce substantial unplanned
population growth in an area, either directly or
indirectly. As noted on DEIR p. 3.1-29 and 3.1-30,
the Proposed Project includes allowable density
ranges in those land use designations where
housing is allowed to be developed, which would
direct housing development to those locations
where it is intended to be developed and at the
densities for which it is planned.

New homes and businesses developed in the
Planning Area as a result of the Proposed Project

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would intend to accommodate growth in Pacifica
that is commensurate with the city’s size, growth
rate, and place in the region. Furthermore,
development will occur incrementally over time,
not immediately after adoption of the Proposed
Project, in anticipation of the growth,
thus preventing development from inducing growth
greater than that projected. Additionally, the
Proposed Project proposes making streets more
efficient for transit, bicycles, and walking rather
than extending roads or adding lanes (including
policies that support Complete Streets, walkable
neighborhoods, and bicycle and pedestrian routes).

Furthermore, policies in the Proposed Project
encourage infill development that would avoid
unplanned development that could be induced
through infrastructure expansions into new growth
areas. This reduces the potential for unplanned,
induced growth. Therefore, the Proposed Project
would not induce substantial unplanned population
growth, either directly or indirectly, and the
Proposed
Project’s impact would be less than significant.

Impacts analysis focused on how where and what
type of development the plan allows might lead to
significant impacts for CEQA. It is speculative to
assume that development would not comply with
adopted policies; any projects would be required to
show consistency with the General Plan during the
permitting process.

C34-27 Richard
Grassetti
4/3/22 With respect to the undeveloped San Pedro Avenue Site please address the clear non-compliance of the
GPU’s high intensity land use designation with the
policies of promoting wetlands preservation (CO-I-4),
minimizing impacts of coastal development on
vegetation (CD-I-16), Open Space Conservation and
Habitat Protection (LU-I-13), Open Space Preservation
(OC-G-5), Protection of Creeks and Riparian Areas (COG-9), Other Environmentally Sensitive Areas (CO-G-11) , and Protection of Biological Resources with New
Development (CO-I-26). Please revise the land use
designation for consistency with the policies.

As noted in its Staff Report for Application CDP-2-19-
00262, the California Coastal Commission has declared
areas adjacent to the Rhodes property as an ESHA,
Further, the July 7, 2014 comments of ecologist Dr.

Peter Baye are that the seasonal wetlands at the
undeveloped San Pedro Avenue site and the zone
bordering the CRLF habitat of the swale meet the
definition of ESHA. Dr. Baye has provided additional
evidence of the suitability of much of the Site as CRLF habitat in his March 2022 letter. Dr. Baye further
provides substantial evidence that development of the
The General Plan and associated DEIR review citywide sensitive and Critical Habitat and general locations of Special Status Species. The General Plan
proposes numerous policies to reduce habitat loss,
as described in response to comments A2-3, A2-16,
and A2-20. Please see Master Response 6: ESHA
and Master Respones: Undeveloped San Pedro Ave
site for more information.

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site may adversely affect the special-status tidewater
gobi which occurs at the lower end of San Pedro Creek.

Please revise the land use designation for consistency
with Verification of ESHA (CO-1-27) and Management
of ESHA (CO-I-28), and Habitat Preservation (CO-I-31).

C34-28 Richard
Grassetti
3/8/22 Chapter 3.1 also needs to be revised to address
potential land use incompatibilities. As written there is no assessment of any potential incompatibilities of
proposed new land uses with existing nearby uses. For
example, the DEIR does not disclose if intense
residential development of the undeveloped San Pedro
Avenue Site will have noise or traffic incompatibilities with surrounding residential land uses. The DEIR also
does not disclose if intense residential development of the undeveloped San Pedro Avenue Site would displace
flood storage, important habitat, or recreational uses
of the Site.

C34-29 Richard
Grassetti
3/8/22 Geology, Soils, and Seismic Risk
CEQA Guideline 15126.2(a) states, “The EIR shall also
analyze any significant environmental effects the
project might cause by bringing development and
people into the area affected…..Similarly, the EIR
should evaluate any potential significant impacts of
locating development in other areas susceptible to
hazardous conditions (e.g., floodplains, coastlines,
wildfire risk areas) as identified in authoritative hazard maps, risk assessments, or in land use plans addressing such hazard areas.” As described below for both
geology and hydrology, this DEIR fails to conduct these required assessments.

The DEIR includes robust analysis of geology and
hydrology impacts at a programmatic level and finds
impacts to be less than significant. Authoritative
hazard maps from the Department of Conservation
(For Seismic Hazard Zones, Figure 3.6-1 and
Tsunami Evacuation Areas, Figure 3.5-1); and FEMA
(Flood Zones, Figure 3.5-1) are included in the DEIR.

As noted in the DEIR summary, Potential seismic
impacts associated with implementation of the
Proposed Project could include exposure to ground
shaking, liquefaction, and soil settlement. In
addition, the Alquist-Priolo Earthquake Fault Zone
for the San Andreas fault intersects the northern
portion of the Plan Area which has the potential for
surface fault rupture. Soil erosion and loss of topsoil is most likely to occur during construction, when it
is not protected by vegetation or structures. Coastal
erosion is also a known hazard for the Planning
Area. Erosion is often caused by waves and wind,
and may be exacerbated by stormwater if not
handled effectively; please see comment C69-8 for
more information on how regulations and policies
in the Proposed Plan reduce the impacts. The
potential for expansive soils is determined on a sitespecific basis and likely present in some areas.

Compliance with the California Building Code and
other state and local regulations, as well as

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proposed General Plan and Sharp Park Specific Plan
policies, ensures that impacts are reduced to a less
than significant level.

For hydrology, the potential impacts associated
with implementation of the Proposed Project
include increased rates of storm water runoff and
subsequent flooding hazards, erosion, increase in
nonpoint source pollutants affecting receiving water
quality, and coastal erosion and flooding that may
be intensified by sea level rise. These impacts would
be reduced to less-than-significant levels through
regulatory compliance and with implementation of
proposed policies.

C34-30 Richard
Grassetti
3/8/22 Figure 3.6-1: The undeveloped San Pedro Avenue Site appears to include areas of Very High and Medium
liquefaction potential (DEIR Figures 3.6-1 and 3.6-2). It also may be subject to impacts from coastal erosion, as described on DEIR p. 3.6-14 and elaborated upon in the
CCC’s Staff Report for the adjacent Rhodes site. Yet the GPU’s land use designation seems oblivious to these
threats, and the DEIR fails to analyze these reasonably foreseeable potential Project impacts.

The comment is noted. The DEIR includes a robust
analysis of potential liquefaction impacts and
coastal erosion 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 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." Impacts due to coastal erosion are
described on p. 3.6-30. In addition to policies like
SA-I-8: Geotechnical Studies, which require
geotechnical site investigation in Coastal Zone or
hillside areas, any proposed development
permitting in the portion of the site within the
Coastal Zone would be under the jurisdiction of the
Coastal Commission, and subject to additional
policies in the certified LCP. Please see also Master
Response 4: Undeveloped San Pedro Ave Sites.

C34-31 Richard
Grassetti
3/8/22 Impacts 3.6-1 and 3.6-3: The DEIR provides no analysis of the potential impacts of proposed land use
designations shown in the GPU land use map.

It also fails entirely to address whether and how the
listed general policies will reduce impacts such as those identified above for the undeveloped San Pedro
Avenue Site to less-than-significant levels and then
inexplicably finds the impacts to be minimal. The DEIR
just lists the policies and concludes that the impacts
would be less than significant. There’s a big difference The comment does not provide an example of how
analysis under the impacts listed is deficient.

Required topics of analysis under CEQA for Land use
and Housing include the following:

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between reducing impacts, which is what the policies
are aimed at, and reducing them to a less-thansignificant level. The DEIR must be revised to analyze the impacts of the proposed changes in land use
compared to existing conditions.
for housing and economic development, and
improving linkages, the Proposed Project provides
improved connections to and continuity with
surrounding neighborhoods. Thus, no division of a
community would occur. Policies listed in the DEIR
describe how this concentrated development will
occur; this impact is less than significant.

New homes and businesses developed in the
Planning Area as a result of the Proposed Project
would intend to accommodate growth in Pacifica
that is commensurate with the city’s size, growth
rate, and place in the region. Furthermore,
development will occur incrementally over time,
not immediately after adoption of the Proposed
Project, in anticipation of the growth,
thus preventing development from inducing growth
greater than that projected. Additionally, the
Proposed Project proposes making streets more
efficient for transit, bicycles, and walking rather
than extending roads or adding lanes (including
policies that support Complete Streets, walkable
neighborhoods, and bicycle and pedestrian routes).

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shall determine the level of review needed, and the
scope of that analysis will depend on the specifics of
the particular project. These projects may, however,
use the discussion of impacts in this EIR as a basis of their assessment of these regional, citywide, or
cumulative impacts.

C34-32 Richard
Grassetti
3/8/22 Further, please provide monitorable, enforceable mitigation for these potentially severe impacts on the
undeveloped San Pedro Avenue Site. The proposed
policies mostly involve future studies, which do not
suffice as mitigation, particularly in the absence of
express performance standards. Please note that
Geologic Hazard Abatement Districts do not ensure
mitigation, but rather just shift funding responsibilities for mitigation from the City to buyers of subject
properties.

The comment is noted. This DEIR is a programmatic
DEIR and addresses where impacts could potentially
occur. 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.

C34-33 Richard
Grassetti
3/8/22 Hydrology and Water Quality
The Hydrology and Flooding section introduction states
that the section analyzes water resources “in relation
to the location of projects comprising the buildout of
the Proposed Project [General Plan].” (DEIR p. 3.5-1).

However no such analysis is included relative to those
projects.

This comment is untrue. One example of how the
DEIR analyzed locational impacts can be found as
DEIR p. 3.5-31: "While the proposed General Plan
would include relatively few new housing units,
many of which would be placed outside these
hazard areas, there are areas of new development
or other structures that may be located within 100-
year flood zone areas." These areas are identified in
maps and in the Settings sections.

As noted in 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." However, analysis
was conducted on land use parcels that changed or
developed from existing conditions (see Master
Response 3: Buildout and RHNA). These vacant
parcels are shown on Figure 3.1-1; the General Plan
Land Use Diagram is shown in Figure 2.2-1.

C34-34 Richard
Grassetti
3/8/22 The DEIR also states, “San Pedro Creek has a history of flooding in the Linda Mar area,” (p. 3.5-8) but the DEIR provides no information on flooding at the sites where
land use is proposed to intensify substantially as a
result of the GPU. The PPCA has provided the City with
photos of the Site entirely flooded to a depth of several feet, indicating that substantial flooding has occurred The comment states that the DEIR provides no
information on flooding at sites where land use is
proposed to intensify as a result of the GPU. On
page 3.5-8, the DEIR mentions '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

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on the Site. This flooding occurred again in the 2021-
2022 rainy season. The City has been provided with
evidence (attached hereto and submitted by PPCA
under separate cover) that the Site has been frequently flooded by San Pedro Creek, the adjacent hillsides, is
subject to flooding under projected sea level rise, and is subject to tsunami hazards.
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.'
Figure 3.5-1 was created based on the following
sources:
the latest tsunami evacuation zone data which is
available at the City's website
(https://www.cityofpacifica.org/civicax/filebank/blo
bdload.aspx?BlobID=2499), as well as the National
Flood Hazard Layer for San Mateo County mapped
by the Federal Emergency Management Agency
(FEMA). Please see response to comment C13-3 for
more information on coastal flooding and sea level
rise.

C34-35 Richard
Grassetti
3/8/22 The 2014 DEIR for the Pacifica General Plan Update at Figure 3.5-1 showed the Site is subject to flooding from tsunami runup. However, without explanation, that
figure has been omitted from this DEIR. Why was this
figure deleted? As noted in the DEIR and the CCC Staff
Report, tsunami runup is a hazard that will only worsen with sea level rise.

This comment is noted.

The map was updated to account for new tsunami
evacuation zone data which is available at the City's
website,
https://www.cityofpacifica.org/civicax/filebank/blo
bdload.aspx?BlobID=2499

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C34-36 Richard
Grassetti
3/8/22 As detailed in the CCC Staff Report on the adjacent Rhodes project site, “With respect to coastal hazards,
the site would be subject to potential future impacts
from the combination of shoreline retreat, sea level
rise, wave runup, and inundation. As proposed, the
structures are not sufficiently sited and designed to
avoid such problems, and the northernmost building
includes a basement structure, all of which would be
subject to flooding over the expected life of the
development. “
“… Commission staff geologist Dr. Joseph Street
estimates that with 6.6 feet of sea level rise, wave
runup with the 100-year storm could extend about 170
feet inland of the shoreline (i.e., of MHTL) across the beach and flatter ground near San Pedro Creek,
northeast of the project site. This provides a more
conservative estimate of potential storm wave runup
beyond the future shoreline position. If 170 feet of
horizontal wave runup distance is added to the
projected future shoreline position (with 5.7 or 6.6 feet of sea level rise), the seaward portion of the project
site (where Building 1 is proposed which includes the
two-story surf shop on the first floor, office and storage space on the second floor, and a 3,500 square-foot
basement subgrade) would be affected by wave runup
within the 100-year analytic period referenced by the
LCP.
“Another option to approximate the future wave runup
hazard risk to the site is to add projected sea level rise to the current FEMA 100-year flood elevation. Adding
the medium-high risk scenario sea level rise projection (+5.6 to +6.9 feet by 2090-2100) to the current FEMA
100-year flood elevation of the VE zone (representing
areas within the 1% annual chance coastal floodplain
which have additional hazards associated with storm
waves) where the proposed project is located (i.e., at
+17 feet elevation) yields a rough estimate of the
future 100-year flood elevation in the range of +22.5 to +24 feet NAVD88. Given the existing elevations at the
project site (+16 to +21 feet) and the elevations of the topographic lows adjacent to the project site (+16 to
+17 feet NAVD88), it is thus possible that future flood elevations in this range affect at least a portion of the project site toward the end of the project life. At the very least, additional, more detailed analysis would be needed to rule out this possibility.” The San Pedro
Avenue Site is lower than the adjacent Rhodes project
site, rendering it even more likely to be impacted from coastal flooding hazards. This should have been
considered in planning for Site development in the
GPU, as well as in determining impacts in the DEIR.

Please see response to comment C13-3 for more
information on sea level rise data, and how
compliance with federal, state, and local regulations
as well as Proposed Plan policies reduce impacts to
coastal flooding to less than significant. The
Proposed Plan is programmatic; a land use
designation does not represent a project. As noted
in 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
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, projectlevel 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. These projects may, however,
use the discussion of impacts in this EIR as a basis of their assessment of these regional, citywide, or
cumulative impacts. Because this project is within
the Coastal Zone, projects would be required to
demonstrate compliance with Coastal Act policies.

As noted in policy LU-I-29,"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."
C34-37 Richard
Grassetti
3/8/22 Because the undeveloped San Pedro Avenue Site is located in the Coastal Zone, designation of the Site
Please see response to comment C34-36

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must be assessed for compliance with Coastal
Commission policies with respect to flooding and sea
level rise. The Commission’s draft polices state that
LCP’s must integrate sea level rise into planning, using a maximum rise of 6.3 feet, which is based on the best
available science as identified in the CCC Staff Report on the adjacent Rhodes project site. The Coastal
Commission Guidance is that coastal hazard risks
should be avoidable, wherever feasible. Increasing
development density on an undeveloped site subject to
sea level rise and other coastal hazards is the opposite of this Coastal Commission Guidance. The DEIR fails to
even mention this impact.

C34-38 Richard
Grassetti
3/8/22 The DEIR Hydrology discussion fails to even disclose, much led address, the tsunami and sea-level-rise
flooding related hazards associated with this Site (see, for example, DEIR Figure 3.5-1, which shows the Site as having no flooding hazards), in spite of detailed
evidence of those hazards provided by the California
Coastal Commission’s experts. The DEIR consistently
ignores on-the-ground analyses, in favor of lessaccurate generic mapping, rendering the document inadequate.

The comment states that the DEIR does not
accurately portray tsunami and sea-level-rise
flooding related hazards associated with this site.

Figure 3.5-1 was created based on the following
sources:
the latest tsunami evacuation zone data which is
available at the City's website
(https://www.cityofpacifica.org/civicax/filebank/blo
bdload.aspx?BlobID=2499), as well as the National
Flood Hazard Layer for San Mateo County mapped
by the Federal Emergency Management Agency
(FEMA).

The DEIR also mentions localized flooding risks
along San Pedro Creek: '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.'
C34-39 Richard
Grassetti
3/8/22 In the 2014 DEIR for that General Plan Update, the Hydrology section included an impact on sea level rise
(Impact 3.5-6). Inexplicably that impact, as well as
Impact 3.5-7 in the 2014 DEIR, have been deleted,
leaving a jump from Impact 3.5-5 to 3.5-8 in the 2022
DEIR. Given that the undeveloped San Pedro Avenue
Site would be subject to extreme flooding from sea
level rise and that runoff to and from the project Site would aggravate that flooding (see CCC comments),
this issue must be addressed in the stormwater runoff
and flooding discussions of this Project and DEIR.

In Ballona Wetlands Land Trust v. City of Los
Angeles (Ballona Wetlands), the California Court of
Appeal held that CEQA does not require the lead
agency to analyze or disclose the effects of sea-level
rise on the proposed development. However, in the
spirit of full disclosure, sea level rise impacts are
addressed in impacts 3.5-3 and 3.5-4. Please see
response to comment C13-3 for more information
on sea level rise mapping.

C34-40 Richard
Grassetti
3/8/22 Also, designating this Site for development is in clear violation of sea-level-rise policies in the General Plan Update itself. The fact that the City is willing to adopt a land use plan that is inconsistent with the policies in the very same plan shows that the policies are not
effective mitigation.

As mitigation, please revise the land use element of the Project to eliminate the density increases in these
Policies within the LCLUP related to effects of
climate change and sea level rise are addressed in
the LCLUP. See response to comment C13-3 for
more information about coastal flooding and sea
level rise. Please also see Master Response 4:

Undeveloped San Pedro Ave Sites.

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areas and respond to the real hazards by reducing
densities instead. The DEIR – by suggesting
unenforceable policies that conflict with the underlying land use as mitigation measures - does not comply with
CEQA requirements for mitigation, which must be both
enforceable and verifiable, and must actually mitigate
the impact.

C34-41 Richard
Grassetti
3/8/22 Public Services and Recreation
The draft general policies state that access to coastal areas shall be maximized. Yet, this Project would
eliminate an informal access trail to the beach, as
documented in a set of photos and maps attached to
our previous comments. The DEIR entirely omits
coastal access outside of designated parks from its
impact analysis. The Project’s impacts on access
through the Site are not disclosed in this DEIR.

The DEIR considers coastal access in its impact
analysis. Under Impact 3.12-2 on page 3.12-49, the
DEIR analyzes whether buildout of the Proposed
Project will result in an increase in the use of
existing parks and recreational facilities such that
substantial physical deterioration would occur or be
accelerated. The DEIR acknowledges that increased
traffic to these recreation areas could have a
negative impact on these resources unless access is
properly tended to and appropriate buffers and
conservation protections are enforced. Thus, the
Proposed Project promotes coordination with the
various entities that manage these areas to ensure
that they receive the necessary attention.

Additionally, the Proposed Project contains many
policies that extend trails and augment coastal
access for all visitors to keep the impact to a less
than significant level. Such policies that aim to
augment coastal access include OC-G-8, OC-G-9,
OC-G-10, OC-I-37, OC-I-38, OC-I-39, OC-I-40, OC-I41, OC-I-42, and OC-I-43.

C34-42 Richard
Grassetti
3/8/22 Alternatives
As described previously, the DEIR fails to provide clear objectives as required by CEQA. This makes it
impossible to determine if the range of alternatives in the DEIR is appropriate. This deficiency is compounded
because project alternatives must reduce impacts
compared to the Project and, as detailed above, the
DEIR fails to adequately address potential impacts of
the Project on nearly all topics. Further, it appears that the alternatives addressed in Chapter 4 are merely
planning options and not actual CEQA alternatives. In
fact, the three criteria on DEIR p. 4-2 state that the
alternatives were selected to, “bracket the range of
choices that have the broadest support from the
community”, apparently without specific consideration
of their potential environmental impacts.

Page 2 ends

Feasible alternatives that could reduce or avoid
impacts while also meeting most or all of the
objectives were developed and analyzed in the DEIR
consistent with statutory requirements (CEQA
Guidelines Section 15126.6(d)) Impacts for each of
the CEQA Alternatives are described in section 4.3
and summarized on p. 4-32.

C34-43 Richard
Grassetti
3/8/22 There is no location-specific analysis of flooding in this DEIR alternatives chapter, which results in inaccurate
statements that the no-project alternative would
increase flood hazards compared to the proposed
Project. Certainly this is false at the undeveloped San Pedro Avenue Site. More generally, why wouldn’t
ongoing flood-improvement projects continue with or
without the 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. Required CEQA
analysis of flooding is related to substantially
altering the existing drainage pattern of a site or
area (Impact 3.5-3) or risk release of pollutants due
to project inundation, if located in flood hazard,

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tsunami, or seiche zones. These areas of flood
hazards and tsunami evacuation zones are
identified in Figure 3.5-1, and appropriate policies
that reduce impacts apply to these areas. The
Alternatives chapter analyzes these impacts for
each of feasible Alternatives required by CEQA.

Drainage control measures and flood prevention
policies in the Proposed Project would not apply to
the no project alternative because they are not
included in the current (1980) general plan;
however, existing policies and state requirements
would apply.

C34-44 Richard
Grassetti
3/8/22 Planning Issues
As noted above, the proposed Coastal Residential
Mixed Use land use designation at the undeveloped
San Pedro Avenue Site would subject increased
densities of people to geologic and hydrologic hazards, in non-conformance with both City and LCP policies.

Further, sensitive ecological resources would be
adversely affected, which also undercuts and fails to
comply with the policies regarding those resources. As
noted in the DEIR’s Project Description, the Site’s
current Commercial Recreation land use designation is
most similar to the GPU’s proposed Visitor Serving
Commercial (VC) designation. The VC designation,
“allows uses that create public access to the coastal
setting and are adaptable to changing environmental
conditions: campgrounds, rustic lodging, concession
stands, warming huts, outdoor event sites, and similar
uses. Development may occur up to a 0.20 FAR, but
must have an overall very low-intensity character on
sites of more than one acre. Buildout is assumed at

0.05 FAR, recognizing the large land areas and minimal
buildings expected to support recreational uses.” (DEIR, p. 2-14.)

It is clear that, given the Site location and constraints, the GPU’s policies as applied at the undeveloped San
Pedro Avenue Site can only be met by applying the
Conservation (C) General Plan designation and
associated zoning because of the onsite hazards and
identified ESHA.

Please see Master Response 4: Undeveloped San
Pedro Avenue Sites for more information about
how proposed projects will be required to
demonstrate compliance with Coastal Act policies
to receive a coastal permit; and 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 6:

ESHA for more information on sensitive species at
the 505 San Pedro Avenue site.

C34-45 Richard
Grassetti
3/8/22 Conclusions
The DEIR fails entirely as an informational disclosure
document because of its assumptions that plan policies
would equate to mitigation and its failure to actually
analyze the effectiveness and likelihood of
implementation of those policies.

Please see comments C34-12 and C134-1 for more
information on the general adequacy of analysis in
the DEIR.

C34-46 Richard
Grassetti
3/8/22 Further, with respect to the undeveloped San Pedro Avenue Site, the DEIR ignores voluminous substantial
evidence of major flooding hazards and ecological
sensitivity of the Site. While an EIR may choose
between conflicting experts’ opinions, if they are all
The DEIR adequately analyzes required impacts
under CEQA for flooding and ecological resources.

Please see Master Response 6: ESHA; Master
Response 4: Undeveloped San Pedro Ave Sites; and
response to comment C13-3 for more information

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supported by evidence, it cannot fail to disclose
evidence contrary to its own conclusions, which, with
respect to both flooding and biological resources on
the Site, are entirely unsupported by either evidence or analysis.
on coastal flooding and sea level rise. Please see
comment C34-46 for more information on how
compliance with federal, state, and local policies, in
addition to proposed policies in the General Plan,
reduce potential impacts to less than significant.

C34-47 Richard
Grassetti
3/8/22 It is my professional opinion that, given the extent of the flaws detailed above, which reflect only a partial
review of the DEIR’s technical sections, this document
does not meet CEQA requirements for full disclosure of
potential impacts of the proposed project. The DEIR
will require substantive revisions - to the project
description; environmental baseline; reassessment of
potentially adverse biological resources, hydrologic,
geologic, and recreational impacts; identification of
mitigations; and a revised alternatives analysis – to
comply with CEQA
The comment is noted. Please see responses to
above comments in letter C34 for more information
on how the DEIR does represent an adequate
document and meets requirements under CEQA.

C34-48 Richard
Grassetti
3/8/22 Addressing the deficiencies cited above are especially critical because of the potential for “infill” residential projects to be permitted under CEQA exemptions for
such projects as permitted under CEQA Guideline
Sections 15182, 15183, and 15183.3. While this DEIR
promises further site-specific CEQA review, it is
possible that for some developments, no such review
could occur. In those cases, given the analytical
deficiencies in this DEIR, the impacts will not be
assessed in any CEQA document. This sort of CEQA
“shell game” would deprive the public and
decisionmakers of meaningful information and input in
the environmental review process.

C34-49 Richard
Grassetti
3/8/22 The DEIR anticipates Initial Studies and Negative Declarations for future compliance with CEQA, but
contends that it is not required to currently assess
Project level impacts. (DEIR, p. 44.) Such an assertion violates one of CEQA’s prime policies; the prohibition
against ignoring foreseeable impacts for later analysis is clearly proscribed by CEQA. Laurel Heights. Cases
citing Laurel Heights continue to disapprove of program or plan-level EIRs that defer impact analysis: “tiering is not a device for deferring the identification of
significant environmental impacts that the adoption of
a specific plan can be expected to cause.” California
Native Plant Soc.
v. City of Rancho Cordova (2009) 172 Cal.App.4th 603,
623-25.

Therefore, it is my professional opinion that the entire DEIR should be rewritten and recirculated for public
review. The current approach of setting plus policies
Please see response to comment C4-1 and Master
Response 3: Buildout and RHNA for more
information on adequacy of buildout projections.

According to Cal. Code Regs. tit. 14 § 15088.5, A
lead agency is required to recirculate an EIR when
significant new information is added to the EIR after
public notice is given of the availability of the draft EIR for public review under Section 15087 but
before certification. As used in this section, the
term "information" can include changes in the
project or environmental setting as well as
additional data or other information. New
information added to an EIR is not "significant"
unless the EIR is changed in a way that deprives the
public of a meaningful opportunity to comment
upon a substantial adverse environmental effect of
the project or a feasible way to mitigate or avoid
such an effect (including a feasible project
alternative) that the project's proponents have

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Individuals (C)
equals mitigation should be discarded and the impacts
of the proposed land use changes should be carefully
evaluated. Please feel free to contact me at XXX-XXXXXX if you have any questions regarding the comments herein.
declined to implement. "Significant new
information" requiring recirculation include, for
example, a disclosure showing that:
(1) A new significant environmental impact would
result from the project or from a new mitigation
measure proposed to be implemented.
(2) 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.
(3) 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.
(4) The draft EIR was so fundamentally and basically
inadequate and conclusory in nature that
meaningful public review and comment were
precluded. (Mountain Lion Coalition v. Fish & Game
Com.(1989) 214 Cal.App.3d 1043).

Recirculation is not required where the new
information added to the EIR merely clarifies or
amplifies or makes insignificant modifications in an
adequate EIR. The DEIR does not meet any of these
criteria; any additions are clarifications and do not
change findings of significance.

C34-50 Richard
Grassetti
3/8/22 Attachment A is Mr. Grassetti's resume No response needed.

C34-51 Richard
Grassetti
3/8/22 Attachment B is the California Coastal Commission Rhodes Report, Selected Figures, and Exhibits. Includes a memo regarding Documentation of California redlegged frog occurrence at Pedro Point, Pacifica, San Mateo County from Peter Baye, Ph.D.,
coastal plant ecologist to Jim Browning, U.S. Fish and
Wildlife Service, SFWO, Sacramento
No response needed.

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C35: Deb Wong, 3/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C35-1 Deb Wong 3/11/22 I read the Sharp Park Specific Plan, and do have some concerns. My family and I live on San Jose street. I grew up here (moved here in 1954), and have seen many
changes, but none that have altered the basic
"personality" of our city. I agree that this plan, if fully implemented, would change some of the special
character of our town. When we visit other small towns
(and I still see my home town of Pacifica as a "small
town"), what makes them charming is their distinctive
character/quirks, etc. Economic viability doesn't
necessarily mean adding more shopping areas, or
making things more generic. People visit our
community for the pier, the ocean, the hiking trails, and the beautiful scenery. That is destination enough. I live 1/2 block from the pier. Why not fix what needs fixing, before new construction projects? That pier needs
repair. That, and the seawall, is priority. It is folly to even start building until we know that the ground that
we are building on is relatively safe (and let's face it - in the event of a large quake/tsunami, all bets are off).

The plan to widen the sidewalk in front of our home by
2 feet will just eliminate our front planter box, which shouldn't be a problem (less work for me), and I agree
that Sharp Park could use some improvements. Some of
the ideas are positive ones. But having 4-5 story
buildings on Palmetto (or elsewhere in Sharp Park)
would definitely affect the look and feel of our town,
and not in a good way. That look is generic and overbuilt. If future grants depend upon having buildings higher than 3 stories - max - I vote no to those future grants (not that I get a vote, but if I did).

The illustrations in the Sharp Park Pacifica Plan of the buildings on Palmetto make Pacifica look like the
peninsula. What if some of these buildings eventually
become vacant, as they often do on the peninsula?
Covered in graffiti, vandalized? There are already
vacant buildings on Palmetto. We don't need more.

One of the contradictions I found when reading up on
this proposal is that hotels right now are not doing well, so the solution offered is to...build more hotels! As you have seen, more hotels do not necessarily mean more
visitors.

Nope. Do not like it. We live in a small town, surfingfishing village. THAT is why visitors come here. Why add restaurants when the ones we already have need the
business?
We DO need affordable housing, especially for those
who work here. I'm all for that, but in the section
dedicated to "affordable housing" there are no specifics of how much of the housing would be used for lowerincome residents. If that percentage is small, and the rest of it for outside investors, etc., how does that
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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benefit those who already live and work here? If there
MUST be plan for 990 new housing units in Pacifica,
three-story buildings on Palmetto should accommodate
some of those units, right? Anything over 3 stories high is too much for our area.

Sharp Park and much of the Manor area are already
user-friendly for those who walk and bike. I like the
improvements made on Palmetto, the bike lanes, and
clean-up. The banners on Palmetto need replacing - the
one for the Easter Egg hunt is 2 years out of date. The Manor Drive overpass could use a makeover. So could
the Manor Shopping Center, which I say with slight
regret, since I remember that shopping center when it
was first built, and is one of the places which is
consistent with my memories of growing up here. But
still - it has gotten a bit run-down, after 60 years.

The plan description for Sharp Park nightlife activities has its pluses and minuses. I am in bed by 7 PM, so do
not appreciate the idea of noise after hours. We like it quiet here at night. That is why we are a "bedroom
community". But I know that others might welcome
more nightlife in Sharp Park. Don't know anyone
specifically, but I am sure they are out there!
Bottom line is that my main concern are those 4-5 story buildings, along with possible influx of traffic and
overcrowding. The rest can be worked around.

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C36: Patrick Mora, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C36-1 Patrick
Mora
3/8/22 COMMENTS TO THE DRAFT GENERAL PLAN

AMENDMENT PURPOSE
To acknowledge the efforts by the Planning Department,
City Council Members, Planning Commissioners,
Consultants, and the General Public to produce a
comprehensive draft that is now scheduled for review
and adoption.

GENERAL PLAN LAND USE DESCRIPTION
Commercial Potential commercial uses that the City
might attract, including visitor-serving commercial, retail commercial, office, heavy commercial and light
industrial. Mixed residential and commercial uses are
allowed when the dwelling units are located above the
commercial uses.

Analysis and comments:

Please see enclosed diagrams with possible locations of commercial and residential. Type I Residential over
commercial, as stated in the general plan. May apply
only to level, flat sites, fronting a street with pedestrian activity. It works well in a situation where the building commercial frontage at ground level is cohesive. Type II Separate commercial and residential buildings, where
the pedestrian activities and visitor serving commercial interact at pedestrian level, without the separation in different levels. Example would be Main Street Half
Moon Bay south end, where U-shaped courts with
fountains provide rest areas for visitors and locals. Type III Hybrid interaction between commercial and
residential. An arrangement where there’s residential
over commercial and commercial over residential. To
adapt to unusual conditions and slopes, where the
standard specified residential over commercial
arrangement would be difficult to implement. Or where
the strict application of the code would not render the desired results in terms of practicality, business success, views, aesthetics and neighborhood coherence.

PARKING FOR RESIDENTIAL UNITS
Visitor Parking Where the code requirement is an extra
parking space for every four residential units. Suggested to provide one parking space for approximately every six units, not for visitors but for service, maintenance,
manager calls, emergency vehicles or contractors.

Experience shows that most visitors parking spaces are
being used by the same residents or tenants for
additional vehicles and not by visitors. Whereas a
designated yellow zone for service parking may serve a
better purpose. General Parking Where the code
requirement is two off street parking spaces for a typical two-bedroom unit. Most communities are moving
towards electric powered vehicles and public
transportation. Even densely populated cities are not
requiring off street parking. Examples would be the
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. 873 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 209
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requirements for an ADU close to transportation, where
the ADU would not need its own off street parking space that could take valuable land or space that could be used for open space, greenery, or more housing if feasible.

BUILDING HEIGHT LIMITATION
Code required height must not exceed 35’-0”. This
limitation has applied to all growth from the beginning.

Now we face different challenges. If we wish to have
some of our hills preserved then we must accept growth
and in fill development where it is allowed, A bonus in the height limitation may add an extra floor, where
appropriate, to a 3-story existing fabric that could look too uniform or tedious for a vibrant city. Terraces and balconies above could provide life and texture to streets that are in the process of becoming favorite for strolls or outings. Architectural features that partially increase the height are often allowed and encouraged. Example, the
Clock Tower on Old County Road Connected Buildings -
Height Computation Where two or more buildings are
connected the height might be measured not from the
lowest point of the lower building, but rather from the lower ground level of each individual building A
compound of individual buildings allowed to be
measured in this way may offer potential uses that
encourage visitor serving commercial and tourist
attractions that otherwise could go unexplored. Perhaps the connection can be limited to a percentage of the face of each connected building. Pacifica is a jewel in the
rough. All of us who come in contact, as professional,
residents, or visitors would like to protect it and enhance it. Well planned development by educating the
community must always be a part of local growth. The
work of Pacifica Planners is underestimated but much
respected and appreciated by all of us.

Respectfully,

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C37: Allison West, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C37-1 Allison
West; Pedro
Point
Community
Association
3/7/22 I am writing in my capacity as President of the Pedro Point Community Association (PPCA), a neighborhood-based,
all-volunteer nonprofit organization that serves as a
strong and well-informed voice for the entire Pedro Point community and actively seeks to represent the expressed opinions and desires of its residents.

The PPCA is submitting the following comments on the
City of Pacifica’s January 2022 Draft General Plan Update (GPU) and Draft Environmental Impact Report (DEIR). Our comments incorporate by reference the GPU/DEIR
comment letters prepared on our behalf and submitted
under separate cover by CEQA consultant Richard
Grassetti, our attorney Brian Gaffney, and attached memo from consulting Coastal Ecologist, Dr. Peter Baye (Exhibit A). Land use designations are the heart of the General
Plan, as a guiding document for the city’s development
and policy making decisions. That is why the purpose of this letter is to clearly state that the PPCA emphatically objects to the GPU and DEIR’s proposed land use
designation change to “Coastal Residential Mixed Use”
(CRMU) for the undeveloped San Pedro Avenue site in
Pedro Point (locally referred to as the Pedro Point field). It should be noted that the PPCA made similar objections to this same CRMU designation change when it was
proposed in a previous draft GPU and DEIR released for
public comment in 2014, but never approved.

For decades, the PPCA has made extensive efforts to
collect residents’ input to inform city planners about our community’s preferences for land use and development,
and the value that is placed on maintaining our
community’s environmental assets and natural aesthetics to ensure harmony with the scale and character of
existing neighborhood conditions. (These efforts and
preferences have been well documented and are on
record with the City of Pacifica, as well as on the PPCA website at www.pedropoint.org.)
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.

C37-2 Allison
West; Pedro
Point
Community
Association
3/7/22 Based on residents’ continued input and support, the PPCA previously urged the City to revise the proposed
land use for the Pedro Point Field site in the GPU and DEIR to be designated as either “Low-Intensity Visitor- Serving Commercial” (LIVC) or “Conservation” (C). However, due
to more recent evidence presented in CDP application 2- 19-0026 related to the adjacent property’s ESHA and
hazards identification (which - under state law -
development would be a nuisance) it now appears that
only the designation of “Conservation” (C) should be
applied.

Pedro Point residents have consistently registered strong preference for maintaining the existing open space of the Pedro Point field and opposition to any residential
The comment is noted. 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 the potential impacts to less
than significant, regardless of the
final determination of ESHA. Please
also see Master Response 4:

Undeveloped San Pedro Ave Sites.

For other coastal hazards, such as
flooding, development would be
required to comply with proposed
policies related to sea level rise, best
available science, and vulnerability

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Individuals (C)
development, due to a number of expressed negative
impacts. In its current existing state, the field is an open space with seasonal wetlands.
identification and mapping (SA-G-5
and SA-I-28); flood map review and
floodplain management (SA-I-18 and
SA-I-19); flood hazard reductions (SAI-20); and flood control structures (SA-I-23).

C37-3 Allison
West; Pedro
Point
Community
Association
3/7/22 It should be noted that reasonably foreseeable
development under the proposed CRMU land use
designation for the Pedro Point field would result in:

1. Significant adverse aesthetic impacts. (see Exhibit B) Natural environmental beauty is an integral part of the existing visual character of our small coastal Pedro Point community. Generations of residents have treasured the
scenic environment of the field which affords unique
views of the surrounding hillsides and provides an open space that serves as a park-like setting for residents and visitors. The proposed CRMU designation would have a
substantial adverse effect on scenic vistas, substantially degrade the existing visual character of the neighborhood, and create new source of substantial light and glare which would adversely affect views.

The DEIR analyzes scenic vistas on
pages 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 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. The DEIR also 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 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.

C37-4 Allison
West; Pedro
Point
Community
Association
3/7/22 2. Significant adverse biological impacts. (see Exhibit B) The development flowing from the CRMU designation
would diminish an environmentally sensitive wildlife
habitat. Neighbors have long-enjoyed sightings of many
species of birds, animals and reptiles that inhabit the field, including documented photos of endangered species such
as the California Red-Legged Frog (CRLF). The
opportunities for wildlife encounters with diverse species found in and around the field have become an essential
part of our neighborhood identity.
a. NOTE: The City was also recently made aware from the denial of CDP application 2-19-0026 dated 12/7/2020 that the adjacent unnamed watercourse to this property has
Please see response to comment
C34-27. Please see Master Response
6: ESHA and Master Response 4:

Undeveloped San Pedro Ave Sites for
more information on how
compliance with federal, state, and
local regulations, in addition to
Proposed Plan policies, reduce
impacts to less than significant,
regardless of the final determination.

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Individuals (C)
been identified as ESHA by CA Dept. of Fish & Wildlife, the US Fish and Wildlife Service, and Senior Biologist Dr.

Garske-Garcia of the California Coastal Commission (CCC), and that the CRLF require a minimum 300-foot foraging
buffer zone. In addition, CCC found the watercourse likely also supports several other species as a habitat corridor.

Coastal Act Section 30240 prohibits non-resource
dependent development within an ESHA.

C37-5 Allison
West; Pedro
Point
Community
Association
3/7/22 3. Significant adverse traffic impacts. (see Exhibit B) With San Pedro Avenue serving as the only singlelane road in and out of the Pedro Point neighborhood, the increased
traffic volume, congestion, and vehicle miles travel
generated by CRMU-related residential development in
the field would make this main thoroughfare unnavigable, and present significant adverse hazards for emergency access or evacuation. This increased traffic
would also have related air quality and GHG impacts.

The comment is noted. Congestion is
not a required topic for CEQA
analysis. 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. Policies
listed under Impact 3.2-4 as well as
the existing programmatic
framework reduce impacts to
evacuation to less than significant.

Please see Master Response 7:

Evacuation Routes for more
information regarding emergency
access. See response to comment 37-
6 regarding air quality and
greenhouse gas impacts.

C37-6 Allison
West; Pedro
Point
Community
Association
3/7/22 4. Significant adverse transportation, air quality and GHG impacts. Our narrow streets are already choked with
parked cars from increased commercial, residential and
beach tourism parking demands. Increased parking
generated by scores of CRMU-related residential units and visitors would result in excessive congestion and
overwhelm on-street parking in our already overburdened neighborhood, and further exacerbate the transportation, air quality and GHG impacts.

The comment is noted. Parking and
Level of Service are not required
analysis under CEQA. As described in
Chapter 3.3, any impacts for the
Proposed Plan to potentially conflict
with or obstruct implementation of
the applicable air quality plan; result
in a cumulatively considerable net
increase in any criteria pollutant for
which the project region is classified
as a nonattainment area under an
applicable federal or state ambient
air quality standard; expose sensitive
receptors to substantial pollutant
concentrations; and result in other
emissions (such as those leading to
odors) adversely affecting a
substantial number of people are
reduced to less than significant. As
described in Chapter 3.4, Impact 3.4-
1, the Proposed Project's potential to
generate GHG emissions, either
directly or indirectly, that may have a
significant impact on the
environment, is found to be less than
significant with mitigation measures.

C37-7 Allison
West; Pedro
3/7/22 5. Increase pedestrian safety hazards. (see Exhibit B) Increased street parking and vehicular traffic along San The comment is noted. As discussed
in Impact 3.2-3, the Proposed Project

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Individuals (C)
Point
Community
Association
Pedro Avenue where there are no sidewalks or crosswalks would obstruct the only pedestrian routes, creating
significant adverse safety hazards for pedestrians and
emergency vehicles, and put residents (and pets)
increasingly at risk.
has been developed with an
emphasis on Complete Streets, which
by their nature, would improve
compatibility between different
transportation modes as well as
between the transportation system
and adjacent land uses. Proposed
policies that promote bicycle and
pedestrian safety as well as the
development of safe routes to
school, and that require mitigation of
traffic-related impacts would help to
identify and address potential safety
concerns. Therefore, with adherence
to policies included in the Proposed
Project, impacts increasing hazards
due to a design feature or
incompatible uses would be less than
significant.

C37-8 Allison
West; Pedro
Point
Community
Association
3/7/22 6. Significant adverse flooding impacts. (see Exhibit B) In its undeveloped state, the field serves as a natural catch basin for street run off from the surrounding the
community and steep hillsides, and has historically been subject to flooding, occurring as recently as the 2021- 2022 rainy season. Residents have also identified above ground, year-round spring percolation in the southwest
corner of this property (see Exhibit B). Residential
development adding more impervious surfaces would put
businesses and homes along San Pedro Avenue at risk for even greater flooding and safety hazards.

Please see response to comment
C13-3 for more information about
flooding. 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-I-17,
SA-I-19, SA-I-20, SA-I-22, SA-I-23, SAI-25, SA-I-39, SA-I-40, SA-I-88, to decrease impact to a less than
significant level.

Policies, including CO-I-15, will help
reduce impervious surfaces, to help
decrease the impact of flooding to a
less than significant level.

C37-9 Allison
West; Pedro
Point
Community
Association
3/7/22 Additionally, the CCC has been in communication with the City of Pacifica for more than a decade to express concern about negative impacts of development on the habitats of a watercourse adjacent to the Pedro Point field, which
likely would meet the one-parameter definition of
wetlands under the Coastal Act. The CCC asked that a oneparameter wetland delineation be conducted. The City denied the request. The CCC has also identified the
undeveloped San Pedro Avenue site as potential
wetlands. Any development on this field would reduce the biological productivity or water quality of the wetlands due to runoff created by new development, in violation of the Coastal Act.

Please see response to comment
C37-4. The Army Corps of Engineers
has not made a final determination
of environmental significance to the
site.

C37-
10 Allison
West; Pedro
Point
3/7/22 Comment letters submitted by Pedro Point residents, our environmental and legal experts provide additional
specific details how a proposed change of the existing
Please see response to comment
C30-5 and Master Response 2:

Programmatic EIR for more

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Individuals (C)
Community
Association
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. They also document how these impacts have not
been adequately analyzed or mitigated in the DEIR. Nor
does the DEIR identify any meaningful reasonable
alternatives to the proposed CRMU designation that are
1) environmentally superior, 2) consistent with Coastal Act policies, and 3) compatible with the unique coastal character of Pedro Point and conservation of its important remaining open spaces.
information about the programmatic
nature of the DEIR, and how project
EIRs would be required to
demonstrate that the specifics of the
project would not create a significant
impact. Please also see Master
Response 4: Undeveloped San Pedro
Ave Sites for more information.

C37-
11 Allison
West; Pedro
Point
Community
Association
3/7/22 Most notably, the GPU Land Use map for the entire City of Pacifica (section 4-6, p. 67) shows the one main property proposed for the new CRMU designation is the privatelyowned, undeveloped San Pedro Avenue field. We assert that 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.

In conclusion, based on our counsel’s review of the law, our experts’ opinions - and in order to address the noted DEIR deficiencies as well as be in compliance with CEQA and Coastal Act policies – the most expedient solution
would be to change the proposed land use designation for the Pedro Point field from CRMU to Conservation (which
is most consistent with the current state of the
undeveloped property). The PPCA strongly encourages
you to consider this option, so that we can all look
forward to soon having an updated General Plan that will put Pacifica on the map for being a smart, vibrant,
environmentally savvy, jewel of a city.

Please see Master Response 1: EIR
Comments for more information
about GP- or SPSP-related responses.

C37-
12 Allison
West; Pedro
Point
Community
Association
3/7/22 Attachment B Community Sourced Photos No response needed.

C37-
13 Allison
West; Pedro
Point
Community
Association
3/7/22 2. Summary of findings:

The 2022 DEIR presents an inconsistent and inaccurate
description of existing environmental conditions regarding environmentally sensitive endangered fish and wildlife
species distributions, movements, and wetland habitats in the vicinity of Pedro Point.

The commenter's assertion is
unfounded. Please see responses to
comments C37-14, C37-15, C37-16,
and C37-17 for more information.

C37-
14 Allison
West; Pedro
Point
Community
Association
3/7/22 The substantial errors and omissions regarding existing environmental conditions, particularly occupied
environmentally sensitive habitats (ESHA) of federally
listed tidewater goby and California red-legged frog, and coastal seasonal and perennial wetlands connected to the mouth of San Pedro Creek, are apparently related to
arbitrary conclusions that underestimate potential
significant impacts that are neither identified nor
mitigated.

The General Plan and DEIR make use
of best available evidence from
reputable federal and State
governmental sources. The federallyprotected Critical Habitat of the CRLF and Potential ESHA sites are shown in
Figure 3.7-3 and the general
locations of special status species
(including the CRLF) are shown in
Figure 3.7-4. Based on CNDDB data
from June 2021, there have been no

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Packet Pg. 879 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 215
Letter Commenter Date Comment Combined Response
Individuals (C)
recorded instances of goby sightings
in the Planning Area.

Existing federal, state, and local
regulations along with proposed
policies identify and mitigate impacts
on environmentally sensitive habitats
and special status species to a less
than significant level.

The following clarifying language will
be added under Impact 3.7-3 on page

3.7-56. This does not change the
findings of significance of the DEIR. "Proposed Project policies ensure that implementation would
comprehensively continue to manage
entire watersheds (CO-G-2), preserve
water quality through best
management practices (CO-I-11),
protect sensitive habitat areas and
special-status species (CO-I-26), and
protect and restore creeks (CO-I-1).

Therefore, compliance with the
provisions of the Clean Water Act in
combination with implementation of
the following Proposed Project would
help to further reduce potential
impacts to federally protected
wetlands to a less than significant
level."
The following clarifying language will
be added under Impact 3.7-4 on page

3.7-62. This does not change the
findings of significance of the DEIR.
"Although there are no regulations
which protect wildlife movement
corridors per se, migratory birds that
may use riparian corridors for
dispersal, are protected under the
federal Migratory Bird Treaty Act (16
USC, Sec. 703, Supp. I, 1989). In
addition, Proposed Project policies
ensure that implementation would
properly manage public lands (CO-I42), conserve and protect open spaces that support critical wildlife
habitat and special status species
(LU-G-7), preserve steep and
sensitive terrain (LU-I-14), and
protect other environmentally
sensitive areas that include wildlife
movement corridors (CO-I-31).

Therefore, compliance with the
provisions of the Migratory Bird

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Individuals (C)
Treaty Act in combination with
implementation of the Proposed
Project policies set forth below
would help to reduce potential
impacts to wildlife movement
corridors and movement of fish or
wildlife species to a less than
significant level."
C37-
15 Allison
West; Pedro
Point
Community
Association
3/7/22 Programmatic mitigation measures in the GPU that claim to address endangered species and wetlands impacts are
mere restatements of long-standing existing state and
federal regulations and policies beyond City of Pacifica jurisdiction, and provide no additional or independent
mitigation.

This statement is patently untrue.

The Proposed Project contains a
number of policies that reduce
potential impacts. Please see Master
Response 6: ESHA and Master
Response 4: Undeveloped San Pedro
Ave Sites, and response to comments
A2-3, A2-21, A2-17, and A2-20.

C37-
16 Allison
West; Pedro
Point
Community
Association
3/7/22 The proposed GPU zoning for the Pedro Point Field is apparently inconsistent with Coastal Act policies that
depend on accurate factual baseline information
describing existing environmental conditions.

Please see response to comments
C131-1 through C131-9 for more
information on how the CRMU
designation does not conflict with
the Coastal Act.

C37-
17 Allison
West; Pedro
Point
Community
Association
3/7/22 3. Existing Conditions and Impact Assessment: Significant Errors and Omissions 3.1. Tidewater Goby. The DEIR fails to disclose the presence of a federally listed fish that inhabits San Pedro Creek, the northern tidewater goby
(Eucyclogobius newberryi). The DEIR impact assessment
and GPU zoning proposals fail to account for potential
significant indirect and cumulative impacts to the
tidewater goby. The northern tidewater goby is a small (< 6 cm total length), cryptic, annual fish that inhabits
isolated lagoons, sloughs, and stream-mouth estuaries
that are widely separated from each other. This federally listed species has experienced a reduction in the number of isolated estuarine sites it inhabits because of coastal development, droughts, and invasive non-native species
(USFWS 2005).

Sutter (2018) used highly sensitive environmental DNA
methods (eDNA) to monitor the presence or absence of
an endangered tidewater goby species, the northern
tidewater goby through its coastal range in California. He detected northern tidewater goby using eDNA methods at
four sites where they have not previously been detected, including San Pedro Creek (Sutter and Kinziger 2019). San Pedro Creek showed a strong signal of tidewater goby
presence. No recent field detection survey records based on traditional methods (seining, trapping) are available for San Pedro Creek. San Pedro Creek had previously been
listed by the U.S. Fish and Wildlife Service as potential reintroduction sites in the tidewater goby recovery plan, based on presumed absence (USFWS 2005).

The DEIR existing conditions descriptions in biological resources and hydrology sections fail to account for the Please see response to comment
C107-15. Policies related to runoff
include creek protection and
restoration (CO-I-1), improvement of
impaired waterways (CO-I-2),
limitations on diking, filling, or
dredging (CO-I-4), continued
participation in the Countywide
Water Pollution Prevention Program
(CO-I-9), protecting water quality
through Best Management Practices
(CO-I-11), on-site stormwater
management requirements (CO-I-16),
preventing contaminated runoff (COI-17), and required biological surveys prior to development (CO-I-26)
would all help to reduce the impacts
to a less than significant level.

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presence of this federally listed endangered species in San Pedro Creek. The DEIR assessments of indirect and
cumulative impacts fail to account for potential significant impacts of new development near the mouth of San
Pedro Creek. Potential indirect and cumulative impacts of new development on Pedro Point may occur because of
hydrologic linkage between Pedro Point Field and the
mouth of San Pedro Creek, where a culvert drains the
swale/ditch at the east end of the field into the small estuarine lagoon at the stream mouth. The potential
impacts of tidewater goby are not dependent on the
distribution of federally listed critical habitat, which is a legal designation of a sub-set of sensitive habitats for the species made after considering economic factors. Figure

3.7-3, Sensitive and Critical habitat, does not represent any potential or likely habitat of tidewater goby in San Pedro Creek, especially near the estuarine mouth, the
most likely location of resident populations. This figure is incomplete, inaccurate, and misleading regarding
potential significant impacts of the GPU zoning proposals to tidewater goby. The DEIR Hydrology section at 3.5-4
states that San Pedro Creek is a key coastal watershed
because it contains federally listed anadromous steelhead trout. This description of existing hydrological conditions in context of federally listed aquatic species repeats and reinforces the significant omission of the other resident federally listed non-anadromous fish species, tidewater goby (Eucyclogobius newberryi) that has been
conclusively been determined to be present in the
watershed by environmental DNA (eDNA) methods
(Sutter and Kinsiger 2019). The GPU proposes zoning
changes for the Pedro Point Field that support new
development. The potential impacts of proposed zoning
and land use changes to the tidewater goby population
were not considered in the DEIR. New development
runoff could transport sediment, pesticides, surfactants (detergents from automobile washing), spilled fuels,
polycyclic aromatic hydrocarbons (PAHs), fertilizer runoff, and heavy metals, and point-discharge directly to the
likely primary habitat of tidewater gobies at the mouth of San Pedro Creek. Adverse impacts to water quality in the lowest (estuarine lagoon) reach of the creek could
significantly adversely affect growth, survivorship, and reproduction of the population of this listed fish species.

This potentially significant impact was not identified or assessed in the DEIR at all.

1.f
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Individuals (C)
C37-
18 Allison
West; Pedro
Point
Community
Association
3/7/22 3.2. California red-legged frog. The California red-legged frog (Rana draytonii) inhabits the mouth of San Pedro
Creek and neighboring wetlands and non-wetland
foraging habitats. Since 2005, I have observed multiple adult California red-legged frogs basking on the banks of the roadside pool at the corner of San Pedro Avenue and the Pedro Point Field, and diving into the pool when
disturbed. I first documented this locality and reported it to the U.S. Fish and Wildlife Service in 2005. This pool, which is perennial (standing water most of the year), is connected to the mouth of San Pedro Creek by a
continuous wetland swale and channel, ending in culverts that discharge to the freshwater estuarine reach of San Pedro Creek. The wetland swale provides a continuous
habitat movement corridor (dispersal, foraging) for adult California redlegged frogs. The pools also provide
potential breeding habitat when they have standing water through at least early summer.

The main local (core) source population of the California red-legged frog is likely the restored freshwater marsh at the mouth of San Pedro Creek. In 2014, during
construction of the Highway bridge retrofit that required dewatering of the creek mouth and authorized capture
and translocation of California red-legged frogs, I
observed contract biologists capturing many dozens (total over 100) of adult California red-legged frogs from the path of excavator operations, and from wetland soil
loaded in excavator buckets from marsh at the mouth of
San Pedro Creek. This main population is likely to provide adult frog colonizers of intermittently available habitats along the wetland swale corridor bordering San Pedro
Field.

None of these known occupied habitats is shown in Figure

3.7-3 Sensitive and Critical habitat. The map omits all occupied existing California red-legged frog wetland
habitats (marsh and willow wetland) at the mouth of San Pedro Creek, as well as the known occupied wetland
swale at the east end of Pedro Point field. The extensive freshwater marsh here is not even mapped as wetland
habitat in the DEIR. Individually and in combination, these are highly significant and misleading omissions about
existing conditions for California red-legged frog habitat and populations.

Sensitive habitats of California red-legged frogs are not limited to federally listed, legally designated “critical habitat”. In a CEQA and Coastal Act (ESHA) context, all breeding and adult habitat, including terrestrial dispersal and foraging habitats (especially where “take” of the
species may occur) must be considered “sensitive”
habitat. The description of existing conditions is not the same as the description of designated critical habitat, which is a federal listing (Federal Register) of lands with 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 clearly shows the Critical
Habitat areas for the CLRF, in
coordination with the most up to
date information provided by
USFWS. Figure 3.7-3 also clearly
shows a portion of San Pedro Creek
as potential ESHA. Figure 3.7-4
clearly shows recorded detections of
the CRLF, sourced from the California
Natural Diversity Database. This
represents the best available
evidence at the programmatic level.

Proposed Project includes multiple
policies to protect the CRLF; please
see response to comments A2-3, A2-
16, and A2-20. Level of detail of
analysis and programmatic nature of
the Draft EIR are summarized under
Master Response 2: Programmatic
EIR.

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Individuals (C)
special legal status under the Endangered Species Act, not factual existing conditions about habitat and species
distributions relevant to impact assessment. The Figure

3.7-3 map is incorrect and misleading in respresenting
actual sensitive species habitats, by omitting known
occupied and suitable habitats that are not federally
listed. As a CEQA (State) document, this omission is
particularly inappropriate for a state-listed wildlife
species.

The habitat of California red-legged frogs is not limited to aquatic breeding habitat or perennial freshwater marsh, but includes nearby coastal terrestrial habitats that
produce prey, regardless of habitat quality or cover.

Nocturnal foraging of adult red-legged frogs occurs
terrestrial, nonbreeding habitats in moist, coastal
climates. Telemetry study of California red-legged frogs on the Central coast has shown that 66% of female and 25%
of male frogs moved 150 m (median; up to 1400 m) to
nonbreeding terrestrial areas for foraging, even when the breeding site retained water. (Fellers and Kleeman 2007).

Research findings of Fellers and Kleeman (2007) and
Bulger et al. (2003) indicate that terrestrial habitats of California red-legged frog migration corridors do not have to be high quality or “pristine” riparian or upland habitats (e.g., overland nocturnal foraging habitat of California redlegged frogs includes “degraded” closely grazed fields, plowed agricultural land, etc.).

The zoning proposals of the GPU fail to account for the California red-legged frog ESHA (Coastal Act) of the
wetland swale and adjacent lowland grassland of Pedro
Point Field. General, programmatic mitigation measures
are inadequate, because they do not consider existing
conditions of the species habitat and movements in the
vicinity of San Pedro Creek and ecologically and
hydrologically connected wetlands and adjacent lowlands.

C37-
19 Allison
West; Pedro
Point
Community
Association
3/7/22 3.3. Vegetation. The description of existing conditions for vegetation in the DEIR is inaccurate and misleading with regard to the distribution of northern coastal scrub,
grasslands, and wetlands.

Figure 3.7-1 vegetation classification map represents the Pedro Point Field location color-code mapped as
“northern coastal scrub”. In fact, none of the dominant or associated plant species enumerated as northern coastal scrub species indicators in the DEIR occur in the Pedro Point field, which is dominated by herbaceous (not scrub) lowland non-native grassland species, and a minority of seasonal wetland plants occurring in poorly drained flats.

The vegetation map representing the distinct polygon
over Pedro Point field is incorrect, completely
misrepresents existing conditions for vegetation.

The DEIR uses the best available
evidence from credible government
sources, such as from the California
Department of Fish & Game;
California Department of Forestry;
National Wetlands Inventory, U.S.;
and Fish and Wildlife Service National
Wetlands Inventory and the U.S. Fish
& Wildlife Services, at the
appropriate scale of a Programmatic
EIR for a General Plan. Please see
Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro
Ave Sites for more information.

C37-
20 Allison
West; Pedro
Point
3/7/22 The vegetation map of Figure 3.7-1 also omits the distinct perennial wetland swale (drainage trough containing
native and nonnative marsh vegetation) at the east end of The DEIR uses the best available
evidence from credible government
sources, such as from the California

1.f
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Individuals (C)
Community
Association
the field, which is significant as ESHA (environmentally sensitive habitat area) in itself, independent from its ESHA status as likely terrestrial foraging and migration habitat for federally listed California red-legged frogs.

Department of Fish & Game;
California Department of Forestry;
National Wetlands Inventory, U.S.;
and Fish and Wildlife Service National
Wetlands Inventory and the U.S. Fish
& Wildlife Services, at the
appropriate scale of a Programmatic
EIR for a General Plan. Please see
Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro
Ave Sites for more information.

C37-
21 Allison
West; Pedro
Point
Community
Association
3/7/22 The DEIR description of “wetlands” in Pacifica (3.7-10) does not accurately reflect any of the dominant wetland vegetation types that exist at the mouth of San Pedro
Creek freshwater marshes and riparian areas, or the
Pedro Point Field, though the depressional freshwater
wetlands at the north end of Pacifica State Beach are
described. The extensive perennial freshwater and
estuarine-influenced restored marsh at the mouth of San Pedro Creek, which is known to support a large
population of federally listed California red-legged frogs and many wetland wildlife species (including garter
snakes, subspecies undetermined; Great blue herons,
Great Egrets, breeding red-winged blackbirds, dabbling
ducks, etc.) is not represented in the DEIR as a wetland, let alone an important one. The description of wetland
existing conditions here is significantly erroneous and misleading.

See response for C37-19. This
comment is false, the mouth of the
San Pedro Ave creek is designated as
Estuarine and Marine Deepwater. It
is also shown as a potential ESHA on
Figure 3.7-3. Please see response to
comments
C37-
22 Allison
West; Pedro
Point
Community
Association
3/7/22 The DEIR also fails to represent the wetland riparian corridor (willow scrub to sedge marsh and smartweed
marsh) along the drainage swale connecting the culvert at San Pedro Creek to the east end of the Pedro Point Field along the eucalyptus grove, an area where the DEIR does propose a change in land use and zoning. Inexplicably, as the DEIR arbitrarily omits the important freshwater
wetland complex of San Pedro Creek mouth and
connected, adjacent lowlands, it emphasizes freshwater
wetlands at the north end of Pacifica State Beach, where there is no proposed zoning change to analyze. This
arbitrary inversion of DEIR focus, coupled with significant omissions of existing important wetlands of the San Pedro creek mouth complex, is profoundly misleading, and
makes meaningful public comment impossible.

See response for C37-19. The DEIR
used the best available and most
appropriate data for a programmatic
analysis. Please see also Master
Response 6: ESHA and Master
Response 4: Undeveloped San Pedro
Ave Sites.

C37-
23 Allison
West; Pedro
Point
Community
Association
3/7/22 The DEIR treats erroneously classifies all grassland vegetation in Pacifica as “annual grasslands”, and
describes “annual grassland” composition only in terms of dominant non-native herbaceous species of hillslope
(foothill) grasslands, regardless of ecologically significant components of native perennial or annual plant species, or lowland (valley, alluvial) topography, soils, hydrology and drainage. Pacifica grasslands in fact include coastal prairie with subdominant to dominant (seasonally
variable) native perennial and annual herbaceous
Please see response to comment C1-

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vegetation, such as that of Rockaway Head and Pedro
Point headlands.

C37-
24 Allison
West; Pedro
Point
Community
Association
3/7/22 At Pedro Point Field, the dominant vegetation is lowland valley grassland with significant local patches of native and non-native seasonal wetland vegetation. Pedro Point Field is seasonally saturated and flooded (intermittently during droughts), and has supported persistent
inconspicuous (small and identifiable only in moist spring conditions) remnant populations of native wetland
species including Triglochin scilloides (Lilaea scilloides; flowering-quillwort), Juncus bufonius complex (variety
undetermined; toad rush), and (rarely) Cicendia
quadrangularis (Oregon timwort) despite dominance in
most seasons by introduced ryegrass (Festuca perenne,
syn. Lolium perenne) and Mediterranean non-native
annual grasses. The omission of the lowland, alluvial
seasonal wetland character of the poorly drained valley grassland flats in the field, combined with their map
misrepresentation as coastal scrub, and the general
identification of all grasslands in Pacifica as non-native annual hillslope grasslands, is inaccurate and misleading as a description of existing conditions with potential
significant impacts at stake for proposed zoning changes.

See response for C1-7 and C37-19.

Please also see Master Response 6:

ESHA and Master Response 4:

Undeveloped San Pedro Avenue
Sites.

C37-
25 Allison
West; Pedro
Point
Community
Association
3/7/22 Other figures in the DEIR exacerbate the ecological misrepresentation of existing conditions for vegetation and habitats at the Pedro Point Field. Figure 2.1-2:

General Plan Land Use represents “paper” non-existent
streets through the Pedro Point Field lowland grassland, misrepresenting “existing conditions” as more developed with road infrastructure than actual existing conditions, and an expression of the novel zoning designation,
“Coastal Residential Mixed Use”.

The General Plan Land Use figure
shows land use changes under the
Proposed Project, not existing
conditions. Existing Land Use is
shown in Figure 3.1-3. The comment
on "paper streets" is noted and will
be removed from the Existing Land
Use map. Vegetation and habitats at
the Pedro Point site are shown in
figures 3.7-1 and 3.7-3, respectively.

C37-
26 Allison
West; Pedro
Point
Community
Association
3/7/22 Figure 3.6-3: Slope Failure and Coastal Erosion shows the field separated from the ocean directly behind a shoreline marked “critical coastal erosion”, and “Severe Beach &
Cliff Erosion” (potential tsunami, coastal flooding and erosion hazard). See 3.6-17, “ bluffs…projected to have eroded by 23-24 m by 2050” . Figure 3.6-1: Seismic Hazard Zones shows the whole field as “Liquefaction zone”, in
contrast with adjacent residential slopes, reflecting the siting of the field on deep alluvium of historic marsh and swamp.

Please see response to comment
C47-3 for more information about
coastal flooding and coastal erosion,
and C21-10 for more information
about liquefaction on this site.

C37-
27 Allison
West; Pedro
Point
Community
Association
3/7/22 Figure 3.5-1 Hydrology and flood zones, shows the entire field mapped as “tsunami flood evacuation zone”. The
context for existing conditions and future potential land uses of the field and its existing habitats should be made clear, combined with the indirect effects of accelerated sea level rise on flooding and groundwater elevations
within the time-horizon of the GPU, in context of
proposed zoning changes.

See Master Response 2 regarding the
programmatic nature of the DEIR.

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less than significant and therefore
the analysis in the DEIR is valid. See
response to comment C13-9
regarding California Coastal Act
Regulations.

C37-
28 Allison
West; Pedro
Point
Community
Association
3/7/22 Groundwater elevations rise with rising sea levels, and coastal flooding risks during extreme rainfall events must increase as the base level of drainage (at the culvert
connection to San Pedro Creek, relative to storm wave
runup elevation) increases. This is pointedly relevant to the assessment of cumulative impacts to seasonal and
perennial wetland habitats of Pedro Point Field and
zoning changes, but it is not analyzed or disclosed at all in the DEIR. As flooding and groundwater levels increase
with sea level rise, ESHA wetland habitats are likely to expand naturally, or set up conflicts with new
development requiring increased flood protection, surface drainage, and sub-drainage (groundwater pumping that
dewaters wetlands) in ESHA. The DEIR does not analyze
this impact and policy conflict in terms of Coastal Act Section 30240 Environmentally sensitive habitat areas
(ESHA); adjacent developments, which states:
(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.
(b) Development in areas adjacent to environmentally
sensitive habitat areas and parks and recreation areas
shall be sited and designed to prevent impacts which
would significantly degrade those areas, and shall be
compatible with the continuance of those habitat and
recreation areas.

See Master Response 2 regarding the
programmatic nature of the DEIR.

In regards to wetlands, proposed
policy CO-I-4 prohibits new
development in existing wetlands
except as allowed under the federal
Clean Water Act and the California
Coastal Act. It continues 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 nonet-loss goal regarding wetlands. See also Master Response 8 regarding
ESHA.

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Individuals (C)
C37-
29 Allison
West; Pedro
Point
Community
Association
3/7/22 4. Programmatic mitigation is vague and ineffective for wetlands, ESHA and sea level rise.

Programmatic mitigation measures related to ESHA,
wetlands, and special-status species are vague and
redundant re-descriptions of existing state and Federal regulations or policies that provide no meaningful
additional mitigation to potential significant impacts of proposed GPU actions, including location-specific zoning proposals for Pedro Point. For example, CO-1-4, “wetland preservation” establishes a meaningless and incomplete
prohibition that establishes an exception that swallows the rule, allowing any wetland development that is
permitted by the Corps of Engineers (Clean Water Act
Section 404) and Coastal Commission (Coastal Act). The
Corps has no history of permit denial in Pacifica or San Mateo County, and the Coastal Commission has (a)
limited geographic jurisdiction in Pacifica seaward of the first ridge, and (b) a history of “emergency” authorizations for coastal erosion that bypasses policies, including ESHA.

The DEIR fails to explain any evidence or analysis
demonstrating how this policy could possibly provide any substantive mitigation or protection to Pacifica wetlands in conflict with development. Similarly, impermissibly
vague policy CO-I-7, “Maintain Functional Capacity of
Wetlands, Ensure that any diking, filling, or dredging in existing wetlands maintains or enhances their functional capacity” provides no substantive criteria to make it
enforceable.

Compliance with federal and state
regulations, including the Clean
Water Act and Coastal Act, represent
meaningful ways of reducing
impacts. The U.S. Army Corps of
Engineers regulatory program
supports the national goal of “no
overall net loss” of wetlands. For
permitted activities that result in
unavoidable losses, the Corps
requires replacement wetlands to
offset those losses. The Corps places
a significant emphasis on ensuring
that the ecological quality of
impacted and replacement wetlands
are the same. The Coastal
Commission also has regulatory
jurisdiction for areas in the Coastal
Zone and includes specific policies
related to wetlands and ESHA.

Should the Coastal Commission find
that development is not consistent
with Coastal Act policies and policies
in the LCLUP, they would not
approve a permit, and the project
would not be allowed to occur.

Policy CO-I-4 does not represent a
meaningless and incomplete
prohibition; it prohibits new
development except as allowed
under the Clean Water Act and
California Coastal Act. The Clean
Water Act Section 404 requires a
permit before dredged or fill material
may be discharged into waters of the
United States, unless the activity is
exempt from Section 404 regulation
(e.g., certain farming and forestry
activities). When an applicant applies
for a permit, they must first show
that steps have been taken to avoid
impacts to wetlands, streams and
other aquatic resources; that
potential impacts have been
minimized; and that compensation
will be provided for all remaining
unavoidable impacts. Coastal Act
Section 30233 states (in relevant
part): (a) The diking, filling, or
dredging of open coastal waters,
wetlands, estuaries, and lakes shall
be permitted in accordance with
other applicable provisions of this
division, where there is no feasible
less environmentally damaging

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Individuals (C)
alternative, and where feasible
mitigation measures have been
provided to minimize adverse
environmental effects, and shall be
limited to the following:

New or expanded port, energy, and
coastal-dependent industrial
facilities, including commercial
fishing facilities.

Maintaining existing, or restoring
previously dredged, depths in
existing navigational channels,
turning basins, vessel berthing and
mooring areas, and boat launching
ramps.

In open coastal waters, other than
wetlands, including streams,
estuaries, and lakes, new or
expanded boating facilities and the
placement of structural pilings for
public recreational piers that provide
public access and recreational
opportunities.

Incidental public service purposes,
including but not limited to, burying
cables and pipes or inspection of
piers and maintenance of existing
intake and outfall lines.

Mineral extraction, including sand for
restoring beaches, except in
environmentally sensitive areas.

Restoration purposes.

Nature study, aquaculture, or similar
resource dependent activities.

CO-I-7 specifies that "any alteration
of coastal wetlands identified by the
Department of Fish and Wildlife or as
defined by the Coastal Commission
shall be limited to very minor
incidental public facilities, restorative
measures, or nature study." As stated
above, the Coastal Commision
enforces permitting in areas
designated as wetland, and if the
project did not demonstrate feasible
mitigation, they have authority to
deny the permit. Please also see
Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro
Ave Sites for more information about
site-specific studies required for any
development approval in this area.

Proposed Project policies are not
intended to act as mitigation

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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. Please see Master
Response 2: Programmatic EIR for
more information.

C37-
30 Allison
West; Pedro
Point
Community
Association
3/7/22 Similarly, policy SA-G-5,”Sea Level Rise and Best Available Science. Planning and development reviews shall use, as applicable, the best available science about projected sea level rise and other climate change-related environmental changes when addressing coastal erosion, bluff failure, flooding, and other coastal hazards” is a vague
exhortation with no substantive procedures or criteria
that apply to any location-specific proposed zoning
changes, such as CRMU for Pedro Point Field. In fact, the DEIR does not even refer to sea level rise and related
indirect hydrologic changes (flooding and groundwater
elevations), or apply this vague policy, in considering zoning for Pedro Point Field.

Policies within the LCLUP related to
effects of climate change and sea
level rise are addressed in the LCLUP.

See response to comment C13-3 for
more information about coastal
flooding and sea level rise. Please see
also Master Response 4:

Undeveloped San Pedro Ave Sites.

C37-
31 Allison
West; Pedro
Point
3/7/22 Attachment Comments do not apply to the most
recent EIR submittal and pertain to
the 2014 DEIR. As such, these are not
addressed.

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Community
Association

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C38: Peter Loeb, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C38-1 Peter Loeb 3/7/22 1. There are 2 Pacifica General Plan DEIRs – Pacifica General Plan Draft Environmental Impact
Report (DEIR) released on Jan. 7, 2022, State
Clearing House number 2020089010 and another
DEIR released on Feb. 14, 2022 with a new State
Clearing House number, 2012022046, but with
the same publication date of Jan. 7. There are
differences between the two documents. 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
The two DEIRs are the same; the public
requested a version with an interactive table
of contents. A duplicated wildfire chapter was
removed to present an accurate table of
contents. This version was uploaded to the
State Clearinghouse.

C38-2 Peter Loeb 3/7/22 2. Maps and data are either missing or out of date for fire hazards, landslides, flooding, earthquakes,
sea level rise, and erosion. More recent data and
maps need to be included in revised General Plan
and DEIR documents.

Please see response to comment C22-10 for
more information on the adequacy of hazards
mapping for wildfire (see also Master
Response 5: Wildfire), landslides, and
flooding; these use the latest, best available
data. Please see response to comment C13-3
for more information on sea level rise
mapping.

C38-3 Peter Loeb 3/7/22 3. Policies referenced in both the General Plan and DEIR are inconsistent or have different
wording. There are many instances where the text
in the DEIR does not match that of the samenumbered policy in the General Plan. These inconsistencies need to be corrected.

These inconsistencies are corrected in errata.

These clarifications do not change findings of
significance in the DEIR.

C38-4 Peter Loeb 3/7/22 4. Data missing from the General Plan includes how much acreage is in each land use
designation. The DEIR does not analyze the
environmental impacts of total buildout. The
General Plan and DEIR do not address full
buildout, the RHNA housing numbers, and the
effects of SB9 & SB10 and other state legislation
that will affect development and full buildout
numbers.

The comment is noted. Please see response
to comment C4-1 and Master Response 3:

Buildout and RHNA for more information
about buildout adequacy and how RHNA
impacts will be analyzed in a separate EIR.

C38-5 Peter Loeb 3/7/22 5. The Local Coastal Update Plan has not been certified by the California Coastal Commission.

The CCC will need to approve that part of the
General Plan that is in CCC jurisdiction, including
the Sharp Park Specific Plan.

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

C38-6 Peter Loeb 3/7/22 6. Traffic data used in the DEIR analysis is from 2010, before the Devil’s Slide tunnel was built.

More recent traffic data is available. The General
Plan and DEIR should use more recent data in
analyzing traffic impacts of full buildout.

Traffic counts from pages 3-12 to 3-21 were
conducted in 2018 and 2019, and analysis
from Table 3.2-7 on page 3-41 was conducted
in 2020 and 2021, in accordance with the
table references in the DEIR. No further
response is required.

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Individuals (C)
C38-7 Peter Loeb 3/7/22 7. Add an overlay district for no new subdivisions in high hazard or high value habitat or climate
resilience areas
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.

C38-8 Peter Loeb 3/7/22 8. Add an overlay district that encourages density for infill development, as for example in strip
malls.

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

C38-9 Peter Loeb 3/7/22 9. Finally, the names of three of the five Pacifica City Council members are spelled incorrectly and
need to be corrected.

The comment is noted. The text changes are
incorporated in the General Plan errata. They
do not relate to adequacy of DEIR analysis.

C38-10 Peter Loeb 3/7/22 Conclusion: The General Plan and DEIR both need to be extensively revised to address changes in
material facts and other issues raised in the public
comments, then the General Plan and DEIR
should be recirculated.

The comment is noted. Please see prior
responses in letter C38 for more information
about the adequacy of the DEIR.

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C39: Paul Totah, 2/25/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C39-1 Paul Totah 2/25/2
2 C-163 is latest version of this email - comments are marked in that version
No response needed.

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C40: Adam Mayle, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C40-1 Adam Mayle 3/7/22 II. 45-day comment period is inadequate. On January 7, 2022, the City of Pacifica released public review drafts of the draft Environmental Impact Report (EIR), General Plan Update, and Sharp Park Specific Plan. The deadline for public comments was set for February 21, 2022.

This 45-day comment period is inadequate and unreasonable for documents that cumulatively run over 1,000 pages. Moreover, the documents themselves were poorly assembled, difficult to understand, and hard to navigate. As noted in a recent column in the Pacifica Tribune: “Some of the documents lack page numbers.

The table of contents are not live links online, so you have to guess, say, where Page 283 is on the massive document you just downloaded onto your suddenly overburdened laptop. The
documents are laden with government speak, charts, illustrations and maps. The “executive summary,” meant to briefly explain what lies beyond, comes in at a weighty 147 pages.”3 Forty-five days is a nearly impossible deadline for an engaged and civic-minded Pacifica resident to absorb, evaluate and react to this volume of information. Moreover, this 45-day period is stricter than the comment period that other governmental entities provide to industry and advocacy groups – whose full-time job is to evaluate and react to proposals that are much less extensive than the Plan Draft. Those comment periods may be 60, 90, or 120 days or longer.4 An unfortunate perception from this rushed and troubled comment process is that the City of Pacifica is actively attempting to hinder Pacifica residents from engaging in the General Plan update. It’s not a good look. The City of Pacifica should extend the comment period immediately to allow Pacifica residents a reasonable opportunity to review the Plan Draft, the EIR, and the Sharp Park Specific Plan.

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.

C40-2 Adam Mayle 3/7/22 III. Develop one city center – in Sharp Park According to the Plan Draft, “a unique, Vital Center for Pacifica” would provide a community gathering place and strengthen the City’s identity. “Currently, Sharp Park is the city’s civic core and is home to many unique businesses, as well as the iconic Pacifica Pier.” “Palmetto Avenue, the ‘backbone’ of the Sharp Park Specific Plan Area, has potential to expand its function as a town center retail district by transitioning to a pedestrian-oriented, mixed-use area.”
I enthusiastically support an implementation program to develop a “city center” in Sharp Park and create a pedestrian district along Palmetto Avenue for the reasons articulated in the Plan Draft.

However, I encourage the City of Pacifica to not develop a second “center” elsewhere (e.g., in Rockaway Park or the Quarry). There is an old adage in football: “If you have two quarterbacks, you have no quarterbacks.”5 The same holds for city centers, particularly when one doesn’t yet exist. The City of Pacifica should focus any attention on Sharp Park development and get it right. If two centers are promoted, they would risk competing with each other and preventing the critical mass of customers and foot traffic at either location that is necessary for success. As noted in the Plan 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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Draft, Pacifica has an underdeveloped retail market and suboptimal demand.6 Where would the demand come from for two centers? Moreover, if Pacifica attempts to develop two city centers with more intensive, mixed-use retail, local business may face critical staffing shortages. As the Plan Draft noted, Pacifica’s unemployment rate is extremely low: as of 2019, on average 2.2 percent.7 An unemployment rate this low means a significant lack of surplus workers, which likely has only gotten worse during the pandemic. For instance, businesses across the nation have reported critical staffing shortages and the inability to find employees.8 In theory, Pacifica businesses potentially could meet this demand by attracting workers from surrounding communities (which would raise new traffic and public transit issues). However, perhaps more likely, the new city centers would compete for employees within existing Pacifica businesses and cannibalize their workforce. To avoid these complications, the City of Pacifica should focus on encouraging one city center in Sharp Park.

C40-3 Adam Mayle 3/7/22 IV. Permitting a major hotel or resort development in the quarry is misguided. The Plan Draft repeatedly suggests developing a resort or luxury hotel in the Rockaway Beach Quarry site. Given Pacifica’s proximity to San Francisco, the Plan Draft suggests that Pacifica may have a comparative advantage to other resort locations, “such as Half Moon Bay, Point Reyes, and even Napa.” The Plan Draft notes that “a resort hotel also could provide conference facilities that could attract business groups.”
The Plan Draft’s arguments in favor of a hotel – let alone a “luxury hotel” or “resort” – are based on fundamentally flawed
assumptions and are not realistic. There likely would be limited demand for luxury or conference services that the Plan Draft proposes. As the Plan Draft concedes, Pacifica’s existing hotels underperform relative to the county average in terms of occupancy rates.9 The former Holiday Inn (now, Fairfield Inn and Suites) has already undergone a major expansion and it’s unclear how that will impact occupancy rates in the city. Where will the customers for a luxury hotel or resort come from? It is widely reported that tourism to the San Francisco area has declined in recent years, which has directly impacted occupancy rates. In September 2021, San Francisco hotel occupancy rate was approximately 40 percent.10 With respect to conference-based tourism, San Francisco is losing ground to other destinations, including Las Vegas. As reported in the San Francisco Chronicle, “Las Vegas’ tourism recovery has outpaced San Francisco’s sluggish comeback, and some Bay Area events have moved to Sin City.” 11
The proposition that a luxury hotel would succeed is also dubious.

Pacifica is a lovely city with gorgeous sunsets and pleasant trails, but by the Plan Draft’s own admissions it lacks the type of amenities – such as fine dining or sophisticated retail – that would be expected by a luxury consumer segment. In addition, while Pacifica has picturesque beaches, it is candidly not the type of locale that would attract those seeking a “beach vacation.” The weather is variable, the water is cold, and the waves can be hazardous.

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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Individuals (C)
For someone arranging a vacation in the Bay area, it’s far more likely that they’d stay in San Francisco and make a day trip to Pacifica than the reverse. For a consumer seeking accommodations outside of San Francisco, would Pacifica really have a “comparative advantage” over Napa, which is a world-class wine and dining destination? By the Plan Draft’s own admission, its retail is “older and underutilized.” I love my home. But the City of Pacifica must be realistic about the prospects for a resort or luxury hotel and guard itself against motivated reasoning. By embarking such a project, the City of Pacifica would create a heavy commercial footprint in an environmentally sensitive area. At best, it would siphon customers from existing hotels. At worst, it would be an albatross around the Pacifica’s neck. On a final note, it’s ironic and paradoxical that the Plan Draft would propose to “foster a distinctive sense of place” by recruiting a major resort hotel.12 On its own terms, this plan is nonsensical. The world has enough Wyndhams. As discussed further below, Pacifica has a more genuine and interesting “brand” to offer. A new luxury hotel or resort in Pacifica is unrealistic given Pacifica’s existing retail offering and amenities. Such a project would almost certainly become a “white elephant” whose costs would be grossly out of proportion to its benefits.

C40-4 Adam Mayle 3/7/22 V. Promoting tourism to Pacifica would be beneficial, but the General Plan’s primary goal should be to improve retail and amenities for Pacifica residents. According to the Plan Draft, “Pacifica has the potential to be ‘place-making’ and build tourismbased shopping environment over time.” The Plan Draft calls for developing a Pacifica “brand” to “shape its image as a desirable destination.”
This is an understandable goal, but Pacifica can’t become a beacon for tourism solely through marketing efforts. While endowed with natural beauty, Pacifica’s commercial foundation is lacking, which inhibits both tourism and, more importantly, consumption by Pacifica residents. As the Plan Draft concedes, “[m]any of the retail properties are older and underutilized (though some have undergone renovations) . . .The lack of diverse retail opportunities limits the City’s regional retail draw.” When descending into Pacifica on Highway 1, one of the first sights that greet visitors is Manor Plaza, the sign for which is literally held together with ropes. While Eureka Square has been improved, Linda Mar Shopping Center is very dated. Owing the City of Pacifica’s new RV ordinances, derelict vehicles have settled by the golf course, at major intersections near Manor, and monopolize the views along Esplanade Avenue.

To try to boost tourism before addressing these and other lifestyle issues is to put the cart before the horse. If the General Plan guides development to make Pacifica desirable for Pacificans, boosting internal retail demand and local spending, tourism will follow.

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.

C40-5 Adam Mayle 3/7/22 On a final note, I push back on the notion that Pacifica lacks a “brand.” Pacifica is a well-regarded surfing destination and home to some of the best mountain biking trails on the west coast. The City of Pacifica could work with local groups, develop and preserve infrastructure (including preserving local trails) and sponsor The comment is not related
to the adequacy of the DEIR,
therefore no further
response is required in the
FEIR. However, the

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contests. Comparable strategies have put other cities, such as Bend, Oregon, on the map. Further, the City of Pacifica should look at a business segment that is thriving today: breweries. Pacifica Brewery and the recent addition of Humble Sea have no lack of customers. Other cities, such as Rehoboth Beach, Delaware, in conjunction with Dogfish Head Brewery, have gained notoriety with highquality beer. For instance, if Monterey has a “cannery row,” why couldn’t Pacifica recruit and foster high-quality breweries and establish a “brewery row?”
Pacifica should play to its strengths and nourish and encourage truly distinctive business sectors rather than trying to develop a generic beach tourism premised on a hypothetical population of luxury consumers.
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.

C40-6 Adam Mayle 3/7/22 VI. A better use for the Quarry As discussed above, the luxury hotel or resort development in the Rockaway Beach Quarry is based on unreasonable assumptions.

However, the quarry is a site with potential, and the City of Pacifica should make better use of it. Whatever is developed there, the City of Pacifica should try to ensure that there is a light development footprint that is appropriate for the environmentally-sensitive coastal location and does not require a significant development of municipal infrastructure.

For example, the city could develop a multi-purpose, “fair”-like setting for civic events. This could be used as a location for an expanded farmer’s market, food trucks or train cars (such as the extremely successful Gorilla BBQ), sporting competitions (for example, archery or bike racing), or potentially even a music venue. If it was desired, the Quarry could serve as a unique, natural amphitheater along the lines of Stern Grove. Given the exodus of music venues and events from San Francisco proper, Pacifica would be in a position to capture some of this business. A venue destination called “The Quarry” would market itself.

Utilizing the Rockaway Quarry community and cultural events would be an environmentallyresponsible strategy and more reliably generate tourism than a generic luxury hotel or resort.

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.

C40-7 Adam Mayle 3/7/22 VII. Let’s improve the trail system – but not overdevelop it.

The Plan Draft would identify “priorities for open space preservation and strategies to protect open space while allowing limited development, to be clustered and designed to fit into its natural setting. It also proposes an enhanced trail system connecting the coastline and ridges throughout Pacifica.” This is an excellent goal, but I would caution the City of Pacifica from overdeveloping Pacifica’s trail systems. For example, developing “hiker’s huts” and “cabins” are completely unnecessary, as none of Pacifica’s trails are particularly lengthy. Even the hike from San Pedro Valley Park, over Montara Mountain and down to Gray Whale Beach, can be accomplished in a few hours at a moderate pace. Moreover, such physical infrastructure along trails would detract from the natural beauty that drives demand.

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.

C40-8 Adam Mayle 3/7/22 In addition, I’d discourage the development of concession stands along trails. Concession stands would increase the amount of trash The comment is not related
to the adequacy of the DEIR,

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that builds up along trails. A stark example of this problem is the trashcans near Mori Point, which routinely overflow on weekends. 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.

C40-9 Adam Mayle 3/7/22 With regard to additional signage and wayfinding, it’s nice in theory, but in practice it probably has extremely limited value.

Pacifica’s trails are not extensive and it’s hard to get lost, particularly in an age of GPS and apps like AllTrails. With respect to interpretive signage, I’ll offer a personal anecdote as to their value.

I walk from Fairway Park to the beach nearly every day. Over the last two years, I can probably count on one hand the number of times that I’ve seen anyone stop to read the signage about Mori Point or the endangered California garter snake. The City of Pacifica could probably find better uses for money than on such interpretive signage.

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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C41: Adam Mayle, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C41-1 Adam Mayle 3/7/22 Repeat of C40. Repeat of C40, no further response needed.

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C42: Sheila Gamble-Dorn, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C42-1 Sheila
Gamble-Dorn
3/7/22 I am a resident at XXX Shoreside, known as the
railroad berm on Pedro Point. Since the pandemic
and especially with the initial stay-at-home orders,
our beach area and road has become widely known
as a destination place for many people.

The railroad berm road is a one-way, dead-end road
and cars must back-off the road to get out. We have
plenty of signs and have orange cones to notify
people of the private road for their safety and ours.

So I was happy to see that the berm #25 on the map
of the plan is designated as a “private road with no
public access to the beach”.

I was also pleased with the section of the plan that
deals with upkeep for areas the public uses on a
private road since sections of the road are always
subject to maintenance. “ Until such a private entity
agrees to be responsible for liability and maintenance
of such access ways, they are not required to be open
for public use.”Designating the berm as a “public
viewpoint” does mean concern for the public’s safety
on a road built about 100 years ago.

It would be better not to designate the railroad berm
as a “public viewpoint” since so many people come
here on their own and this would only increase
erosion of the railroad berm road. It is also the
driveway for the residents living there and can be
unsafe if people don’t understand that the residents’
cars will be using that road.

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.

C42-2 Sheila
Gamble-Dorn
3/7/22 I would also like clarification of fig. 6.3 on the coastal access map which says, “improve new segment of
Coastal Trail along former railroad berm.” The berm
wouldn’t connect to the Coastal Trail. It leads away
from the Coastal Trail. Connecting the the Coastal
Trail by Ace Hardware should happen east of the
shopping center at Pedro Point.

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.

C42-3 Sheila
Gamble-Dorn
3/7/22 My other concern is giving a Mixed Use and MDR
Medium Density Residential designation to building in
the field at Pedro Point—70 residences. There is only
one way out of Pedro Point for everyone living here.

Adding such a high density of people trying to exit the field is disturbing and not safe especially if there is an emergency, such as a tidal wave.

The comment is noted. Please see Master
Response 3: Buildout and RHNA, which
notes that "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. 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." Please also see Master
Response 4: Undeveloped San Pedro Ave
Sites, which clarifies that density will be

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further limited on the currently
designated CRMU parcels. While it is
individual projects are subject to
emergency accessibility assessments is
typically assessed at a project level, an
overarching programmatic framework
exists that addresses emergency access
through local and regional regulations and
proposed General Plan policies. Given the
existing framework 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. Please see Master
Response 7: Emergency Access for more
information.

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C43: Sam Casillas, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C43-1 Sam Casillas 3/8/22 It is with great concern that I write to protest the continued willful ignorance and outright disregard of
science and all common sense that the city continues
to push for the land use designation for the five acres of land known as the Undeveloped San Pedro Avenue
Site (Site) from commercial recreation to a new
designation for residential under the designation of
“coastal residential mixed use”(CRMU) in the General
Plan Update (GPU). The city has failed to update the
GPU of many years of feedback from the start of the
GPU process as far back as 2014. The City has also
failed to include recently updated ESHA and hazard
zone data provided by he California Coastal
Commission (CCC) and has refused to conduct a valid
DEIR knowing that if they did they would have no
choice other than to designate this site as Open Space
under the Conservation (C) land use designation.

Please see Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro Ave Sites.

C43-2 Sam Casillas 3/8/22 Every scientific study, government planning document and flooding model shows that this Site has had and
will continue to have severe flooding due to its lowlying location. The city is also ignoring sea level rise and storm surge data which is due to the climate
crisis. It is not a matter of IF but WHEN a major
flooding disaster will occur on that property if it is
developed and yet the city continues to ignore science
and oppose its own citizens in Pedro Point in order to
add residential development in a highly vulnerable
location. If the City choses to ignore all the science and current evidence, endangered species, property and
lives will be at risk and any harm to people based on
this ill-conceived decision will have major
consequences on those city officials who chose the
path of disaster that could have been avoided.

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.

C43-3 Sam Casillas 3/8/22 In my original review and comments of the 2014 draft GPU I pointed out the following facts:

1. The Site is in a Federally designated Wetland. At
that time the city chose to ignore this fact. The city
also chose to ignore the illegal ditching and discing of the field in order to drain it as also documented
Please see response to comment C37-4 and C37-9.

C43-4 Sam Casillas 3/8/22 2. The 2014 GPU chose a 5.7 ft flooding scenario at which level the whole field on-line model shows it is
completely flooded, yet I was never given an answer
as to why the diagram of the flooding was
manipulated to show the field as not affected by
annual flooding and SLR. (The level of predicted SLR is now much higher)
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

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main stem with the North Fork of the San Pedro
Creek.’.

C43-5 Sam Casillas 3/8/22 3. I also presented documentation that there were endangered species (California Red-Legged frogs)
living and breeding in the adjacent waterway that is in the field and is connected to San Pedro Creek
The CRLF habitat for this area is shown in Figure 3.7-

4. This data is taken from the CNDDB.

C43-6 Sam Casillas 3/8/22 4. Furthermore I pointed out the field had never changed from its land use designation of Commercial
Recreational to which the planning department
erroneously answered that it was changed in 1982 by
a vote of the city council to commercial or mixed-use
commercial that the Coastal Commission does not
recognize.

C43-7 Sam Casillas 3/8/22 Furthermore, As a member on the city appointed Sea Level Rise Adaption Committee, my review of the
proposed Sea Level Rise Adaptation Plan found
multiple areas in need of corrections concerning the
property in question including:

1. On page 73 of the “Wetlands” section of the plan it
states that: “There are two primary areas of wetland
habitat in Pacifica: wetlands in Laguna Salada and
wetlands at the mouth of San Pedro Creek” when in
fact the whole of the site is a documented designated
federal wetland in the USFWS wetland National
Wetlands Inventory. This error is also in the Appendix
B as an “unconfirmed wetland” that also needs
correction.

2. The same section on wetlands states that “No data
on CRLF are available for the local lagoon <in San
Pedro Creek>”. The culvert that leads to San Pedro
Creek running along this property has been
documented as a known California Red Legged Frog
habitat (see Exhibit B) and is now confirmed by
California Fish & Wildlife
This comment is about the Sea Level Rise Adaptation
Plan and does not relate to adequacy of the DEIR.

C43-8 Sam Casillas 3/8/22 3. Most importantly the Pacifica Institutes hazard map and program models the site to be fully under water
with 4.6 ft. of SLR. Pacifica is using a 5.7 ft scenario, yet it only shows a portion of the field under flooding in its SLR scenario. This also needs to be corrected.

Note that FEMA also utilizes utilizes the Pacific
Institute as source for their SLR flood mapping
Figure 3.5-1 was created based on the following
sources:
-The latest tsunami evacuation zone data which is
available at the City's website
(https://www.cityofpacifica.org/civicax/filebank/blob
dload.aspx?BlobID=2499),
-As well as the National Flood Hazard Layer for San

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Mateo County mapped by the Federal Emergency
Management Agency (FEMA).

C43-9 Sam Casillas 3/8/22 4. For the “Transfer of Development Credits(TDRs) section for Pedro Point this property should fall under the Guidance of the Recommendation of the State of
California’s “Natural Resources Agency(NRA)
Safeguarding California and SB379: Reducing Climate
Risk Adaptation Strategy. This document states on
page 12 paragraph 4: One opportunity to achieve
broad environmental benefits is through the use of
natural infrastructure solutions to mitigate climate
risk. Restoration and conservation of natural systems
such as forests, grasslands and shrublands, agricultural lands, and wetlands can provide more resilient natural
systems that also offer protection from climate
impacts. For example, wetlands can provide
protection from flooding, while also providing valuable habitat and other hydrological benefits. Prioritizing
these solutions can maximize the benefits of
investments to reduce climate risks by providing a
broad portfolio of benefits across several sectors.
(Please note that the Pacifica adaption plan
erroneously rebutted a comment on this mitigation
strategy from Alison West that this strategy can only
be implemented on publically owned land. The NRA
document does not state anything on ownership and
the cities own TDR strategy states that it should work
with private land owners in other areas of Pacifica; the same TDRs should apply here.

C43-
10 Sam Casillas 3/8/22 5. This NRA document also states on page 179 paragraph 1: In order to minimize the adverse effects
of sea-level rise and storms, it is important to carefully consider decisions regarding areas vulnerable to
flooding, inundation and erosion. The state should not
build or plan to build, lease, fund, or permit any
significant new structures or infrastructure that will
require new protection from sea-level rise, storm
surges or coastal erosion during the expected life of
the structure, beyond routine maintenance of existing
levees or other protective measures, unless there is a
compelling need. Again the best use of this property is for flood mitigation and not development. By law
under SB379 the city must identify appropriate sites
where this guidance can be applied.

This comment is not related to the adequacy of the
DEIR. Thus, no further response is required. Please
see response to comment 13-3 for more information
on sea level rise analysis and regulations and policies that reduce the impact, as well as policies in the
LCLUP regarding sea level rise monitoring.

C43-
11 Sam Casillas 3/8/22 These concerns in the SLR adaption plan were never addressed and never taken into consideration for the
proposed and continued City support of residential
development on this site that is a known hazard zone.

And now the research is showing there is even more
evidence that this field is and will be a dangerous
hazard zone for storm surge, flooding and other
hydrology issues. The recently published scientific
from Bernard, et al, specifically shows Pedro Point as a highly vulnerable area for storm surge.

Policies within the LCLUP related to effects of climate change and sea level rise are addressed in the LCLUP.

See response to comment C13-3 for more
information about coastal flooding and sea level rise.

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(https://www.nature.com/articles/s41598-019-40742-
z)
C43-
12 Sam Casillas 3/8/22 In consideration of all these issues above how is it that the city has chosen to consider housing in an area that historically and in the future is a flooding catastrophe? And even more egregious the City has received over
30+ written comments with the vast majority stating
building residential will endanger lives, yet the City
chose to parse those comments to draw your own
conclusions that the citizens were only concerned
about high density so this medium density plan must
be okay. Please let me be clear: there is no
justification for ANY permanent structures to be built
on this site. The owner bought it as CR with nothing
built on the property, as a designated federal wetland
and was a golf driving range which is compatible with
a Conservation land use designation.

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-I-17, SA-I-19, SA-I-20, SA-I-22, SA-I-23, SA-I-25, SAI-39, SA-I-40, SA-I-88, to decrease impact to a less than significant level.

As shown on Figure 3.7-2, this site is not designated
as a federal wetland as per the latest National
Wetlands Inventory. The latest inventory can be seen
here:
https://fwsprimary.wim.usgs.gov/wetlands/apps/wet
lands-mapper/
C43-
13 Sam Casillas 3/8/22 The City is also aware that the Pedro Point Community Association (PPCA) held a meeting for the whole
neighborhood, at the request of the city council, with
the current owner of the field (who was part of and
the PPCA board) and to discuss the best use of the
field and the conclusion of the open meeting was that
it should either remain CR or Conservation.

C43-
14 Sam Casillas 3/8/22 Under the current draft of the 2022 GPU the document states implementation policies to Expanded
low-intensity outdoor Commercial Recreation on sites
near Pacifica State Beach (ES-I-34), Preserve the
Experience of the Natural Environment that do not
disrupt view corridors (ES-I-35), be a center for
recreation and community (CD-I-1), Improve
pedestrian routes along corridors (CD-I-24), Open
Space Conservation and Habitat Protection that
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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support critical wildlife habitat and special status
species (LU-G-7) and to not increase the density or
intensity of land use designations beyond those
indicated in the LCLUP for sites located within Coastal Vulnerability Zones (LU-G-8), yet these policies are
exactly what the City chose to ignore by
recommending CRMU at this site.

C43-
15 Sam Casillas 3/8/22 Further, the city is fully aware of the of the CDP application 2-19-0026 denial which is adjacent to the
site. The Coastal Commission denied the project due
to the multiple hazards including flooding, shallow
water table, identified multiple species wetlands and
an ESHA designation for the CRLF which needs a
minimum of 300 ft foraging corridor. Again, the City
has chosen to ignore this data. The city does recognize the existence of the CRLF in the DEIR “Special Status
Species” figure 3.7-4 but omits this in the GPU and
omits the USFWS guidance of a minimum of 300 feet
of foraging corridor for the endangered species.

Additionally, because the species is not able to forage in any other direction because of the existing
developing to the south and east the whole west of
the Site is needed for foraging habitat.

Please see Master Response 6: ESHA for more
information.

C43-
16 Sam Casillas 3/8/22 The GPU also states that Development of the site will require detailed evaluation of coastal
hazards/vulnerabilities and biological resources to
ensure that any sensitive habitat and wetlands that
may exist on the site are protected; this is a violation of CEQA which requires an EIR/evaluation before
changing the land use designation. Further, the City
now has documentation based on the CDP application
2-19-0026 denial which would actually substantially
reduce density at this site. Why would the city chose
to increase density at this site when it is a known ESHA and hazard zone as determined by the CCC, CFWD and
USFWS?
The General Plan and associated DEIR describes
sensitive and Critical Habitat and general locations of Special Status Species and determines that
compliance with federal, state, and local regulations,
in addition to the beneficial impacts of Proposed
Project policies, would reduce any potential impacts
to less than significant. These policies include those
that protect and restore creeks (CO-I-1); preserving
wetlands or otherwise including compensation
measures in line with the State's no-net-loss goal
(CO-I-4) and protecting ESHAS (CO-G-11) through
verification (CO-I-27) and management (CO-I-28.)
Please see Master Response 2: Programmatic EIR for
more information; any project would require
additional CEQA analysis. Please see Master
Response 6: ESHA for more information about ESHA
on the site, and Master Response 4: Undeveloped
San Pedro Ave Sites for more information.

C43-
17 Sam Casillas 3/8/22 The Conservation (C) designation states that it applies to privately-owned open areas where the land is
physically unsuitable for development due to
geotechnical hazards, excessive steepness, wetlands,
Environmentally Sensitive Habitat Areas (ESHA) or
other environmental constraints or lies within stream
channels; this site should result instead as a density
transfer to another area of Pacifica if needed. The
ideal transfer would be to add housing as a policy
overlay to strip malls throughout Pacifica where very
little environmental damage will occur due to hazards
or ESHA.

This comment does not relate to the adequacy of
DEIR analysis. Please see Master Response 4:

Undeveloped San Pedro Ave Sites, as well as Master
Response 1.

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C43-
18 Sam Casillas 3/8/22 LU-I-2 specially prohibits development on properties that include any areas that are within or adjacent to
an Environmentally Sensitive Habitat Area (ESHA) and
are to be set aside for conservation. Why is this site
not considered under this implementation policy?
Please see Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro Ave Sites for
more information. This comment does not relate to
the adequacy of the DEIR; please see Master
Response 1.

C43-
19 Sam Casillas 3/8/22 LU-I-15 allows the Transfer of Development Rights (TDR) to relocate development rights from Coastal
Vulnerability zones and other hazardous areas
(sending sites). Why was this site not identified?
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.

C43-
20 Sam Casillas 3/8/22 Also LU-I-19 replacing a single citywide height limit of 35 feet would be a violation of Coastal Act provision
30251 and would NOT Protect Natural and Scenic
Resources
Section 30251 of the Coastal Act does not mention
increasing height limits to be violation. The DEIR
analyzes impacts on scenic vistas on pages 3.9-12
through to 3.9-22 and includes polices to reduce
impacts including CD-G-4, CD-G-5, CD-I-11, CD-I-12,
CD-I-13,, CD-I-15, 5-I-66, 5-I-67 and DS-1. Any future
project in the coastal zone would also be required to
get a coastal permit, and would be required to
demonstrate compliance with Coastal Act provision
30251.

C43-
21 Sam Casillas 3/8/22 Due to the above polices LU-I-29 designating the site to CRMU would be in conflict making this designation
void Undeveloped San Pedro Avenue Site.

C43-
22 Sam Casillas 3/8/22 The GPU further goes to acknowledge the requirements of Coastal Commission regulation13557
(Title 14, California Code of Regulations) for a wetland survey to delineate potential wetlands on the site is
needed but then goes on to say it would require the
developer to do the survey which is a violation of
CEQA; the city must conduct the survey prior to the
new land use designation. Further in the denial of CDP
application 2-19-0026 a wetland and ESHA were
established so why is the city purposely ignoring this
information?
The comment is noted. See response for C43-16,
Master Response 6: ESHA, and Master Response 4:

Undeveloped San Pedro Ave Sites.

C43-
23 Sam Casillas 3/8/22 OC-G-5 purports to preserve Open Space Preservation in areas to protect natural resources, visual amenities, where the top priority areas for conservation are areas that support critical wildlife habitat and endangered
species. Again, the City is aware that ESHA has been
established in the site with the denial of CDP 2-19-
0026 so why is the city not evaluating the Site under
this policy when it is known that the CRLF will need a
minimum of 300 feet of foraging into the site?
The comment is noted. See response for C43-16,
Master Response 6: ESHA, and Master Response 4:

Undeveloped San Pedro Ave Sites.

C43-
24 Sam Casillas 3/8/22 Additionally, the city states that in a 1992 study, groundwater wells in the City were monitored to
As part of a Sewer System Evaluation Survey,
groundwater wells in the City of Pacifica were

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determine the location of seasonally shallow
groundwater, yet a historic well was in place on
Danmann Ave above the field for many decades and
year-round spring activity has been documented in the
southwest corner of the site. Why hasn’t the city
evaluated this site considering city workers have been
at this area directly observing ground water
percolation on multiple occasions?
monitored to determine the location of seasonally
shallow groundwater. The groundwater was mapped
for three depths below the ground surface: less than

1.5 feet, less than 3.0 feet, and less than 6.0 feet.15 Communities with seasonally shallow groundwater
include Pedro Point, Park Pacifica, Vallemar, Fairway
Park, Linda Mar, and Sharp Park.

C43-
25 Sam Casillas 3/8/22 According to the City’s own proposed implementation policy CO-I-4 the City would prohibit new
development in existing wetlands in an area where
potential wetlands have been identified. So why
would the City increase the density in a area that they are fully aware of an area where a wetlands exist?
Additionally, Figure 7-2: Vegetation: Vegetation and
Wetlands Inventory needs to be updated due to the
denial of CDP 2-19-0026 identifying the adjacent
watercourse as wetlands.

The comment is noted. See response for C43-16,
Master Response 6: ESHA, and Master Response 4:

Undeveloped San Pedro Ave Sites.

C43-
26 Sam Casillas 3/8/22 It is also interesting that the city is now proposing COI-7 to Maintain Functional Capacity of Wetlands to ensure that any diking, filling, or dredging in existing wetlands maintains or enhances their functional
capacity, yet the city has been complicit in allowing
the owner of the city to violate the Coastal Act in the drainage of the site and the city’s excavation of a
known ESHA in the adjacent watercourse.

The comment is noted. See response for C43-16,
Master Response 6: ESHA, and Master Response 4:

Undeveloped San Pedro Ave Sites.

C43-
27 Sam Casillas 3/8/22 Figure 7-3: Sensitive and Critical Habitat Area: this map needs to be updated as ESHA as confirmed in the
denial of CDP application 2-19-0026. Additionally, a
wildlife movement corridor for Mountain Lions (a
protected species in California) needs to be
acknowledged due the city awareness of their
movement along the San Pedro Headlands and into
the Pedro Point neighborhood for foraging and water
access through the safety the site provides under the
proposed CO-G-11 to protect ESHAs, high habitat
value areas, and wildlife movement corridors from
development that would significantly disrupt habitat
values.

This comment is noted. Please see Master Response
6: ESHA for more information on differences in
expert opinion. Please see response to comment A2-
10 for more information on mountain lions, and A2-4
for more information on wildlife connectivity.

C43-
28 Sam Casillas 3/8/22 CO-I-28: Management of ESHA needs to apply to the site as it state “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 resourcedependent uses that can be demonstrated to have no significant adverse impact needing a 100 foot buffer,
but the USFWS determined that the CRLF requires a
minimum 300 foot buffer as established in the denial
of CDP application 2-9-0026
See response for C43-16
C43-
29 Sam Casillas 3/8/22 Figure 8-1: Seismic Hazard Zones: The site lies within the Liquefaction Zone(figure 8-2) which needs to be
The site lies within a Seismic Hazard Zone, as shown
in Figure 3.6-1. Geotechnical analysis is required, as
noted in described on DEIR p. 3.6-8.

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updated to show high risk due to site being a wetland
and adhering to proposed policy SA-1-2
C43-
30 Sam Casillas 3/8/22 SA-I-9 Maintain Restrictions on Hazardous Areas.

Continue enforcing the restriction of development in
hazardous areas where access is impractical and areas
prone to…tsunami inundation, or flooding. The site is
both a hazard from Tsunamis and flooding so why
would the city’s own implementing policies violate SAI-2 and SA-I-9? 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.’.

C43-
31 Sam Casillas 3/8/22 Figure 8-4: This “Flood Zones” figure shows all of Field in tsunami zone but then ignores the required H++
scenario for SLR and flooding which is required under
SB379 which would have the whole of the Site flooded
in a 100 yr scenario. Additionally, Sea Level Rise maps have been manipulated where source document of
FEMA flooding relies on the Pacific Institute models
which shows whole field as flooding hazard at this
time ( Pacific Institute, The Impacts of Sea Level Rise on the California Coast. A paper from the California
Climate Change Center. Available online at:
http://www. pacinst.org/reports/sea_level_rise/2009)
Please see Master Response 4: Undeveloped San
Pedro Avenue Sites for more information about how
proposed projects will be required to demonstrate
compliance with Coastal Act policies to receive a
coastal permit; and how compliance with federal,
state, and local regulations, in addition to Proposed
Project policies, reduce impacts to less than
significant for flooding hazards. Please also see
response to comment C13-3 for more information
about coastal flooding and sea level rise.

C43-
32 Sam Casillas 3/8/22 SA-I-33 Adaptation Funding. The City should make its citizens aware that under this policy the City would
allow development in hazard zones only to later
“pursue…new funding mechanisms, such as the
formation of Geologic Hazard Abatement Districts
(GHADs) as supported by SA-I-14 … to finance
adaptation strategies for public infrastructure. This
policy would allow for the formation of an assessment
district (i.e., tax) on its citizens to pay for a zoning change in an area that is known to have multiple
hazard encumbrances
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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C43-
33 Sam Casillas 3/8/22 SA-I-68 Shoreline Protection Structure Upgrades.

Allow maintenance of existing or new shoreline
protection structures to reduce hazards and resource
impacts if consistent with Policies SA-I-82 and SA-I- 83.

Mitigate impacts consistent with the City’s Shoreline
Mitigation Program (SA-I- 32) or SA-I-85 as necessary.

Note that the building new shoreline protection
structures for new development is illegal under the
Coastal Act.

This policy remains accurate; it refers to
maintenance, not new construction.

C43-
34 Sam Casillas 3/8/22 In accordance with SA-I-77 any development in this property which is a known wetland and ESHA would
not constitute a taking since it is a floodplain with a protected species
See response for C43-16
C43-
35 Sam Casillas 3/8/22 SA-I-78 Habitat Sea Level Rise Migration Buffers.

Under this guidance the Site should be identified as a
mitigation buffer and re-zoned as conservation, but
corrected to 300 foot buffer due to the confirmation
of endangered species foraging range needed for the
CRLF and ESHA.

See response for C43-16
C43-
36 Sam Casillas 3/8/22 The City is also required to comply with SB379 as stated in Chapter 1.2, General Plan Requirements:
“Climate Change Adaptation and Resiliency Legislation
(SB 379)…requires the safety elements of general
plans to be reviewed and updated to include climate
adaptation and resiliency strategies.” SB379 further
requires the identification of hazard zones that can
serve as mitigation areas for said hazards, yet the GPU fails to identify any properties in Pacifica for such
mitigation and it is insufficient to only set “Coastal
Resiliency Policies” when areas like the Undeveloped
San Pedro Avenue Site would qualify to be designated
as hazard mitigation sites due to its many hazard
vulnerabilities and ESHA designation. Why was this
site not designated as a mitigation site under SB379?
Under separate cover Richard Grassetti, Principal of
Grassetti Environmental Consulting has provided a
multitude of areas with the DEIR violates CEQA and is
therefore fatally flawed. Mr. Grassetti also recognizes the reasonable argument that this Site should be
designated Conservation.

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C43-
37 Sam Casillas 3/8/22 Also under separate cover, The Law Offices Of Brian Gaffney have also concluded that the DEIR is fatally
flawed due to the lack of substantive or deferring
environmental impact evaluation of this new land use
designation on the Site without adequate explanation
as to how an actual increase in density will have a less than significant impact on draining, flooding, increases in stormwater runoff, ESHA, wetlands and other
wildlife habitat. How was this conclusion made?
Deferring the review to the future developer is also in conflict with CEQA Guidelines Section 15378(a)
defines the “project” as the whole of the action that
has potential for resulting in either direct physical
changes in the environment or a reasonably
foreseeable indirect physical change in the
environment. Considering this is a wholly undeveloped
site with confirmed flooding, ESHA, tsunami zone,
year-round surface spring activity and SLR risk how
was the city able to reasonably conclude it could
change the land use to residential, increased density
and defer a legally required EIR of the Site?
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. Please see Master
Response 2: Programmatic EIR for more information.

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. These projects may, however, use
the discussion of impacts in this EIR as a basis of their assessment of these regional, citywide, or cumulative
impacts. This does not represent a deferral: projects
must submit any required evidence and demonstrate
consistency with the Proposed Project to receive a
permit; otherwise, development cannot occur. Please
also see Master Response 4: Undeveloped San Pedro
Ave Sites for more information about site design and
biological and geotechnical analyses required prior to
any development.

C43-
38 Sam Casillas 3/8/22 In summary the Undeveloped San Pedro Avenue Site (Site) has a multitude of encumbrances including
environmental designations and hazards the City has
chosen to willfully ignore and places the adoption of
the Local Coastal Program (LCP) by the California
Coastal Commission (CCC) in jeopardy. At this time
because of the City’s consistent inability to integrate undeniable scientific data as far back as 2005 if would be prudent to have the CCC assume responsibility of
the LCP process in order to reconcile the required GPU
alignment so that we do not continue to rely on a GP
that is over 43(!!!) years old and a City that negligent and unwilling to listen to its citizens or sound data.

The comment is noted. The programmatic-level DEIR
thoroughly documents and analyzes potential
impacts at the citywide level, including those in
general vicinity of the parcel in question. The Coastal Commission would continue to have permitting
authority over the portion of the site in its
jurisdiction; please see Master Response 6: ESHA for
more information.

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Packet Pg. 912 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 248
C44: Jean Turk, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C44-1 Jean Turk 3/7/22 The General Plan (GP) section on Sharp Park begins with reference to “fast talking” promoters trying to establish a rail-line through Pacifica, which was quickly dismantled with the onset of the automobile. Lets not fall prey to these same forces in establishing the General Plan. The sincerity of developers in Pacifica must be questioned. They see only a nice piece of real estate on the ocean, near San Francisco and an airport. On paper, this looks like a pretty good place to developers and promoters. But, what is not on paper is the people who live here, or want to live here and the quality of life they want to maintain. This General Plan does not speak to a quality of life.

The GP states that Palmetto Avenue, was recently updated with bike lanes, landscaping, and lighting, but the landscaping has become weed beds, the light poles are broken and promotional banners are left to flap in the wind. Perhaps a good idea at one time, but with no plan on how to maintain it. Pacifica has a poor track record utilizing and maintaining what it has. For example, the GP envisions an area for “new programming, experiences, and temporary activities like festivals, farmers’ markets, music, and other events.” The maintenance yard at the old sewage treatment plant has been under utilized for over twenty years. It remains a perfect space for a farmers market, outdoor theater or music events. If developers of the GP believe these activities would bring new revenue, lets do it now. If in the future this proves true, we can develop more permanent facilities for the City. With the uncertainty of the impact of sea level rise to our coastline, development of a hotel or entertainment center is not financially feasible and unrealistic.

The GP calls for “anchoring” Palmetto Avenue as Sharp Park’s historic Main Street with new four- to five story buildings that will “activate” the Palmetto corridor at multiple levels. Does anyone even know what that means? I don’t know any small town Main Street that relies on four to five story buildings to “activate” their downtown. Think San Anselmo, Carmel or Half Moon Bay. Besides developers have built such buildings on Palmetto, and they are not attractive, they are not inviting and have not enhanced the commercial or pedestrian activity on the street. he same can be said about the newly built large blue building dominating the corner of Francisco and Carmel Avenues.

Regarding new housing and live work space. The live work space just south of Recology on Palmetto Avenue, lasted a couple of years and to this day there is no original owner who lives and works in that building. It was just a way for a developer to build. Regarding higher density apartment buildings. The large unit apartment building at the corner of Palmetto and Paloma should not be a model for the future. The large number of units on site result in major maintenance problems and a lack of a sense of community. More buildings but with a smaller number of units speaks to a better quality of life. Floor Area Ratio, or FAR, meaning -using every square foot to generate dollars, does not speak to quality of life. FAR should not be the model for the future. There was a reason why the 1907 subdivision plan called for small affordable lots. Only in a developers eyes do the small lots present “challenges for redevelopment at higher densities/intensities.” Pacifica still has plenty of space to grow out, not up. Height is not the answer and neither is buying into a developer’s one size/solution fits all. We all agree Pacifica is unique and we need a unique and creative plan for the future.

While acknowledging the need for a city like Pacifica to “enhance its economic base, and strengthen its tourist industry,” an equal need is for the City to seek ways to enhance the quality of life and economic opportunities for those who 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 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. 913 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 249
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here. This GP does not address this, but speaks to the “quality” of streets, sidewalks, materials, air and the environment. Only three times does the GP mention directly the quality of life for those who live here or may want to live here. While the GP reflects how a developer dreams of the future, it does not reflect the reality of our City and its residents. If outdoor concerts, musical events and farmers markets will attract people to Sharp Park, do it now. Take some money and the enhancements that would be offered to developers and put it into reconfiguring the maintenance yard at the old sewage treatment plant. Add a bar and small kitchen to the Council building and you would have a nice City owned facility that locals would support. Instead of having a developer create plans for a large apartment complex, why not take 40 units spread out over four separate buildings. Hire four separate builders and generate competition by offering a bonus to the builder who creates the most affordable or best liked design.

Develop economic growth in the way of Call Centers, small lab testing facilities, or other small industry and businesses that would offer jobs that reflect the abilities and educational levels of those who already live here, and attract new comers as well.

I guess what I am saying is that Pacifica City planners need to think out of the box.

Pacifica is small enough that a thirty or forty year general plan is not the best way to invest our current time and financial resources. Let’s look at what we have now and get creative with that. If these simple ideas serve to generate more economic opportunities, then move on from there. Let’s not commit Pacifica to a long term plan that does not reflect the uniqueness of who we are.

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Packet Pg. 914 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 250
C45: Jonathan Cordero, Association of Ramaytush Ohlone, 3/3/2022 Letter Commenter Date Comment Combined Response
Individuals (C)
C45-1 Jonathan
Cordero;
Association
of
Ramaytush
Ohlone
3/3/22 Thank you for reviewing comments for the Draft EIR for the City of Pacifica General Plan.

I have two corrections to offer and one suggestion all for paragraph 2 on page 7-40. First, the language of discovery privileges a Eurocentric perspective and reinforces colonialism.

Others have been suing language like, “the European discovery of the San Francisco Bay” instead of just discovery to qualify the meaning.

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.

C45-2 Jonathan
Cordero;
Association
of
Ramaytush
Ohlone
3/3/22 Second, the notion that the village of Pruristac was wiped out reinforces the extinction hypothesis, when it is possible that a person did survive from that specific village.

The DEIR mentions states
that 'The Costanoan village
was wiped out by disease in
1791.', and not the village of
Pruristac.

This comment is noted. It
does not address the
adequacy of the DEIR, thus,
no further response is
required
C45-3 Jonathan
Cordero;
Association
of
Ramaytush
Ohlone
3/3/22 I have one suggestion. The report uses “persons speaking the Costaonoan/Ohlone language” to make a linguistic and therefore ethic differentiation. To be more specific, the passage should say something like “persons who spoke the Ramaytush dialect of the San Francisco Bay Costanoan/Ohlone Language.”
The comment is noted. The
first 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
persons who spoke the
Ramaytush dialect of the San
Francisco Bay
Costanoan/Ohlone
Language, and living in and
around two villages:

Pruristac, in San Pedro
Valley, and Timiigtac, in
Calera Valley.

C45-4 Jonathan
Cordero;
Association
of
Ramaytush
Ohlone
3/3/22 We do appreciate the sentence on 7-41 that states, “There is considered to be a high likelihood that unrecorded Native American cultural resources are present.” Please aunderstand that we have a broad view of tribal cultural resources as including, for example, cultural areas, cultural materials, and natural resources. Although we are not on the NAHC list (we are 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

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applying, by the way), we would like to consult on cultural resources uncovered in any projects that affect said resources in that context. Please see
Master Response 1: EIR
Comments for more
information about GP- or
SPSP-related responses.

C45-5 Jonathan
Cordero;
Association
of
Ramaytush
Ohlone
3/3/22 Last, please note that the village at Timigtac is our ancestral village of origin within the territorial boundaries of the Aramai, an independent tribe of the Ramaytush Ohlone peoples.

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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C46: Terrell Watt, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C46-1 Terrell Watt 3/8/22 These comments are submitted on behalf of the Coalition of Pacificans for an Updated Plan and
Pacifica resident Summer Lee (collectively,
“CPUP”)in regard to the City of Pacifica’s
proposed General Plan Update and Sharp Park
Specific Plan (Proposed Project), and
programmatic Draft Environmental Impact
Report (DEIR). Formed by a group of Pacificans in
2020, CPUP is a coalition of residents who care
about safe, responsible planning. CPUP has
championed the need for an updated General
Plan and aims to work with the City to enact a
General Plan based on current science and
environmental standards, consistent with
applicable regulations and plans, and which
provides clear and consistent guidelines for
development decisions benefitting all Pacificans.

These comments are submitted in the spirit of
working together toward a General Plan that
reflects and addresses the challenges of a
changing climate and the urgency to provide
affordable housing while protecting natural lands
for the multiple benefits they provide to buffer
the City, sequester carbon, foster biodiversity,
provide recreation and other benefits.

Comments were prepared by me, Terry Watt, a
professional planner with expertise in general
plans, specific plans, local coastal plans and
environmental documents.1 Jared M. Ikeda, also
a professional planner with direct experience in
the preparation of General Plans, assisted me in
preparing these comments.2 These comments
consist of this letter and a separate set of Exhibits
referenced throughout this letter.

To prepare these comments, we reviewed all of
the documents on the City’s General Plan website
including but not limited to the General Plan
Update, Sharp Park Specific Plan and both Draft
EIR’s3, appendices and supporting reports. We
also reviewed expert comments from community
members who have independently submitted
comments on a wide range of topics covered in
this letter.

For the reasons described in detail below, the
General Plan and Sharp Park Specific Plan
(Proposed Project) fail to meet basic
requirements to provide a clear blueprint for
future development in Pacifica and a basis for
determining whether specific development
proposals and other projects are consistent with
the Proposed Project (the General Plan and Sharp
Please see response to comments C46-1 through
C46-56. Please see Master Response 3: Buildout
and RHNA for more information about the
Housing Element.

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Park Specific Plan). The DEIR is also inadequate
under CEQA, and thus prevents informed public
participation and decision making. Because of the
extensive defects described herein, the Proposed
Project and DEIR deprive the public and decision
makers of meaningful public review and
comment. Once these documents are revised,
they must be recirculated for review and
comment. We also urge the City and decisionmakers to pause the completion of the Proposed Project to incorporate the Housing Element
update due shortly and, revise the DEIR to cover
a comprehensive planning package that includes
the Housing Element update. Pausing the
completion of this General Plan so that it can
include the Housing Element update would
provide the community a chance to work
constructively with the City to strengthen Plan
policies (mitigation) and fix the defects in the
Proposed Project and DEIR. This approach will
save the City time and resources and help to
clarify the Proposed Project’s project description
with regard to allowable and required (Regional
Housing Needs Assessment, RHNA) development.

C46-2 Terrell Watt 3/8/22 Our comments address the proposed Pacifica General Plan Update and Sharp Park Specific Plan
(collectively the Proposed Project), as well as the
related draft environmental impact report (DEIR).

In addition, because the Proposed Project must
be consistent with the Local Coastal Plan (LCP)
update for the coastal zone, these comments
include examples of inconsistencies that must be
rectified for the Proposed Project to meet legal
requirements for consistency between the
Proposed Project and LCP. Rather than recite
every flaw in the document, these comments
provide examples of the major flaws in the
Proposed Project and DEIR.

We hereby incorporate by reference the
additional detailed comments submitted by local
experts that describe other flaws including but
not limited to the significant differences in the
two DEIR’s filed with the state4, DEIR text and
Proposed Project discrepancies, omitted and
outdated setting information, omitted impact
analyses, and discrepancies in the project
description, among others. These flaws
collectively make review and comment nearly
impossible and alone require revision and
recirculation of the Proposed Project documents
and DEIR. In addition to calling out examples of
major flaws in the Proposed Project and DEIR,
constructive recommendations are made in these
comments that would actually achieve the City’s
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.

Any DEIR and GP discrepancies, including
differences in policy numbering, will be
addressed in a redline version. All policies in
the DEIR are described in full in each of the
analysis chapters.

Please see responses to other comments in
this letter; C46-3 through C46-62.

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overarching objective to adopt a comprehensive
and legally adequate General Plan and SPSP that
actually “…is consistent with MTC’s and ABAG’s
transit-oriented development goals in which
urban development is directed toward existing
urban infill sites near transit corridors in order to
avoid the loss of open space…[and achieves] this
goal through tools and policies that give high
priority to density, connectivity, jobs-housing
balance, and preserving open space and
ecological areas.” DEIR at E-10. Pausing this
planning process to incorporate the Housing
Element update has the advantage of providing
time for the City working with the community
and experts to craft a legally adequate and
consistent General Plan, SPSP and DEIR.

C46-3 Terrell Watt 3/8/22 Proposed Project fails to accomplish the basic requirements of a general plan: The fundamental
job of a General Plan is to provide a blueprint for
future development and a clear set of rules in the
form of land use designations, goals, policies and
implementation measures providing the basis for
the City to determine whether specific
development proposals are consistent with the
General Plan (and in this case Specific Plan and
Local Coastal Plan).5 Consistency with the
applicable general plan (and other applicable
plans and regulations) is a requirement for
development or infrastructure project approval.

Where consistency cannot be determined due to
the lack of adequate and/or consistent general
plan policies – including land use designations –
the general plan is inadequate. All of the plans
(General Plan, SPSP and LCP) must provide
consistent rules and cannot be vertically or
horizontally inconsistent. The Proposed Project
fails to provide a clear and consistent set of rules
for future development and in many cases defers
those essential “rules” to a future uncertain date.

The DEIR states this most clearly:
“The City’s Planning Department has primary
responsibility for administering the laws,
regulations and requirements that pertain to the
physical development of the city. For example,
the City’s Zoning Ordinance will be amended to
conform to the adopted Plan. The Zoning
Ordinance will translate the Plan’s policies into
specific use regulations, development standards,
and performance criteria that will govern
development on individual properties, and the
Zoning Map will provide more detail than the
General Plan diagrams.” DEIR page 3.1-26; see
also DEIR page 2- 8 purposes, bullets.

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

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It is the job of the General Plan to govern
development on individual properties and to do
so clearly and consistently through correlated
plans, land use designations and policies. The
General Plan must “serve as a yardstick so that
one can take an individual parcel and check it
against the general plan and know what uses
would be permissible/allowed. In this case, the
Proposed Project does not provide a yardstick.

Instead the Proposed Project and DEIR
improperly defer the construction of essential
rules (yardstick) for development to the future
zoning ordinance, standards, and other future
planning exercises. In so deferring the Proposed
Project lacks the guidance for future
development required by law.

By deferring the rules that will govern
development on individual properties to a later
unknown date, the Proposed Project (General
Plan) abdicates its legal responsibility to set forth
clear guidance for future development. Sufficient
detail must be included in the Proposed Project
(General and Specific Plans) to determine a
proposed development’s consistency with the
General Plan. Instead of deferring to future
ordinance updates, standards and mapping, the
General Plan Update must do this work, must
provide a yardstick. As currently drafted it is not
clear what is allowed in terms of development
citywide or in many cases on a given parcel due
to inconsistent, ambiguous and deferred
guidance.

Examples of deferred detail include but are not
limited to the following:
• Development of consistent zoning (LU-I-15),
development standards and performance criteria;
• SA-I-80 Subdivisions Limitations – deferred to
Zoning update6;
• LU-I-14 Hillside Preservation – updated district
also deferred to later date;
• LU-I-15 Transfer of Development Rights --
noting the General Plan states the TDR needs to
be amended to “identify areas where densities
and heights may be increased;”7 and
• deferred Climate Action Plan update.

C46-4 Terrell Watt 3/8/22 Ripple effect of a Proposed Project deficiencies into the DEIR: In some cases these same policies
are relied on to justify conclusions that significant
impacts of the Proposed Project will be less than
significant. Policies that defer the actual limit on
development (e.g., SA-I-80), provide measurable
performance criteria, require land use
designations (LU-I-15) to be completed through
zoning or standards at unknown future date
Please see Master Response 2: Programmatic
EIR. Policies that require future project-level
study as a condition of development do not
represent a deferred mitigation. Please see
response to comment C46-3 for more
information on how required update of the
zoning code does not represent a deferred
mitigation.

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cannot be relied on, as they are throughout the
DEIR, to justify a conclusion that a significant
impacts will be rendered less than significant with
mitigation (implementation of a specified policy
or policies). A summary of major flaws in the
Proposed Project and DEIR is outlined below and
sections of this letter provide additional details.

C46-5 Terrell Watt 3/8/22 Summary of Major Flaws
• General Plan and SPSP: The Proposed Project
(General Plan and SPSP) fails to meet basic legal
requirements8 including to provide a clear
blueprint for future development that is
comprehensive and internally consistent and
provides a basis for a determination of a
proposed development project’s consistency with
the applicable plans (general plan, SPSP and in
some cases LCP). The General Plan must serve as
a yardstick so that one can take an individual
parcel and check it against the general plan and
know what uses would be permissible/allowed.

The Proposed Project fails to meet this
fundamental test. The opposite of a yardstick, the
Proposed Project leaves uncertain how much
development, and where, the Proposed Project
actually allows. Instead of describing allowable
development, the Proposed Project (General
Plan, SPSP) and DEIR describe growth “projected”
by 2040. Instead, the Proposed Project
“description” must account for growth “allowed”
by the combination of land use designations and
policies.

Projected development constitutes only a portion
of the development allowed by the Proposed
Project. Thus, the whole of the action (the whole
Project) is never disclosed or analyzed. Moreover,
this flawed approach leaves the Proposed Project
without a yardstick to determine a specific
development proposal’s consistency with the
General Plan and SPSP as required by law. Land
use designations in numerous cases conflict with
policies (e.g., Pedro Point site) and there are both
vertical and horizontal internal inconsistences in
and between the General Plan, the SPSP and the
LCP updates leaving the Proposed Project without
the required yardstick.
• Lack of Correlation: The circulation element of
the General Plan is not correlated with the land
use element or the other elements of the
Proposed Project as required by law. This is a
fundamental flaw and one that stems from the
use of projected growth instead of allowable
development. In order for the circulation
(infrastructure element) to provide a plan for
Please see comment C46-3 for adequacy of
land use classifications in providing a
yardstick. Please see comment C30-5 for more
information on the purpose of a program EIR
and how project-specific development would
require additional CEQA analysis.

This comment alleges that potential impacts
of the DEIR are underestimated because
buildout does not use estimates of “maximum
capacity” or incorporate Regional Housing
Needs Allocation 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.

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

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adequate infrastructure to serve planned growth,
it must be based on actual full buildout allowed
by the Proposed Project (GP and SPSP) and not a
projection.
information.

The comment also alleges without any
substantial evidence asserts that the
circulation element is inconsistent with the
land use element. This is untrue; reasonably
foreseeable improvements are described on
DEIR p. 3-16.

C46-6 Terrell Watt 3/8/22 Summary of Major Flaws
• General Plan and SPSP: The Proposed Project
(General Plan and SPSP) fails to meet basic legal
requirements8 including to provide a clear
blueprint for future development that is
comprehensive and internally consistent and
provides a basis for a determination of a
proposed development project’s consistency with
the applicable plans (general plan, SPSP and in
some cases LCP). The General Plan must serve as
a yardstick so that one can take an individual
parcel and check it against the general plan and
know what uses would be permissible/allowed.

The Proposed Project fails to meet this
fundamental test. The opposite of a yardstick, the
Proposed Project leaves uncertain how much
The comment is noted. Please see response to
comment C4-1 and Master Response 3:

Buildout and RHNA for more information
about buildout adequacy and how RHNA
impacts will be analyzed in a separate EIR.

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development, and where, the Proposed Project
actually allows. Instead of describing allowable
development, the Proposed Project (General
Plan, SPSP) and DEIR describe growth “projected”
by 2040. Instead, the Proposed Project
“description” must account for growth “allowed”
by the combination of land use designations and
policies.

Projected development constitutes only a portion
of the development allowed by the Proposed
Project. Thus, the whole of the action (the whole
Project) is never disclosed or analyzed. Moreover,
this flawed approach leaves the Proposed Project
without a yardstick to determine a specific
development proposal’s consistency with the
General Plan and SPSP as required by law. Land
use designations in numerous cases conflict with
policies (e.g., Pedro Point site) and there are both
vertical and horizontal internal inconsistences in
and between the General Plan, the SPSP and the
LCP updates leaving the Proposed Project without
the required yardstick.
• Lack of Correlation: The circulation element of
the General Plan is not correlated with the land
use element or the other elements of the
Proposed Project as required by law. This is a
fundamental flaw and one that stems from the
use of projected growth instead of allowable
development. In order for the circulation
(infrastructure element) to provide a plan for
adequate infrastructure to serve planned growth,
it must be based on actual full buildout allowed
by the Proposed Project (GP and SPSP) and not a
projection.

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C46-7 Terrell Watt 3/8/22 • Housing requirements and allocations: The Proposed Project and DEIR assume only 990 units
of housing by 2040, a projection that does not
include state requirements to accommodate the
RHNA allocation of 1,892 units by 2031. As
Governor Newsom said in releasing his new
Housing Plan in March 2022: “California’s 2.5
million unit target is no longer a paper exercise.

It’s an expectation for the zoning, permitting and
construction of real, new housing units.”
Surprisingly the DEIR fails to include pertinent
setting information including but not limited to:
a) the Regional Housing Needs Assessment
(RHNA) allocation of 1,892 for the cycle ending in
2031,
b) new state laws allowing additional
development on single family lots (e.g., SB 9), and
c) the more than 1,700 accrued residential
development allocations (RDAs), among other
information available at the time the DEIR was
being prepared.

Housing requirements and allocations are
relevant to the question of what constitutes the
“whole” Proposed Project for purposes of impact
evaluation and adequate alternatives.

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.

With respect to the 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

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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 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
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.

Therefore, this approach does not constitute
“piecemealing,” or dividing a large project into
separate parts, each of which might have
individually minimal environmental
consequences. Please see Master Response
3: Buildout and RHNA for more information.

C46-8 Terrell Watt • 2 Different DEIR’s/Two State Clearinghouse Documents: Two different DEIR’s were filed with
the State Clearinghouse and these documents
differ in material ways. Which is the right DEIR?
As per public request, an updated DEIR with
an interactive table of contents was added
and submitted to the State Clearinghouse on
February 14, 2022.

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Both are still available on-line and it is not clear
which is the right DEIR. Due to the length and
complexity of the Project and DEIR, our review
began early, when the “first” DEIR was made
available.
• Inconsistences between the Proposed Project’s
text (e.g., goals and policies) and the DEIR’s
mitigation measures (in the form of goals and
policies from the Proposed Project): In addition
to the question of which is the correct DEIR, there
are significant inconsistencies between the
policies cited in the DEIR that purportedly
mitigate impacts and the policies contained in the
General Plan and SPSP. Because “policies” are the
basis for mitigating significant impacts, it is
essential that the DEIR and Proposed Project are
consistent as to policy numbering and text. Again,
this defect rises to the need for revision and
recirculation of both the Proposed Project and
DEIR.

The comment also states that there are
inconsistencies between the Proposed
Project's text and the DEIR's, clarifications will
be noted in a redlined version of the DEIR.

C46-9 Terrell Watt 3/8/22 The Opportunity
Pacifica is required to identify sites for, and plan
and zone for 1,892 units by January 2023 to be
built during the RHNA cycle ending in 2031, or
nearly double the total amount of new housing
“projected” by 2040 in the Proposed Project and
analyzed in the DEIR (only 990 units). Specifically,
Pacifica is required to adopt a Housing Element
update by January 2023 with sufficient sites
identified and zoned to meet the RHNA
allocation. Pacifica is also mandated to allow
residential lot splits and duplexes in single family
areas, another requirement omitted from the
Proposed Project and DEIR. The fact that the NOP
was issued prior to these significant events does
not excuse the DEIR from including this
information in its evaluation of impacts and
identification and analysis of feasible mitigation
measures and alternatives. 9 Instead of
addressing these and other omissions in
responses to comments, the City should consider
using the DEIR as the foundation for a refreshed
Project that includes the Housing Element
update. This would save time and resources and
provide a much needed opportunity for
additional public input to craft policies with
measurable efficacy to achieve Project goals of
sustainable development near transit, protection
of open space and avoidance of hazards. To the
extent there are areas of the City where
development poses public health and safety
concerns, the Council could enact a temporary
Moratorium during this planning process as they
did for the completion of the Hillside
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.

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Preservation Overlay, Marijuana and other
planning matters in the past.

The promise of this General Plan update was a
welcome one. However, a review of the Proposed
Project fails to reveal the tools and policies (the
yardstick) required and needed to determine
future project consistency and to achieve the
desired outcomes of urban infill near transit
corridors and jobs centers, protection of open
space and ecological values and avoidance of
hazards. The lack of consistent and clear land use
designations and policies render the Proposed
Project incomplete, inadequate and internally
inconsistent for reasons set forth in more detail
below.

Projects under SB 9 are only subject to
ministerial review. Please see Master
Response 3: Buildout and RHNA for more
information about adequacy of buildout.

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

C46-
10 Terrell Watt B. The Proposed General Plan is Inadequate and Internally Inconsistent
As the City’s local “constitution” and blue-print
for future development, Pacifica’s General Plan
should meet the highest standards for
completeness, consistency, and accuracy of
information, including mapping of resource
values and hazards. Legal requirements triggered
by this comprehensive update have not been met
including but not limited to the following:

• The Proposed Project (GP and SPSP) does not
serve as a yardstick: One cannot determine
permissible development on parcels throughout
Pacifica where the land use designation and
policies do not agree. The Proposed Project
(General Plan and SPSP) must allow property
owners, decision-makers, planning staff and the
public to reach the same conclusion as to the
permissible uses and intensity or density allowed
on any given parcel. What is allowed on parcels
with biological resources that are proposed for
protection? (e.g., wetlands, ESHA’s). What is
permissible on parcels with steep slopes, flood
and liquefaction potential? What is allowed on
parcels in flood prone areas where policies and
land use designations are in conflict or leave
uncertain what development is permissible? The
Proposed Project also fails to clarify what effect
state laws allowing lot splits and fourplexes mean
for single family parcels, many of which are
located on constrained sites (e.g., steep slopes,
biological importance, flood prone and within sea
level rise areas, among others). This is a major
defect in the Proposed Project and one that must
be addressed in the Proposed Project so that the
public, decision-makers, planning staff and
Please see Master Response 1 for more
information on GP-related comments. Please
see response to comment C46-3 for more
information on land use classifications and
requirements of a programmatic DEIR. 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.

The comment also alleges without any
substantial evidence that the circulation
element is inconsistent with the land use
element due to perceived inadequacies in
buildout estimations. 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

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property owners all understand the development
permitted on every parcel and the total allowable
development in the City.
• Circulation Element Correlation: The circulation
element10 must be correlated with the land use
and other elements of the Proposed Project,
including housing, conservation, safety and open
space. Correlation is not possible until the
Proposed Project describes the full extent of
allowable development and where that
development will occur.
• Areas subject to flooding including from sea
level rise: Maps and data are incomplete to allow
identification of rivers, creeks, streams, flood
corridors, riparian habitats, and land that may
accommodate floodwater for purposes of
groundwater recharge and stormwater
management as well as flood hazards, including
but not limited to flood hazard zones, flood
insurance maps, historical data on flooding, sites
that have been repeatedly damaged by flooding,
existing, and planned development in flood
hazard zones, and establishing goals for
protection of the community from risks of
flooding including whether new development
should be located in a flood hazard zones. The
Proposed Project defers this information to a
later uncertain date when ordinances,
development standards and performance criteria
are updated.
• Consistent maps and text: The Proposed Project
lacks current maps and fails with respect to
hazards and biological resources to provide
guidance that is consistent between maps and
text (policies and land use designations).

Examples include lack of consistency and clarity
as to whether development is allowed on slopes
over 35%, in areas of flooding, and areas of
wetlands and ESHA’s.
• A fiscally responsible and complete Project:

Neither General Plan nor SPSP contain a program
of implementation measures including public
works projects and financing necessary to carry
out the policies and ensure a development
pattern that together with planned and funded
infrastructure mitigates otherwise significant
impacts to traffic, biological resources, public
health and safety among others. Deferring the
identification of financing and funding sources to
implement critical infrastructure to the Capital
Improvement Plan or other future investigation
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.

Figure 3.5-1 shows areas within FEMA flood
zones, coastal flood zones, and creeks.

Description of watersheds on DEIR p. 3.5-2
describe drainage patterns in the Planning
Area, and robust descriptions of flood history
of each of the creeks is described in pages 3.5-
2, 3.5-4, and 3.5-6, with recent San Pedro
Creek flooding noted on P. 3.5-8. Contrary to
the comment, the DEIR does show FEMA
Flood insurance Rate Maps in Figure 3.5-1,
which "identify areas of greater flood risk
(e.g., 1 and 0.2 percent annual chance flood
areas, also referred to as 100 and 500 year
events) in the lower reaches of the main
stream channels, as well as the risk of coastal
flooding along the shoreline." In addition to
compliance with the National Flood Insurance
Act, the U.S. Army Corps of Engineers, policies
related to floodplain management (SA-I-17),
flood map review (SA-I-18), flood hazard
reduction and maintenance (SA-I-20 and 22),
flood control structures (SA-I-23) reduce

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obviates the point of approving a General Plan
and SPSP that is feasible. The Proposed Project
recommended for adoption must be feasible and
one element of feasibility is that it can actually be
financed.
• Informational, readable and available to the
public: In its current form, the Proposed Project
Instead of including best available mapping and
data, the Proposed Project includes out of date
and incomplete data and mapping, improperly
deferring to the future updates of the zoning
ordinance, subdivisions regulations, and Capital
Improvement Plan for that detail. As a result the
Proposed Project fails to include adequate
information as required by law and in so failing,
lacks the basic information needed to craft
binding, consistent and measurable policy so that
the Proposed Project functions as a yardstick.

Examples include but are not limited to land use
designations that would result in development in
wetlands and environmentally sensitive
ecological areas (Pedro Point), and in high fire
danger and other hazard areas without adequate
evacuation routes (Vallemar, Pedro Point and
Fassler/Rockaway).11 More detail about these
flaws follows. does not meet this requirement for
a logical, understandable and complete package.
impacts to less than significant. These policies
do not represent deferred mitigation.

The DEIR contains consistent maps and text
that utilize best available data. As noted in
DEIR p.
• Consistent maps and text: The Proposed
Project lacks current maps and fails with
respect to
hazards and biological resources to provide
guidance that is consistent between maps and
text
(policies and land use designations). Examples
include lack of consistency and clarity as to
whether development is allowed on slopes
over 35%, in areas of flooding, and areas of
wetlands
and ESHA’s.
• A fiscally responsible and complete Project:

Neither General Plan nor SPSP contain a
program of
implementation measures including public
works projects and financing necessary to
carry out
the policies and ensure a development pattern
that together with planned and funded
infrastructure mitigates otherwise significant
impacts to traffic, biological resources, public
health and safety among others. Deferring the
identification of financing and funding sources
to
implement critical infrastructure to the Capital
Improvement Plan or other future
investigation
obviates the point of approving a General Plan
and SPSP that is feasible. The Proposed Project
recommended for adoption must be feasible
and one element of feasibility is that it can
actually
be financed.
• Informational, readable and available to the
public: In its current form, the Proposed
Project
Instead of including best available mapping
and data, the Proposed Project includes out of
date and
incomplete data and mapping, improperly
deferring to the future updates of the zoning
ordinance,
subdivisions regulations, and Capital
Improvement Plan for that detail. As a result
the Proposed Project
fails to include adequate information as
required by law and in so failing, lacks the
basic information

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needed to craft binding, consistent and
measurable policy so that the Proposed
Project functions as a
yardstick. Examples include but are not limited
to land use designations that would result in
development in wetlands and environmentally
sensitive ecological areas (Pedro Point), and in
high fire
danger and other hazard areas without
adequate evacuation routes (Vallemar, Pedro
Point and
Fassler/Rockaway).11 More detail about these
flaws follows.

C46-
11 Terrell Watt 3/8/22 1. The Proposed Project (General Plan and SPSP) is Fatally Flawed
The Proposed Project fails to provide basic
information required concerning allowable
development (full buildout; the whole project)
and is internally inconsistent, both among the
elements and among the plans (General Plan,
SPSP and LCP). The consistency requirement
applies to maps and drawings as well as text.

Here the internal inconsistencies implicate the
adequacy of the DEIR since without consistent
policies, it is not possible to determine what is
permissible development on a parcel specific
basis; a fundamental building block for an
adequate Project Description. Without an
adequate and complete description of the whole
project, it is not possible for the environmental
impact report to disclose, analyze and determine
impacts or to identify and evaluate the efficacy of
mitigation measures (policies) and alternatives.

Examples of major flaws in the Proposed Project
include but are not limited to the following:
a. Development Allowed by the Proposed Project
(full buildout) is not Disclosed or Analyzed12 The
Proposed Project fails to provide the most basic
guidance as to what constitutes allowable
development or actual buildout. This in turn
undermines the Proposed Project’s performance
as a yardstick to determine what is allowed on a
parcel specific basis. There are various
explanations provided in the General Plan and
DEIR as to what amount and type of development
is projected. Not a single one of these
explanations include full buildout; that is
allowable development should each parcel fully
develop as permitted by the applicable proposed
land use designation and policies. Development
projected by 2040 is 990 units and approximately
630,000 square feet of non-residential uses.

Development allowed by the Proposed Project is
clearly much greater. Will development proposals
Plesae see Master Response 1 for more
information on GP-related responses to
comment. Please see response to comment
C4-1 and Master Response 3: Buildout and
RHNA for more information on adequacy of
buildout projections. As noted in the Master
Response, 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 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
General Plan from 1980 is out of date and
inappropriate for that purpose.

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that go beyond the 990 units or 630,000 square
feet be denied? Is there a priority for which
parcels get to develop first?
The projection of 990 units does not fully reflect:
• More than 1,700 accrued residential
development allocations. See Sharp Park
conditions report section 2 Land Use and
Development page 2-21.
• Actual development capacity when land use
designations are applied to acres in each
designation less existing development. Clearly,
development capacity allowed by this Proposed
Project is greater than 990 units and 630,000
square feet of non-residential as shown in Table
1-3, Summary of Development Capacity and
Projected Demand from Existing Conditions
Report and Table 4-7.13 Residential development
capacity or allowed development – as contrasted
with projected development – is far greater at
1,511 units and over 2 million square feet of
nonresidential uses. See Exhibits 1 and 2 which
provide figures for planned capacity (allowable
development) based on the current general plan.

Proposed Project densities and intensities are
even greater than the current general plan
making it likely that allowable development is
even greater than shown in Exhibits 1 and 2.

Updated information for planned
capacity/allowable development must be
provided for the Proposed Project including acres
by Proposed Project land use designations.
• RHNA allocation of 1,892 units which must be
planned, zoned and sites identified for by January
2023 and achieved by 2031. What is the site
inventory planned and zoned to build these units
and if already planned and zoned, why are these
units not included in “buildout?”
• Ministerial or by right development under
California law including but not limited to SB 330
(Skinner) and SB 9.
• Second Units, Accessory dwelling units and
density bonuses encouraged and allowed by the
Proposed Project (General Plan and SPSP policy)
and by state law. Significant questions must be
addressed in the responses to these comments
including but not limited to the following:
• What is the total amount of development
allowed by the Proposed Project (the whole
project) that could result in impacts? The whole
project must also include essential infrastructure
(transportation-related, services and utilities).
• Where will projected growth (990 units and
630,000 s.f.) actually occur (by parcel)? Since
projected growth reflects only part of the
development allowed, which parcels with
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.

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development capacity beyond projected growth
will not be allowed to develop until after 2040?
Which site specific projects are included in the
projected growth of 990 units and approximately
630,000 square feet14 of non-residential
development? How was the location of projected
growth factored into traffic/VMT/LOS, and other
impact analyses? Pacifica is not a large city.

Development allowed by the Proposed Project
can be depicted by total acres by designation (a
new Table) and by mapping (by Traffic Zones and
neighborhoods and by parcels). This is an
accessible data base the City should have to
process applications and track existing
development. It is also essential information for
adequate analysis of traffic, GHG, AQ and other
impact analyses. In responding to comments or a
revised document, this information must be
provided.
• Why were RDAs, RHNA allocation, second units,
ADUs, density bonus units and other units
allowed by law not counted or transparently
reflected in the Project Description? In
responding to comments transparency of
whether and how these units are accounted for
must be provided.
• Will development be “capped” if it exceeds
“projected buildout?” Is there a trackable and
enforceable limit on development both
residential and non-residential that would
constrain development to the projection of 990
units and 630,000 square feet? Would the growth
management ordinance, expiring this year, if
extended, cap growth?15 Even if so, the DEIR
must evaluate the whole Project and any such
limit or cap would appropriately be discussed as
an alternative.
• How were the projections for buildout by 2040
derived? If based on projected demand – what is
the basis for projected demand? If based on past
growth trends, please describe those trends in
detail and why those trends are a predictor of
future growth. Specifically, since the onset of the
pandemic, there has been a clear trend of people
exiting major cities for communities like Pacifica.

What are the trends that have emerged since
2020 and how might those influence growth
pressure in Pacifica?
• Why is there no table such as for the current
General Plan with acres by land use, existing
development and allowable development or
“capacity?” See Exhibits 1 and 2 for examples of
such tables.
• What happens when the 990 units have been
approved and aren’t more than 990 already in

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the pipeline by virtue of the 1,700 RDA’s?
Meeting RHNA – 1,892 units by 2031 – would
take the City well beyond the 990 units projected
and purportedly analyzed in the DEIR.

The proposed General Plan’s omission of
allowable buildout is a fundamental and
foundational flaw with the collateral result of an
inadequate Project Description in the DEIR.

C46-
12 Terrell Watt 3/8/22 A sample of the many and inconsistent explanations for using projected “buildout”
rather than actual allowed buildout in the
Proposed Project and DEIR individually and
collectively fail to explain how projected
“buildout” by 2040 was derived:

DEIR Executive Summary, page E-5: “ESTIMATED
BUILDOUT OF THE PROPOSED GENERAL PLAN”
“Full development under the General Plan is
referred to as “buildout.” Although the General
Plan envisions policies and land use intentions in
the Plan to be realized by 2040, the year is not
intended to be certain; nor does the designation
of a site for a certain use necessarily mean the
site will be built or redeveloped with that use in
the next 20 years.”
DEIR Page 2-20: “2.4 Buildout under the
Proposed Project
General Plan
Development resulting from application of land
use designations and assumed densities under
the General Plan is referred to as “buildout.”
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, discussed above.” Emphasis
added. [Note: The two definitions within this
definition are inconsistent].

DEIR at 2-21: “RESIDENTIAL DEVELOPMENT AND

POPULATION
Implementation of the Proposed Project is
projected to result in an additional 990 units…”
DEIR at 2-22: “NON-RESIDENTIAL DEVELOPMENT

AND EMPLOYMENT
Assuming typical averages of non-residential floor
area per employee, the estimated 1,400 new jobs
gained between 2020 and 2040 would require
the development of approximately 630,000
square feet of additional non-residential building
area. As shown in Table 2.4.1, the General Plan is
projected to result in an additional 645,400
square feet of non-residential floor area. At
Please see response to comment C4-1 and
Master Response 3: Buildout and RHNA for
more information on adequacy of buildout
projections.

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buildout, the Planning Area will accommodate
approximately 7,310 jobs. The mix of new jobs by
land use type during the planning period is shown
in Table 2.4-3. The total number of new jobs was
obtained by determining the number of jobs by
land use classification and subtracting the
number of jobs from existing development.

DEIR at 9-2 Glossary:

Buildout. That level of urban development
characterized by full occupancy of all developable
sites in accordance with the General Plan; the
maximum probable level of development
envisioned by the General Plan under specified
assumptions about densities and intensities.

Buildout does not assume that each parcel is
developed to include all floor area or housing
units possible under zoning regulations. Land Use
Element page 25, Buildout “Potential new
development through the horizon year and the
corresponding growth in population and
employment is referred to as “buildout.” Buildout
is based on existing development and an
estimated amount of potential new development
in the Planning Area.

Buildout estimates should not be considered a
prediction for growth, as the actual amount of
development that will occur through 2040 is
based on many factors outside of the City’s
control,
including changes in regional real estate and
labor markets and other long-term economic and
demographic trends. Therefore, buildout
estimates represent potentialities rather than
definitive figures. To estimate buildout,
assumptions were made about the density of
development in each proposed land use
designation, as well as the percentage of parcels
that would actually develop depending on
location and land use designation. The
designation of a site for a particular land use in
the General Plan does not guarantee that the 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.” Land Use Element
page 25, Buildout “As Table 4-2 shows, buildout
would result in an estimated 990 new housing
units. Of these units, 12 percent would be single-
family residential, and 88 percent would be multi-
family residential including those in mixed-use
developments.”
None of the various explanations of Proposed

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Project projected “buildout “actually represent
what the proposed General Plan and SPSP allow
based on land use designations and acres in each
designation less existing development. Instead at
best we get a guess at what might be built by
2040; a “projection.” There is no credible
explanation as to how or why only 990 housing
units and approximately 630,000 square feet of
non-residential uses would be the maximum
development built by 2040 with implementation
of this proposed General Plan and SPSP.

C46-
13 Terrell Watt 3/8/22 Moreover, there is no explanation of where these units and non-residential square footage would
be built; essential information for many of the
DEIR’s impact evaluations. Allowable
development or “true” buildout is foundational
to an accurate analysis of traffic-related impacts
including Vehicle Miles Traveled (VMT), air
quality and greenhouse gas emissions (GHG),
emergency access and evacuation routes, as well
as other impacts. Allowable development or full
buildout is also foundational to a correlated
circulation element and internally consistent
general plan. Without information about full
buildout, the DEIR does not have the
foundational information and data to evaluate,
analyze and disclose project-related and
cumulative impacts. Without adequate analysis
and disclosure of impacts, the DEIR’s
identification and evaluation of mitigation
measures and alternatives is also flawed.

What is Required: The Proposed Project and DEIR
must include a detailed description of actual
allowed buildout. The resulting General Plan
must provide a yardstick so that the permissible
development of each parcel is known and
understood by property owners, decision makers,
city staff and the public. Actual buildout/allowed
development is what determines the full
potential for environmental impacts.

A reasonable definition of buildout is the state of
maximum development as permitted by a plan or
regulation or as the glossary states: That level of
urban development characterized by full
occupancy of all developable sites in accordance
with the General Plan. By replacing actual
buildout allowed by the Proposed Project with a
2040 “projection” the General Plan and SPSP fail
to describe what is actually allowed. Therefore
the proposed General Plan and SPSP fail to
provide a legally adequate blueprint or yardstick
for development and an accurate description of
the Project for purposes of environmental
The Proposed Project provides Plan envisions
“concentrated and compact development
primarily in already developed areas” (DEIR
p.3.1-19) , with an includes policies to provide
more linkages and enhanced connectivity
within and between those areas. As noted on
DEIR p. 3.1-20, the “Proposed Project includes
new land use designations that replace older
and more generic land use designations in the
same or nearby areas; the new land use
designations accommodate more diverse
housing types, densities, and commercial
developments, primarily in already-developed
areas. There are three mixed use
classifications to create areas where housing
and active commercial uses may be
integrated.” As shown in Table 2.4-2,
approximately 76 percent of new units are
projected to occur in these new mixed use
classifications, shown in Figure 2.2-1. The
remaining units would be accommodated in
smaller vacant “infill” lots found primarily in
the West Sharp Park, East Sharp Park,
Westview-Pacific Highlands, Rockaway, and
Pedro Point neighborhoods; these vacant
parcels are shown on the existing land use
map, Figure 3.1-1. Given environmental
factors such as slope and sensitive species,
there are some constraints on the
development potential of these sites. Nonresidential development is shown in Table 2.4- 3; approximately 76 percent of non-residential
development is expected to occur in a Visitor
Mixed Use designation shown at the Quarry
site in Figure 2.2-1.

Land use classifications and applicable
densities and intensities are described in Table

2.3-1.

Please see Master Response: Buildout for
more information about how buildout

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analysis. In describing buildout all assumptions
must be clearly explained. Pacifica is not a large
city making it well within the realm of feasibility
to depict on accessible and clear maps allowed
development. This omission alone is reason for
revision and recirculation of the Proposed Project
and DEIR.
represents a reasonable estimate of
development.

C46-
14 Terrell Watt 3/8/22 Existing Development is also improperly based on projections rather than actual existing
development on the ground. Making accurate
calculations of buildout even more fraught, the
Proposed Project and DEIR base existing
development – units and non-residential square
feet – on estimates. This approach renders
existing development figures highly suspect. The
City of Pacifica must use real on the ground
development and permit records to document
existing development. For jobs, the DEIR and
Proposed Project rely on C/CAG2040 Travel
Demand Model estimates for 2020 jobs by sector.

See DEIR page 2-21 footnote 1 to Table 2.4-1.

Housing units are from the 2020 Dept of Finance
Population and Housing Estimates. See DEIR page
2-21 footnote 1 to Table 2.4-1.

Use of projections and estimates both for existing
development (units/jobs) and for allowable
development renders the Proposed Project an
inadequate blueprint for development, makes
development project consistency determinations
impossible and renders the DEIR inadequate as
well.

DOF estimates, conducted annually are some
of the most accurate estimates of on-theground existing conditions, as they are estimated by adding new construction and
annexations and subtracting demolitions, and
adjusting for units lost or gained by
conversions.

The C/CAG model estimate is used to
adequately model potential VMT impacts in
Pacifica. Because existing conditions data is
from 2015, it represents a conservative
estimate.

C46-
15 Terrell Watt 3/8/22 b. Examples of a Flawed Project Description The most basic question when approving a
project is whether the parcel can be developed at
all, and is so, with what uses, coverage,
intensities and densities. It is the most basic job
of a general plan to provide that clear guidance.

In order to accurately describe the project –
development allowed by the proposed General
Plan and SPSP – and where that development will
occur, the land use designations and policies
must be unambiguous and consistent with one
another. This is the work of a General Plan and
Specific Plan and cannot be deferred to the
zoning ordinance, development standards or
other future rule making.

For example, Pedro Point field is an undeveloped
site within the Coastal Zone. It is frequently
flooded and in a Tsunami evacuation zone. It is
also home to special status, possibly endangered
species and wetlands and ESHA. What
development proposal would be consistent with
The Proposed Project does provide a yardstick
and includes both allowable gross
development (as described in the comment)
as well as potential constraints that could limit
development of a site. Please see response to
comment C46-3 for more information on land
use classifications and requirements of a
programmatic DEIR. 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

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the Proposed Project? What is permissible in
terms of development coverage of the parcels,
land uses and maximum intensities and
densities? The land use designation proposed is
for Coastal Residential Mixed Use allowing 15
units per gross acre (not counting density bonus)
and up to 0.5 FAR. Policies prohibiting
development of wetlands, protecting species and
habitats, among others appear to limit
development well below what the land use
designation would allow. However, with state
housing law increasingly constraining local
control it is imperative that the Proposed Project
(General Plan and SPSP) provide a clear and
concise “rules” for future development, in other
words a yardstick. Otherwise the ambiguities and
inconsistencies between designations and
policies make it impossible understand what is
permissible and to make General Plan
consistency determinations. See Exhibit 8 for
more details.
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.

C46-
16 Terrell Watt 3/8/22 2. The Proposed Project Fails to Include Information Required by Law
State laws and the Office of Planning and
Research provide checklists for the required
contents of a legally adequate general plan,
including contents for each element and contents
triggered by plan updates. Specific Plan law
specifies the required contents of specific plans.

This letter touches on some of the omissions
above under Summary of Major Flaws with more
examples summarized below.
• Circulation Element: A complete and correlated
circulation element identifying proposed
transportation routes and public utilities and
facilities including sewage transport and
treatment, transmission lines and upgrades,
broadband, drainage facilities meeting stated
performance standards and the needs of all types
of users. In this case, the circulation element
cannot be complete because it is based on only a
portion of the growth planned and allowed by
the Proposed Project.
• Land Use Element Correlated w All Elements:

Consistent land use designations and policies that
allow the public, city staff and decision makers,
property owners and developers, permitting
agencies and others to understand what is
permissible in terms of land use, parcel coverage,
density and intensity on every legal parcel in
Pacifica.
• General Plan and SPSP: Information about the
These comments largely relate to perceived
inadequacies with the General Plan, not the
adequacy of the DEIR.

Please see Master Response: Buildout for
more information on how buildout represents
a meaningful and allowable means of
estimating potential impacts.

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total development allowed (actual buildout).
• Land Use, Safety, Conservation and Open Space
Elements: Up to date, best available maps clearly
showing the location of hazards (flooding, sea
level rise, steep slopes, etc.) and biological
resources targeted for protection at a parcel
level. Maps and data required by law are either
omitted entirely from the General Plan or in
other cases are out of date or inadequate to
allow identification of rivers, creeks, streams,
flood corridors, riparian habitats, and land that
may accommodate floodwater for purposes of
groundwater recharge and stormwater
management as well as flood hazards (including
but not limited to flood hazard zones, flood
insurance maps, historical data on flooding, sites
that have been repeatedly damaged by flooding,
existing, and planned development in flood
hazard zones, and establishing goals for
protection of the community from risks of
flooding including whether new development
should be located in a flood hazard zones).
• Conservation and Open Space (also correlated
with land use): Identification (maps) of vacant
lands that cannot be developed due to
environmental constraints (hazards, biological
values, other). Strategies for protecting important
open space and conservation lands including
financing proposals.
• Financing and funding sources to implement
the General Plan and SPSP.
• Climate adaption and resiliency strategies as
required to be integrated into general plans by SB
379.16
This is not intended to be a comprehensive list of
the required contents of general and specific
plans. See Office of Planning and Research
General Plan Guidelines 2017 and supplementary
planning advisories: General Plan Information -
Office of Planning and Research (ca.gov)

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C46-
17 Terrell Watt 3/8/22 C. The DEIR is Inadequate
As explained below, the Proposed Project’s flaws
described above have a ripple effect on the
adequacy of the DEIR and its ability to disclose,
analyze and characterize impacts as well as the
adequacy of mitigation measures (policies) and
alternatives.

1. The DEIR’s Project Description is Inadequate An
accurate, stable and complete project description
is foundational to an adequate environmental
impact report. Where the project description is
truncated or incomplete in any way there is
insufficient basis for evaluation and review of
environmental impacts. In this case, the DEIR’s
description of the Proposed Project (General Plan
and SPSP) is fatally flawed. Therefore the DEIR
fails to provide the information required to
support disclosure, analysis and mitigation of the
potentially significant impacts of the
development allowed by the Proposed Project.

CEQA Guidelines Section 15378(a) defines the
“project” as the whole of the action that has
potential for resulting in either direct physical
changes in the environment or a reasonably
foreseeable indirect physical change in the
environment. Case law notes that lead agencies
should define its projects broadly to ensure a
complete analysis of impacts and must include
consideration of future expansion or other
actions that are reasonably foreseeable
consequences of the proposed project. Sufficient
detail about the project must be knowable and
included for evaluation and review of
environmental impacts.

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.

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

C46-
18 Terrell Watt 3/8/22 a. The DEIR Fails to Analyze Impacts from Development Allowed by the Proposed Project
(General Plan and SPSP) As described above, the
amount of development allowed by the Proposed
Project and the location(s) of that development
are not fully disclosed. Instead “buildout” under
the Proposed Project is a projection and does not
reflect development actually allowed. As a result
of a flawed description of the Proposed Project,
the DEIR grossly underestimates permissible
development and the associated impacts of that
development. As described above, allowable
development is likely double or more that
projected by 2040. Impacts, such as traffic,
greenhouse gas emissions, would be magnitudes
greater than disclosed in the DEIR if that is the
case. Moreover, additional infrastructure and
services would likely be required to serve “full
buildout.” Because the Proposed Project fails to
account for full buildout, it also fails to account
According to Cal. Code Regs. tit. 14 § 15125
related to Environmental Settings, “…a lead
agency may also use baselines consisting of
both existing conditions and projected future
conditions that are supported by reliable
projections based on substantial evidence in
the record.” Buildout represents a realistic and
reliable projection. Thus, buildout represents
an adequate estimation. Preparation of a
Housing Element requires a sites inventory,
which details where Pacifica will plan for
housing at various income levels. At the time
of DEIR preparation, no housing element
exists. Thus, incorporation of this RHNA
number would be speculative and not
appropriate for DEIR analysis of the Proposed
Project. Please see Master Response 3:

Buildout and RHNA.

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for infrastructure and services needed to support
full buildout and the associated impacts. The
DEIR bases its analysis of impacts on “projected
growth” until the horizon year of 2040 rather
than on allowed growth. For CEQA purposes, a
guesstimate of projected “buildout” is not
representative of the whole project. Allowable
development represented by the land use
designation is likely the best source of true
“buildout.” The City’s decision to use a projection
for growth by 2040 rather than development that
is allowed under the Proposed Project results in
an underestimation of both residential and nonresidential development that could occur in the City.17
While it may be appropriate to also analyze the
likely projected growth by a horizon year, the
environmental review must be of the whole
project that could result in impacting the
environment. Without a cap on total
development to limit it to projected growth,
actual growth could be greater and in different
locations than analyzed in the DEIR leading to
even greater impacts on traffic, air quality,
greenhouse gas emissions, public services and
more. A revised DEIR must include an analysis of
true buildout; that which can be built under the
Proposed Project. A revised DEIR can also analyze
projected growth, but it cannot exclude analysis
of the whole project.

C46-
19 Terrell Watt 3/8/22 b. The DEIR fails to Analyze Development Allowed By Right by State Law
The DEIR must base its analysis of impacts on the
whole of the action that has potential for
resulting in either direct physical changes in the
environment or a reasonably foreseeable indirect
physical change in the environment. Case law
notes that lead agencies should define its
projects broadly to ensure a complete analysis of
impacts and must include consideration of future
expansion or other actions that are identifiable as
reasonably foreseeable consequences of the
proposed project. In addition to artificially
constraining “build out” to projected growth by
2040 only, the project description fails to include
additional development that could occur with
approval of the Proposed Project. Specifically, the
project description fails to include foreseeable
additional housing allowed by State and local
density bonuses, accessory or second dwelling
units and lot splits/additional units associated
with Senate Bill 9. Many of the units allowed
under these policies and statutes are by-right. For
Please see Master Response 3: Buildout and
RHNA for more information on the adequacy
of buildout in evaluating impacts to VMT and
GHG.

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example, under newly affirmed state density
bonus law, once a developer commits to making
a specified portion of a project affordable to
lower-income households, increased building
density, exemptions from zoning rules, height
limits and other local restrictions are available
ministerially (by-right). As with additional
accessory dwelling units and lot splits, the
additional housing potential associated with
these and other state laws can be estimated and
must be included in the project description.

Having failed to include this development
potential in the project description renders the
DEIR inadequate and results in the DEIR grossly
underestimating impacts.

Many of the units allowed by newly minted state
law, such as lot splits and fourplexes, will most
likely be built outside of transit and jobs rich infill areas but rather in single family neighborhoods
and at the City’s edge. In fact at least one
application has already been filed under SB 9 for
a lot split. In addition to analyzing these
additional units as part of a revised Project
Description (or alternative), the DEIR must
analyze impacts based on where these units are
likely to occur. Such impacts could be higher VMT
and GHG where units are not served by transit or
new jobs and services. Greater impacts from
hazards due to growth in areas underserved by
evacuation routes should also be analyzed.

C46-
20 Terrell Watt 3/27/22 2. The DEIR’s Environmental Setting is Inadequate An EIR must present an adequate and complete
description of the environmental setting in the
vicinity of the project as it existed before
commencement of the project. Specifically, the
DEIR must describe the physical conditions which
exist within the area affected by the project
based on the most recent information available.

An adequate, accurate and complete description
of these pre-existing conditions establishes the
baseline for analyzing whether the project’s
impacts are or are not significant. In combination
with the project description, this environmental
setting information provides the foundation for
an EIR’s evaluation and analysis of environmental
impacts. In this case the combination of flawed
project description and setting cripple the DEIR’s
ability to adequately evaluate and analyze
project-related and cumulative impacts, and to
identify and evaluation mitigation measures and
alternatives. Thus, the very basic functions of an
EIR cannot be performed.

The DEIR’s description of environmental setting
Please see response to comment C123-1 for
more information on the adequacy on the
environmental settings and the project
description. To the extent where potential
impacts and potential exceedance of
thresholds can be quantified, the DEIR does
so, such as with VMT, GHG, and air quality
analysis. As noted in CEQA Guidelines Article
10, 15142, qualitative analysis is permitted:
"An EIR shall be prepared using an
interdisciplinary approach which will ensure
the integrated use of the natural and social
sciences and the consideration of qualitative
as well as quantitative factors."

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alone and in combination with the flawed project
description is insufficient to allow analysis of
many impacts, including but not limited to traffic
and VMT, air quality and GHG, emergency access
and evacuation routes, and impacts to important
biological resources. More was possible to
describe existing conditions; the City and its
consultants simply chose not to do so. Examples
of omitted, out of date and otherwise flawed
setting information include but are not limited to
the following.

C46-
21 Terrell Watt 3/8/22 Population, demographic and jobs information.

The DEIR fails to provide information needed to
inform whether the Proposed Project improves or
makes worse the jobs housing ratio and even
more importantly jobs housing “fit.” Jobs housing
fit refers to whether the jobs provide wages
sufficient for employees to reside in or near
Pacifica and in turn is an important metric for
determining commutes, VMT and related impacts
such as air quality and greenhouse gas emissions.

What is the current jobs-housing fit? Are jobs
generated by the Proposed Project at wage scale
employees can afford to live in Pacifica? Many
jobs such as those in hospitality and services
cannot be performed remotely. Are 17 growth
pressures increasing due to those seeking more
suburban lifestyles during Covid?
Impacts to the housing-employed residents
balance is described on DEIR p. 5-3 and 5-4.

Jobs housing fit is not a required topic of
analysis under CEQA; wages are not
something within the General Plan's control.

Impacts to VMT and GHG are adequately
addressed in chapters 3.2 and 3.4, and
Cumulative growth pressures are analyzed in
chapter 5, section 5.1.

Growth pressures due to Covid are speculative
at this time, and no reliable, stable data exists
to assess that local impact.

C46-
22 Terrell Watt 3/8/22 o Traffic and VMT: Much of the setting data for the analysis of traffic and VMT is out of date or
for different periods. For example, 2010 data is
used for some analysis, which is prior to the
completion of the Devil’s Slide Highway 1 tunnel.

More recent and reliable data is available from
Caltrans and other sources.

Traffic counts from pages 3-12 to 3-21 were
conducted in 2018 and 2019, and analysis
from Table 3.2-7 on page 3-41 was conducted
in 2020 and 2021, in accordance with the table
references in the DEIR. The raw results of this
analysis can be found at
https://cityofpacifica.egnyte.com/dl/QvA0lqy
N5J.

C46-
23 Terrell Watt 3/8/22 o Fire Hazard in the City and its planning area.

The fire map, DEIR figure 3.14-1, does not include
Very High Fire Hazard Severity Zone, but such
zones exist and are mapped in readily available
public sources, including the 2014 Draft General
Plan Figure 8-5 and included here as Exhibit 6. In
addition, the State’s Office of Planning and
Research and California Public Utilities
Commission provide free, easily downloadable
maps of fire hazard areas that should be part of
the DEIR’s analysis of fire. See Exhibits 3-6. Fire
hazard is no longer merely a function of areas
located in High and Very High Wildfire Severity
Zones. Other sources should be included that
inform the City’s vulnerability to fire. See also
comment letter submitted by Christine Boles on
3/6/22.

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
Severity Zones for Local Responsibility Areas
(LRAs), State Responsibility Areas (SRAs), and

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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.

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
(i.e. an exposure model) . 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

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of preparation.

Maps from 2014 do not use the 2008 CAL FIRE
Recommended LRA maps and thus do not
represent the latest and best available data.

C46-
24 Terrell Watt 3/8/22 o More recent wetlands and habitat’s surveys for areas planned for development in the proposed
GP and SPSP. For example, more recent surveys
and studies were done for the Quarry as part of
the 2020 rockaway Quarry Reclamation Plan.

Link:
https://www.cityofpacific.org/depts/planning/pr
oposed_pacifica_quarry_reclamation
_pr_oject.asp.
o Current information about biological resources
including presence of the Tidewater Goby,
omitted from the inventory in the DEIR, ESHA’s,
and wetlands mapping readily available from the
National Wetlands Inventory. Omission of this
information results in underestimating Projectrelated impacts.

The final Reclamation Plan and DEIR was
published in February 2022, after release of
the DEIR. This DEIR includes special status
species occurrences in Figure 3.7-4 from the
CNDDB; this level of analysis is appropriate for
a programmatic EIR and includes species
described in the Reclamation Plan DEIR.

Nevertheless, any development occurring on
the Quarry site would be required to comply
with policies and mitigation measures
identified in the Quarry Reclamation Plan. This
new information does not change findings of
significance.

The tidewater goby is mentioned in Table C-1
(page A-98) of the DEIR and states that the
potential for the tidewater goby to occur in
the Planning Area is low. The tidewater goby is
a Special Status species, 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. In addition to State and federal
species and habitat protection laws, the
General Plan includes multiple policies to
address biological resources and habitat
protection which would apply to potential
tidewater goby and wetland habitat which
include:
(CO-I-1) Creek Protection and Restoration.

Maintain, protect, and restore Pacifica’s
creeks, including San Pedro, Calera, Sanchez,
and Milagra creeks, as environmental and
aesthetic resources. Actions will include, but
are not limited to:
• Continuing restoration efforts along San
Pedro Creek to improve conditions for
steelhead by removing obstacles to fish
passage, placing rock weirs to facilitate fish
passage, and by monitoring the effectiveness
of these projects;
• Partnering with local organizations, such as
the San Pedro Creek Watershed Coalition, Go
Native, the Pacifica Land Trust, and others, on
restoration efforts;
• Exploring opportunities to collaborate with
other agencies and organizations on stream
restoration and riparian habitat restoration

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along Sanchez and Calera creeks;
• Enforcing restrictions on the planting of
invasive species near creek areas;
• Identifying and working with property
owners to take advantage of unique
opportunities where human active use (e.g.,
through trail development) would enhance
creek appreciation without disrupting
ecological function;
• Requiring a minimum of 100-foot setbacks
from the top of creek banks, or from the outer
edge of riparian vegetation, where it exists, for
development proposed adjacent to creeks, in
keeping with City regulations and Best
Management Practices. 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, shall prevent impacts that
significantly degrade the creek. 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 creek.
(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.

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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-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. 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 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

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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.
(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 special-status species
through implementation of the following
measures:
1) Discourage development and/or buildout in
critical habitat of special status species during

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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 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.

If the tidewater goby was found as part of a
project-level EIR analysis, then these policies
would mitigate habitat impacts to the greatest
extent practical. Therefore, potential impacts
to Sensitive Species or Critical Habitat will be
fully mitigated with implementation of the
General Plan.

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C46-
25 Terrell Watt 3/8/22 o Landslide susceptibility mapping available from the Department of Conservation. Exhibit 7.
o Up to date and parcel specific vulnerability
mapping and information including long-term
potential for erosion of shorelines and bluffs. This
information is critical to formulating land use
designations and policies for “planned retreat” as
warranted by past and projected bluff and
shoreline retreat.

The DEIR indicates areas of landslide hazard in
Figure 3.6-1, which shows all areas where
geotechnical analysis is required. It represents
the most up-to-date publicly available data.

Evaluation of coastal erosion is described on
DEIR p. 3.16-7; the 2018 Sea Level Rise
Vulnerability Study, incorporated by
reference, used an updated methodology that
builds upon a 2009 study to create hazard
maps that are also included in the LCLUP. As
noted, "It is important to reiterate that these
models are approximate, and not meant to be
used for parcel-specific land use planning.

These models indicate that there could be
new risks of erosion along the length of
Pacifica’s coastline in areas that are not
currently exposed to wave action erosion,
which could impact all of the coastal
neighborhoods and coastal habitats."
Additionally, any development in the Coastal
Zone would be subject to Coastal Commission
approval and would be required to comply
with policies in the LCP.

C46-
26 Terrell Watt 3/8/22 Other examples are provided in comment letters submitted as listed in Footnote 4. The DEIR omits
this readily available and in many cases free or
low cost information that forms the foundation
for the evaluation of project-related and
cumulative impacts. The DEIR must include this
information; it can’t be referenced in other
documents. Based on a revised setting, revised
impact analysis must be completed.

Please see responses to comments C46-21
through C46-25.

C46-
27 Terrell Watt 3/8/22 3. The DEIR’s Analysis of Impacts is Flawed An EIR must evaluate all significant effects of a
proposed project, in this case both the proposed
GP and SPSP. The severity and probability of the
occurrence of these impacts must also be
disclosed and documented. Bare conclusions
without evidence, explanation and analysis is not
sufficient. Reasons for why an impact is deemed
significant or insignificant must be clearly
explained. The DEIR also must separately
evaluate subcomponents of the Proposed Project
and assess the impacts of potential future
projects allowed by these Plans. In order to
adequately evaluate the impacts of the project
(GP and SPSP), the DEIR must reflect the most
recent information available for each impact
topic. For example, there are readily available
and free downloadable maps depicting the
wildland urban interface (source: State Office of
Planning and Research Fire Hazard Planning
Technical Advisory, 2020 Update: OPR Fire
Hazard Planning Technical Advisory: Fire-Threat
Please see Master Response 5: Wildfire for
more information about the adequacy of fire
mapping and the adequacy of analysis. Please
see comment C123-28 and C123-38 for more
information about the adequacy of analysis
more generally.

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Maps and Fire-Safety Rulemaking (ca.gov). See
also fire threat maps from CalFire, Fire Resource
Assessment Program (FRAP) and CPUC Fire
Threat maps: Exhibits 3-6. This readily available
and free information is foundational to an EIR’s
evaluation of projectrelated and cumulative
impacts.

C46-
28 Terrell Watt 3/8/22 As described above, the DEIR’s ability to analyze project-specific, direct and indirect and
cumulative impacts is gravely hampered by the
lack of an adequate project description including
but not limited to the full potential allowable
development or buildout and the location of
where that development is allowed to occur. The
DEIR’s ability to analyze project-specific, direct
and indirect and cumulative impacts is further
hampered by the lack of adequate environmental
setting information. Of the numerous impacts
covered in the DEIR, strikingly only one impact—

3.2-2 Vehicles Miles Traveled – is found
significant and unavoidable. All other impacts are
found less than significant; most based on the
implementation of mitigation consisting of weak
and in many cases, deferred mitigation, in the
form of proposed General Plan and SPSP
(Proposed Project) policies. Where the DEIR
attempts to analyze impacts, the analysis is not
based on accurate project and setting
information and the conclusions concerning
significance of impacts lacks analytical rigor and
facts. Impact evaluation is mostly
“conversational” and qualitative with little to no
quantitative analysis. Thus, the DEIR’s conclusion
that all but one impact is less than significant is
unsupported by facts and evidence. For example,
mitigation measures (policies) are attributed with
reducing significant impacts such as greenhouse
gas emissions, but nowhere are there metrics
(use numbers, percentages or calculations)
documenting the efficacy of these measures. And
many of the most promising measures, such as
Subdivision Limits, Transfer of Development
Rights, Funding for Open Space presentation, are
improperly deferred until zoning updates are
completed or later.

Some of the examples of inadequate impact
analyses are explained below.

The commenter's assertion that the project
description is inadequate is incorrect. Please
see response to comment C123-1 for more
information on the adequacy on the project
description. The environmental setting is
adequately described in each individual
analysis chapter. Please see Master Response
3: Buildout and RHNA for more information on
how buildout represents a reasonable
estimate allowed under CEQA.

To the extent where potential impacts and
potential exceedance of thresholds can be
quantified, the DEIR does so, such as with
VMT, GHG, and air quality analysis. It is untrue
that GHG emissions are not disclosed; please
see tables 3.4-2 and 3.4-3. It is also untrue
that the source for GHG mitigation measure
effectiveness is not quantified-- please see
Table 3.4-4.

As noted in CEQA Guidelines Article 10, 15142,
qualitative analysis is permitted: "An EIR shall
be prepared using an interdisciplinary
approach which will ensure the integrated use
of the natural and social sciences and the
consideration of qualitative as well as
quantitative factors."
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 general law city, Pacifica is legally
required to ensure zoning and general plan
consistency. Thus, this does not represent a
deferred mitigation.

C46-
29 Terrell Watt 3/8/22 a. The Proposed Project (General Plan and SPSP) will have Significant Adverse Traffic Impacts that
are not Disclosed or Properly Analyzed in the
DEIR The Proposed Project will have significant
adverse traffic impacts that are not disclosed or
This example does not specify what the
inadequacies are for conflicts with circulation
system programs and policies; the DEIR
analyzes potential conflicts with C/CAG on p.
3-29 and 3-30. The Proposed Project

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analyzed in the DEIR. Potential impacts
associated with the Proposed Project include
conflicts with circulation system programs and
policies, significantly increased traffic and VMT,
and lack of emergency access. With the exception
of the DEIR’s identification of VMT impacts as
significant and unavoidable, all other traffic
impacts are found to be less than significant
through implementation of proposed policies
itigation). The DEIR’s analysis and conclusions are
flawed for all traffic impacts, but we focus our
two main examples on VMT and emergency
access.
specifically includes policies to ensure
compliance with the CMP and to reduce
congestion on CMP roadway segments.

Therefore, the Proposed Project would be
consistent with the CMP and the impact of the
Proposed Project would be less than
significant.

Increased traffic congestion is not a topic of
analysis required under CEQA. Please see
responses to comments C46-30 and C46-31
for more information on VMT impacts and
emergency access.

C46-
30 Terrell Watt 3/8/22 VMT: Vehicle Miles Traveled is the most important metric for measuring the multidimensional quality of growth in a community and can be a key strategy for achieving desired
growth patterns (e.g., infill near transit, jobs and
services, reduced sprawl into hazard and
biodiverse areas). Specifically, where
communities are using VMT metrics and
exchanges to direct where development occurs,
VMT provides an enforceable approach to reduce
high VMT development (low densities and
development at or beyond the community edge
away from jobs, transit and services) and in
transit and jobs rich infill locations. Not only does
the Proposed Project miss an opportunity for
leading edge policy to achieve stated outcomes
(such as San Jose’s VMT policy and fee program),
BUT the DEIR ALSO fails to adequately analyze
and disclose the Proposed Project’s full VMT
impacts. Data relied on for the analysis is
incomplete and out of date. Nowhere does the
DEIR disclose the full VMT that would be
generated by the Proposed Project. Even though
the DEIR finds VMT impacts significant and
unavoidable it must still impose all feasible
mitigation measures.

VMT is Grossly Underestimated: The DEIR
concludes that the Project would have a
significant and unavoidable impacts with respect
to CEQA Guidelines section 15064.3, sub. (b); or
VMT. However, in so finding, the DEIR grossly
underestimates VMT since calculations were
based on the Preferred scenario or Proposed
Project and not on the whole Project (i.e.,
buildout allowed under the Proposed Project).

See DEIR at 3-28 and explanation of buildout
above. Our estimate is that buildout allowed
under the Proposed Project would at a minimum
be an additional 500 housing units beyond the
projected 990 units, and more likely double that
given second units/ADUs, 1,700 RDAs,
The Commenter incorrectly states that DEIR
fails to adequately analyze and disclose the
Proposed Project’s full VMT impacts or
proposed all feasible mitigation.

The DEIR analysis is correctly based on
reasonably foreseeable projection of buildout
under the Proposed Project. See also Master
Response: Buildout.

Table 3.2-7 shows projected VMT metrics for
the proposed project. As described on DEIR p.

3.3-41, “It should be noted that the VMT
information presented is produced from the
regional travel demand model and only
accounts for the built environment variables
to which the model is sensitive. Additional
policies in the General Plan Circulation
Element supporting variables the model is not
sensitive to (such as connectivity in
neighborhoods, presence of bicycle and
pedestrian facilities, and transportation
demand management (TDM) measures) are
not reflected in these estimates. Thus, the
VMT estimates in this analysis are
conservatively high.” Table 3.4-3 on pages 3.4-
33 of DEIR demonstrates associated GHG
emissions in 2040 unmitigated. Table 3.4-4
shows the quantified reductions for policies in
the plan, as well as mitigation measures.

Decrease in per capita VMT is seen across all
future scenarios, to varying degrees. This likely
reflects that as the city grows, there are more
local opportunities to access jobs, goods and
services and trips become shorter. The
reduction is wholly because of proposed land
use and not a result of modeling the
effectiveness of specific policies.

The Proposed Project contains a number of
policies that would help reduce VMT, including
those that enhance connectivity for nonmotorized transportation, including pedestrians and bicycles. Policies that enhance
overall safety, connectivity, and accessibility

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implementation of SB 918 and density bonuses.

See Exhibits 1 and 2 which show planned capacity
based on the current general plan far in excess of
990 units and 630,000 s.f. of non-residential uses.

The DEIR’s analysis only considered the
“projection” for an additional 990 units and
630,000 s.f. of non-residential uses by 2040. The
analysis is also flawed. There is no explanation as
to how the proposed policies (mitigation) would
decrease VMT per capita by 8.6 percent. DEIR
page 3-40. Nor does the DEIR measure or explain
how mitigation measures, specifically TDM
measures and requirement that new
developments prepare transportation impact
assessments, reduce VMT impacts. Through nonquantitative commentary, the DEIR concludes that such policies as those “encouraging” infill
will further reduce VMT, but no quantitative
documentation is provided (metrics or
calculations) to support that conclusion. Also,
because there will be fewer jobs per capita with
allowable development (true buildout), and
development likely more spread out (ADUs/lot
splits in single-family neighborhoods) VMT per
capita of 15.77 miles per resident is likely low and
overall VMT will likely be much greater with
implementation of the Proposed Project -- which
in turn factors into greater air quality and GHG
emissions impacts. Even though VMT is found to
be significant and unavoidable, all feasible
mitigation measures must be identified. Where
mitigation is relied on to suggest impacts, or in
this case per capital VMT, will be reduced the
DEIR must include quantified analysis
(transparent mathematical calculations). In
addition to the questions above, please address
these questions in the responses to comments
(or revised documents):
• Which specific mitigation measures (policies or
land use designations) contribute to a reduction
in VMT per capita under the Proposed Project?
And by how much?
• How will policies critical to achieving reduced
VMT, as well as air quality and GHG emissions,
including but not limited to LU-G-2 Concentrated
Development and LU-G-3 Future Residential
Development limits actually be achieved and
enforced given RHNA requirements, SB 2 and
other factors?
• Which specific mitigation measures contribute
to a reduction in total VMT and by how much?
• How much VMT will be generated by the
Proposed Project (whole project rather than
projected growth)?
include policies CI-I-1, CI-I-2, CI-I- 3, CI-I-4 and
CI-I-5. Additional policies specifically support
connectivity for pedestrians (policies CI-I-13,
CI-I-16, CI-I-17, CI-I-27, CI-I-28, CI-I-29, CI-I-31)
and bicycles (policies CII32, CI-I-33, CI-I-34, CI-I-35, CI-I-36, CI-I-37, and CI-I-38). Policy CO-I-58 would also implement
the most recent BAAQMD Clean Air Plan’s
Transportation Control Measures, which are
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.

Proposed General Plan policy CI-I-5 details
streetscape improvements to increase
walkability along Palmetto Drive, Rockaway
Beach Avenue, Linda Mar Boulevard, Manor
Drive, and secondary streets in the planning
area. This would prioritize walkability and a
pedestrian-friendly environment in the
planning area, thus encouraging residents and
visitors to walk and reduce vehicle trips.

Proposed General Plan policies CI-I-2, CI-I-3,
and CI-I-4 identify opportunities to
incorporate Complete Streets
concepts in the planning of all circulation
improvement projects and roadway retrofits.

The proposed General Plan includes several
policies focused on expanding transit services
within the Planning Area by coordinating with
local transit agencies. Goal CI-G-17 advocates
for public transit providers to improve and
expand transit service and facilities to enable
trips made without the use of a car. Policies
CI-I-46, CI-I-47, CI-I-48, and CI-I-49 call for the
City to work with transit agencies to maintain
safe and efficient service, provide convenient
connections to high-use activity areas and key
destinations outside of the City, improve
transit stops and access to facilities, improve
convenience of park-and-ride facilities to
increase ridership, and facilitate transitoriented
development. Policy CI-I-52 would expand
Local Transportation Services tailored to the
schedules and destinations of students,
seniors, and recreational visitors. Finally,
policy CI-I- 50 would lead an initiative to
promote transit use and reduce reliance on
the private automobile to reduce congestion,
VMT, and GHG emissions.

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• How does implementation of new state laws
allowing lot splits and fourplexes factor into per
capita VMT?
• How much VMT will be generated by the
accommodation of the RHNA allocation? Also,
how will RHNA allocations change LOS
throughout the City?
• Were units allocated by the City’s growth
management ordinance (1,700) included in the
VMT
calculations? Also in the LOS analysis?
Proposed General Plan policy CI-I-51 would
establish a Transportation Demand
Management
(TDM) programs for City employees that could
include transit passes or subsidies,
preferential
carpool parking, car share programs, bicycle
lockers, and other incentives to encourage
alternative transportation modes. Attachment
X describes how compliance with C/CAG’s
TDM strategy requires that any land use
projects that will add more than 100 peak
hour trips to the CMP roadway network
inform C/CAG within ten days of completion of
the CEQA initial study, and local jurisdictions
are then required to work with the developer
and/or tenants to develop a TDM program to
reduce the peak hour trips. As noted on DEIR p

3.2-41, "new developments would be required
to evaluate their project-specific impacts on
the transportation system," including through
compliance with C/CAG TDM policy. Explain it
would have a positive benefit but that it would
be speculative to quantify because project
details cannot be known at this time.

Attachment X also shows how VMT mitigation
strategies listed in the technical guidance on
SB 743
implementation published by the Governor’s
Office of Planning and Research. As shown in
Table 1, General Plan policies that align with
the strategies are identified alongside where
applicable.

Regarding mitigation measures, MM-TRA-1
complements C/CAG’s TDM policy with
provisions for smaller employers. While the
DEIR states that it is difficult to quantify the
exact reduction potential of these mitigation
measures, CAPCOA guidance notes that
commuter trip reduction (as captured in
C/CAG’s TDM policy, supplemental MM-TRA-1
strategy, and BAAQMD Transportation Control
Measures) Quantification of GHG reduction of
this required measure, coupled with policy
CO-I-58 (Transportation Control Measures) is
described in Table 3.4-4. While Measure MMTRA-2 is voluntary, Proposed General Plan policy CO-I-58 would implement the 2017
Clean Air Plan’s
Transportation Control Measures. Measure
TR1 would develop best practices for
employers

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and strategies to promote telecommuting.

Mitigation Measure MM-TRA-2 also
encourages
Pacifica businesses to implement
telecommuting, hybrid, and alternative work
schedules to
reduce vehicle-based commutes. As shown in
Table 3.4-4, implementation of this policy
would
reduce transportation-related emissions by
3,409 MTCO2e.

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

C46-
31 Terrell Watt 3/8/22 Emergency Access and Evacuation: The Proposed Project will have significant adverse impacts to
emergency vehicle access that are not disclosed
or analyzed in the DEIR. The DEIR asserts without
foundation that although implementation of the
Proposed Project and increases in regional travel
passing through Pacifica would increase the
amount of vehicular traffic in and around the City
-- and may therefore increase the number of
potential emergency vehicle conflicts --
implementation of Project policies will improve
connections between communities, provide
additional routes and result in a less-thansignificant impact. DEIR at 3-45. The discussion notes that emergency access is typically assessed
at a project level. Contrary to that assertion, it is
at the General Plan Update time that
infrastructure must be planned to accommodate
planned land uses (requirement that the
circulation/infrastructure element be correlated
with the land use plan). This could be
accomplished through appropriate land use
designations and overlays and planned
improvements to the circulation system reflected
in a legally adequate circulation element.

Deferring the obligation to plan for adequate
infrastructure including safe emergency access
and evacuation routes to the project level
neither addresses the problem as the General
Evacuation routes are addressed in Impacts

3.2-4 and 3.11-1. The DEIR also describes on p.

3.4-18 how the Proposed Project advocates
policies at a programmatic level, whereas
emergency access is typically assessed at an
individual project level. 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. As noted in Impact 3.2-4,
project-level review by the City includes site
access review for emergency vehicles and
traffic control plans as needed that account
for emergency vehicles. Potential
improvements to the roadway network
(policies described on DEIR p. 3.2-46), traffic
signal preemption devices, additional access
routes (Ci-I-26, SA-I-94, SA-I-103, SA-I-104),
community evacuation education (SA-I-35),
and agency coordination (SA-I-102) and
ensure inadequate emergency access does not
occur.

Guidance for evacuation routes and
procedures also exists at a programmatic level
and is described in the 2019 All Hazards &
Evacuation Plans, and grants authority to the
Pacifica Police Department in conjunction with
the NFCA to plan coordinate, and carry out all

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Plan must nor mitigates the significant impacts of
the Proposed Project.

A key policy (mitigation measure) underscores
why it is at the General Plan level that a city-wide
plan needs to be in place for adequate
emergency and evacuation access:

SA-I-104 Areas that Lack Emergency Access.

Develop a plan to widen critical rights-of-way that
do not provide adequate clearance for
emergency vehicles. For areas that are not
feasibly accessible to emergency vehicles,
develop a contingency plan for reaching and
evacuating people in need of treatment. This
initiative should nclude a plan to open access to
or otherwise serve the Pedro Point,
Fassler/Rockaway, and Vallemar neighborhoods.

The project description must include a general
description of the project’s technical, economic
and environmental characteristics, considering
principal engineering proposals and supporting
facilities. A legally adequate and correlated
circulation element must include planned
infrastructure sufficient to serve planned
(allowed) development. To the extent that key
policies require additional infrastructure be built
such as road widening, new routes, those
improvements must also be included in a revised
circulation element and Project Description. The
impacts associated with those improvements
must be analyzed.

A revised DEIR must either include additional
mitigation measures to reduce clearly significant
impacts associated with the lack of emergency
access and evacuation routes, or find this impact
Significant and Unavoidable.
evacuation plans in the affected area. This
existing plan represents a contingency plan for
reaching and evacuating people. The Proposed
Project continues and builds upon actions
outlined in the 2021 MJ-LHMP to improve
emergency response and coordination, such
as protecting critical transportation
infrastructure, developing outreach programs
to prepare businesses and residents for
disaster, supporting the retrofit and relocation
of structures in hazard-prone areas, and
supporting regional inter-agency coordination
for hazard mitigation.

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 along with
the existing programmatic framework will
ensure that inadequate emergency access is
reduced to the extent practicable, and will
result in a less than significant impact. In
addition, see Master Response 7: Emergency
Access.

C46-
32 Terrell Watt 3/8/22 Improper Baseline: In addition to these examples of inadequate disclosure and analysis resulting in
understating the significance of raffic-related
impacts, the traffic analysis uses an improper
baseline or baselines. CEQA requires the lead
agency to use a baseline that represents real
conditions on the ground at the time of CEQA
review. The DEIR relies on traffic data that in
some cases goes back to 010, 2011 and in the
case of potential VMT thresholds of significance,
2015 (DEIR page 3-28, 3-40). More current
information exists and should be the basis for
revised impact analysis.

Traffic counts from pages 3-12 to 3-21 were
conducted in 2018 and 2019, and analysis
from Table 3.2-7 on page 3-41 was conducted
in 2020 and 2021, in accordance with the table
references in the DEIR.

As noted on DEIR p. 3-28, VMT calculations
rely on the most recent version of the tripbased travel demand model jointly maintained by C/CAG and the Santa Clara County VTA
(C/CAG 2020, published February 2021.) The
latest C/CAG model does not have a 2020
scenario; the 2015 baseline represents the
best available information at the time of the
study.

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C46-
33 Terrell Watt 3/8/22 Inadequate Cumulative Analysis: The traffic analysis fails to include many reasonably
foreseeable future projects including but not
limited to accommodation of the RHNA allocation
of 1,892 units and foreseeable housing required
by state law (e.g., SB 9). These projects will have
adverse cumulative traffic and other impacts
together with the Project, which are not disclosed
or analyzed in the DEIR.

Buildout projections are reasonable under
CEQA; thus, VMT analysis is sufficient, and
findings of "significant and unavoidable" with
mitigation remain correct. Please see Master
Response 3: Buildout and RHNA for more
information about the purpose and adequacy
of Proposed Project buildout.

C46-
34 Terrell Watt 3/8/22 Feasible Mitigation: While the DEIR acknowledges that the Project has significant impacts to VMT, it
does not impose all feasible mitigation measures
to reduce such impacts as is required by CEQA.

The DEIR’s measures are weak, unenforceable,
unmeasurable and incomplete. Examples of the
types of measures that should be included in a
revised DEIR include but are not limited to the
following:
• A VMT-based fee and VMT exchange program
promoting infill near transit, jobs and services
and provide funding to purchase properties
whose development would result in high VMT.

See e.g., City of San Jose VMT policy and
program: Mobility: Vehicle Miles Traveled | City
of San Jose (sanjoseca.gov)
• Land use overlay designation prohibiting new
subdivisions, limiting development to one unit
per legal lot of record, and requiring
development to be transferred where possible
(VMT exchange program/updated TRD program)
where evacuation routes are inadequate and
hazardous conditions high (e.g., flood, landslide,
fire, sea level rise, tsunami, etc.).

Please see response to comment C46-30 for
more information about VMT mitigations.

C46-
35 Terrell Watt 3/8/22 b. The Project is Likely to have Significant Adverse Air Quality and Greenhouse Gas Impacts that are
not Disclosed or Analyzed
The DEIR concludes that the Proposed Project
would have a less than significant impact for all
four air quality significance criteria. DEIR section

3.3 Air Quality. This conclusion is incorrect for
several reasons. First, as noted herein, the air
quality analysis conducted within the DEIR is
based on outdated baseline data that do not
accurately reflect current population, traffic and
other relevant metrics within the Project area.

This statement is inaccurate. The DEIR uses
the latest and best available data for this
analysis. Traffic counts from pages 3-12 to 3-
21 were conducted in 2018 and 2019, and
analysis from Table 3.2-7 on page 3-41 was
conducted in 2020 and 2021, in accordance
with the table references in the DEIR. The raw
results of this analysis can be found at
https://cityofpacifica.egnyte.com/dl/QvA0lqy
N5J. GHG impacts, as noted on DEIR p. 3/4-23,
notes "or transportation energy use, the
analysis uses DKS Associates estimates of the
daily VMT generated in 2015 and estimates of
daily VMT generated for the 2040 Proposed
Project buildout. "As noted on DEIR p. 3-28,
VMT calculations rely on the most recent
version of the trip-based travel demand model
jointly maintained by C/CAG and the Santa
Clara County VTA (C/CAG 2020, published
February 2021.) The latest C/CAG model does
not have a 2020 scenario; the 2015 baseline

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represents the best available information at
the time of the study.

C46-
36 Terrell Watt 3/8/22 Second the DEIR fails to account for allowable development under the Proposed Project (i.e.,
the whole of the project or full buildout), relying
instead on a projection for development by 2040.

Projected development reflects only a portion of
development allowed by the Proposed Project.

Allowable development is significantly more units
and non-residential square feet than the 2040
project of 990 units and 630,000 s.f. of nonresidential use as described above.

Please see Master Response 3: Buildout and
RHNA for more information about the
adequacy of buildout.

C46-
37 Terrell Watt 3/8/22 Third, the DEIR fails to account for development projects already proposed under SB 9 and
foreseeable development pursuant to the RHNA
allocation and RDAs, which development could
be considerable in number over the life of the
Project. Due to these and other reasons, the
DEIR’s air quality analysis and resultant
significance determinations underestimates and
misrepresent the significance of air quality
impacts.

This comment alleges that potential impacts
of the DEIR are underestimated because
buildout does not use estimates of “maximum
capacity” or incorporate Regional Housing
Needs Allocation 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.

Separately, the City is preparing to initiate its

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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.

Projects under SB 9 are only subject to
ministerial review. Please see Master
Response 3: Buildout and RHNA for more
information about adequacy of buildout.

C46-
38 Terrell Watt 3/8/22 In order for the DEIR to analyze whether or not the Proposed Project would conflict with or
obstruct implementation of an applicable air
quality plan the analysis must consider the
existing population and VMT and population and
VMT under the proposed Project. DEIR page 3.3-

20. As discussed above in the traffic section, the
DEIR fails to follow this methodology and as a
result does not disclose the vehicle miles traveled
generated by mplementation of the Proposed
Project. The DEIR has a figure for Pacifica’s 2015
VMT in Table 3.2-6, as well as for No Project
(current general plan) and Proposed Project
(portion of development allowed by the
proposed General Plan or 990 units by 2040).

Nowhere in the DEIR is the VMT resulting from
implementation of the Project disclosed (i.e.,
This comment contains an inaccuracy. For
existing baseline, the calculations rely on the
most recent version of the trip-based travel
demand model jointly maintained by C/CAG
and the Santa Clara County VTA (C/CAG 2020
published February 2021).Calculations were
made for four scenarios – the model’s 2015
baseline scenario, the 2040 Pacifica Preferred
scenario (Proposed Project), and three 2040
scenarios representing the No Project
Alternative and Alternatives 1 and 2 (analyzed
in Chapter 4: Alternatives). A methodology is
provided in Appendix A. The C/CAG model
does not have a 2020 scenario; the 2015
baseline represents the best available
information at the time of the study. Analysis
of VMT based on implementation of the

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buildout allowed under the Proposed GP and
SPSP). Therefore, there is no evidence supporting
the DEIR’s conclusion that impacts with respect
to the applicable air quality plan is less than
significant.

General Plan, including the Specific Plan, is
described under Proposed Project, shown in
Figure . As previously noted, the Proposed
Project will affect VMT in the area. It should
be noted that the VMT information presented
is produced from the regional travel demand
model. Table 3.2-6 shows VMT calculations for
the 2015 baseline scenario for various
geographic regions including the City of
Pacifica, San Mateo County, and the ninecounty Bay Area. As shown, both VMT per capita and VMT per employee are higher for
the City of Pacifica than for the county or Bay
Area statistics. Table 3.2-6 also establishes
thresholds based on a 15 percent reduction
from the various baseline VMT rates. The
threshold of significance based on a 15%
reduction would be a VMT per capita of 13.40
miles per resident for the City of Pacifica; and
a home-based work VMT per employee of

14.22 at the Countywide level. Table 3.2-7
summarizes the VMT calculations for Pacifica
under the No Project condition and Proposed
Project.

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C46-
39 Terrell Watt 3/8/22 In determining that all air quality impacts would be less than significant, the DEIR relies heavily on
a few policies (mitigation measures) including
(see DEIR 3.3-21-22):
• Policy CO-I-54 requiring the City to update its
Climate Action Plan.
• Goals and policies focusing on promoting
mixed-use and transit-oriented development,
sustainable and environmentally-sensitive design
and multimodal mobility.
• Policies promoting preservation of open space
including coastal areas, ridgelines, parks, and tree
canopy.

Based on many of the same polices (mitigation
measures) the DEIR finds impacts related to
greenhouse gas emissions less than significant.

The evaluation of GHG suffers from the same
problems as for air quality, notably the lack of a
complete Project Description. Similar policies
(mitigation measures) are relied on to reduce
GHG impacts. The efficacy of these policies to
reduce air quality and GHG emissions is unclear
as there is no quantitative analysis of the efficacy
of these policies to reduce air emissions.

Moreover, the efficacy of these well-intentioned
high level policies is significantly undermined by
the fact that the Proposed Project allows more
development than analyzed, and includes land
use designations that encourage or ministerially
permit low density development in areas that are
not transportation efficient or jobs and services
rich. The first SB 9 application is for a lot in a low
density residential area adjacent to San Pedro
Mountain which would by definition be a high
VMT area. At the very least, the “whole” project
must be analyzed and impacts disclosed and
feasible mitigation measures capable of reducing
significant impacts recommended.

All assertions are incorrect. The statement
contains an inaccuracy, policies that reduce
GHG are quantified in Table 3.4-4 and Table

3.4-5. As noted on DEIR p. 3.4-27, it is
acknowledged that "implementation of [the
existing] CAP does not necessarily guarantee
that an updated CAP will be prepared or that
all GHG reduction measures included will be
capable of meeting an updated, and
potentially lower, GHG emissions reduction
target." Because impacts and potential
reductions could not be quantified, the DEIR
concludes that "therefore, on a local scale,
implementation of the Proposed Project
would generate GHG emissions that could
have a significant impact on the environment
and this impact would be potentially
significant and mitigation measures would be
required." These mitigation measures are
described on p. 3.4-47, and 3.4-48. This does
not a deferred mitigation and the conclusions
in the DEIR remain valid.

Please see Master Response 3: Buildout and
RHNA for more information on the adequacy
of buildout.

C46-
40 Terrell Watt 3/8/22 c. The DEIR Fails to Disclose and Analyze Land Use, Population and Housing Impacts The DEIR
erroneously concludes that impacts of the
Proposed Project on land use, population and
housing would be less than significant. This
conclusion is based on much lower growth and
development than is actually allowed by the
Proposed Project and by state law. For example,
the DEIR’s analysis of growth, population,
employing and housing impacts is inadequate.

The DEIR concludes: “The Proposed Project would
not induce substantial unplanned population
growth in an area, either directly or indirectly,”
finding this a less than significant impact. DEIR at

3.1-29 The DEIR bases this conclusion on
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. Therefore, this approach does
not constitute “piecemealing,” or dividing a
large project into separate parts, each of
which might have individually minimal
environmental consequences. At this time,

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projected development by 2040 rather than on
actual development allowed by the Project (the
whole of the project or full buildout). The
Proposed Project only anticipates 990 units by
2040, thereby understating allowable
development by 50 percent or more. DEIR at 3.1-

29. Not included in the growth assumptions are
the required units under the RHNA allocation
(1,892 units not 990), 1,700 RDA’s, ministerially
permitted fourplexes, lot splits, ADU’s and
density bonus units or the actual development
allowed by land use designations in the Proposed
GP and SPSP.

The additional 500+ units above the projected
990 units will certainly increase the jobs-housing
imbalance as well as jobs-housing fit, thereby
increasing not only VMT but likely also VMT per
capita. Increases in VMT and in VMT per capita
bring into question compliance with the Air
Quality Plan. Increased traffic and VMT,
particularly where resulting from spread out,
lower density development such as lot splits,
ADUs and fourplexes could trigger significant
localized and regional air quality and GHG
emissions above those analyzed in the DEIR. Also,
additional units and residents will certainly
increase the need for a full range of services
including but not necessarily limited to schools,
day care, police and fire, and more.

According to the DEIR discussion "...policies in the
Proposed Project encourage infill development
that would avoid unplanned development that
could be induced through infrastructure
expansions into new growth areas,” concluding
therefore the Proposed Project would not induce
substantial unplanned population growth, either
directly or indirectly, and the Proposed Project’s
impacts would be less than significant. DEIR at

3.1-30. Nowhere does the DEIR provide metrics
or calculations that show how much these
policies (mitigation measures) will actually result
in these land use patterns or how these policies
would reduce significant air quality impacts. As
described above, a substantial amount of the
development allowed by the Project beyond the
990 units projected, could occur in currently
singlefamily areas of the City19, stretching road
capacity, parking, evacuation routes, and
services. This is precisely the kind of induced
growth impact a DEIR must disclose, analyze and
mitigate. By ignoring the full growth and
development allowed by the Proposed Project
(GP and SPSP) the DEIR fails to disclose and
the number of units and locations of
ministerially approved development is
speculative. Please see Master Response 3:

Buildout and RHNA for more information
about the adequacy of buildout.

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analyze likely significant growth, population,
employment (jobs housing ratios and jobs
housing fit20) and the full array of housingrelated impacts. The direct and indirect impacts of the full growth potential of the Proposed
Project must be disclosed and analyzed in a
revised DEIR.

C46-
41 Terrell Watt 3/8/22 Moreover, the DEIR’s conclusion that implementation of the Proposed Project would
not conflict with any land use plan, policy or
regulation adopted for the purpose of avoiding or
mitigating an environmental effect is less than
significant is in error. DEIR at 3.1-26, Impact 3.1-

2. One example of conflict is the Proposed
Project’s designation of Pedro Point Avenue Site,
an approximately 4-acre undeveloped site within
the Coastal Zone, for Coastal Residential Mixed
Use, allowing 20+ units and 17,000+ square feet
of non-residential uses on this site not including
potential density bonus and other residential
uses that are now by right under state law. This
site has been classified by US Fish and Wildlife as
a wetland within the National Wetlands
Inventory.

In addition, as noted in a letter submitted to the
City by Dr. Peter Baye, the site is valuable habitat
for special status species. In addition,
development of this site at the density and
intensity proposed would further impact an
inadequate evacuation route; an impact not
disclosed, analyzed or mitigated in the DEIR. The
Proposed Project (General Plan) does including
policies requiring more detailed evaluation once
a project is proposed (e.g., SA-I-11 Grading and
Drainage Plans, CO-I-4 Wetlands Preservation).

The most important measure
is the General Plan’s land use designation which
in this case is inconsistent with Coastal Act Policy
and internally inconsistent with numerous goals
and policies in the General Plan. This is a clear
case of conflict and the Proposed Project land use
designation should be changed to be consistent
with site characteristics and constraints and the
Coastal Act. In this case the lowest possible
density is appropriate, 2 units subject to merging
the three parcels; or maximum of 1 unit per legal
parcel in combination with a “Climate Resilience
Overlay” requiring analysis of potential purchase
or transfer of development as a condition of any
development proposal. See mitigation measures
section of this letter.

Please see Master Response 6: ESHA for more
information on ESHA mapping; the US Army
Corps of Engineers has not made a final
wetlands determination. The General Plan
and associated DEIR review at the city-wide
scale sensitive and Critical Habitat and general
locations of Special Status Species appropriate
for a programmatic EIR, as noted in Master
Response 2: Programmatic EIR. At the time of
a development application, such as at the San
Pedro site, the environmental conditions will
be analyzed in coordination with applicable
habitat conservation and mitigation policies.

Such policies to protect sensitive habitats and
ESHA include creek protection and restoration
(CO-I-1); wetlands preservation, coupled with
compensation in line with no-net-loss goals
(CO-I-4); and protection of environmentally
sensitive areas (CO-G-11) through verification
(CO-I-27) and management of ESHA (CO-I-28).

Please also see Master Response 4:

Undeveloped San Pedro Ave site for more
information about project-level requirements
and consistency with Coastal Act policies.

C46-
42 Terrell Watt 3/8/22 Another example of the Proposed Project (General Plan’s) conflict with Coastal Act Policy
This comment is not related to the adequacy
of analysis in the DEIR. Please see Master

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and the draft Local Coastal Plan (LCP) is the
General Plan’s policy allowing under some
circumstances the use of seawalls or shoreline
alterations for protection of new development.

General Plan page 8-9. Whereas the draft LCP
provides that any new development in the
Coastal Zone shall not in any way require the
construction of protective devices that would
substantially alter natural landforms along bluffs
and cliffs. These provisions provide conflicting
advice for new development and should be made
consistent. How would restrictions on use of
protective devices under the Coastal Act change
proposed and permissible development of Sharp
Park? Other low lying areas of the City?
Policies in the Proposed Project (GP, SPSP and
LCP) that are in conflict are too numerous to list
but also include cases of land use designations
allowing development of ESHA’s, wetlands and
high hazard areas where there are other choices
for more restrictive land use designations that
would avoid those conflicts (e.g., as described
above in the section on VMT).

Response 1 for more information on GPrelated responses.

This policy is consistent with PRC Div 20. Ch 3,
article 4:. Marine Environment [30230 -
30236] ( Article 4 added by Stats. 1976, Ch.
1330. )Revetments, breakwaters, groins,
harbor channels, seawalls, cliff retaining walls,
and other such construction that alters natural
shoreline processes shall be permitted when
required to serve coastal-dependent uses or
to protect existing structures or public
beaches in danger from erosion and when
designed to eliminate or mitigate adverse
impacts on local shoreline sand supply.

Existing marine structures causing water
stagnation contributing to pollution problems
and fishkills should be phased out or upgraded
where feasible.

C46-
43 Terrell Watt 3/8/22 A revised DEIR must include a comprehensive list of applicable federal, state, regional and local
policies, standards and regulations and state how
the Proposed Project is consistent with each. This
typically done in table form listing all potential
inconsistencies so that they could be rectified
prior to Project approval. We request this
information either in text or table form be
included in a revised DEIR.

Each of the DEIR analysis chapters include a
list of applicable federal, state, regional, and
local policies that apply.

C46-
44 Terrell Watt 3/8/22 d. The DEIR Fails to Disclose and Analyze Significant Wildfire Hazards and Impacts The DEIR
erroneously concludes that implementation of
the Proposed Project (General Plan) would not
expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires, finding this impact
less than significant. DEIR at 3.11-23. According
to the DEIR: “…wildland fire hazard is minimal in
most of Pacifica within city limits because it is
mostly urbanized.” DEIR at 3.11-23.

This statement is unsupported by facts and
evidence and is clearly incorrect. In the last
decade numerous “urbanized” areas have been
significantly impacted and some wiped out by
wildland fire, including major urbanized areas of
Redding, Santa Rosa and the entire town of
Paradise. No longer is wildland fire just a threat
to community perimeters. The DEIR itself
contradicts the conclusion that the threat to
developed areas in Pacifica from fire hazard is
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
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

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less than significant: “In California, most wildfire
damage occurs inn wildland urban interface
[WUI] areas, where homes and woodland
vegetation are directly adjacent. Neither the
Proposed Project nor the DEIR contain a map of
the WUI areas within Pacifica even hough a map
of California’s WUI is available from CAL FIRE’s
Fire and Resource Assessment Program and a
downloadable version can also be found on the
Office of Planning and Research’s website. Nor
does the Project or the DEIR contain other readily
available maps of high fire threat. Exhibits 3-6. By
inappropriately constraining the impact
evaluation for fire hazard risk to defined fire
zones (only Very High Fire Severity Zones) the
DEIR fails to consider the rapidly changing climate
and fact that all of Pacifica is under threat due to
a new era of catastrophic fire behavior. In a
recent (June 7, 2021) oastal Conservancy grant
award to the City for wildlife urban nterface fuel
reduction (Chipper Program), the staff
ecommendation states in pertinent part: “The
City of Pacifica is bordered by Very High Fire
Hazard Severity Zone at its southern boundary,
where vast swaths of open space extend down
the San Francisco and San Mateo Coastside
(Exhibit 1). Each year hot weather and high winds
pose a fire hazard throughout the City of
Pacifica.” Page 3, Link to Coastal Conservancy
Staff Report, source of quote: PROJECT NAME
(ca.gov) The DEIR’s analysis of fire impact should
be completely revised taking into account the
information readily available in the Office of
Planning and Research’s Technical Advise series
including Fire Hazard Planning Advisory: General
Plan Guidelines and Technical Advisories - Office
of Planning and search Wildfire risk takes into
account a number of factors that render all of
Pacifica at risk for damage due to a spreading
wildfire including high fuel hazard at the
community edge, probability of a fire, roximity or
presence of WUI, slopes, topography and other
factors. In addition to measures trained on urban
areas that could be mpacted by wildfire, the
Guidelines recommend protection of open space
and conservation of natural and working lands for
multiple benefits including carbon sequestration
but also wildfire mitigation and risk reduction.

A completely revised DEIR must analyze fire risk
based on the nditions present in a new era and a
changing climate, designate fire a Significant and
Unavoidable impact21 of the Proposed Project.

The revisions should also reclassify the potential
for exposure of eople or structures to significant,
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.

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 , 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 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 alreadyurbanized neighborhoods where risk is lower as compared to areas of higher fire threat, but
not devoid. While it is possible that

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including downslope or ownstream flooding or
landslides as a result of runoff, post-fire lope
instability, or drainage changes to significant and
unavoidable nless stronger policies (mitigation
measures) are adopted. This ections conclusion
concerning the disposition of Impact 3-14.4 is
based on the erroneous conclusion that wildfire
risk is less than significant. DEIR page 18:
“…because the Proposed Project maintains
restrictions on development in hazardous areas
near VHFHSZ, the potential exposure of people
and structures to post-fire landslides and flooding
would not increase significantly…”. Montecito
California is an example of where a wildland fire
swept through the area later resulting in
catastrophic landslides throughout the
ommunity. These DEIR sections must be updated
to reflect this era of changing risk and
recommendations for stronger and nforceable
mitigation measures in the form of policies and
land uses. Examples of meaningful mitigation
measures:
• General Plan level land use overlay designation
prohibiting new subdivisions, limiting
development to one unit per legal lot of record,
and requiring development to be transferred
where possible (VMT exchange program/updated
TRD program) for areas with inadequate
evacuation routes and hazardous conditions high
(e.g., flood, landslide, fire, sea level rise, tsunami, etc.). As another example of mitigation, the City
of Berkeley recently prohibited ADUs in high fire
areas of the Berkeley Hills.
• Designation of a proposed Greenbelt (Multiple
benefit resilience buffer) with funding identified
through either 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.
• LA County style policies to prohibit new
subdivisions where fire hazard (and other
hazards) is significant. Safety Element Update |
Climate Action (lacounty.gov) The proposed
policy SA-I-80
could be the basis for a stronger policy not only
prohibiting new subdivisions in shoreline areas
but also areas that are at risk of fire, flooding,
slope failure.
• Additional home and structure hardening and
fuel reduction requirements for new
development based on OPR and other guidelines.
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 fire-prone 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 (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-I98), plan review in fire-prone areas (policy SAI-95), and coordination with North County Fire Authority and other agencies (SA-I-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.

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C46-
45 Terrell Watt 3/8/22 e. The DEIR Fails to Disclose and Analyze Significant Impacts to Biological Resources
The DEIR without analysis or evidence finds all
impacts to biological resources less than
significant. Proposed policies relied on to reduce
potentially significant impacts – such as LU-G-7
Open Space Conservation and Habitat Protection
and CO-G-7 Wildlife and Critical Habitat – are well
meaning but undercut by inconsistent land use
designations that would allow development in
these very areas (e.g., Pedro Point field
designation for Coastal Residential Mixed Use up
to 0.5 FAR and 15 units per acre not counting
density bonus, ADUs and second units or lot
splits).22 Policy CO-I-43 is also well meaning –
Explore opportunities for public acquisition of
land or easements. However, unless changed,
land use designations allowing development of
these high value areas --and the related impacts
associated with that development including
grading, runoff, human activity, lighting and noise
among others -- warrants identification of
biological impacts (Impacts 3.7-1, 3.7-2, 3.7-3,

3.7-4 and 3.7-5) as significant and unavoidable.

Policies and land use designations must be
consistent in protecting these important
resources and should not defer “mitigation” as
exemplified by LU-I-12 requiring the hillside
preservation map to be updated sometime in the
future to show all hillside properties. In the
interim, numerous parcels are not covered by this
protective policy.

Please see response to comment C46-41.

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 general law city, Pacifica is legally
required to ensure zoning and general plan
consistency. Thus, this does not represent a
deferred mitigation.

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C46-
46 Terrell Watt 3/8/22 4. The DEIR Fails to Adequately Analyze Mitigation Measures and to Identify Feasible
Mitigation Measures in the form of Policies and
Land Uses
Feasible mitigation measures for significant
environmental effects must be set forth in an EIR
for consideration by the lead agency’s decision
makers and the public before certification of the
EIR and approval of the Proposed Project
(General Plan and SPSP). Formulation of
mitigation measures should not be deferred until
some future time. However, measures may
specify performance standards which would
mitigate the significant effect of the Project and
accomplished in more than one way. The DEIR
must explain how measures relied on to support
a conclusion that an impact would be reduced
from significant to less than significant
accomplish that reduction. Ideally the efficacy of
a policy (mitigation measure) to reduce a
significant impact to less than significant should
be quantified. As described in the sections of this
letter above, there are numerous feasible
mitigation measures that should be included in
either a revised Project or the DEIR capable of
reducing the Proposed Projects potentially
significant impacts to traffic, emergency access
and evacuation, hazards, coastal and biological
resources, water quality, and more. Pausing the
completion of this General Plan so that it can
include the Housing Element update would
provide the community a chance to work
constructively with the City to strengthen Plan
policies (mitigation) and fix the defects in the
Proposed Project and DEIR.

Please see also response to Comment C34-17.

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. Mitigation measures are required only
if impacts remain significant after policy
impacts are analyzed.

Further, the commenter's assertion that the
DEIR did not quantify the reductions that
would result from mitigation measures is
incorrect. On DEIR p. 3.3-39, Table 3.3-6
summarizes daily mobile, area, and energy
source emissions generated under existing
(2020) and 2040 conditions with
implementation of the Proposed Project and
its policies. To evaluate the magnitude of the
change in the air quality environment due to
implementation of the Proposed Project, the
emissions under the Proposed Project at
buildout in 2040 are compared to the
emissions under existing conditions, and the
resulting net increase in emissions is
compared to BAAQMD’s project-level
thresholds. On DEIR p. 3.4-3, Table 3.4-3
shows how mass GHG emissions would be
further reduced to a total of 79,851 MT CO2e
in 2040 with implementation of Proposed
Project policies that are quantifiable using
CalEEMod. Table 3.4-4 shows "Additional GHG
Emissions Reduction from General Plan
Policies." GHG mitigation measures are also
quantified on p. 3.4-48.

Additionally the commenter's assertion that
feasible mitigation measures related to VMT
were not considered is also incorrect. Please
see response to comment C46-30 for more
information.

Please see Master Response 3: Buildout and
RHNA for more information on the Housing
Element.

C46-
47 Terrell Watt 3/8/22 Summary of Feasible Measures (Policies) for Consideration:
• Make the Land Use Designation changes for an
implementable TDR Program and designate
sender and receiver sites as part of the Proposed
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

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Project rather than after density and intensity has
already been determined. LU-I-15 Transfer of
Development Rights. The General Plan states the
TDR needs to be amended to “identify areas
where densities and heights may be increased”
The General Plan Update is the time to make
these land use designation changes. The TDR
Program provides a mechanism to relocate
potential development from areas where
environmental or land use impacts could be
severe to other areas more appropriate for
development. This is a priority for the Proposed
Project/GP Update not later. If the Proposed
Project “gives away” increased development
now, it will leave no room to tie those rights to
additional and valuable market rate housing and
non-residential uses. This is also a feasible,
measurable and meaningful mitigation when
overlaid on areas that should not be developed
due to hazards and resource values.

Related to TDR:
o General Plan level land use overlay designation
prohibiting new subdivisions, limiting
development to one unit per legal lot of record,
and requiring development to be transferred
where possible (VMT exchange program/updated
TRD program) for areas with inadequate
evacuation routes and hazardous conditions high
(e.g., flood, landslide, fire, sea level rise, tsunami, etc.).
o Designation of a proposed Greenbelt (Multiple
benefit resilience buffer) with funding identified
through either 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.
that context. Please see Master Response 1:

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

C46-
48 Terrell Watt 3/8/22 • LA County style policies to prohibit new subdivisions where fire hazard (and other
hazards) is significant. Safety Element Update |
Climate Action (lacounty.gov) The proposed
policy SA-I-80 could be the basis for a stronger
policy not only prohibiting new subdivisions in
shoreline areas but also areas that are at risk of
fire, flooding, slope failure.
• Additional home and structure hardening and
fuel reduction requirements for new
development based on OPR and other guidelines.

The recommendations are noted. The
comment is not related to the adequacy of the
DEIR, thus no further response is required; see
Master Response 1 for more information on
GP-related responses. Please see Master
Response 5: Wildfire for more information on
how compliance with regulatory frameworks
and proposed policies reduce impacts to less
than significant, to the maximum extent
practicable.

C46-
49 Terrell Watt 3/8/22 5. The DEIR Fails to Identify Significant and Unavoidable Impacts
The DEIR concludes that all but one impact, VMT,
would be less than significant basing the
Please see response to comment C34-12 and
C123-28 for more information on adequacy of
analysis, as well a response to comments C 46-
50; C46-51; C46-53; C46-54; C46-55; and C46-

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conclusion on non-quantitative commentary
concerning the efficacy of vague, unenforceable,
unmeasurable and in many cases deferred
policies. In addition to the examples above, at a
minimum the following additional impacts should
be redesignated significant and unavoidable
unless: a) new analysis is provided that includes
quantification and evidence that impacts will in
fact be less than significant or b) new mitigation
measures in the form of enforceable and
measurable policies are included.

56. 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. Please see
Master Response 2: Programmatic EIR. 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 and any required
mitigation 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.

C46-
50 Terrell Watt 3/8/22 3.4-1 GHG Emissions – no quantification is provided as to how policies listed would reduce
potentially significant GHG emissions to less than
significant. For example, how much will TDM
reduce GHG? What reductions would be achieved
through the updated CAP. Please list the policies
relied on to reduce GHG emissions and quantify
the reduction each achieves.

The comment states that no quantification is
provided as to how policies listed would
reduce potentially significant GHG emissions
to less than significant. This statement
contains an inaccuracy, quantification of GHG
emissions reduction by implementation of
General Plan policies is stated in Table 3.4-5
(page 3.4-35) and Table 3.4-6 (page 3.4-48).

As noted on DEIR p. 3.4-34, Proposed General
Plan policy CO-I-58 would implement the 2017
Clean Air Plan’s Transportation Control
Measures. Measure TR2 would require
employers with 50 or more employees to
provide commuter benefits in order to reduce
transit costs to employees and develop
innovative ways to encourage rideshare,
cycling, and walking for work trips.

Mitigation Measure MM-TRA-1 also requires
applicants for non-residential projects that
employ 20 or more people to implement an
employee commute trip reduction program
that identifies alternative modes of
transportation to the project and provides
ride-matching assistance, subsidized public
transit passes, vanpool assistance, and/or car
sharing programs. As shown in Table 3.4-4,
implementation of this policy would reduce
transportation-related emissions by 7,809
MTCO2e.

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The CAP has not been updated yet. The latest
information about the update can be found in
the City's website:
https://www.cityofpacifica.org/depts/plannin
g/climate_action_plan.asp
The policies who's mitigation measures have
been quantified have been stated in Table 3.4-
4 (page 3.4-35) and Table 3.4-5 (page 3.4-48).

C46-
51 Terrell Watt 3/8/22 3.5-3 Substantial alteration of drainable patterns etc. -- Please list the policies relied on to reduce
significant impacts and quantify the reduction
each achieves.

Based on analysis under Impact 3.5-3 starting
on page 3.5-29, implementation of existing
local regulations and compliance with the
following proposed General Plan policies, the
impacts of the Proposed Project related to the
alteration of drainage patterns, flood flow,
stormwater runoff, and exceeded capacity of
stormwater drainage systems would be less
than significant. See policies CO-G-1, CO-G-2,
CO-G-3, CO-G-4, CO-G-6, CO-I-1, CO-I-2, CO-I4, CO-I-5, CO-I-7,CO-I-9 through CO-I-16, CO-I23, CO-I-24, CO-I-25, CO-I-38, CO-I-46, CO-I-47, CO-I-58, CO-I-63, SA-G-4, SA-G-5, SA-I-11, SA-I12, SA-I-15, SA-I-17, SA-I-18, SA-I-19, SA-I-20, SA-I-22, SA-I-23, SA-I-24, SA-I-25, SA-I-28, SA-I30, SA-I-79, and SA-I-86.

C46-
52 Terrell Watt 3/8/22 3.6-1 and 3.6-3 Exposure to substantial adverse risks – In addition to listing the policies relied on
to reduce these risks and the reduction each
achieves, please provide a map showing where
policies would prohibit development based on
risk factors (e.g., SA I-2, SA I-9).

Policy SA-I-2 refers to Figure 8-2, which is DEIR
Figure 3.6-2. However, any project within a
Liquefaction Zone as shown in Figure 3.6-1 is
also required to undertake geotechnical
investigation: "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." Policy SA-I-9
refers to Coastal Zone Combining Areas and
Hillside Preservation Districts; these locations
are determined in Zoning maps.

C46-
53 Terrell Watt 3/8/22 3.7-1 through 3.7-5 Biological resource impacts (also addressed above) -- In addition to listing the
policies relied on to reduce impacts to these
resources and the reduction each achieves,
please provide a map showing where policies
would prohibit development (e.g., LU-G-7, C0-G7, 8 and 9).

This comment does not relate to the adequacy
of DEIR analysis. Please see Master Response
4: Undeveloped San Pedro Ave Sites
C46-
54 Terrell Watt 3/8/22 3.9-1, 3.9-2, 3.9-3 and 3.9-4 Adverse visual and scenic resource impacts and impacts to light and
glare -- Please list the policies relied on to reduce
visual impacts and quantify the reduction each
achieves.

The DEIR analyzes scenic vistas on page 3.9-14
through 3.9-22. It includes regulations and
policies that would further reduce impacts on
pages 3.9-19 through 3.9-22.

Analyses regarding scenic resources is
included in the DEIR on pages 3.9-22 to 3.9-24,
including policies that would help further

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reduce impacts on pages 3-9.23 and 3.9-24.

The DEIR analyzes impacts visual character or
quality of public views on page 3.9-24 through

3.9-29. It includes policies that would further
reduce impacts on pages 3.9-26 through 3.9-

29. Impact related to light and glare are discussed
on pages 3.9-29 through to page 3.9-31.

Policies to help reduce impacts are listed on
pages 3.9-30 and 3.9-31.

C46-
55 Terrell Watt 3/8/22 All public service and utilities impacts should also be found 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.

See response to comment C9-2.

C46-
56 Terrell Watt 3/8/22 6. The DEIR Fails to Adequate Disclose and Analyze Cumulative Impacts
The DEIR’s discussion of cumulative impacts is
incomplete and inadequate. Conclusions
concerning the disposition of cumulative impacts
are unsupported by facts and evidence. The only
cumulative impact found potentially cumulatively
significant is cultural resources, which brings into
question why the DEIR did not find significant and
unavoidable Proposed Project-related impacts to
cultural resources (Impacts 3.8-1, 2, 3 and 4.

In the responses to comments, please explain this
inconsistency or change the disposition of those
impact to Significant and Unavoidable. Also a
conundrum is how the DEIR finds Proposed
Project-related VMT impacts significant and
unavoidable, but cumulative transportation
impacts less than cumulatively considerable.

A revised DEIR must also include foreseeable
projects including the increased growth locally
and regionally from the RHNA allocations. This
growth is not optional, but required by law to be
planned and zoned for and likely to be required
to be built. The sections reliance on a “summary
of projections” method for considering the
significance of cumulative impacts is simply
The commenters' claim regarding disposition
of cumulative impacts is unsubstantiated. As
noted on DEIR p. "CEQA requires that the EIR
examine cumulative impacts. As discussed in
CEQA Guidelines Section 15130(a)(1), a
cumulative impact “consists of an impact
which is created as a result of the combination
of the project evaluated in the EIR together
with other rejects causing related impacts.”
Furthermore, the analysis of cumulative
impacts need not provide the level of detail
required of the analysis of impacts from the
project itself, but shall “reflect the severity of
the impacts and their likelihood of
occurrence” (CEQA Guidelines
Section15130(b)). In order to assess
cumulative impacts, the EIR must analyze
either a list of past, present, and probable
future projects or a summary of projections
contained in an adopted general plan or
related planning document.

As noted on pages 5-5 and 5-6, the DEIR
analysis evaluates whether the impacts of
development under the Proposed Project,
together with the impacts within the
Cumulative Context, would result in a
cumulatively significant impact. It then

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insufficient and underestimates cumulatively
considerable impacts. If a plan based analysis is
part of the methodology, the revised section
must include a detailed description of the growth
assumed.

Conclusion For all of the above stated reasons, a
revised Project (General Plan and SPSP) must be
prepared that meet legal requirements for such
plans. Based on revisions to the Project
documents, and the comments herein, the DEIR
must also be revised. Both Proposed Project and
DEIR must be recirculated.
considers whether the incremental
contribution of the Proposed Project to this
cumulative impact would be considerable.

Both conditions must apply in order for the
Proposed Project’s cumulative effects to rise
to the level of significance.

Regarding cultural resources, the following
edit is made to clarify the text of the DEIR:
"While individual projects can avoid or
mitigate the direct loss of a specific resource,
the effects could be cumulatively
considerable, and therefore could result in a
cumulatively significant impact. Potentially
cumulative impacts would occur if multiple
sites made accidental discoveries in a short
period of time, which would be rare.

Compliance with federal, state, and local
regulations, including Proposed Plan policies
as described in Impacts 3.8-1, 3.8-2, 3.8-3, and

3.8-4 would not be cumulatively
considerable." This clarification does not
change the findings of the DEIR, which as
noted in on pages 3.8-15, 3.8-19, and 3.8-21,
are less than significant."
The DEIR notes that several analyses
presented in Chapter 3 represent cumulative
analyses of issues over the General Plan time
horizon to 2040 because they combine the
anticipated effects of the Proposed Project
with anticipated effects of regional growth
and development.[For example] Issue areas
for which Chapter 3 analyses that are
specifically cumulative include transportation,
air quality, energy and greenhouse gases, and
noise, because the project-specific effects
cannot reasonably be differentiated from the
broader effects of regional growth and
development.

Cumulative transportation impacts excludes
analysis of VMT; which was found to be a
significant and unavoidable impact as
described on DEIR p. 5-5. The following
clarification is made: "Therefore, the Proposed
Project has less than cumulatively
considerable contribution on transportation.

As noted on p. 5-5, however, impacts to VMT
are by nature cumulatively considerable; thus,
this represents a significant and unavoidable
cumulative impact."
C46-
57 Terrell Watt 3/8/22 Attchment 1 is Terrell Watt's CV No response needed.

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C46-
58 Terrell Watt 3/8/22 8 Review Comments on General Plan designations for Pedro Point Field and Vista Mar
New development within Pacifica is challenging
due to existing physical hazards and
environmental considerations. These limitations
can affect buildout numbers since certain
undeveloped areas may not be suitable for
development. The policy inconsistencies and
deferred actions within the General Plan create
situations where it is questionable how and
where new development can occur and whether
the DEIR can truly state that potential impacts are
less than significant.

There are a couple of highly controversial
locations where these inconsistencies and
deferred actions are examples. They are the Vista
Mar development project off Monterey Road and
the undeveloped open parcel at Pedro Point off
San Pedro Avenue. The Vista Mar project is
located on an undeveloped hillside parcel
designated in the proposed General Plan as
“Open Space/Agriculture/Residential” land use.

The Pedro Point parcel is designated in the
General Plan for “Coastal Residential Mixed Use.”
Pedro Point Field
The Pedro Point field is an undeveloped area
within the Coastal Zone and affected by
inconsistencies with General Plan policies and
Local Coastal Program policies. The site has been
frequently flooded by storm runoff and rise of
San Pedro Creek during storms. It is also
designated within a tsunami evacuation area (See
DEIR Figure 3.5-1 Tsunami Evacuation Area). The
site has been classified by US Fish and Wildlife as
a wetland within their National Wetland
Inventory. Further, as noted in a letter by Dr.

Peter Baye, the site is valuable habitat for special
status species. Tidewater Goby (Eucyclogobius
newberryi), a federally listed endangered species,
is likely present within wetlands of San Pedro
Creek. This has been noted through
environmental DNA sampling reported in an
article by Michael Sutter & Andrew P. Kinziger
published June 2019 in “Conservation Genetics.”
Tidewater Goby normally live in brackish lagoon
backwaters, often near stream mouths, but they
also move upstream into creek pools and
connected ponds at different times. It has also
been reported that Pacific lamprey (Entosphenus
tridentatus) which is a CDFW Species of Special
Concern is present in San Pedro Creek.

On pg 7-4 , the General Plan does recognize the
existence of California Red-legged frog within
See Master Response 3: Buildout for more
information on adequacy, it notes that 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. Please see also Master Response 2:

Programmatic EIR for more information about
program vs. project-level CEQA.

Please see Master Response 6: ESHA and
Master Response 4: Undeveloped San Pedro
Ave site for more information about biological
and geotechnical study requirements on the
site.

In regards to your comment about site
hydrology, 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 Master Response 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-I-17, SA-I-19,
SA-I-20, SA-I-22, SA-I-23, SA-I-25, SA-I-39, SA-I40, SA-I-88, to decrease impact to a less than significant level.

Other issues are related to GP and LCLUP, not
required to be analyzed under CEQA.

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wetlands of San Pedro Creek. The General Plan
also states on pg 4-25 “… Development of the site
will require detailed evaluation of coastal
hazards/vulnerabilities and biological resources
to ensure that any sensitive habitat and wetlands
that may exist on the site are protected…” The
General Plan land use designation for the site is
“Coastal Residential Mixed Use.” This designation
allows up to 15 units per gross acres and nonresidential development may have a floor to area ratio of up to .5 FAR. The total FAR including
residential and non-residential cannot exceed

1.0. This area is just over 4 acres in size and it is
conceivable that 20 units and 17,000 sq. ft of
non-residential use could be
accommodated by this land use designation. Also,
within the “Coastal Residential Mixed Use”
category, the GP says “…Coastal access and public
open space must 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….”
Within the General Plan Land Use policies, there
is a specific policy for this site. It states: “Policies for Specific Sites – LU-I-29 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.” The draft Local Coastal Plan
(pg 5-12) stipulates that any new development in
the Coastal Zone shall assure stability and
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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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. However, the proposed General Plan
states on pg 8-9 that “New development that
would require the use of seawalls or other
shoreline alterations for protection either now or
in the future shall not be permitted unless this
would make the property undevelopable.

The General Plan is inconsistent with the City’s
draft Local Coastal Plan. These documents were
supposedly prepared in conjunction with each
other. The General Plan is proposing to adopt
structural development policies rather than the
LCP policy of maintaining natural processes of
stability and structural integrity.

General Plan Guiding Policy LU-G-8 Changes in
Density or Intensity of Land Use in Coastal
Vulnerability Zones does state: “Do not increase
the density or intensity of land use designations
beyond those indicated in the LCLUP for sites
located within Coastal Vulnerability Zones.” The
GP Safety Element Implementation Policy SA-I-11
Grading and Drainage Plans states:
“Continue to require a grading and drainage plan
for proposed development requiring a coastal
development permit and a grading permit. The
Plan should demonstrate how the project will
maintain natural surface drainage and existing
vegetation to the greatest extent feasible, by
minimizing alteration of natural topography and
removal of existing trees and vegetation;
stabilizing cut-and-fill surfaces with native
vegetation; restricting the movement of heavy
equipment and machinery; and other means.

Driveways and utilities may be allowed in the
case that there is no less environmentally
damaging alternative for providing access to the
building site.”
Again, the General Plan stresses structural
development policies in deference to existing
vegetation and
natural features of a wetland.

General Plan Implementing Policy CO-I-4
Wetlands Preservation states: “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

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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 netloss goal regarding wetlands.” And in its General Plan Implementing Policy LU-I30 Pedro Point Upper Slopes, it states: “Maintain zoning for the upper slopes of Pedro Point to
ensure that any new development is at a density
appropriate to the steep slopes. If any portion of
the property is designated as official habitat for
California red legged frog, a biological resources
survey must be conducted and development will
be required to avoid habitat areas.”
C46-
59 Terrell Watt 3/8/22 The DEIR cites Conservation Element implementing policy CO-I-37 Protection of the
California Red-Legged Frog During Construction
and San Francisco Garter Snake during
Construction states:
“To minimize disturbance, require all grading
activity within 100 feet of aquatic habitat shall be
conducted during the dry season (May 1 and
October 15) to protect California red-legged frog
and San Francisco garter snake. A qualified
biologist shall conduct presence/absence surveys
for California red-legged frog and San Francisco
garter snake prior to construction in or adjacent
to riparian areas, grasslands near
ponds/wetlands, or other sensitive habitat. Any
individuals identified shall be treated in
consultation with USFWS. Construction shall
follow accepted procedures for exclusion and
avoidance of California red-legged frog and San
Francisco garter snake and their habitat.

Additionally, the biologist shall supervise the
installation of exclusion fencing along the
boundaries of the work area, shall conduct
environmental awareness training for
construction workers, and shall be present during
initial vegetation clearing and ground-disturbing
activities.”
As reported by Sutter & Kinzinger, Tidewater
Goby has been reported to exist in the wetlands
of San Pedro Creek. Tidewater Goby has
experienced a reduction in their number within
estuarine sites it inhabits due to coastal
developments, droughts, and exotic species
introductions. Development of San Pedro Field
would add potential contaminant loads from
impervious surface runoff directly to the creek
mouth, where the field ultimately drains.

Whereas, an open field reduces flood peaks by
detaining floodwater and improves water quality
Please see response for C46-24. The DEIR uses
the best and latest available data from
credible government sources. There are no
historic records of the tidewater goby
occurrence in the Planning Area as reported at
the time of survey in the CNDDB. (June 2021).

This site is also currently subject to litigation
regarding the ESHA designation on this site.

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 the potential
impacts to less than significant, regardless of
the final determination of ESHA. Please also
see Master Response 4: Undeveloped San
Pedro Ave Sites.

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by containing runoff sediments.

But, the DEIR states that implementation of the
General Plan would not have a substantial
adverse effect, either directly or through habitat
modifications, on candidate, sensitive, or special
status species identified in local or regional plans,
policies, or regulations, or by the California
Department of Fish and Wildlife or U.S. Fish and
Wildlife Service. It goes on further to state (pg E71) -5 “Implementation of Proposed Project would not conflict with local policies or
ordinances protecting biological resources, such
as a tree preservation policy or ordinance.”
It is unclear with these policies whether the
Pedro Point Field can be developed and protect
its wetland and sensitive species downstream.

The inconsistencies and policies that allow
development with deferred studies make it
unclear what level of development may occur at
the Pedro Point Field. Is it a “Mixed Use
Residential” development or Wetland
Preservation? It is not clear what takes
precedence here. Is it to protect wetlands and
endangered species or to give preference to
allow development? The conflicting policies and
inconsistencies between different plans and
policies of the Local Coastal Plan and the General
Plan make it difficult to determine buildout, and
resulting environmental impacts both at this site
and overall within the city.

C46-
60 Terrell Watt 3/8/22 Vista Mar The Vista Mar project is located on steep slopes largely greater than 35% with a
substantial number of existing trees and
shrubbery and potential biological resources
including possible habitat for Mission Blue
Butterfly. The site has been reported to have
several existing landslides but is shown in Fig 8-3
of the General Plan as within “Few Landslides”
area. The site drains in a southwesterly direction
toward a channel that connects to the Big Inch
Creek waterway. This channel has seen significant
recent downstream channel downcutting and
bank erosion.

On this 1.2 acre parcel with all these hazards and
constraints, the General Plan designation of
“Open Space/Agriculture/Residential” would
allow residential development at a density of 0.2
units/acre. Any residential development on such
a parcel would require massive earth moving,
vegetation removal, structural walls and
additional development of impervious surfaces
for road and driveway that would increase
The site in question is within a Zone of
Required Investigation, shown in Figure 3.6-1.

Please see response to comment C49-19 for
more information on geotechnical
investigation requirements for these zones as
mandated by the state.

Runoff and erosion are addressed in DEIR
Impact 3.5-3. Project applicants would be
required to include site design and source
control stormwater measures into project
plans. Further, new development would be
required to adhere to the City’s stormwater
guidelines, which are part of the regional MS4
NPDES permit requirements, and select and
design the stormwater solutions onsite to
control the stormwater volume.

Chapter 18 of the CBC covers the
requirements of geotechnical investigations
(Section 1803), excavation, grading, and fills
(Section 1804), load-bearing of soils (1806), as
well as foundations (Section 1808), shallow

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downstream runoff.

The overall land Use designation of “Open
Space/Agriculture/Residential” within the city has
been calculated in the DEIR for 40 additional units
(Table 2.4.2, pg2-22). Also, within this land use
designation, density calculations for Farm Worker
housing in agriculture zones are not required.

There is a significant a loop hole within the GP
Safety Element: SA I-2 Development in Hazardous
Areas implementation policy. It states: “Prohibit
development in areas of mostly landslides or high
or very high liquefaction risk as shown in Figure
8-2, or on slopes steeper than 35 percent, unless
detailed site investigations ensure that risks can
be reduced to acceptable levels and the structure
will be protected for its design life.” This loophole
enables major structural construction to be
permitted to allow development. Such structural
development and associated grading would be
inconsistent with policies that require protection
of important natural landscapes and their
resources. Safety Element policy SA-I-8 also
requires geotechnical site investigation for slopes
greater than 15% to identify net developable
areas.Again, this opens up steep hillside areas for
further development.

The site is also within a “Hillside Preservation
District.” However, the GP Land Use
Implementation Policy LU-I-14 says that the
Hillside Preservation District and Zoning Map be
updated to ensure that all steep and sensitive
terrain is subject to these regulations. .It’s
unclear whether an update to the Hillside
Preservation District would change the
development potential for such an area. Further,
the GP Safety Element Implementation Policy SAI-4 seeks to provide provision to form “Geologic Hazard Abatement Districts “(GHAD). These are
not in place, and formation and funding are
unknown. Similarly, GP Conservation Element
Policy, CO-I-3 seeks to “Establish funding
mechanism to require property owners with land
adjacent to creeks to pay proportionate share of
creek improvement maintenance.”
Downstream erosion and downcutting is a key
concern for residents within this area. It is
unclear how and when a “funding mechanism” is
to be established. New developments in the
hillsides above should be restricted to ensure
runoff is completely captured on site or
downstream capacity improvements are part of
foundations (Section 1809), and deep
foundations (Section 1810). Per Section
1603.1.6, construction documents must show
the design load-bearing values of soils.

Chapter 18 also describes analysis of
expansive soils and the determination of the
depth to groundwater table. For Seismic
Design Category C, Chapter 18 requires
analysis of slope instability, liquefaction, and
surface rupture attributable to faulting or
lateral spreading. For Seismic Design
Categories D, E, and F, Chapter 18 requires
these same analyses plus an evaluation of
lateral pressures on foundation walls and
retaining walls, liquefaction and soil strength
loss, and lateral movement or reduction in
foundation soil-bearing capacity. It also
requires mitigation measures to be considered
in structural design. Mitigation measures may
include ground stabilization, selection of
appropriate foundation type and depths,
selection of appropriate structural systems to
accommodate anticipated displacements, or
any combination of these measures. The
potential for liquefaction and soil strength loss
must be evaluated for site-specific peak
ground acceleration magnitudes and source
characteristics consistent with the design
earthquake ground motions. Chapter 18
requires site-specific geohazard reports for all
proposed construction evaluating known
faults, geology, soil conditions, and groundmotion parameters as specified in CBC Section 1613 and ASCE 7. Finally, Appendix J of the
CBC regulates grading activities, including
drainage and erosion control and construction
on unstable soils.

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the developments.

The possible extent and location of new
development within these areas by the deferred
actions of these policies make it questionable
whether the DEIR can authoritatively state that
the implementation of the General Plan would
not result in substantial adverse physical impacts.

C46-
61 Terrell Watt 3/8/22 Summary:

The General Plan policy inconsistencies,
loopholes and deferred actions enable future
development to occur by structural means or
undefined compensatory actions in areas with
hazardous conditions or environmental
sensitivity. These deficiencies could enable
development to occur in locations that could be
questionable in an environmental review. The
DEIR does not account for potential development
within these areas or calculate the actual size,
quantity or locations to fully determine
environmental impacts. Without these
considerations, the EIR is flawed and needs to be
revised and recirculated.

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 2: Programmatic EIR for
more information.

Please also see Master Response 3: Buildout
and RHNA for more information about
adequacy of buildout projections.

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C46-
62 Terrell Watt 3/8/22 9. Review Comment regarding Fire and Hazard Issues in the DEIR: The Land Use Element of the
General Plan enables new development in
locations that have been considered to have
hazardous conditions such as landslides, coastal
erosion, or fire hazards. The DEIR states that the
policies of the General Plan regarding fire and
other hazardous conditions within Pacifica will be
less than significant. However, many polices have
deferred actions or are inconsistent with other
policy documents such as the LCP or the Multi
Jurisdictional Local Hazard Mitigation Plan of San
Mateo County. If these deferred actions and
inconsistencies are not resolved prior to adoption
of the General Plan, these impacts cannot be
considered less than significant.

The General Plan states (pgs 8-37 and 38) “A
2008 study determined that the Vallemar, West
and East Fairway Park, Rockaway Beach, and
Rockaway neighborhoods in central Pacifica are
beyond fourminute travel distance from northern
San Mateo County fire stations, corresponding
with the standard response time for first-due fire
apparatus. The full assignment response time
standard cannot be met in Pacifica from Vallemar
south.”
General Plan Policy SA-I-107 Local Hazard
Mitigation Plan. Continue to maintain and update
a Local Hazard Mitigation Plan as an
implementation action for the Safety Element.

The following Table is extracted from the Local
Hazard Mitigation Action Plan (pg 14-15) DEIR
states (pg E-100) Impact 3.11-7 Implementation
of the Proposed Project would not expose people
or structures, either directly or indirectly, to a
significant risk of loss, injury or death involving
wildland fires. Impact is “Less than Significant”
due to the following policies: GP Safety Element -
SA-G-8 Fire Prevention. Protect Pacifica residents
and businesses from potential wildland fire
hazards.

GP Safety Element - SA-I-94 Development
Review. Continue to review development
proposals to ensure that they incorporate
appropriate fire-mitigation measures, including
adequate provisions for evacuation and access by
emergency responders. GP Safety Element - SA-I98 Vegetation Management. Promote and support the North County Fire Authority’s
Vegetation Management Program to reduce
urban/wildland interface fire hazards. DEIR states
(pg E-101-102) Impacts 3.12-1 Implementation of
The comment letter does not provide
examples of inconsistencies with the LCP or
MJ-LHMP. As noted 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." As
described on DEIR p. 3.5-17, "All goals and
policies in the adopted MJ-LHMP are
applicable to the Proposed Project." The table
in the MJ-LHMP does not demonstrate an
inconsistency; it reinforces the integration of
the General Plan and LHMP.

CEQA requires analysis of whether a plan
triggers the need for new or expanded public
facilities, the construction of which could
result in significant environmental impacts.

As noted, a new station may be needed to
address new development in areas such as the
Quarry site. The City has not determined that
a new station will be built; and no funding has
been allocated. Thus, development of a new
fire station is not reasonably foreseeable, and
a specific location not determined at this time.

Buildout of the plan will happen incrementally
over the next 20 years. The City and NCFA will
commit to monitoring the situation and
explore solutions to ensure adequate
emergency response, such as pre-positioning a
fire apparatus; mutual aid and adequate
staffing; or potentially building a new station,
which would be subject to CEQA requirements
at the time of proposal. As noted on the DEIR
p. 3.12-28, "The Proposed Project supports
consideration of this and other options to
ensure adequate fire protection services
throughout the city...neither the single new
NCFA facility under discussion nor any facilities
enhancement or sharing programs that may
be considered as solutions will substantially
increase the area of developed land in
Pacifica. Moreover, any construction activity
would require additional environmental
review and compliance with City standards
and best management practices (BMPs)."
An overarching programmatic framework
addresses emergency access through local and
regional regulations and proposed General
Plan policies, in addition to policies related to
evacuation planning at the project level. As
noted in Impact 3.2-4, project-level review by

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the Proposed Project would not result in
substantial adverse physical impacts associated
with the provision of new or physically altered
governmental facilities, need for new or
physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or other
performance objectives for fire protection, police
protection, schools, parks, or other public
facilities.

Impact is “Less that Significant” due to the
following policies:

GP Safety Element - SA-I-91 Response Time.

Support efforts by North County Fire Authority to
meet its response time standards throughout the
City. This effort may include construction of a
third fire station in the central part of Pacifica,
near the police station or the Quarry site. The
City could provide land or shared facilities. GP
Safety Element - SA-I-100 Rockaway Quarry
service. Ensure that any new development at the
Rockaway Quarry site is adequately served by
public infrastructure, including fire and police
services.

GP Safety Element - SA-I-103 Emergency Access
on New Roadways. Ensure that new roadways are
developed in accordance with standards the
Municipal Code. In all new development, require
adequate access to be provided for emergency
vehicles, including adequate widths, turning radii,
hard standing areas, and vertical clearance. GP
Safety Element - SA-I-104 Areas that Lack
Emergency Access. Develop a plan to widen
critical rights-of-way that do not provide
adequate clearance for emergency vehicles. For
areas that are not feasibly accessible to
emergency vehicles, develop a contingency plan
for reaching and evacuating people in need of
treatment. This initiative should include a plan to
open access to or otherwise serve the Pedro
Point, Fassler/Rockaway, and the Vallemar
neighborhoods.

GP Land Use Element - LU-I-13 Public Service
Priorities. Ensure that existing and planned public
works facilities accommodate needs generated
by development or uses permitted over the
planning period. 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
the City includes site access review for
emergency vehicle sand traffic control plans as
needed that account for emergency vehicles.

Potential improvements to the roadway
network (policies described on DEIR p. 3.2-46),
traffic signal preemption devices, additional
access routes (Ci-I-26, SA-I-94, SA-I-103, SA-I104), community evacuation education (SA-I35), and agency coordination (SA-I-102) and ensure inadequate emergency access does not
occur. The impact remains less than
significant. Given the existing framework
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-thansignificant impact. Please see Master Response 7: Emergency Access for more
information.

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economic health of the region, state, or nation,
public recreation, commercial recreation, and
visitor-serving land uses shall not be precluded by
other development. GP Land Use Element - LU-I14 Hillside Preservation. Update the Hillside Preservation District and the zoning map to
ensure that all steep and sensitive terrain is
subject to these regulations. The Hillside
Preservation map (Figure 4-4 of the proposed
General Plan) should be used as a guide.

Summary: All the issues and policies above
illustrate that the General Plan and EIR are
inconsistent and/or defer actions that would
mitigate the potential impacts. The General Plan
itself states that fire response times are not up to
standards. These cannot be stated as less than
significant. It would be appropriate that
hazardous areas have an overlay that would
preclude development until these deferred
actions and inconsistencies are resolved and in
place.

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C47: Cindy Abbott, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C47-1 Cindy Abbott 3/8/22 Additionally, though a municipality can adopt a General Plan without an approved/updated
Local Coastal Plan, I must put right up front a
question as to why this is being done in our
coastal community. Please address why the
City of Pacifica hasn’t completed work with
the California Coastal Commission to move
forward a responsible coastal program that
addresses the climate crisis that has already
significantly impacted infrastructure and
where the impact of coastal erosion and
future sea level rise must be accounted for.

The result of the process being followed is a
waste of time and resources as the draft plans
(GP, SPSP, DEIR) must be consistent with an
aged LCP that doesn’t reflect current
circumstances.

Please see response to comment C30-8.

C47-2 Cindy Abbott 3/8/22 Please provide a comprehensive chart that details by property current and proposed land
use designation changes. (The current colorcoded maps are inadequate.) This is necessary for a thorough review of the impact of
development proposals and consistency with
the policies in the draft General Plan.

The comment is noted. Please see Master
Response 2: Programmatic EIR for more
information on the adequacy of identifying
potential impacts at the citywide level.

C47-3 Cindy Abbott 3/8/22 Please provide how the City is preparing for emergency response in light of the naturally
occurring and accelerating coastal erosion
that Pacifica had endured since the 1980’s
and does more than continue the destructive
practice of armoring that impacts our precious
coastal resources; flooding that has continued
to plague coastal and creek areas; the growing
impact of fire hazards particularly at Wildland
Urban Interface areas and risks in canyons
that other communities have experienced.

While it had been hoped that the Multijurisdiction Hazard Mitigation Plan would have provided this roadmap, it doesn’t. And,
maps and documentation in the DEIR are
outdated and lacking full information and
disclosure. Please consider the creation and
implementation of a Hazard Overlay District
with clear details as to what development will
be allowable in those areas.

The DEIR addresses coastal erosion on DEIR p.

3.6-14 and 3.6-17. This same information is
found in Pacifica's 2018 Sea Level Rise
Vulnerability Study, which represents the best
available information at time of publication of
the NOP. Please see response to comment C49-
11 and C49-12 for more information on the
updated methodology used in the study. As
noted on DEIR p. 3.6-31, The proposed General
Plan shares policies with the LCP, including
policies SA I-28 and SA-I-29, which commit to
mapping areas vulnerable to coastal erosion and
other coastal hazards on a regular basis, and to
implementing a Sea Level Rise Adaptation Plan
to safeguard against coastal hazards, including
coastal erosion. Policy SA-I-41 sets the goal of
restoring regional beach sediment while
minimizing coastal erosion. Policies under
impact 3.6-2 require site-specific analysis, siting
and design, and compliance with provisions in
the California Coastal Zone reduce the impacts
to less than significant. Impacts of coastal
armoring are not required topics of analysis
under CEQA.

Flooding is adequately characterized in Ch 3.5.

Figure 3.5-1 was created based on National
Flood Hazard Layer for San Mateo County
mapped by the Federal Emergency

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Management Agency (FEMA). This represents
the latest and best available data for floodplain
mapping. Patterns of localized flooding are also
described in the text; for example, 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.’ As noted on
DEIR p. 3.5-31, should any developments be
proposed in an area within the 100-year flood
zone, they would be required to meet local,
state and federal flood control design
requirements. In addition, many ongoing
improvements to flood protection infrastructure
by the U.S. Army Corps of Engineers and the
City's Flood Control Committee, for example, to
areas of San Pedro Creek and the Sharp Golf
Course, should help to minimize areas subject to
flooding. Coupled with policies in the General
Plan that include floodplain management (SA-I17), flood hazard reduction (including compliance with the Flood Damage Prevention
Ordinance (SA-I-20)), flood control structures
and maintenance (SA-I-22 and SA-I-23),
shoreline change monitoring (SA-I-30),
vulnerability mapping (SA-I-28), the impacts are
less than significant.

Adequacy of analysis of wildfire is described in
Master Response 5: Wildfire. As noted, it uses
the latest and best available data from CALFIRE.

The MJ-LHMP includes significant information
on hazard event history and actions to address
hazards in Pacifica. Actions are applicable to the
Planning Area.

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.

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determine the level of review needed, and the
scope of that analysis will depend on the
specifics of the particular project. These projects
may, however, use the discussion of impacts in
this EIR as a basis of their assessment of these
regional, citywide, or cumulative impacts.

Please see response to comment C30-5 and
Master Response 2: Programmatic EIR for more
information on project-specific CEQA analysis.

C47-4 Cindy Abbott 3/8/22 My area of focus for many years has been on the development of the Sharp Park Specific
Plan area.The West Sharp Park area is a highly
constrained network of small one-way streets,
is designated as a historic area by the City of
Pacifica, is increasingly vulnerable due to the
climate crisis with increased storm activity
and future sea level rise, and has been noted
for decades (including in the 1980 general
plan) to have a lack of parking capacity. The
area under study for the Sharp Park Specific
Plan represents less than 3% of the buildable
land in the City of Pacifica. To place most of
the City’s aspiration for economic and housing
growth – that does not reflect a required
focus on coastal access and coastal serving
development, preservation of community
character, and has the potential for placing
low income individuals in harms way -- in this
limited area is a significant concern. I’m
shocked by the remarks in the DEIR that the
implementation of the SPSP will have “less
than significant impact”.

The comment is noted. As the DEIR describes,
"[the Sharp Park area] has been designated a
“Priority Development Area” by the
Metropolitan Transportation Commission and
the Association of Bay Area Governments due to
its potential to support new housing and
employment near transit." Impacts due to
coastal flooding are described in Chapter 3.5.

Please also see Master Response 2:

Programmatic EIR.

C47-5 Cindy Abbott 3/8/22 Please address:

1. The current DEIR does not adequately
address the potential impacts of proposed
height increases in West Sharp Park with
regard to visual character of the surrounding
area and/or public views to and from the
ocean. Images provided have largely focused
on Palmetto Avenue alone, without regard or
illumination of the impact to the residential
neighborhood. Please thoroughly document
the CEQA analysis undertaken (as also
requested by the California Coastal
Commission in correspondence dated July 16,
2020 and September 9, 2020) to justify the
“less than significant impact” statement.

Please see response to comment C77-10.

C47-6 Cindy Abbott 3/8/22 2. Please provide the analysis and detail specifics regarding policies that support the
statement (3.9-25) that there is less than
significant impact in Sharp Park, when the
policies propose significant changes in land
use and design and that the proposed project
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

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will “ensure the harmony with the scale and
character of the existing neighborhoods.”
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, 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.

C47-7 Cindy Abbott 3/8/22 3. Please describe how West Sharp Park will be the city’s “cultural core”. (CD-I-1) when
cultural amenities are provided throughout
the city and other than the proposed new
library, no other policies are focused on
“culture” (a pocket park at the re-visioned
Civic Center and already existing scenic views
and promenade don’t constitute this
becoming the “cultural center”).

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.

C47-8 Cindy Abbott 3/8/22 4. How can Sharp Park’s historic character be “signaled by higher-intensity buildings along
the Highway 1 corridor, including Eureka
Square”? (3.9-27)
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.

C47-9 Cindy Abbott 3/8/22 5. Please provide the analysis and visualizations that support 5-1-6 View
Corridor Preservation; 5-I-67 Coastal View
Preservation; and DS-1 East-West Corridor
Stepbacks as policies that will minimize the
impact of the Proposed Project in West Sharp
Park.

The DEIR analyzes scenic vistas on page 3.9-14
through 3.9-22. Figures 3.9-4 through 3.9-9 in
the DEIR show that by implementing 5-I-66, 5-I67, DS-1 and DS-2 policies in relation to setbacks/stepbacks along with additional design
standards/guidelines specified in the SPSP, the
impacts would be further reduced from an
already less than significant level.

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C47-10 Cindy Abbott 3/8/22 6. Please describe how new development in the coastal zone along Palmetto Avenue will
be habitable for 100 years when the proposed
(unapproved and unfunded) sea wall has only
a 50-year life.

Issues related to coastal protection are
addressed in the LCLUP. The LCLUP is not
included for analysis under CEQA.

C47-11 Cindy Abbott 3/8/22 7. How were environmental risks related to coastal erosion and sea level rise evaluated
and incorporated into the DEIR when current
detailed maps regarding these long-standing,
ongoing and currently unstoppable hazards
are not included in the planning documents?
Please see response to comment C49-11.

C47-12 Cindy Abbott 3/8/22 8. What policies address resiliency of existing and new development in the West Sharp Park
area such as a plausible future need to elevate
structures and move away from the
shoreline?
Resiliency policies and triggers are addressed in
the LCLUP, which is not analyzed in this DEIR.

This DEIR does addresses flooding hazards and
includes policies for properties in a FEMA
floodplain including beneficial policies shared in
hte LCLUP. please see response to comment
C13-3. As noted on DEI p. 3.6-31, the proposed
General Plan shares policies with the LCP,
including policies SA I-28 and SA-I-29, which
commit to mapping areas vulnerable to coastal
erosion and other coastal hazards on a regular
basis, and to implementing a Sea Level Rise
Adaptation Plan to safeguard against coastal
hazards, including coastal erosion. Policy SA-I-41
sets the goal of restoring regional beach
sediment while minimizing coastal erosion.

Policies under impact 3.6-2 require site-specific
analysis, siting and design, and compliance with
provisions in the California Coastal Zone reduce
the impacts to less than significant. Impacts of
coastal armoring are not required topics of
analysis under CEQA.

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C48: Paul Tota, 2/25/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C48-1 Paul Totah 2/25/2
2 C-163 is latest version of this email - comments are marked in that version
Please see comment
responses to letter C-163.

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C49: Christine Boles, 2/28/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C49-1 Christine
Boles
2/8/22 1. Page 3.6 second paragraph refers to
a 2018 Sea Level Rise Vulnerability
Assessment. I believe this is in
reference to ESA’s DRAFT Assessment.

Please confirm and provide the
reference to that document in the
footnotes. The document and link
should also be added to the DEIR
bibliography.

This comment is noted. A clarification is thereby added to footnotes and bibliography. This clarification does not change any findings of significance.

C49-2 Christine
Boles
2/8/22 2. In the discussion of the various
active faults, information about
probability of a magnitude 6.7 or
greater earthquake is included in most
listings. It is missing in the description
of the San Andreas fault on page 3.6-
3, which is the only fault that bisects
Pacifica. This USGS document
indicates the risk on this fault is 22%.

Please update the DEIR accordingly.
https://pubs.usgs.gov/fs/2016/3020/f
s20163020.pdf
The following change is thereby made: "In the San Francisco Bay Area, the San Andreas Fault Zone was the source of the two recent major seismic events that affected the San
Francisco Bay region. The 1906 San Francisco earthquake was estimated at magnitude (M) 7.9 and resulted in
approximately 290 miles of surface fault rupture, the longest of any known continental strike slip fault. Horizontal
displacement along the fault approached 17 feet near the epicenter. The more recent 1989 Loma Prieta earthquake, with a moment magnitude (Mw) of 6.9, resulted in
widespread damage throughout the Bay Area. The USGS
Working Group on California Earthquake Probabilities
indicates there is a 22 percent likelihood of the San Andreas Fault generating earthquakes of M 6.7 or greater in the Bay Area."
C49-3 Christine
Boles
2/8/22 3. Page 3.6-5 References 2008
Quaternary fault and fold databases.

This source is out of date. Current data
from the USGS appears to be from
2014. Please confirm and update
source and link accordingly.
https://www.usgs.gov/programs/eart
hquake-hazards/faults
The response is noted; the reference is thereby corrected:

USGS and CGS. Quaternary fault and fold database for the United States, from USGS web site:
https://www.usgs.gov/natural-hazards/earthquakehazards/faults,accessed September 10, 2008. June 2021. The date of the San Gregorio fault zone record remains the same and thus does not change any findings of significance.

C49-4 Christine
Boles
2/8/22 4. Page 3.6-7 The 2013 source for the
Severity of an Earthquake is no longer
current. Please confirm best available
data and update source material and
link.

The reference refers to date of access. The information is from a widely known, publicly available USGS publication, "The Severity of an Earthquake", 1989:
https://pubs.usgs.gov/gip/earthq4/severitygip.html It
remains the authoritative source on earthquake intensity description. The date of reference is thereby updated to June 2021. The reference is thereby updated on DEIR p. 3.6-7 as follows: "USGS. The Severity of an Earthquake,
http://pubs.usgs.gov/gip/earthq4/severitygip.html, January 11, 2013 Accessed June 2021."
C49-5 Christine
Boles
2/8/22 5. Page 3.6-8 discusses seismic hazard
zones and liquefaction and refers to
new 2021 Department of
Conservation mapping of these risks.

The links to this online information are
missing, please add them to the
footnotes and bibliography. They can
be found at
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 1: EIR Comments for more information about GP- or SPSP-related responses.

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C49-6 Christine
Boles
2/8/22 6. Under Seismic Hazard Zones on
page 3.6-8 the DEIR says “The City is
required to use the official California
Geological Survey Seismic Hazard Zone
Maps in their land use planning and
building permit processes.”
Figure 3.6-1: Seismic Hazard Zones
appears to be taken from the website
link I provided above. It is important
to understand that not all information
is clearly shown at the scale shown in
this figure in the DEIR and General
Plan. For example, the figure has blue
and green coding for landslide OR
liquefaction zones. If you actually
zoom in (which you can do online
down to parcel level) you will see
another color, orange, for areas that
are subject to BOTH liquefaction and
landslide risk. See screenshot below of
Pacifica’s southern border area for
example. The link should be added to
the figure along with notation that the
website should be used to understand
both regional area and property level
risks. The Department of Conservation
legend indicates other colors too that
should be reflected, including gray for
areas that have not been mapped.

I would expect to see specific policies
and mitigation measures to address
the necessary use of these maps in the
General Plan. Please clarify if and
where these policies are written, and
if they are not written, please add
them accordingly. If the City does not
feel they are justified, please provide a
detailed reasoning for the omission.

This comment is noted. Please see Master Response 1 for more information on how General Plan-related comments
will be addressed.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 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 AlquistPriolo Earthquake Fault Zone Act and other relevant state laws. (See the Seismic Hazards map, Figure 8-1). "
C49-7 Christine
Boles
2/8/22 7. There are discrepancies between
maps 3-6.1 and 3-6.2 in terms of
liquefaction areas. Clarify how you
would use one map versus the other.

Consider eliminating liquefaction on
one map to avoid conflicting data.

Figure 3-6.1 shows liquefaction zones where geotechnical analysis is required as part of the Seismic Hazards Mapping Act, as described on p. 3-16-18. Figure 3.6-2 shows varying levels of liquefaction potential in areas that may also be Seismic Hazard Zones. While all development in Seismic
Hazard Zone area requires geotechnical analysis, policy SA-I-2 prohibits development in areas of very high or high
liquefaction risks shown in Figure 3.6-2 unless detailed site investigations ensure that risks can be reduced to acceptable levels and the structure will be protected for its design life.

C49-8 Christine
Boles
2/8/22 8. Figure 3.6-3 uses USGS Open File
Report 97-745, as source material
which dates from 1997. Going to the
website link in footnote 15 clearly
shows that data has been updated
The date of update is noted; the 1997 year refers to the year of folio release. However, the year will be thereby amended to reflect the update on DEIR p. 3.6-13 as follows: "USGS.

Open File Report 97-745, San Francisco Bay Landslide Folio, http://pubs.usgs.gov/of/1997/of97-745/, 1997. Updated

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Packet Pg. 990 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 326
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Individuals (C)
since that date. Please confirm and
update best available data sources in
this document, the general plan, and
in the bibliography, and update map
accordingly. I also refer you to my
daughter, Elisabeth Boles’ letter2 to
you dated November 23, 2020
regarding the inaccuracies in this
figure 3.6-3 map from the 2014 draft
General Plan. Those inaccuracies
continue to be reflected in the current
map in the DEIR and draft General
Plan. I have attached the letter for
reference and copied her annotated
map below.
1999."This data is used in ABAG's Hazard Viewer (available at https://abag.ca.gov/our-work/resilience/dataresearch/landslide) and thus represents a relevant data source despite its age. Additionally, this data is intended to supplement the 2021 Seismic Hazards Zone mapping from the Department of Conservation, which represents the latest and best available data. Comments received outside of the
comment period as attachments are not required to be
addressed in FEIR response.

C49-9 Christine
Boles
2/8/22 9. I see that this figure 3.6-3 has been
updated in the current DEIR, and yet it
still references outdated data from the
Pacific Institute 2009 (what is the
actual document reference?) and
FEMA revised DFIRM 2011(I cannot
find reference to this document on the
current FEMA website), and USGS
1998. Please confirm and update the
sources and map accordingly. Please
clarify what policies and mitigation
measures need to be revised based on
new current data.

The 2018 Sea Level Rise Vulnerability Assessment erosion projections use an updated methodology based on the 2009 Pacific Institute report and represent the latest and best available information for Pacifica. Reference to the 2011 DFIRM is erroneous and will be removed from sources. 1998 represents the latest update of this USGS dataset.

The latest landslide inventory efforts were conducted as part of the Department of Conservation's 2021 Seismic Hazards Zones map. Please see response to comment C63-1 for more information.

C49-
10 Christine
Boles
2/8/22 10. This figure 3.6-3 now shows a red
line for critical coastal erosion, but
right next to the red line, is colored
white “not landslide prone”. This is
misleading in that coastal erosion can
take out tens of feet of bluff in one
rainy winter alone, as was
demonstrated as recently as 2016. The
2018 ESA Sea Level Rise Vulnerability
maps should be refenced and used to
map likelihood of bluff erosion in the
next 100 years. For example,
Esplanade Avenue, where Pacifica has
already lost a row of single family
homes and several apartment
buildings to coastal erosion as late as
2016, is shown in the current map as
mostly white, “not landslide prone”.

The ESA map tells a very different
story, with projected bluff erosion
bounded by a very different red line
expanding inland far past Esplanade
Avenue, even threatening Highway 1
in the next 100 years. Policy 1 on page

3.6-22 (should this not have a proper
policy identification number to
Landslide mapping in Figure 3.6-3 includes the following category: "Not Landslide Prone refers to areas of gentle slope at low elevation that have little or no potential for the formation of slumps, translational slides, or earth flow except along stream banks and terrace margins; defined by the
distribution of surficial deposits." The bluffs along Esplanade Avenue represent terrace margins. As such, the mapping
characterization remains correct. The DEIR sufficiently describes coastal erosion per the 2009 Pacific Institute study, the data source used in the 2018 Sea Level Rise Vulnerability Assessment.

Policy 1 refers to the existing 1980 General Plan policy, which would regulate development until the Proposed Plan is
implemented and the LCLUP certified by the Coastal
Commission. All development in the Coastal Zone would be subject to Coastal Commission permitting.

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reference to the General Plan?)
specifically requires development to
be designed to withstand a 100-year
hazard event, this is critical
information missing in the DEIR and
Safety Element in regard to slope
failure projections for coastal erosion
which is necessary to be able to avoid
and mitigate these hazardous areas.

C49-
11 Christine
Boles
2/8/22 11. Page 3.6-17 discusses the effects
of sea level rise on erosion, but quotes
a Pacific Institute study from 2009.

Again, this is old data. The text copied
below notes dune erosion of 115-116
meters by 2025. Certainly this is an
error, or we would lose all of Pacifica
State Beach in Linda Mar in 3 years’
time!
Please confirm source of current best
available data and actual projected
coastal bluff and dune erosion rates
and update DEIR and General Plan
accordingly along with policy
recommendations and mitigation
measures. This is particularly critical
for the proposed Sharp Park Specific
Plan (SPSP). I cannot in good faith
review the SPSP or other proposed
planning and land use changes in the
Coastal Zone without this updated
information. Please update data, maps
and policies as necessary clearly
identify changes in response.

As noted in the 2018 Sea Level Rise Vulnerability Assessment, in order to maintain consistency with the Sea Change SMC study, coastal erosion hazard maps used in Pacifica's
Vulnerability Assessment, which utilizes an updated
methodology from the 2009 report that includes accelerated erosion in response to SLR, projections of future beach widths, and modifications for a range of potential adaptation alternatives including allow erosion (do nothing), beach nourishment, beach nourishment with reef, armor, and
hybrid approaches. Thus, coastal erosion data represents the best publicly available data for the City. The Vulnerability Assessment used the best available science, or most recent peer-reviewed science reasonably validated by qualified experts in the scientific community, to determine the
potential exposure of assets to flooding and erosion hazards under sea level rise scenarios selected for study. The
following clarification is thereby made:
"Bluffs, meanwhile, are projected to have eroded by 8m to 9m by 2025, 23m to 24m by 2050, and 58m to 64m by 2100, with geology, wave exposure, and bluff toe elevation all playing important roles in producing variation. The City of Pacifica's 2018 Vulnerability Assessment utilizes an updated methodology originally developed for the Pacific Institute Study and include accelerated erosion in response to SLR, projections of future beach widths, and modifications for a range of potential adaptation alternatives."
C49-
12 Christine
Boles
2/8/22 12. In fact, coastal erosion threatens
much of Pacifica from this north
border all the way to our southern
border at Pedro Point and Shelter
Cove. Coastal erosion is already an
issue limiting development with
projects recently approved in Pacifica
by the Planning Commission and City
Council, and subsequently overturned
or modified by the Coastal
Commission, such at 1567 Beach
Boulevard in Sharp Park and 1300
Danmann in Pedro Point. The current
project being reviewed by the
planning department for 4000
Palmetto, “the Bowl” has recently
issued a plan showing access after
Palmetto, the main north south artery
connecting the city blocked because of
Please see response to comment C69-8 and C110-2 for more information on where the DEIR addresses coastal erosion, and how compliance with federal, state, and local regulations and Proposed Plan policies reduce impacts to less than significant.

The USGS Central California CoSMoS v3.1 projections of
coastal cliff retreat map provided by the commenter does not have the benefit of the updated methodology used in
Pacifica's Vulnerability Assessment, which utilizes a
methodology that includes accelerated erosion in response to SLR, projections of future beach widths, and modifications for a range of potential adaptation alternatives including allow erosion (do nothing), beach nourishment, beach nourishment with reef, armor, and hybrid approaches. Thus, coastal
erosion data represents the best publicly available data for the City.

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projected erosion.

The current DEIR and draft General
Plan however, fail to analyze these
risks and provide any policy guidelines
towards maintaining access to critical
roads and infrastructure that connect
the city. See for example this section
of the DEIR from Chapter 3.2.

Another helpful map to reference
would be the USGS Central California
CoSMoS v3.1 projections of coastal
cliff retreat due to 21st century sea-
level rise which shows bluff
projections under various sea level
rise scenarios.
https://data.doi.gov/dataset/central-
california-cosmos-v3-1-projections-of-
coastal-cliff-retreat-due-to-
21stcentury- sea-
lev?fbclid=IwAR3KFjO3KtPSCGv3mz3x
yX43uXtL26bZZpk6znHXJA5hrXD7s7-
myKktQi4 This kind of information
would actually allow us time to
consider larger adaptation scenarios,
including relocation of major arterial
roads and utility infrastructure. This is
the kind of vulnerability assessment
and adaptation planning I understand
is required under SB379. Please clarify
why the DEIR and General Plan neglect
to include any of this information,
analysis and resilience planning.

According to the San Francisco
Chronicle January 29, 2016 article,
entitled Perilous Cliffhangers of
Pacifica Tell a Cautionary Tale,
“Erosion has increased by roughly 50
percent along the coast of Pacifica
since the 1970s, mainly as a result of
several El Niño winters that pounded
the sandy shore, according to
geologists. Scientists believe such
storms will be more frequent in the
future.”
I am aware that the City of Pacifica is
embarking on major civil engineering
studies and projects to shore the coast
to buy us some time, but as these
projects are not fully designed nor
funded, nor have environmental
impacts reports even been started, we
must simultaneously plan for
adaptation. It is also important to note

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that Pacifica’s sea wall consultant,
GHD, said that the design life of the
proposed sea wall for Sharp Park is 50
years. It will not solve our problems of
sea level rise and coastal erosion, only
“buy us time”, the lead engineer
Gillian said. Time for what? Please
clarify the city’s long-term plan for
coastal resilience and adaptation for
the entire coastline.

C49-
13 Christine
Boles
2/8/22 13. Page 3.6.17 under Shoreline
Protections Programs discusses the
work in 2002 for the removal of
homes and rebuilding of dunes at
Pacifica State Beach. It neglects to
discuss the later work to purchase
properties and create a long ago
completed shoreline park on
Esplanade, or proposed park projects
where the apartments were torn
down in 2016 around 310 Esplanade.

Please update DEIR with all current
and relevant information to properly
understand our past, current and
future hazards. There are several
buildings on the cliff edge now that
have been red-tagged and deemed
uninhabitable, such as 1112 Palmetto.

Please clarify the city’s approach to
these and other similar properties so
that their removal can be properly
addressed before further
environmental damage is done from
buildings and potentially hazardous
materials and debris falling into the
ocean. Policies and mitigation
measures seem to be missing in both
the DEIR and draft General Plan for
areas that may be subject to necessary
removal of structures and
infrastructure due to sea level rise and
coastal erosion. Please clarify and add
additional policies as needed, and
revise land use and other sections of
the General Plan as required with this
data. Provide detailed documentation
of revisions and additions and
recirculate documents as required.

The MJ-LHMP, incorporated by reference into the DEIR,
describes severe weather and coastal erosion events since 1983. The remainder of the comment focuses on potential environmental impacts of the environment on the Proposed Project. However, CEQA only requires analysis of potential environmental impacts of the Proposed Project on the
environment. Therefore, the range of potential impacts from coastal erosion are not required to be analyzed in the DEIR.

In addition, the current condition related to coastal erosion is part of the existing environmental baseline and is not a result of the Proposed Project. The future collapse of the buildings described in the comment are speculative and not reasonably foreseeable. Furthermore, the comment does not address
the City's police power to require demolition of any
hazardous or threatened building before potential
environmental impacts could occur. The City's police power to order and, if necessary, undertake demolition of hazardous structures is not part of the Proposed Project and, as a result, is not required to be evaluated in the DEIR
C49-
14 Christine
Boles
2/8/22 14. Page 3.6-19 references the
California Geological Society (CGS).

Special Publication 117, Guidelines for
Evaluating and Mitigating Seismic
Hazards.1997. There is at least one
more current document from 2008.

Please update source and related
The most up-to-date mapping is represented in Figure 3.6-1.

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material and recommendations
accordingly and clarify detail any
required changes.
https://www.conservation.ca.gov/cgs/
Documents/Publications/SpecialPublications/SP_117a.pdf 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 shadedrelief 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..."
Figure 3.6-3 is intended to supplement data in Figure 3.6-1.

Together, the maps represent an accurate assessment of
landslide hazards and policies in the Proposed Plan require geotechnical investigation in these areas.

C49-
15 Christine
Boles
2/8/22 15. Page 3.6-20 References Pacifica’s
Multi-Jurisdictional Local Hazard
Mitigation Plan (LHMP), which was
adopted by the City Council on
November 21, 2021, despite multiple
errors and omissions in the documents
as outlined by members of the public
including Dr. James Kremer and
myself. Both City Manager
Woodhouse and then Mayor, and now
Council Member, Sue Beckmeyer
stated that accuracy was not
important in these LMHP documents,
that our hazards would be properly
analyzed and mitigated through the
upcoming General Plan and Safety
Element update. We just needed to
file our LMHP with San Mateo County
to be eligible for FEMA funding. Now,
infuriatingly, the DEIR and General
Plan Safety Element quote the LHMP
as source material in multiple areas,
including landslides and fire risk.

Please see my attached 2020
correspondence with the City of
Pacifica regarding the errors and
omissions in the LMHP3. Page 3.6-21
states “All goals and policies in the
adopted MJ-LHMP are applicable to
the Proposed Project, including those
that concern geologic hazards.” Either
the reference to the current LHMP
must be removed from the DEIR and
GP, or the LMHP must be properly
Information in the MJ-LHMP remains an accurate source of information for landslide and coastal erosion threat. Please see Master Response 5: Wildfire for more information on the adequacy of mapping and applicability of actions under the MJ-LHMP.

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updated to be able to use it as source
of accurate information regarding
hazards and appropriate mitigation
measures. Please confirm which
option the city chooses and update all
documents, including policies and
mitigation measures accordingly.

C49-
16 Christine
Boles
2/8/22 16. Page 3.6-21 City of Pacifica
General Plan – Seismic Safety and
Safety Element. This section discusses
the last update to the Safety Element
in 1983 following the horrific El Nino
winters that caused 475 landslides,
massive flooding, permanent loss of
roads in Pedro Point, massive
evacuations of hundreds of Pacificans,
property damage and loss in the
millions of dollars, and the deaths of
three children asleep in their beds
when an unexpected debris flow
landslide engulfed their home. In fact,
Pacifica is the USGS’ poster child for
the horrors of debris flow landslides
with the image of homes on Oddstad
Road that were lost.

Pacifica commissioned an in-depth
study of those landslides by Howard
Donley and Associates, known as the
HDAI report, which is quoted
extensively in the 1983 Safety
Element. All 475 landslides were
mapped, and this large scale “blue
print” map can be found in the city
records in a folder with other technical
documents that informed the current
1980 General Plan. See snapshot
below of areas around Oceana High
School as an example. Roman
numerals indicate the types of
landslides that occurred. There is no
map of historic debris flow landslides
in the DEIR, please explain why this is
missing and/or add as necessary
There is a new map in the General
Plan, labeled 8-3b Landslide Inventory,
which supposedly maps historic debris
flow landslides, but it is missing all
information in the northern section of
town, such as the Moana Way slide,
one of the 9 major slides identified in
the HDAI report. It also omits other
slides, such as the one that blocked
Highway One near the police station a
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 shadedrelief 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.

Together, the maps represent an accurate assessment of
landslide hazards and policies in the Proposed Plan require geotechnical investigation in these areas. The debris flow map will be added to the DEIR to provide context, but the findings of significance do not change.

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few years ago. Please update this map
to include all known available data
and revise planning policies and land
use diagrams accordingly. Both of
these maps also neglect to include
landslides and debris flow landslides I
documented as part of my research
for the Vista Mar project on Monterey
Road. I shared this detailed
information with the City Manager
Woodhouse and the Pacifica City
Council prior to our project appeal
hearing in my letter dated November
22, 20204, which I have attached here
again for reference. All the supporting
documents including geotechnical
reports documenting these past
landslides can be found here.
https://drive.google.com/drive/folder
s/1qCJWAiGWIKkadVPAQ8vd9OOGcnFisDB?usp=sharing
C49-
17 Christine
Boles
2/8/22 17. The HDAI report also went on to
provide policy and mitigation measure
recommendations for areas
susceptible to debris flow landslides.

The current DEIR does not reference
the HDAI report and ignores most of
its recommendations. The
recommendations are not only site
specific, but they also refer to dangers
up and downslope (for example, in the
USGS pamphlet photo of the Oddstad
slide, the slide did not originate on the
subject property).

Page 134 ends

Pacifica City CouncilJune 25, 2022

Pacifica City Council
June 25, 2022