Agenda — Pacifica City Council, June 25, 2022 (part 6 of 23)

Safety Element notes the importance
of these maps from the HDAI report as
well. I find it shocking that this
document and maps are not
referenced. 1982 was indeed a 100
year El Nino series of events which
cumulatively caused this damage.

These events can and will happen
again in Pacifica, especially given the
increased severity of storms with
climate change. Please see relevant
sections of 1983 Safety Element
below. And continuing on page 136
Please see response to comment C49-16.

C49-
18 Christine
Boles
2/8/22 18. The HDAI report and 1983 Safety
Element also include specific
mitigation measures related to debris
flow landslides which seem to be
missing from the current draft DEIR
and Safety Element. Please review
Characterization of landslide hazards is adequate in the DEIR.

Please see response to comment C49-16

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Packet Pg. 997 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 333
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Individuals (C)
these policies with a geotechnical and
hydrological engineer to ensure
appropriate policies are incorporated
in the revised General Plan documents
to minimize and mitigate debris flow
landslides and protect public safety.

From the 1983 Safety Element, pages
101 and 102:

C49-
19 Christine
Boles
2/8/22 19. Policy 1 (again should these
policies not have a specific identifying
number to refence in the General
Plan?) on page 3.6-22 states, “Prohibit
development in hazardous areas
unless detailed site investigations
ensure that risks can be reduced to
acceptable levels and the structure
will be protected for its design life.

Development shall be designed to
withstand a minimum of a 100-year
hazard event, regardless of the
specific nature of the hazard. This
concept applies to both on-site and
offsite hazards.”
First of all, how you identify hazardous
areas without properly updated maps
using best available data in the DEIR
and General Plan? Secondly these
detailed site investigations, borings
and geotechnical analysis should take
place during the planning review
(Entitlement) process so that hazards
can be fully understood and properly
mitigated as otherwise changes may
be required to basic design, number of
units, access, etc. Vista Mar is a
perfect example of a project in a high
hazard landslide prone area where the
city did not require a thorough
geotechnical analysis. City policies and
development procedures need to be
revised to comply with this DEIR policy
to ensure consistency in application.

Please clarify how and when this will
be accomplished to ensure vertical
consistency between General Plan
documents and the Pacifica Municipal
Code
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.

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..."
As noted on DEIR p. 3.6-8 and 3.6-9, "Before a development permit is granted for a site within a Seismic Hazard Zone, a geotechnical investigation of the site must be conducted and appropriate mitigation measures incorporated into the
project design. Geotechnical investigations within Seismic Hazard Zones must incorporate standards specified by the California Geologic Society (CGS) Special Publication 117, Guidelines for Evaluating and Mitigating Seismic Hazards.

C49-
20 Christine
Boles
2/8/22 20. Policy 4 on page 3.6-22 states,
“Prohibit seawalls which are necessary
as a mitigation measure for new
development. Projects should not be
approved which eventually will need
seawalls for the safety of the
structures and residents.” Ensure that
Policy 4 represents an existing (1980) General Plan policy.

Proposed General Plan policies that continue this effort include SA-I-15, SA-I-70, SA-I-71, and SA-I-80. Policies in the LCLUP would also govern site-specific design in the area and would be subject to Coastal Commission permitting review.

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Packet Pg. 998 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 334
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Individuals (C)
this language is clear for all new
development in the Coastal Zone,
including Sharp Park. Even if existing
sea walls are rebuilt to “protect
infrastructure” their presence cannot
be used as a mitigation measure for
new development in the areas of
projected sea level rise and coastal
erosion. Any new buildings and their
access points must be adapted to 100-
year projections for sea level rise. This
may involve major design issues such
raising ground floor levels, providing
long handicapped access ramps to
commercial spaces, etc. Please clarify
where such policies are found in the
General Plan and Sharp Park Specific
Plan to ensure horizontal consistency
between documents.

C49-
21 Christine
Boles
2/8/22 21. Following Policy 4 on page 3.6-22
is Policy 7. What happened to policies
5 and 6. Please confirm if this is an
omission or simply a misnumbering.

These policies are taken from the 1980 GP. Numbering is correct, no action is necessary.

C49-
22 Christine
Boles
2/8/22 23. Methodology and Assumptions on
page 3.6-23 neglects to include local
hazard maps included in the DEIR and
GP. Please revise this paragraph of the
DEIR to name all sources required for
evaluations of hazards as detailed in
the DEIR.

This is not a CEQA requirement. On DEIR p. 3.6-24, "For any proposed development within the Alquist-Priolo Zone, fault identification studies are required by the Alquist-Priolo Act." On DEIR p. 3.6-25, "as shown in Figure 3.6-1, locations within the Planning Area are considered prone to liquefaction
hazards"; this mapping shows Seismic Hazard Zones that
"requires the State Geologist to delineate various seismic hazard zones and requires cities, counties, and other local permitting agencies to regulate certain development projects within these zones. Before a development permit is granted for a site within a Seismic Hazard Zone, a geotechnical investigation of the site must be conducted and appropriate mitigation measures incorporated into the project design." C49-
23 Christine
Boles
2/8/22 24. Under Impacts of the General Plan,
Liquefaction, on page 3.6-25 refers
only to map 3.6-1, but it assesses
areas of highest susceptibility to
liquefaction, which are actually
detailed on map 3.6-2. Please correct
reference or combine maps as
recommended above.

This comment contains an inaccuracy. 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-
24 Christine
Boles
2/8/22 25. Under Impacts of the General Plan,
Seismically Induced Landslides, on
page 3.6-26, it states that proposed
developments would adhere to
existing regulations in the Hillside
Preservation District (HPD). The
Hillside Preservation District
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. 999 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 335
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Individuals (C)
Requirements include limiting
development/disturbance areas based
on slope and size of parcel. The
steeper the slope, the less
development is allowed. That in itself
is a mitigation measure in that it
reduces the amount of development
on sensitive and hazardous slopes. By
only referencing the need for
geotechnical investigations in the HPD
ordinance, the DEIR policies neglect to
affirm this limitation as a valid
mitigation measure. This language
should be added, and clearly
addressed. In my opinion density
bonuses that allow for additional
disturbance should not be considered
on sites within HPD zoning that are
subject to landslide hazards. Please
confirm and add language as
appropriate. This has the potential to
become a source of litigation against
the city of Pacifica as several projects
such as Pacifica Highlands and Linda
Mar Woods are currently proposing
plans in hazardous areas with historic
landslides that include HPD overlays.

Clearly worded policies in the General
Plan and Municipal Code can help the
city avoid conflicting interpretations
and unnecessary litigation. Clear
policies also help us enforce our
overarching General Plan goals of
preservation of hillsides and open
spaces. Please clarify the city’s
intended approach to these policies in
the DEIR.

C49-
25 Christine
Boles
2/8/22 26. The blanket statement on pace

3.6-26 that “the proposed project
impacts from landslides is considered
less than significant” without proper
landslide maps in the General Plan or
DEIR to understand the even basic
locations of hazards, cannot be made.

The maps must be redrawn with
accurate information to fully
understand the potential impacts of
the Project, or the other variations of
the Project that are being considered.

Based solely on the ESA map of Sharp
Park showing projected coastal
erosion and sea level rise in my item
#19, I could not in professional good
conscience make the determination
that the effects of large scale build out
Please see response to comment C49-19 for more
information on the authoritative, best available data source provided by the Department of Conservation.

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Packet Pg. 1000 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 336
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Individuals (C)
in Sharp Park can be mitigated. If you
disagree please clarify in detail how
the determination was made that
impacts from landslides and coastal
erosion are less than significant.

C49-
26 Christine
Boles
2/8/22 27. Proposed General Policies that
Reduce the Impact LU 1-21, 2, 24, 29,
and 34 require site specific
geotechnical information. Please
confirm how existing policies will be
clarified such that site specific
geotechnical investigations include
sufficient borings on a site to
understand the various conditions
over the extent of the footprint of the
proposed development. Two borings
at the sidewalk for a project like Vista
Mar on a 50+ percent slope are not
sufficient to protect the public from
hazards. Policies need to translate to
procedures!
The comment is noted. Before a development permit can be issued or a subdivision approved, cities and counties must require a site-specific investigation to determine whether a significant hazard exists at the site and, if so, recommending measures to reduce the risk to an acceptable level. The investigation must be performed by state-licensed
engineering geologists and/or civil engineers. Please also see Master Response 2: Programmatic EIR.

Seismic Hazard Zone Maps identify where a site investigation is required, and the site investigation determines whether structural design or modification of the project site is necessary to ensure safer development. A copy of each
approved geotechnical report including the mitigation
measures is required to be submitted to the Program within 30 days of approval of the report. A Certified Engineering Geologist or Registered Civil Engineer with competence in the field of seismic hazard evaluation is required to prepare, review and approve the geotechnical report. The SHMA
requires peer review and this individual may be either local agency staff or a retained consultant. Additional information on requirements in the Pacifica municipal code for
geotechnical investigations are found in Sec. 10-1.404.

C49-
27 Christine
Boles
2/8/22 28. Policies LU I-15, 30, 31, 34, 35, 36,
and 41 to reduce the impact by
requiring sites with steep or sensitive
terrain to be added to HPD are vague
and of no enforceable use unless
these sites are identified and mapped,
or unless very specific criteria are
established that would clearly
determine if a property should be thus
classified. Please clarify procedures,
criteria, and a specific timeline for
adding HPD designations. Otherwise,
this vague language cannot be claimed
as a policy that reduces the impact of
the project.

Areas to be added to the HPD are shown in Figure 4-4 of the General Plan. Please also see Master Response 2:

Programmatic EIR.

C49-
28 Christine
Boles
2/8/22 29. SA I-2 “Development in Hazardous
Areas. 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.”
Please see response to comment C49-14 and C49-19 for
adequacy of seismic hazards mapping and required
geotechnical analysis.

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Packet Pg. 1001 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 337
Letter Commenter Date Comment Combined Response
Individuals (C)
Figure 8.2 is not accurate, as detailed
above. Landslides have occurred on
slopes less than 35% so the second
criteria is not enough. Please fix the
figures and updates the sources and
policies appropriate. Please confirm
how this has been addressed.

C49-
29 Christine
Boles
2/8/22 30. SA I-3 Real Estate Disclosure
includes disclosures for landslides.

Please clarify if this includes debris
flow landslides and clarify from what
source this data would be obtained.

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

C49-
30 Christine
Boles
2/8/22 31. SA I-8 Geotechnical Studies.
“Within the Coastal Zone and hillside
areas, continue to require
geotechnical site investigation for
proposed development on sites
located in any of the following areas,
prior to allowing site development:
• On slopes greater than 15 percent. •
In areas showing evidence of
landslides or landslide potential.
• In areas showing evidence of ground
shaking or earth movement
• Within 50 feet of a coastal bluff
• Within sand dune areas.”
I object to the words continue to
require based on Vista Mar. Also,
again landslide maps need to be
properly updated to understand
evidence or potential of landslides,
particularly debris flow landslides. The
maps need to be updated, the policies
and General Plan updated accordingly,
and then the documents recirculated
to verify accuracy. Please clarify your
intended procedures and timeline to
properly assess and address these
hazards. Please also clarify when offsite hazards (upslope and downslope) need to be addressed through
geotechnical studies to comply with
the recommendations in the 1983
Safety Element for debris flow
landslides.

Please see response to comment C49-16 and C49-19 for more information on adequacy of mapping. Department of
Conservation maps represent the latest and best available mapping of seismic hazards. See response to comment C49- 26 for more information on geotechnical analysis.

C49-
31 Christine
Boles
2/8/22 32. SAI-9 “Maintain Restrictions on
Hazardous Areas. Continue enforcing
the existing Coastal Zone Combining
District and Hillside Preservation
District regulations that restrict
development in hazardous areas
where access is impractical and areas
The comment is noted. Projects approved after certification of the General Plan would be required to comply with federal, state, and local regulations as well as proposed policies that would reduce impacts. The impacts from landslides on
development of future land uses associated with the
Proposed Project would be addressed through site-specific geotechnical studies prepared in accordance with CBC

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Packet Pg. 1002 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 338
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Individuals (C)
prone to hillside and coastal erosion,
landslides, seismic shaking, tsunami
inundation, or flooding.”
Again I object to the terms “continue
to enforce”. Since 2020, I have seen
multiple projects approved by the
Planning Commission and City Council
in hazardous zones without proper
geotechnical review, such as Vista
Mar, 1567 Beach Boulevard and 1300
Danmann. The City has also approved
multiple projects recently that did not
comply with HPD including Harmony
One Lot 3, Harmony One Lot D, 801
Fassler, and the home recently
approved at the end of Talbot. Vista
Mar was also proposed to be added to
HPD. What are our policies, when are
variances or takings arguments
acceptable, how will density bonuses
be considered? There are so many
questions unanswered which are
currently being viewed as loopholes
for project approvals, so until we have
clarification on the policy and
exceptions, I strongly object to this
being considered a mitigation
measure. Please confirm when the city
will undertake a proper and thorough
review of our Hillside Preservation
Ordinance so that it can START to be
properly applied again as it was in the
70s, 80s and 90s. I have many
examples of proper planning review
from past project to share with staff
and council so that we can start to
review projects properly again for
compliance with our HPD ordinance.
requirements and standard industry practices, which would specifically address landslide hazards located in landslide hazard areas. Development would conform to the current
design provisions of the CBC to mitigate losses from
landslides. Proposed developments would also adhere to the hillside development requirements contained in the proposed policies below as well as the existing regulations in the Hillside Preservation District to resist landslides through modern construction design and slope stabilization
techniques.

General Plan Policies SA I-2 and I-9 maintain restrictions on hazardous areas including those in the Hillside Preservation District, while Policy SA I-8 requires that proposed
development in hillside areas undertake geotechnical studies which analyze erosion and landslide potential. Policy LU-I-14 extends the Hillside Preservation District on the zoning map to ensure that all steep and sensitive terrain is subject to these regulations. Please also see Master Response 2:

Programmatic EIR.

C49-
32 Christine
Boles
2/8/22 33. SA-I-114 Critical Facilities Locations
– again proper maps are needed for a
comprehensive understanding of
hazardous sites so they can be
avoided for critical facilities. Please
map and provide a detailed list of any
existing critical facilities currently
located in hazardous zones, such as
water storage tanks on hillsides,
sewage pump stations near areas of
projected coastal erosion and sea level
rise, etc.

Location of critical facilities is not a required topic of analysis under the General Plan. In the spirit of disclosure, lease see the 2018 Sea Level Rise Vulnerability Report for more
information on critical facilities. The MJ-LHMP includes actions to relocate critical facilities, as do policies in the General Plan, including SA-I-27 and SA-I-114.

C49-
33 Christine
Boles
2/8/22 34. SA-I-7 Erosion prevention by
revegetation. This is missing critical
information from the 1983 Safety
Element and the Howard Donley
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

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Packet Pg. 1003 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 339
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Individuals (C)
report about the dangers of planting
trees and shrubs on slopes more than
50%. Please revise text of measure
appropriately as was done for the
recent Talbot project approval in 2022
and confirm new language.
context. Please see Master Response 1: EIR Comments for more information about GP- or SPSP-related responses.

C49-
34 Christine
Boles
2/8/22 35. SA-I-11 Grading and Drainage
Plans – Grading and drainage plans
should be required for all projects
requiring a coastal development
permit OR a grading permit, not AND a
grading permit. I believe the word
“and” is in error. In my professional
opinion, all development on slopes
over 15% should require grading and
drainage plans as part of the
development review process before
obtaining entitlements. I am happy to
research similar policies in many other
Bay Areas cities as examples.

This policy also prohibits development
related grading and vegetation
clearance on slopes steeper than 35%,
but other policies herein permit this
grading with geotechnical review.

Which is it? These policies conflict and
will subject the city to legal challenges.

All General Plan documents must be
horizontally consistent as is clearly
stated in the introductory section of
the GP and DEIR.

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

C49-
35 Christine
Boles
2/8/22 36. SA-I-70 Technical Reports please
define “recent”.

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. The policy notes that studies should "consider the impacts from the med-high
projection (CalNRA & OPC 2018) data source.

C49-
36 Christine
Boles
2/8/22 37. CO I-46 Shoreline protection.

Please clarify what “existing
structures” are eligible for shoreline
protection. My understanding is that it
is only pre–Coastal Act (1972 I believe)
and not that all existing structures are
eligible. Please clarify and amend
language.

This comment relates to the LCLUP. It does not relate to the adequacy of the DEIR, thus no further response is required.

Please see Master Response 1.

C49-
37 Christine
Boles
2/8/22 38. Page 3.6-37 Impact of the Sharp
Park Specific Plan says the area is at
risk of few landslides, and yet the map
Figure 3.6-3 indicates this area is
subject to severe beach erosion and
severe beach and cliff erosion on the
northern section. I cannot evaluate
the potential impacts of the Proposed
Project and specifically the Sharp Park
The SPSP area does not include any areas of significant elevation change; thus, no landsliding would occur. The latest coastal erosion and sea level mapping are included in the LCLUP pending certification with the Coastal Commission; the General Plan references the 2018 Sea Level Rise Vulnerability Assessment, which informs area-specific adaptation policies in the LCLUP. The General Plan shares policies with the LCLUP; these policies are included in the DEIR to the extent that they are relevant to CEQA-required impacts.

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Packet Pg. 1004 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 340
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Individuals (C)
Specific Plan with the data and maps
included in this DEIR. Please provide
current updated information and
accurate detailed maps and justify the
city’s position that the impacts of the
proposed project will be less than
significant.

C49-
38 Christine
Boles
2/8/22 39. SA-I-18 Accessory structures in
Coastal Zone on page 3.6-32 of the
DEIR seems to be SA-I-16 in the GP
Safety Element. Please confirm which
number is accurate and what may be
missing in the other document.

These inconsistencies are corrected in errata. These
clarifications do not change findings of significance in the DEIR.

C49-
39 Christine
Boles
2/8/22 40. The Bibliography in the DEIR does
not appear to have been updated
since 2014. Please update accordingly
including proper website links.

References will be updated to reflect the latest data used in analysis. This does not change any findings of significance in the DEIR.

C49-
40 Christine
Boles
2/8/22 41. Please confirm that the Safety
Element meets the requirements of
Government Code Section 35602(g)
(1) “A safety element for the
protection of the community from any
unreasonable risks associated with the
effects of seismically induced surface
rupture, ground shaking, ground
failure, tsunami, seiche, and dam
failure; slope instability leading to
mudslides and landslides; subsidence;
liquefaction; and other seismic
hazards identified pursuant to Chapter

7.8 (commencing with Section 2690)
of Division 2 of the Public Resources
Code, and other geologic hazards
known to the legislative body;
flooding; and wildland and urban fires.

The safety element shall include
mapping of known seismic and other
geologic hazards. It shall also address
evacuation routes, military
installations, peakload water supply
requirements, and minimum road
widths and clearances around
structures, as those items relate to
identified fire and geologic hazards.” I
have not come across evacuation
routes and minimum road widths, nor
peakload water supply requirements
for example. Please clarify where this
information is found in the General
Plan or DEIR.

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

C49-
41 Christine
Boles
2/8/22 42. With Pacifica’s adoption of the
Local Hazard Mitigation Plan by the
City Council on November 21, 2021,
Government Code Section 35602(g)(4)
Analysis in the 2021 MJ-LHMP and the 2018 Sea Level Rise Vulnerability Assessment form the basis for SB 379 analysis.

The General Plan incorporates these documents by reference.

Hazards are adequately addressed in the DEIR chapters 3.5

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Packet Pg. 1005 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 341
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Individuals (C)
requires the Safety Element to be
updated to “to address climate
adaptation and resiliency strategies
applicable to the city or county. This
review shall consider advice provided
in the Office of Planning and
Research’s General Plan Guidelines
and shall include all of the following:
(A)
(i) A vulnerability assessment that
identifies the risks that climate change
poses to the local jurisdiction and the
geographic areas at risk from climate
change impacts, including, but not
limited to, an assessment of how
climate change may affect the risks
addressed pursuant to paragraphs (2)
and (3).
(ii) Information that may be available
from federal, state, regional, and local
agencies that will assist in developing
the vulnerability assessment and the
adaptation policies and strategies
required pursuant to subparagraph
(B), including, but not limited to, all of
the following:
(I) Information from the internetbased Cal-Adapt tool. (II) Information from the most recent
version of the California Adaptation
Planning Guide.
(III) Information from local agencies on
the types of assets, resources, and
populations that will be sensitive to
various climate change exposures. (IV)
Information from local agencies on
their current ability to deal with the
impacts of climate change.
(V) Historical data on natural events
and hazards, including locally
prepared maps of areas subject to
previous risk, areas that are
vulnerable, and sites that have been
repeatedly damaged. (VI) Existing and
planned development in identified atrisk areas, including structures, roads, utilities, and essential public facilities.
(VII) Federal, state, regional, and local
agencies with responsibility for the
protection of public health and safety
and the environment, including special
districts and local offices of emergency
services.
(B) A set of adaptation and resilience
goals, policies, and objectives based
(Hydrology and Flooding, including sea level rise); 3.6 (Geology, Soils, and Seismic Risk) ; 3.11 (Hazards and
Hazardous Materials); and 3.14 (Wildfire).

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Packet Pg. 1006 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 342
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Individuals (C)
on the information specified in
subparagraph (A) for the protection of
the community.
(C) A set of feasible implementation
measures designed to carry out the
goals, policies, and objectives
identified pursuant to subparagraph
(B), including, but not limited to, all of
the following: (i) Feasible methods to
avoid or minimize climate change
impacts associated with new uses of
land.
(ii) The location, when feasible, of new
essential public facilities outside of at-
risk areas, including, but not limited
to, hospitals and health care facilities,
emergency shelters, emergency
command centers, and emergency
communications facilities, or
identifying construction methods or
other methods to minimize damage if
these facilities are located in at-risk
areas.
(iii) The designation of adequate and
feasible infrastructure located in an at-
risk area.
(iv) Guidelines for working
cooperatively with relevant local,
regional, state, and federal agencies.
(v) The identification of natural
infrastructure that may be used in
adaptation projects, where feasible.

Where feasible, the plan shall use
existing natural features and
ecosystem processes, or the
restoration of natural features and
ecosystem processes, when
developing alternatives for
consideration. For purposes of this
clause, “natural infrastructure” means
using natural ecological systems or
processes to reduce vulnerability to
climate change related hazards, or
other related climate change effects,
while increasing the long-term
adaptive capacity of coastal and inland
areas by perpetuating or restoring
ecosystem services. This includes, but
is not limited to, the conservation,
preservation, or sustainable
management of any form of aquatic or
terrestrial vegetated open space, such
as beaches, dunes, tidal marshes,
reefs, seagrass, parks, rain gardens,
and urban tree canopies. It also

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includes systems and practices that
use or mimic natural processes, such
as permeable pavements, bioswales,
and other engineered systems, such as
levees that are combined with
restored natural systems, to provide
clean water, conserve ecosystem
values and functions, and provide a
wide array of benefits to people and
wildlife.”
I do not see this analysis in the DEIR or
General Plan. I believe these
requirements coincide and perhaps
overlap with state requirements under
SB379. Please clarify what additional
studies and sections of the DEIR and
General Plan will be added to ensure
compliance.

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C49-
42 Christine
Boles
2/8/22 1) Slope Failure and Erosion: Figure 8-
2 in the draft Safety Element of the
General Plan Update is reproduced
with additions below (Figure 1). The
current maps are so devoid of real
information that they are useless in
assisting the city in determining
hazard risks. This is corroborated by a
November 18, 2020 email from
Professor Jerry Davis of San Francisco
State University who has extensively
studied the historic slides in the San
Pedro Creek watershed area. In the
July 29, 1982, Howard Donley
Associates, Inc. report titled
Geological Investigation Landslide
Type and Distribution and Mechanic
Details of Nine Representative Failures
, commissioned by the city (referenced
as HDAI report in the 1983 Seismic
Safety and Safety Element), pages 18
and 19 (32 and 33 of the pdf), the
author is very clear. He discusses the
maps produced by the USGS and the
San Mateo County Geotechnical
Hazards Maps.
“ Both of these map sets emphasize
large, bedrock type of slides although
slides with a maximum dimension of
500 feet are plotted. Discussion of
various types of slides are provided
with these maps but nowhere is there
shown a high risk relationship to the
City of Pacifica. The engineering
geologic practice prior to January
1982, has been to consider the slopes
highly sensitive to erosion and surficial
sloughing only. Nowhere in the
geologic literature of Pacifica is there
shown or depicted the threat of mass
wasting of overburden soils such as
occurred in January, 1982. It is
therefore our opinion that much of
the published geologic hazard
information affecting Pacifica is no
longer valid for use in the City; a new
set of landslide hazards maps should
be produced for the area.”
In essence, the type of slide most
common in Pacifica is not represented
in the geologic maps the city uses for
planning. The City has known that the
geologic maps are inaccurate and not
Please see response to comment C49-19 on the adequacy of mapping seismic hazards.

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valid for use in reviewing proposed
projects since 1982, and yet 32 years
later, the 2014 Safety Element update
still neglects to include this essential
information! The HDAI report did
detailed geotechnical analyses of 9 of
the largest slope failures out of the
475 that occurred in Pacifica in 1982. I
have mapped these 9 slides on the
draft 2014 Slope Failure and Coastal
Erosion Map. Except for the Highway 1
slide, all of these landslides occur in
areas noted as Not Landslide Prone or
Few Landslides. The 1983 Oddstad
slide that killed three children is in a
"Not Landslide Prone Area", as are the
more recent major bluff erosion areas
of Linda Mar Beach and Esplanade.

The City of Pacifica appears to have
been negligent in its lack of follow
through on the 1982
recommendations in this report,
putting the lives and property of
Pacificans in potential danger as the
documented risks of building in
hazardous areas have not been
properly assessed. Figure 1: Figure 8-2
of the draft Safety plan reproduced
with additions of noted slides and
erosion sites from the HDAI 1982
report
C49-
43 Christine
Boles
2/8/22 2) Flooding
Figure 8-3 in the draft Safety Element
shows only very limited flooding along
the coasts and some stream banks,
with long return periods. Regions
marked with a 1% annual chance of
flooding are expected to experience
flooding about once every 100 years.

Similarly to the previous section, our
experiences and anecdotal evidence
dating back to the 1980s are
inconsistent with the flooding map in
the Safety Element. As other
neighbors have discussed in their
letters, the region around Monterey
road experiences flooding on an
annual basis, and during extreme El
Niño events (which have recurred
The comment is noted; it contains an inaccuracy regarding the 1% chance of flooding: "Regions marked with a 1% annual chance of flooding are expected to experience flooding about once every 100 years" is untrue; a 100-year floodplain is a flood event that has a 1 in 100 chance (1% probability) of being equaled or exceeded in any given year.

The information shown in this figure is based on the latest information from FEMA, the authoritative source for
floodplain mapping. The DEIR also references the 2018 Sea Level Rise Vulnerability study and hte LCLUP, both of which contain more detailed maps of coastal flood potential. Please see Master Response 1 for more information on General Planrelated responses.

As described under Impact 3.5-5 starting on page 3.5-29, impacts from the redirection or impediment of flood flow, water pollution, and exceedance of stormwater infrastructure

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about every 15 years in recent history)
the flooding has been catastrophic.

This area is not even marked on the
Safety Element map. Quoting from
Richard Drury’s letter dated

11.22.2020, “the current General Plan
lacks accurate and up to date maps of
flooding and flood related risks, and
therefore lacks the information
necessary to evaluate the safety
implications of the proposed
development.” Additionally, in
reviewing the hydrology report for the
Vista Mar development, it came to our
attention that the city drainage
system plans are nearly devoid of
accurate data.
capacity are minimized through the implementation of
stormwater management policies within the Proposed
General Plan, Local Coastal Program, the Pacifica Green Infrastructure Plan, and policies in the SPSP; thus, the impact would be less than significant.

C49-
44 Christine
Boles
2/8/22 3) Sea Level Rise:

Although there is significant
uncertainty in the amount of sea level
rise we will see by the end of the
century, the state of California has
released clear guidance on planning
for sea level rise. 3 The 2018 Update
to the State of California Sea Level
Rise Guidance (link in footnotes)
suggests that any projects with
lifespans beyond 2050 should consider
the more extreme H++ sea level rise
scenario, and that this scenario is
particularly “relevant to communities
considering regional or general plans,
climate action plans, local hazard
mitigation plans, regional
transportation plans, and other
planning efforts, due to the
interrelated nature of critical
infrastructure, homes, businesses,
etc.” This corresponds to an increase
in sea level of 10.2 feet (3.1 m) by
2100. The medium to high risk
aversion projection is 5.7 - 6.9 feet
(1.7 - 2.1 m) by 2100. While sea level
rise is not as relevant for the Vista Mar
development, it was noted at the City
Council meeting last week that no
geotechnical or hydrological analyses
of the Sharp Park area have yet been
done prior to consideration of the
Sharp Park Plan. The USGS’s Our Coast
Our Future project is a useful tool for
visualizing the effects of different sea
level rise and storm surge scenarios
along the California coast. Figure 2
shows the results of 2 m of sea level
The comment is noted. Although the LCLUP is a separate
planning document, the LCLUP policies and relevant
narratives are included in the General Plan Update to ensure coordination between the two documents. The beneficial
impacts of these shared policies as they relate to reduction of potential impacts required under CEQA, such as impacts
related to geology or hydrology, are analyzed in the DEIR. 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. See response to comment C13-3 for more information about
coastal flooding and sea level rise.

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rise and a 100 year storm surge event
for the region of the Sharp Park. A
significant portion of the proposed
downtown development would be
flooded in this medium-high risk
scenario. Importantly, this does not
take into consideration concurrent
flooding from precipitation or local
streams, which would also have to be
factored in for El Niño events, for
example. It seems the city is putting
the cart before the horse in paying
high priced consultant fees for
development models that are not
based on scientific facts.

Figure 2: Our Coast Our Future
flooding map for Sharp Park for the
scenario of 2 m Sea Level Rise and a
100 year flood. 4
C49-
45 Christine
Boles
2/8/22 I would suggest the City concentrate
its efforts on updating the Safety
Element that is out of compliance with
state regulations before other
potential zoning changes can be
considered. Senate bill 379 that
amended Section 65302 of the
Government Code in 2015 requires
the Safety Element to be reviewed and
updated as necessary on or before
January 1, 2022 to address climate
adaptation and resiliency strategies.

There is obviously a lot of work that
needs to be done to meet this
deadline, which is only 13 months
away.

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

C49-
46 Christine
Boles
2/8/22 As you can see from my letter on page
289 of your agenda packet, I have
already spent a considerable amount
of time analyzing the San Mateo
County Multi-Hazard Risk assessment
as it pertains to Pacifica. I reviewed
the revisions this weekend and while I
appreciate some of the changes that
staff incorporated as a response to
public comments, I still have concerns
about the accuracy of some of the
information in the revised report. I
would ask you to pull the item from
the consent agenda so that we the
public can hear from staff and engage
in some dialogue with you all about
whether some other
edits/clarifications might be needed. If
your vote on accepting the document
can be delayed, my preference would
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

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be to move this item to a future
agenda allowing time for a more
thorough review. As this report and
process pertains to council priorities
of ensuring public safety, building
public engagement and rebuilding
public trust, I would hope that you
would see the value of an open
discussion and partnership with the
community on these important issues.

The importance of having an accurate
document that shows a deep
understanding of the many natural
hazards we face in Pacifica and the
necessary mitigation steps to both
prevent and respond to inevitable
environmental catastrophes cannot be
overstated.

I see that the draft response that you
are reviewing as part of today’s
agenda that has not yet been
approved by Council has already been
submitted to the County as it posted
on their website. This seems very odd.

I’d also like to point out that the
Wildfire Hazard Severity Map is
missing from both your agenda and
the county website, so I question
whether this incomplete draft can be
adopted today.

I also wanted to ask if there was a
draft of the General Plan Safety
Element that I could see now? As
according to the City Manager, you
are going to release that draft next
month, surely there is additional
technical information in this new draft
that relates to this hazard mitigation
plan which would help better inform
this document.

C49-
47 Christine
Boles
2/8/22 Item 1 – Landslide Risks Given our
history, that in the winter of 1982/83
alone Pacifica was subject to 475
landslides, with multiple area
evacuations for days due to the risk of
saturated hillsides and flooding, which
also led to the tragic deaths of three
children, I am glad to see that the city
recognizes this as the highest-ranked
hazard in table 14-2. While some
commenters focused solely on Linda
Mar Woods, which is in a high
landslide susceptibility area, so the
Please see response to comment 46-16 and C-63-1 for more information on the adequacy of landslide mapping. Please also see Master Response 1 for comments related to the
General Plan.

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concern there is very real, I am not
asking for property specific level
assessment here as the staff response
claims, but a robust assessment of
landslide hazards that can be used as
part of general planning for the entire
city.

I have pointed out to Council and
Planning Staff multiple times in the
last year, including exactly one year
ago in public testimony as part of the
Vista Mar City Council appeal hearing,
that Pacifica’s General Plan and Safety
Element do not address these hazards.

The Howard Donnelly Report of 1983
which informed the Safety Element
update, specifically said that Pacifica’s
landslide maps were inaccurate for
the type of shallow surficial debris
flow landslides Pacifica is most subject
to. The report called for new landslide
maps to be created back in 1983,
almost 40 years ago. The 2014 Draft
General Plan Safety Element posted
on the city website still does not
address these landslides as I
previously documented to you all in
several letters and emails. If the city is
actually working on a proper update
to the Safety Element now, which is
supposedly soon to be released for
public review with other General Plan
documents, then surely there must be
better information available that we
can refer to analyze and mitigate our
landslide risks. The state USGS has
recently come out with new
interactive landslide maps that appear
to address debris flow landslides, so
we have better tools available to us
right now to address gross planning
for these type of disasters. These
maps should also start to be used
immediately to inform our review of
development applications as there are
several pending currently being
reviewed that are on hazardous sites,
including
A) The home on Talbot on a site with
mostly 100% slope that has already
come before the Planning Commission
once this fall 2021
B) Pacifica Highlands, which is on a
fast-track SB 330 application due to be
complete by February of 2022. Project

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plans shows two areas with historic
landslides, cutting right through
proposed new roads and structures.

C) And of course, this Council majority
approved the Vista Mar project in late
2020, on a site with a 52% average
slope with a history of landslides,
some noted as active, using a
geotechnical report that had no recent
borings in the area where the
buildings were proposed. The test pits
to analyze these landslides that were
required in 1991 as part of the William
Cotton geotechnical peer review for a
very similar project by the same
engineer, were never done.

D) Linda Mar Woods, which is also in
an area with high landslide risk.

Notwithstanding our fatally out of
date General Plan and Safety Element,
our current planning processes do not
sufficiently protect the public from
landslide and flooding risks, and that is
the core reason the city is currently
being sued over this project’s
approvals. We need a major overhaul
of not only our General Plan and
ordinances, but our planning policies
and procedures to ensure the public is
protected and that the city is
protected from the financial losses in
case of hazardous construction and
bankrupt developers who leave us to
pick up the pieces.

I am glad to see our Hillside
Preservation Ordinance added to the
hazard document, as item b under the
very first paragraph about the intent
of the ordinance in Article 22.5 of our
Municipal Code specifically says to
“Help protect people and property
from all potentially hazardous
conditions particular to hillsides;” As
you are aware from public and
Planning Commissioner requests,
making sure our HPD ordinance is
properly reviewed and enforced
requires discussion. I have recently
obtained historical project documents
that show the ordinance was properly
applied to projects in the past; we can
easily learn together from these
documents and improve our processes
moving forwards if Council would
allow the time for an open discussion

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in a study session. I have also offered
several times to meet with the City
Manager as well as planning staff on
these issues and am still very willing to
do so.

C49-
48 Christine
Boles
2/8/22 2. Wildfire Risk
As previously stated, the document
you are scheduled to approve today
appears to be missing the Fire Risk
map. As Pacifica residents Cindy
Abbott and James Kremer so
eloquently analyzed in their
comments, wildfire risk does not
magically change at a city border. As
we saw in the recent CZU fires in the
coastal zone with an identical climate
to Pacifica, our risks have increased
substantially with climate change in
the past decade. Parts of Pacifica,
especially our southern border is filled
with very flammable eucalyptus, is
indeed a high fire risk area. Our own
2014 General Plan Safety Element
notes this area and several other areas
of Pacifica as Very High Fire Hazard
Severity Zones. See image below. The
fire risks in Pacifica are not uniformly
“medium” as proposed in the current
document revisions.

And should we not consider planning
for increasing fire danger due to
climate change? Perhaps new
developments adjacent to open
spaces should be held to stricter state
Wildland Urban Interface
requirements to protect both people
and firefighters? Many Bay Area cities
already incorporate WUIZ fire codes.

And at what point is the Fire
Department brought in to review
projects in fire hazard zones? Recent
examples:

A) The home on Talbot on a site
bordering Milagra open space came
before the Planning Commission this
fall 2021. The drawings contained
errors with relation to fire hose path
lengths and the lengths exceeded
state code maximum requirements of
150 feet. This non-compliance should
have required special exceptions from
the Fire Marshall, which were not
addressed in the staff report.

Please see Master Response 5: Wildfire for more information about areas of fire threat, areas of VHFHSZ, and WUI. Policies related to NCFA site review are included in the Proposed Plan.

Please see Master Response 1 for more information on how GP-related comments will be addressed.

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B) Pacifica Highlands, which is on a
fast-track SB 330 application due to be
complete by February of 2022 I
believe. The current notice of
incomplete states, “A secondary
egress route may be required.

Additional consultation with North
County Fire Authority is required prior
to approval.” I am shocked that this
basic issue of site access has not been
resolved at this stage. On one of my
current architectural projects, on a 69
acre site next to open space in Santa
Clara County, the application is not
deemed complete and yet the fire
department has already given detailed
feedback as to road design and water
capacity. We have even had to add a
new 60,000 water storage tank as a
backup firefighting source as part of
the initial planning review.

C) Linda Mar Woods - the long oneway road does not meet state fire or basic Pacifica city standards. Is the
project even remotely viable?
Pacifica can and must do better in
ensuring projects are safe from fire
hazards with proper agency
coordination and review early on.

C49-
49 Christine
Boles
2/8/22 3. Coastal Erosion and Building
Condemnation I have marked up
packet page 402 with several other
hazard events and building removals
that are not included in the report. I
have not done extensive research, so
others are likely missing.

Staff response states that “The City
has declared one additional building
as unsafe for occupancy that is not
included in Table 14-11 – the property
at 1112 Palmetto Avenue. However,
the building owner is continuing
efforts to obtain approval from the
California Coastal Commission to
protect the property from further
coastal erosion and the building has
not been demolished.” Based on my
research and recent correspondence
on November 5, 2021, City staff and
Council are aware that the owner of
1112 Palmetto has not worked with
the Coastal Commission since 2016
when they received a temporary
Coastal hazard removal is addressed in the LCLUP and is not a required topic of analysis under CEQA. Please see comment C69-8 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. 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.

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permit for armoring. This permit has
expired and the armoring they did is
now illegal. This documentation is all
in the real estate listing disclosure
papers that I attached in this email.

The Coastal Commission had filed
several violation notices on the
property, including one as recently as
last month. On Friday November 12th,
I asked Coastal Commission staff in an
email who takes authority to ensure a
building is removed or moved before
it becomes public danger and ocean
environmental hazard? Here is the
response I obtained from Jo Ginsburg,
the Coastal Commission’s
Enforcement Analyst.

So, what are our policies for coastal
hazard removal? What are the triggers
by which a structure is deemed
uninhabitable and a public danger?
And who pays for the removal? There
are other buildings near the cliff edges
too, such as 1044 Palmetto, where the
building is now only about four feet
from the edge. One major storm could
send the foundations over the edge.

The city’s responses in this document
seem to be severely lacking in analysis
and mitigation planning related to
coastal erosion and sea level rise.

C49-
50 Christine
Boles
2/8/22 The 1980 General Plan contain several
elements that should be applied when
considering the approval of any
development project. I want to draw
your attention to the Seismic Safety
and Safety Element, dated 1983,
which is incorporated into the 1980
General Plan. Based on this element, it
is clear that the Vista Mar project was
not reviewed to these standards by
either the Planning Department or the
Planning Commission, and therefore
the Planning Commission approvals
are invalid and should be voided by
upholding our appeal. I have several
documents I would like to share with
you as part of this letter, and they
located in this Google Folder.
https://drive.google.com/drive/folder
s/1pePLw7vSsUPxoi_RrYL5Vap3wfEK8
o9G?usp=sharing
I have included the current 1980
The comment relates to the General Plan and does not
address adequacy of the DEIR; no further response in the FEIR is needed. Please see Master Response 1 for more
information.

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Packet Pg. 1018 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 354
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General Plan and 1983 Safety Element
document for reference, item
1) The safety element is on page 131
(document page 98).

The 1983 Safety Plan revision date
stems from several landslides that
occurred in the wet winters of 1982
and 1983. Prior to these events,
shallow, debris flow type landslides,
also known as “surficial landslides,” as
noted on page 98, seem to have been
poorly understood. It is unfortunate
that it took the deaths of three
children on Oddstad Road in Park
Pacifica from a landslide that engulfed
their home in mud in the middle of
the night in early January 1983 to
prompt this update to the General
Plan.

I also want to take this opportunity to
remind you that several other
documented landslides have occurred
on the Vista Mar hill since the General
Plan was last updated in 1983. See
image on next page. In my letter of

10.18.20, I shared several of these
geotechnical reports with you as
outlined below; The first three relate
to landslides identified as 8, 9, 10 and
11 on the Vista Mar site itself.

C- 1988 Herzog Report for Vista Mar (I
have included a more legible copy
recently obtained from the public
records search by Summer Lee and
Kristin Cramer)
D- 1991 Hom Report for Vista Mar E1992 William Cotton Geotechnical Peer Review for Vista Mar In addition,
I would like to add the following
reports we have found in the city
records to our documentation of other
landslides on the hillside to the project
record.
2) 1990 Baldwin Report for Pacifica
Palisades Subdivision, identifying
landslides 7 and 13.
3) 1998 PAC Geotechnical Report for
Pacifica Palisades Subdivision,
identifying landslides 6 and 12.
4) 2005/2006 Imperial Park Landslide,
City Council meeting agenda to
approve funds for repairs.

When I asked the city for records of

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previous landslides around the Vista
Mar Site, I was only given information
about two of these events.
1) The Imperial Park landslide off of
Hickey in 2005/2006, which required
$520,000 in repairs in 2008, that was
reimbursed by FEMA. This is item 1 on
the map above.
2) The landslide/major erosion on the
two properties adjacent to mine at
460 and 462 Monterey Road in 2016
that lost half of their back yards to the
open drainage channel behind our
homes known as Big Inch Creek, item
4 on the above map. The only
documentation provided to me by the
City for that event were two photos.

There was no documentation of the
creek bank repair work and large tree
removal that was done as their roots
were undermined by the slide, and no
associated costs were reported, even
though the work took several days to
complete and the city hired an outside
tree removal company. At a minimum,
the City should have a record of City
approved engineering plans for this
major landslide. Photos and videos,
including additional items from
neighbors, were shared previously and
can be found here.
https://drive.google.com/drive/folder
s/19y_rIibT4t8Bsf_boc0WovfqF14nMB
Cg?usp=sharing
The information in this 1983 Safety
Element document is directly related
to the Vista Mar landslides
documented by Herzog and Hom, and
by the William Cotton peer review as
part of the previous 1991 submittal for
this project. These four landslides, two
of which are listed as active, are the
same kind of surficial debris flow
landslides that occurred in 1983 on
Oddstad Road. Again, I remind you
that the current project geotechnical
report contains NONE of this
information, and it is only because of
neighbor demands of public records
that we now have access to these
more thorough geotechnical
investigations, which the planning
department was obligated to consider

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in the review of this project.

Quoting from page 102 of the Safety
Element, Item 1, “Policy – Prohibit
developments in hazardous areas
unless detailed site investigation
ensures that risks can be reduced to
acceptable levels. ImplementationEnvironmental Review procedures mandate detailed studies for any
discretionary review project which
may constitute a risk or which is
located in a hazardous area.

Development is not permitted unless
all risks are adequately mitigated.

Building and planning permits are not
issued unless the City is satisfied that
the level of risk and mitigations are
acceptable. The City recognizes both
on- and off-site hazards and requires
mitigation if necessary and
appropriate.” [emphasis added]
Please note that planning permits are
not allowed, and yet at the
recommendation of the Planning
Department, the Planning Commission
erroneously approved this project.

Does the Planning Department not
consider the Safety Element in review
of projects? Have other projects been
mistakenly approved as well? I have
not seen a risk assessment for this
project or any study of potential off-
site hazards. Is the City willing to
accept responsibility for these
unknown risks at this point without
comprehensive updated geotechnical
and hydrological investigations as is
required by the Safety Element prior
to the issuance of any planning
permits?
In terms of off-site hazards, besides
the potential landslides, there are
flooding issues that must be
addressed. While this project is not in
an “identified” Flood Zone according
to City hazard maps, I have previously
shared with the Planning Department
and Planning Commission evidence of
regular flooding of the area downhill
from the project, both on Monterey
Road, and in Big Inch Creek. Here is a
link to those photos and videos.
https://drive.google.com/drive/folder

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Packet Pg. 1021 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 357
Letter Commenter Date Comment Combined Response
Individuals (C)
s/1iVYWM-Tv1aK-
W9WwkpXqLAocH5JY0LTy?usp=sharin
gNote that the Monterey Road files
are all recent, in dry winters.

As Monterey Road and Hickey join
together just below Vista Mar, and
just above my home, the city streets
are regularly inundated in heavy rains.

The existing stormwater infrastructure
is woefully inadequate and cannot
handle the amount of water coming
down the hillside now, even without
this development. In an email, my
neighbor Lynn Adams, the President of
the Pacific Beach Coalition, told me
she has seen so much water coming
down the hill that cars were moved.

We only finished construction and
moved into our home in 2019, but I
have seen the streets flooded, with
parked cars creating horsetails of
water into our front yards from the
street from curbed tires. Every house
on our block which is located downhill
from the street has barriers next to
the sidewalk to try to contain some of
this water, and additional sandbags
stay in front yards and driveways all
winter long. Neighbors have had to file
insurance claims for flooding from the
street. I have had to wade through 10”
of water on the sidewalk to alert a
neighbor to move their car in the
middle of a hovering storm cell. When
I asked the engineering department to
consider adding additional drainage as
part of the Monterey Road repaving
that happened this year, I was told
there was no money in the budget.
(This begs the question of why the city
is not requiring more infrastructure
improvement funds from developers,
including this one. $5,000 won’t even
pay the permit fees.)
Because of these concerns about
potential additional water flow from
the Vista Mar Development, my
husband, Bob Boles, met with Ray
Donguines of the Engineering
Department on September 14, 2020 to
review existing stormwater systems
and capacity in the area. The City
block book records for this area are
not up to date and contain major

1.f
Packet Pg. 1022 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 358
Letter Commenter Date Comment Combined Response
Individuals (C)
errors and omissions. The Block Book
map in front of Vista Mar is actually
blank. The correspondence from Bob
is item 5) in the Drive folder.

The applicant, Javier Chavarria’s
drainage calculations, even as they are
without proper soils and groundwater
analysis, show at least an 18” pipe is
needed from the Vista Mar swale to
connect to the 24” pipe in the street.

No one seems to know how much
water is already coming into this pipe
from further uphill. One of our
neighbors, Garrick Meeker, who lives
on Monterey just above the Vista Mar
site has seen the stormwater
manhole covers on the street pop off
during heavy rains. We believe this to
be a sign of an overloaded or blocked
system. Again, this is uphill and before
any additional water from Vista Mar is
added. We neighbors are very
concerned for our safety because of
these hazards, and that is why we
have organized the Vista Mar
Preservation Alliance and spent so
much time and resources researching
and questioning this project.

We are appalled that the planning
department has abdicated their
responsibility to fully evaluate the
project risks before advocating for
project approval. We are here to ask
you to carefully review the evidence
we have provided and the questions
we pose, and ask yourselves, can the
City be satisfied with the level of risk
this project poses without a full
geotechnical and hydrological analysis
as is required by the current General
Plan and Safety Element?
Furthermore, there are specific items
mentioned in the Safety Element that
are not recommended for steep
slopes, and yet the Vista Mar project
proposes these very measures.

A. “It is recognized that intense rainfall
is the triggering mechanism for the
majority of slides and, therefore,
drainage improvements are important
mitigation measures. Surface swales

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Packet Pg. 1023 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 359
Letter Commenter Date Comment Combined Response
Individuals (C)
and subsurface drainage can help
avoid saturation of the soil.” P. 102
The Vista Mar Project proposes to
pave over the existing natural surface
drainage swale and probable wetland
with a driveway and retaining walls,
eliminating its ability to manage runoff
on the only relatively flat area of the
site.

B. “For steep slopes in excess of 50%
(Vista Mar site has an existing 52%
average slope), the slopes should
contain a mature stand of grass or
other type of groundcover. However,
shrubbery, brush and trees appear to
be more harmful to the overall
stability of steep slopes and should be
avoided.” P. 102
Because the Vista Mar project
removes 57 trees, 6 of which are
heritage, the project proposes to plant
many new replacement trees on these
steep slopes. Adding insult to injury,
the Planning Commissioners actually
added a substantial number of
additional trees to be planted as a
condition of approval. The planning
staff made no mention of the
incompatibility of this condition with
the General Plan Safety Element in the
staff report or during the public
hearings. Senior Planner Christian
Murdock even assisted in writing a
new condition of approval to add
more trees during the October 19th
hearing here the project was
approved.

C. Short term action item 1, on page
112 says, “Enforce and promote
ordinances requiring geotechnical site
investigation for any site with an
average slope exceeding 15% prior to
allowing site development. The
impacts of increased water runoff
from proposed development should
be determined as part of the
geotechnical study prior to site
approval.”
The water runoff cannot be accurately
calculated without full soils analysis
that ascertains the underlaying soils,
rock depth and water table. No
borings were done in the area of

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Packet Pg. 1024 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 360
Letter Commenter Date Comment Combined Response
Individuals (C)
proposed buildings as part of this
application and so this information
was not available to the civil engineer
in the design of these systems. The
1991 soils report we found in the
records shows water seepage in
August, which could indicate the
presence of a spring. We, our
consulting engineer, Cliff Bechtel, and
our consulting Geology/Hydrology
expert, Steven Bond, have previously
argued the deficiencies in Javier
Chavarria’s drainage calculations.

In the 1991 geotechnical
investigations we found, William
Cotton and Associates wrote, “The
stability of active and historic
landslides at the site should be more
fully evaluated. Geologic cross
sections should be prepared
illustrating the surface profiles and
subsurface investigations of the
landslide masses. Additional
subsurface exploration should be
completed as necessary to
characterize the properties of
landslide materials and the depth of
failure. With consideration of the
prepared cross sections, the project
geotechnical consultant should
recommend any supplemental
mitigation measures which may
necessarily prevent these features
from adversely impacting proposed
site improvements. The consultant
should also address the landslide
identified by Herzog Associates in the
Vicinity of Herzog Test Pit #6.”
Why were these further thorough
investigations required in 1991 under
the very same General Plan and Safety
Element, and yet, now in 2020, the
Planning Department seems to have
abdicated their responsibilities to the
General Plan requirements by allowing
this project to get this far and
recommend approval to the Planning
Commission without a single boring in
the area of construction?
D. Short term action item 17, “Zoning
and other City ordinances should be
revised to restrict development in
hazardous areas where access is
impractical, or areas particularly prone
to hillside and coastal erosion,
landslides,” etc.

1.f
Packet Pg. 1025 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 361
Letter Commenter Date Comment Combined Response
Individuals (C)
The City Planning Department has
indeed updated its zoning ordinance
for this site, twice actually, and yet the
lack of any movement on the updates
to the General Plan are directly
hampering the ability to review the
project to these more demanding
standards that would account for the
risks associated with development on
hillsides.

1. The 2014 General Plan adds a
Hillside Preservation District (HPD)
overlay to the zoning, which
specifically calls for special controls for
any development on hillsides to:
a. Preserve and enhance their use as a
prime resource;
b. Help protect people and property
from all potentially hazardous
conditions particular to hillsides;
c. Assure that any development be
economically sound; and
d. Encourage innovative design
solutions.

HPD zoning regulations contain a
formula for allowing a certain amount
of development area based on
the project’s average slope. 40% is the
maximum slope for which ANY
development is allowed. The
Vista Mar average slope is 52%.

2. The 2020 Draft General Plan
changes the zoning of this site to ROSA
– residential/open
space/agriculture, limiting
development to .2 units per acre. At

1.2 acres, this site would not even
support one home.

As you can see, previous planning staff
understood the risks of development
on this hillside and recommended
zoning changes that consistently
prohibit all development on this site.

And yet the current planning
department
staff report for the public hearing on
August 3rd erroneously said there
were no future proposed zoning
changes
to this site, thereby misleading the
Planning Commissioners. So here we
are, wasting everyone’s time and
money
in reviewing a project with 8 units on
this steep site with identified hazards,

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Packet Pg. 1026 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 362
Letter Commenter Date Comment Combined Response
Individuals (C)
a sea of retaining walls up to 25’
high, and over 6,000 cubic yards of
grading (by comparison San Mateo
County sees any grading over 250
cubic
yards as excessive and requires a
separate discretionary grading
permit).

As I have argued in several previous
letters, the project as currently
designed does not comply with the
1980
General Plan standards for this site
that on page 36 specifically describes
this part of Pacifica,
“A large steep area along Monterey
Road and Norfolk Place, between
Norfolk and the rear of the single-
family lots on
Heathcliff, has been planned and
zoned for low density residential
development. Each site proposed for
development should
have a thorough geotechnical
investigation. In recognition of the
high visibility of the area, innovative
design solutions
should be proposed which minimize
height, building mass, and retaining
walls to the extent feasible.”
The Planning Department and
Planning Commission that reviewed a
very similar proposal for this site
proposed
by the same engineer, Javier
Chavarria, in 1991 unanimously voted
it down for many of these same
reasons I
have argued. (Exhibit F from my
10/18/20 letter, included in the
current Drive folder). The current staff
report
for this meeting on the bottom of
page 2 is misleading, as the 1991 City
Council upheld the strict requirements
that were imposed on this project by
the Planning Commission, Planning
Department, and the City Engineer. I
encourage you to read this report as it
shows the planning department’s
clear review in relation to the 1980
General Plan. When Javier Chavarria
pulled the application on March 31,
1992, he said it was because he could
not comply with the strict
requirements of the City’s

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Packet Pg. 1027 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 363
Letter Commenter Date Comment Combined Response
Individuals (C)
Geotechnical Consultant in time.

The current Vista Mar project proposal
should not have been approved at the
October 19th Planning
Commission Hearing as it does not
comply with the 1980 General Plan or
the 1983 Safety Element, and I urge
the City Council to reconsider the illinformed and non-compliant approval.

C49-
51 Christine
Boles
2/8/22 I also urge the City Council to pressure
the Planning Department to finalize
the General Plan updates as soon as
possible as an outdated General Plan
does not address the potential
hazards and required mitigations. It is
based on outdated analysis and facts
regarding changing local conditions.

Until this work has been done and
adopted, projects in hazard areas
cannot be properly designed or
reviewed. This can potentially put the
Planning Commission and the City
Council in jeopardy as you are
required to make findings that the
proposed projects risks are
“manageable”.

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

C49-
52 Christine
Boles
11/24/
20 In fact, I fear the City’s lack of an
update to the Seismic Safety and
Safety Element since 1983 is in conflict
with California Government Code,
Title 7, Planning and Land Use,
Division 1, Chapter 3, Article 5
regarding Authority for and Scope of
General Plans Here is a link to that
section of the state code.
https://leginfo.legislature.ca.gov/faces
/codes_displayText.xhtml?lawCode=G
OV&division=1.&title=7.&part=
&chapter=3.&article=5. Section 65302
(g)(2) says, “The safety element, upon
the next revision of the housing
element on or after January 1, 2009”
shall be updated to include more
information about flood hazards. As I
understand it, Pacifica’s current
Housing Element was approved in
2015, after the 2009 cutoff, and yet
the current Safety Element still dates
to 1983.

In addition, section 65302 (g)(3) says,
“Upon the next revision of the housing
element, on or after January 1, 2014,
the safety element shall be reviewed
and updated as necessary to address
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

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Packet Pg. 1028 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 364
Letter Commenter Date Comment Combined Response
Individuals (C)
the risk of fire…” Section 65302 (g)(4)
also requires any revisions to the local
hazard mitigation plans after 2017 to
review and update the safety element
“as necessary to address climate
adaptation and resiliency strategies
applicable to the city or county.”
This seems to indicate that the Safety
Element draft as part of the 2014
General Plan update may no longer be
valid as its’ data was taken from
studies done in 2009 and even the
data from those studies is woefully
inadequate concerning hazard zones.

An updated EIR will take some time to
prepare and circulate, and revisions to
the 2014 General Plan and Safety
Element will surely be needed to meet
these state requirements. I would
question how much longer we will
need to wait for an update, and
whether development projects can
continue to be approved in the
meantime.

C49-
53 Christine
Boles
2/8/22 Fortunately for residents of Pacifica,
as of January 1, 2022, the state will
now require all municipalities to
update the safety element on a
maximum 8-year timeline coinciding
with required housing element
updates. These updates will need to
include climate adaptation and
environmental justice elements, which
are of particular importance to
residents. These state requirements
have both legal and financial
implications for the City of Pacifica in
the near term, and I just want to make
sure that the City Council and Planning
Department are working to address
them now as the technical studies
necessary to update these elements
will take some time to prepare and
proces
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

1.f
Packet Pg. 1029 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 365
C50: Karen Clark, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C50-1 Karen Clark 3/7/22 Residential Development Projections To begin with, this draft report only has a scope of
990 additional housing units. Pacifica is supposed to
build 1842 housing units in the next 8 years as
determined by RHNA. I don't understand how this
report is valid when all the areas that are explored
and defined in a 1000 page report only are reporting
on HALF the number of projected homes, many of
which may have two or more people in them.

Whether this is new residents or current Pacificans
moving into new units, this affects everything in
terms of traffic, utilities, city resources, and the
effects on wildlife and surrounding open space.

In addition, with the passing of SB9 and SB10, it
appears that the numbers should be even higher
given that lots can be split and multiple residents can live in each new unit. I am not finding any reference
to these numbers in this environmental draft report,
which makes it look as if it was written in 2014 and
never updated except for a few new maps and a new
cover page.

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. As stated on DEIR p. 3.1-10,
“buildout” refers to the hypothetical
situation where development anticipated
by the Proposed Project has occurred. 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,
existing use and assessed value ratio, and
land use designation. Please see Master
Response 3: Buildout and RHNA.

C50-2 Karen Clark 3/7/22 Hillside Preservation District and Annexation I am pleased to see that the city has prioritized
keeping the Hillside Preservation District zoning
regulations. However it seems that the city is
constantly granting variances to this, which sort of
negates having the zoning at all. I am particularly
concerned about areas of Linda Mar near my
neighborhood, and the proposed Linda Mar Woods
development.

The entire area near my house is marked as potential
landslide area. I am glad to see the inclusion of
geotechnical studies required for any site
development in hillside areas.

It seems that there may be loopholes when it comes
to zoning new areas of unincorporated San Mateo. I
was particularly alarmed to see reference to
Shamrock Ranch and potential annexation,
subdivision and lot development mentioned. These
are crucial areas to keep as open space.

The comment is noted. Policies contained in
the updated General Plan, once adopted,
will complement additional standards
contained in the Hillside Preservation
District zoning regulations.

C50-3 Karen Clark 3/7/22 Tribal Consultation Guidelines Under the area where the DEIR is discussing SB 18,
which requires that the city consult with relevant
Native American tribes about the impact of the
general plan, I find it unacceptable to say there were
“no responses” from tribal contacts and to leave it
that. Who was contacted? How? Was it an email that
may or may not have gone to the correct person?
Was there any follow-up? I find it unconscionable that
there has not been more effort to include Native
peoples and their input besides “there was no
response.”
The Tribal Consultation process was
documented in DEIR Chapter 3.8-3 and 3.8-
4: "In accordance with SB 18 and AB 52, the
City contacted the NAHC in March 2020 to
request
a consultation list of tribes traditionally and
culturally affiliated with the Planning Area.

The NAHC provided a list of five tribes—
Amah Mutsun Tribal Band of Mission San
Juan Bautista,
the Costanoan Rumsen Carmel Tribe, the
Indian Canyon Mutsun Band of Coastanoan,
Muwekma Ohlone Indian Tribe of the SF

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Packet Pg. 1030 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 366
Letter Commenter Date Comment Combined Response
Individuals (C)
Bay Area, and the Ohlone Indian Tribe. The
City
contacted the five listed tribes and received
no responses.

Pursuant to SB 18 and AB 52, the City also
requested a search of the NAHC’s Sacred
Lands File and to obtain a list of California
Native American tribes whom the City
would engage for the purposes of avoiding,
protecting, and/or mitigating impacts on
cultural resources. A search of the Native
American Heritage Commission (NAHC)
Sacred Lands File for the Planning Area in
December 2018 had positive results,
indicating there is potential for the Planning
Area to contain tribal cultural resources
from past Native American activities.

C50-4 Karen Clark 3/7/22 Wildfire
This report does not have recent data. The opening
paragraphs in this section do not give any data since
2013 for San Mateo County, which is outrageous
given the CZU fire in 2020. The last listed wildfire in Pacifica is also incorrect, as there have been fires in east Sharp Park, above Oceana High School, and one
off Fassler above the Rockaway Beach neighborhood,
all since 2015. The area south of Higgins Way, which is in area of proposed development with an application
currently at the Planning Department, is listed as an
extreme fire area by Cal Fire:
https://osfm.fire.ca.gov/media/6526/fhszs_map41.jp
g
However, the maps in the DEIR do not show this at all.

Figure 3.14-1 shows only a few spots of high threat,
when in fact the entire area is an extreme fire danger.

It is unconscionable to prepare an environmental
report that doesn't fully explore this greatest danger
to all of Pacifica residents. Given the forest, filled with eucalyptus, that surrounds the neighborhoods of
Linda Mar, Pedro Point, and Park Pacifica (as well as
Vallemar and Rockaway Beach), it is imperative that
the DEIR gets this right.

If this is highlighted properly, in turn, then the
evacuation routes must be detailed and improved as
well. With the addition of the listed 990 units (but
really 1842, as described above), which may be ADUs,
huge developments as proposed for Linda Mar or
above Vallemar, it is extremely unclear how people
will evacuate in a fire. It is a Paradise, California
situation waiting to happen.

The comment is noted. An update about
the CZU fire will be added in the DEIR errata
using language from the MJ-LHMP. The text
is thereby amended on DEIR p. 3.14-2: "The
most recent wildfire in Pacifica was a 2015
wildfire that burned 2.5 acres of trees and
brush within the City limit. The August 2020
CZU Lightning Complex in Santa Cruz and
San Mateo Counties was caused by a
reported 12,000 bolts of lightning. A
Federal Disaster was declared for this fire
(Declaration DR-4558) was made for the
period of August 16-September 26, 2020."
(Wildfires; CZU Lightning Complex), August
16 – September 26, 2020." This addition
does not change findings of significance.

The data and information referenced in the
DEIR, including the data used to prepare the
referenced maps, was the latest and most
current available at the time the NOP was
released and remains the most current
available as of publication of this FEIR.

Please see Master Response 5: Wildfire for
more information on data used for mapping
and the adequacy of analysis.

Impacts related to evacuation routes
(including impairment of an adopted
emergency response plan or emergency
evacuation plan) are described in Impact

3.14-1. As the DEIR notes, implementation
of the plan would not interfere with any of
the steps or procedures in Pacifica's
evacuation plans. Areas where evacuation
response is challenged is described on DEIR
p. 3.14-4. As noted in Impact 3.14-1, "The
Proposed Project continues and builds upon

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Packet Pg. 1031 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 367
Letter Commenter Date Comment Combined Response
Individuals (C)
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). Additionally, emergency
access is also addressed at the project level,
and any 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.

Thus, the DEIR's conclusion of "less than
significant" is accurate. Please see Master
Response 5: Wildfire and Master Response
7: Emergency Access for more information.

C50-5 Karen Clark 3/7/22 Wildlife Corridor Maps
The map of Sensitive and Critical Habitat, Figure 3.7-3, seems completely inadequate and useless. To say that
the ONLY wildlife corridor in Pacifica is from Milagra
Ridge over to Sharp Park is absurd and does not seem
researched at all. Pacifica's location to the hundreds
of acres of open space, including Montara and San
Pedro Mountains, Sweeney Ridge, and Mori Point
indicate that much more attention should be paid to
this issue in this environmental report.

I can speak to my area of Linda Mar. The old San
Pedro Mountain Trail is regularly used by all kinds of
animals and bobcat and mountain lion scat is often
left on the trail. Recently the the city of Pacifica has put up signs recently acknowledging mountain lion
activity at the start of the trail at the end of Higgins Way. Figure 3.7-3 is completely inadequate as it
Please see response to comment A2-4 for
more information on wildlife movement
corridors.

1.f
Packet Pg. 1032 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 368
Letter Commenter Date Comment Combined Response
Individuals (C)
pertains to Linda Mar. The area off Adobe, parts of
Shamrock Ranch. All of the land off of Old San Pedro
Mountain Road is not listed as a wildlife corridor,
when local walkers and cyclists have recorded video
of seeing bobcats, mountain lions, and other
mammals using the trails and living in the woods of
San Pedro Mountain.

C50-6 Karen Clark 3/7/22 Parking and Traffic
This area seems really outdated and includes little
information as to how Pacifica traffic has changed
since the pandemic. The numbers for the beach
parking at Pacifica State Beach are really low, and do
not indicate the level of insanity that we as citizens
experience every weekend as throngs of people come
and fill the lots (half the time not paying anything),
park on side roads, and leave their trash everywhere.

In addition, once again given that the required
housing unit number is DOUBLE what is listed here, I
don't understand how these numbers for traffic are
viable. More people equal more traffic and increased
danger when it comes to evacuation on the one
roadway we have in and out of the city—Highway 1.

It seems like this has been glossed over, particularly
with lines like CI-G-7, which states, “In consultation
with Caltrans, seek solutions to ease the traffic
congestion that occurs on Highway 1 near Reina del
Mar, Fassler and Linda Mar intersections.” [I should
point out that this statement is ridiculous given the
Planning Department already has applications in
review that are adding HUNDREDS of homes and
people to these exact areas.]
This comment is noted. Parking and
congestion is not a topic of required
analysis under CEQA. The DEIR does
address impacts related to VMT as part of
Impact 3.2-2 on DEIR p. 3.2-40. For this
DEIR and GP update, traffic analysis was
conducted in 2018 and 2019. As stated
under Impact 3.2-4 on page 3-45,
implementation of proposed General Plan
policies will improve connections between
communities, providing addition access
routes, and ensure that inadequate
emergency access does not occur and will
result in a less-than-significant impact.

Please also see Master Response 3:

Buildout and RHNA for more information.

C50-7 Karen Clark 3/7/22 But in closing, I would like to say several things: one, how grateful I am that they city is updating its General Plan, and two) that the effort made in this DEIR is for the most part admirable. But please, for the sake of
the General Plan and the liability of the city for the
next twenty years, do the right thing:

Adjust the projections for ALL areas to raise the
housing units to 1842 required by RHNA. That means
include figures for increased traffic, pollution, land
use, drain on utilities and biological resources.

Update the maps, particularly for wildfire, landslides, and biological resources.

Update the narrative in those corresponding areas
above so it matches the maps and tables.

Only then can we use it with the General Plan to be a
useful and guiding document.

Thank you for your time.

The comment is noted. See Master
Response 3: Buildout and RHNA for more
information on the adequacy of buildout
and CEQA analysis of the forthcoming
Housing Element. Please see Master
Response 1 for more information on how
General Plan-related comments will be
addressed.

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Packet Pg. 1033 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 369
C51: Gail Benton Shoemaker, 3/1/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C51-1 Gail Benton
Shoemaker
3/1/22 The Guiding Principle CO-G-10 in the DEIR (and General Plan) instructs the City to “Conserve trees and encourage native forestation and planting of appropriate trees and vegetation”. This is an excellent guiding principle and reflects the intent of a Tree City USA. There are a couple of cases on pages 85 and 560 where other guiding principles are mislabeled CO-G-10. Can these be relabeled?
These policies will be
renumbered in errata. They
do not change findings of
significance.

C51-2 Gail Benton
Shoemaker
3/1/22 Although the Clean Air and Energy and Greenhouse Gases chapters of DEIR acknowledge the value of trees, the Natural Resources Chapter is less than thorough. It doesn’t acknowledge the concept of the urban forest as a whole, and mentions only a few species of trees. In the section titled Urban/Developed it doesn’t recognize that trees in neighborhoods are at risk due to several issues such as Heritage Tree Ordinance violations, or acknowledge the environmental contributions of these trees other than habitat for wildlife. As climate change warms California, growing the urban forest with diversified species will become even more important to keep cities livable. Please add these points to the Natural Resources Chapter.

Benefits of trees beyond
habitat and impacts to GHG
are not required topics of
analysis for CEQA and are
thus not included in the
DEIR. 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
C51-3 Gail Benton
Shoemaker
3/1/22 In Figure 3.7-1 Vegetation in the DEIR (Figure 7-2 in the General Plan) part of the information comes from the Department of Forestry in 2005. Some of this information is either outdated or in error. For example, the North side of Vallemar is labeled as Eucalyptus, but it is primarily Monterey Cypress and Pine, with only a few Eucalyptus trees. Current online resources such as iTree can more accurately assess tree canopy. Please update this map with more accurate information.

The General Plan and DEIR
make use of best available
evidence from reputable
federal and State
governmental sources.

C51-4 Gail Benton
Shoemaker
3/1/22 As stated above Pacifica’s urban forest includes all trees within the city limits. Unfortunately Figure 3.7-1 labels neighborhoods as “urban” with no indication of trees and other vegetation. Can the “urban" areas be relabeled as “neighborhood" with the presence of trees identified? Most cities with Tree City USA status regard trees as infrastructure, providing services such as controlling storm water and reducing air pollution. In addition, research shows that neighborhoods with trees have higher property values and greater health benefits. Having an accurate representation of all trees in Figure 3.7-1 will help Pacifica manage this important resource. Please change Figure 3.7-1 to reflect the entire urban forest.

Please see response to
comment C41-3.

C51-5 Gail Benton
Shoemaker
3/1/22 There is no Implementing Principle to correspond with the Guiding Principle CO-G-10. Most Tree City USA cities have Canopy Goals for the urban forest that guide the actions of staff and citizens.

Tree City Pacifica is requesting that Pacifica establish a Canopy Goal. Please add an Implementing Principle that states “Adopt an aspirational Canopy Goal to promote the protection and
expansion of the urban forest”.

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Packet Pg. 1034 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 370
Letter Commenter Date Comment Combined Response
Individuals (C)
Comments for more
information about GP- or
SPSP-related responses.

C51-6 Gail Benton
Shoemaker
3/1/22 In the DEIR the Heritage Tree Implementing Principle CO-1-41 states “Protect trees designated by the City Council as having special value, according to the terms on the Heritage Tree Ordinance”. In the General Plan, Heritage Trees are under principle CO-I-39 which has different wording. Please reword both of these Implementing Principles to better reflect the purpose of the Heritage Tree Ordinance, such as “Protect essential trees in Pacifica’s Urban Forest by enforcing the Heritage Tree Ordinance".

These inconsistencies are
corrected in errata. These
clarifications do not change
findings of significance in the
DEIR.

C51-7 Gail Benton
Shoemaker
3/1/22 The Sharp Park Specific Plan 5-1-4 promotes the addition of curb bulb outs to plant street trees along Palmetto as well as east west connections. Research shows trees promote commerce, so this would be a notable addition to this plan. Is this reflected in the DEIR?
Effects on commerce are not
required topics of analysis
under CEQA, nor are they
included in the DEIR.

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. 1035 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 371
C52: Suzanne Moore, 3/3/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C52-1 Suzanne
Moore
3/3/22 QUESTION: an increased
inclusionary zoning of 20%,
similar to East Palo Alto, would
provide more low income units.

Can Pacifica commit to an
increase? Please comment.

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.

C52-2 Suzanne
Moore
3/3/22 QUESTION: What mitigation
does the City plan to reduce
displacement and assure that
residents are compensated for
moving costs and/or find
housing at their prior rent? A
rental registry will provide
much-needed data about
current occupancy, rates,
availabilities, communication
source, and method for
ascertaining displacement.

Please comment.

The DEIR must analyze if implementation of the Proposed Project would displace substantial numbers of existing housing units or people, necessitating the construction of replacement housing elsewhere. As noted in Impact 3.1-4, Development following the Proposed Project would result in modest land use changes compared to the existing General Plan. The majority of developed land in the city is comprised of residential uses, which are not anticipated to undergo significant land use changes under the Proposed Project. The Proposed Project focuses infill development opportunities in underutilized commercial areas in Pacifica, while the Proposed Project’s policies seek to preserve existing neighborhoods. Because the Proposed Project is long-range in nature, it is possible that some residential uses may convert to higher density residential or mixed uses; however, the Proposed Project will increase the overall number of dwelling units (990 new dwelling units), providing opportunities for any displaced residents to find accommodations within the city. Meanwhile, the Plan would also support the development of additional jobs, while featuring policies to both retain and foster existing businesses and attract new ones.

C52-3 Suzanne
Moore
3/3/22 QUESTION: limits Air B&B
conversion of housing from
long-term housing. Long term
rental residents have been
evicted for unit conversion to
Air B&B. Pacifica could limit
conversions if vacancy rates are
below 5%. Pacifica could also
create a transparent database
that provides permits
dispensed. Please comment.

C52-4 Suzanne
Moore
3/3/22 QUESTION: a dedicated city
housing funding source has
been necessary in other
communities to participate in
housing preservation. In my
opinion, it is imperative for
Pacifica to create this fund.

Ways to fund it include transfer
tax, commercial linkage fees,
vacancy tax. Please comment.

C52-5 Suzanne
Moore
3/7/22 QUESTION: Long-term rentals
have been evicted for
significant repairs. Better
tenant protection could include
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR. However, the comment addresses the content of the Proposed Plan and will be shared with decision-makers in that context. Please see

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Packet Pg. 1036 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 372
Letter Commenter Date Comment Combined Response
Individuals (C)
evidence that permits have
been pulled in advance of the
eviction and tenant relocation
benefits in the form of marketrate first, last, and deposit.

Please comment.

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

C52-6 Suzanne
Moore
3/3/22 QUESTION: these models have
been successful in other
communities to create
homeownership at affordable
levels and provide a model for
affordability in perpetuity. Can
Pacifica investigate this as an
option to adopt to include first
right to purchase? Please
comment.

C52-7 Suzanne
Moore
3/3/22 QUESTION: a dedicated city
housing funding source has
been necessary in other
communities to participate in
collaboration with nonprofits.

In my opinion, it is imperative
for Pacifica to create this fund.

Ways to fund it include transfer
tax, commercial linkage fees,
vacancy tax, landlord tax.

Please comment.

C52-8 Suzanne
Moore
3/3/22 QUESTION: I understand there
are potential penalties for
adopting a plan which does not
meet specified RHNA goals.

Explain why this projection will
not put our community at risk?
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.

C52-9 Suzanne
Moore
3/3/22 QUESTION: What is the status
of the Local Coastal Plan, how
can consistency between
documents be assured?
Please see response to comment C30-8.

C52-10 Suzanne
Moore
3/3/22 QUESTION: a TDM Program
could evaluate and provide
funding for anticipated city
growth and create muchneeded transit foundational to
city functioning. Please
comment.

Please see response to comment C46-30 for more information about C/CAG's TDM strategy and the Proposed Project's
supplemental mitigation policy.

C52-11 Suzanne
Moore
3/3/22 The DEIR has maps of fire,
landslides, coastal erosion that
are outdated. Others in our
community have already
brought this to the City's
attention. As we create our
General Plan and our future
vision for Pacifica, safety is a
priority. Please comment on
Maps in the DEIR represent the latest appropriate and available data. Please see Master Response 5: Wildfire and response to comment C22-10 for more information on landslide and erosion mapping.

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Packet Pg. 1037 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 373
Letter Commenter Date Comment Combined Response
Individuals (C)
updating maps and resources
to assure safety in construction
of new housing.

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Packet Pg. 1038 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 374
C53: Cherie and Bruce Chan, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C53-1 Cherie and
Bruce Chan
3/8/22 We are writing to you again to voice our
concerns over the proposed changes to the Land
Use designation in the Pedro Point Basin (aka the
San Pedro Ave Site) from Visitor‐Serving
Commercial Uses to a new Residential Mixed‐Use
Designation. I urge you to listen to your my
neighbors—who have consistently advocated
against this ill‐advised and potentially dangerous
Land Use Change. This change commits the City
of Pacifica towards an avoidable battle against its
own Citizens, Science, the California Coastal
Commission, and the rising tides of the Pacific
Ocean.

Proposing to change the basic framework of our
City’s long‐term land use designation with the
aim of “fixing” the affordable housing crisis with
new development in a seasonal wetlands subject
to frequent flooding and tsunami inundation is a
sham designed to maximize profits in the short‐
run, while leaving the City and its Citizens to
clean up the inevitable disaster. Inexplicably
putting the city at substantial financial and legal
risk benefits only one person‐‐the land owner‐‐
who purchased the swamp in 1997, well after the
Coastal Act was passed and the 1980 Local
Coastal Land Use Plan and General Plan were
adopted, at the expense to all Pacifica Citizens
and Visitors.

Below are the many reasons documented below,
we describe how the City has continued to bias
its decisions towards the desire of one
landowner to modify a known wetlands to
maximize short‐term financial gains at profound
expense and risk to the City, the Environment, its
Residents, and all who wish to enjoy and recreate
at or near California’s Coast.

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

C53-2 Cherie and
Bruce Chan
3/8/22 Under the current approved 1980 Local Coastal
Plan, permissible land uses are described as the
following:
“The designated land use for this area is
commercial with emphasis on coastal related
and/or visitor-serving uses. By combining all of
the parcels in the area between Danmann and
San Pedro Avenue, Highway 1 and the railroad
berm and developing them as an integrated
project along a realigned San Pedro Avenue, this
small, oceanside commercial center could be
rejuvenated and expanded to become an
attractive visitor destination, as well as provide
for neighborhood retail needs" … adding a
This comment contains an error; land use
classifications and applicable densities and
intensities are described in Table 2.3-1. The
maximum FAR for CRMU is 0.5. As described
in Master Response 3: Buildout and RHNA;
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
also see Master Response 4: Undeveloped

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Packet Pg. 1039 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 375
Letter Commenter Date Comment Combined Response
Individuals (C)
cultural center for performing arts and an
attractive motel could, if carefully designed,
enhance the appearance of this area and provide
visitor services near the shoreline. …
Small scale, rustic design and ample landscaping
throughout the commercial development would
complement the existing attractive design
elements in the Pedro Point area. Adequate
public access through the development to the
shoreline and a general orientation to coastal
related/visitor-serving uses within the project
would be appropriate in ·this location. 1’ As
described by the PPCA’s hired consultant, Richard
Grasetti who has submitted his testimony today,
the currently‐allowed land use caps development
at a floor area ratio (FAR) of 0.2, which means
that total development footage cannot exceed
20% of the site area. In contrast, the proposed
Land Use Designation,2 as excerpted below,
represents a radical change which will increase
density by 2.5 times, and will compromise an
entire community’s quality of life, the public’s
access to one of the Bay Area’s best family‐
friendly beginner surfing beaches, and preclude
the opportunity sustainable visitor‐serving jobs
while greenlighting development on an
Environmentally Sensitive Habitat. The DEIR
inexplicably claims that 70 houses will be added
(Table 2.4‐2: Additional Housing Units by Land
Use Type of the Draft EIR at page 2‐22) and that
100 jobs would be created (Table 2.4‐3) through
this land use change; yet, as discussed by the
PPCA, the City fails to provide any analysis to
show how this could be accomplished, and create
the requisite Environmental Impact Report which
addresses these proposed changes.

Rather, the City proposes a new The Coastal
Residential Mixed Use (CRMU) with an FAR of

5.0, two and a half times greater than the current
density, to align with this flyer, which the current
property owner has been distributing, without
any input from the PPCA, although the PPCA has
attempted, on several occasions, to present the
property owner with commercially‐viable
Recreational uses for the Field, such as Open‐Air
dining, a Food Truck Festival, a Drive‐In Movie
Event, and Food trucks.

San Pedro Ave Sitess for more information on
how specific land use policies reduce density
on this particular site.

C53-3 Cherie and
Bruce Chan
3/8/22 Section 30006: Public Participation “the public
has a right to fully participate in decisions
affecting coastal planning, conservation and
development; that achievement of sound coastal
conservation and development is dependent
upon public understanding and support; and that
This comment is noted. It is not related to the
adequacy of DEIR analysis. The public
participation process is described on DEIR p.

2.1. No further response is required.

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Packet Pg. 1040 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 376
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Individuals (C)
the continuing planning and implementation of
programs for coastal conservation and
development should include the widest
opportunity for public participation.” FAIL: The
Pedro Point Community has consistently opposed
the introduction of mixed‐Use land use
designations in the Pedro Point Field; but it has
not been heard. See more below.

C53-4 Cherie and
Bruce Chan
3/8/22 Section 30212 New development projects – (a)
Public access from the nearest public roadway to
the shoreline and along the coast shall be
provided in new development projects except
where:
(1) [conflict] public safety, military security.
protection of fragile coastal resources,
(2) [redundant shore access]
(3) [conflict] agriculture CONSTRAINT OR FAIL:

Mixed residential land use will constrain the
three well‐established and persistent foot trails
that lead from San Pedro Avenue (the nearest
public roadway to the shoreline) to a private
beach with long‐established open public access
This comment asserts that development on
undeveloped San Pedro Avenue site conflicts
with Coastal Act policies. The project design is
not known; this is program-level DEIR. Please
see Master Response: Undeveloped San
Pedro Ave Sites. Please see Master Response
1 for more information on how General Planrelated comments will be addressed.

C53-5 Cherie and
Bruce Chan
3/8/22 Section 30221 Oceanfront land; protection for
recreational use and Development Oceanfront
land suitable for recreational use shall be
protected for recreational use and development
unless present and foreseeable future demand
for public or commercial recreational activities
that could be accommodated on the property is
already adequately provided for in the area. FAIL:

Residential development precludes recreational
use and development or conservation in a critical
wetlands. Recreational opportunities in the
neighborhood on alternate sites are precluded:
steep hillslopes, saturated residential
development.

The Pedro Point Field is less than a one‐minute
walk away from Linda Mar Beach: “The most
wellloved and well‐used beach in Pacifica!”3
Note that the community has welcomed and
encouraged allowable economic benefits from
his property such as rentals from food trucks,
rentals, or its pre‐existing use as a Golf Range.

This comment asserts that development on
undeveloped San Pedro Avenue site conflicts
with Coastal Act policies. This comment is
inaccurate and speculative. The project
design is not known; this is program-level
DEIR. Policies in the General Plan require
parks or open space as part of site
redevelopment (policy OC-I-9). PLease see
Master Response: Undeveloped San Pedro
Ave Sites. Please see Master Response 1 for
more information on how General Planrelated comments will be addressed.

C53-6 Cherie and
Bruce Chan
3/8/22 Section 30222 Private lands; priority of
development purposes
The use of private lands suitable for visitor‐
serving commercial recreational facilities
designed to enhance public opportunities for
coastal recreation shall have priority over private
residential, general industrial, or general
commercial development, but not over
agriculture or coastal‐dependent industry. FAIL:

Private residential development and general
Please see response to comment C53-5

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Packet Pg. 1041 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 377
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Individuals (C)
commercial development are allowed to have
priority over and exclude visitor‐serving
commercial recreational development.

C53-7 Cherie and
Bruce Chan
3/8/22 Section 30240 Environmentally sensitive habitat
areas
(ESHA); adjacent developments
(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. FAIL: Residential development
density range would require fill and drainage of
seasonal wetlands and degrade ESHA wetlands.

See Testimony of Dr. Peter Baye, submitted to
the Council on July 7, 2014 and posted at
pedropoint.org/the‐pedro‐point‐field
The General Plan and DEIR includes policies
to protect ESHA and wetlands at time of
project review. These policies include:
(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.
(LU-I-2) Land Divisions in the Coastal Zone.

Continue to require coastal development
permits for all land divisions within the
Coastal Zone. Land divisions in the Coastal
Zone shall be:
• Designed to minimize impacts to public
access, recreation, and coastal resources.
• Designed to minimize site disturbance,
landform alteration, and the removal of
native vegetation for development or fire
safety.
• Prohibited on properties that include any
areas that are within or adjacent to an
Environmentally Sensitive Habitat Area
(ESHA) unless the resulting parcels can be
developed without building or requiring
vegetation clearance in the ESHA or ESHA
buffer, or unless the resulting parcels are set
aside for conservation.
• Permitted only in areas with adequate
public services to serve development on the
resulting parcels.
• Any land division that would result in a
parcel that could not be developed in
accordance with the policies of this LCLUP is
not allowed.
(CO-G-11) Other Environmentally Sensitive
Areas. Protect other potential ESHAs, high
habitat value areas, and wildlife movement
corridors from development that would
significantly disrupt habitat values.
(CO-I-27) Verification of ESHA. Prior to any
proposed development in an ESHA or
potential ESHA, require that a habitat survey
be conducted by a qualified botanist or
biologist. The habitat survey will verify
whether the site is an ESHA, and document
the extent of the sensitive resources,
document potential negative impacts to the
habitat, and recommend appropriate

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Packet Pg. 1042 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 378
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Individuals (C)
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 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,

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Packet Pg. 1043 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 379
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Individuals (C)
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.
(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 standalone 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.

Please see Master Response 6: ESHA and
Master Response 4: Undeveloped San Pedro
Ave Sites for more information. For GeneralPlan related comments, please see Master Response 1.

C53-8 Cherie and
Bruce Chan
3/8/22 Section 30242. Lands suitable for agricultural use; conversion All other lands suitable for
agricultural use shall not be converted to
As noted on DEIR p.5.5-11, The Proposed
Project does not involve any changes to
existing agricultural or forestry resources or

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Packet Pg. 1044 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 380
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Individuals (C)
nonagricultural uses CONFLICT: Residential—
both horizontal and vertical‐‐development would
require placement of pad fill (flood protection;
100 yr floodplain) and drainage) precluding
agricultural uses. (Adjacent strip of land between
the Pedro Point Field and the berm was
previously used for a Llama and an Emu)
policies affecting agricultural or forestry
activities. The site in question is not farmland.

Thus, this does not represent a conversion of
farmland as designated under the Farmland
Mapping and Monitoring Act, and does not
constitute an impact to agricultural
resources.

C53-9 Cherie and
Bruce Chan
3/8/22 Section 30251 Scenic and visual qualities
The scenic and visual qualities of coastal areas
shall be considered and protected as a resource
of public importance. Permitted development
shall be sited and esigned to protect views to and
along the ocean and scenic coastal areas, to
minimize the alteration of natural land forms, to
be visually compatible with the character of
surrounding areas… CONFLICT: Residential
development would infill the last open space in
coastal lowlands from Linda Mar to Pedro Point.

Vertical Development would greatly obstruct
existing views and enjoyment of the ocean.

The DEIR analyzes scenic vistas on page 3.9-
14 through 3.9-22. Typically, scenic vistas
would include mountain ranges, ridgelines, or
bodies of water as viewed from a highway,
public space, or any other area designated for
the express purpose of viewing and
sightseeing. The view across the site is not a
scenic vista (not along a coastal view corridor,
have any prominent ridges or prominent
landforms as seen on Figure 3.9-1).

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

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

C53-10 Cherie and
Bruce Chan
3/8/22 Section 30253 Minimization of adverse impacts
New development shall do all of the following:
(a) Minimize risks to life and property in areas of
high geologic, flood, and fire hazard.
(b) Assure stability and structural integrity, and
neither create nor contribute significantly to
erosion, geologic instability, or destruction of the
site or surrounding area or in any way require the
construction of protective devices that would
substantially alter natural landforms along bluffs
and cliffs. […] FAIL. Most of field lies
approximately 15‐17 feet in elevation above
Mean Sea Level (MSL), only about 3‐5 feet above
the marsh and high tide beach at the mouth of
San Pedro Creek. Residential development
requires flood protection and drainage.

Wave runup to the field depends on the
nonengineered privately owned berm which is
not maintained by Pacifica. Residential
development would likely require armored flood
protection structures as sea level rises. Alluvial
soils (historical wetland) of the field have the
same relative liquefaction (earthquake shaking)
potential as diked bay muds and marshes in San
Francisco Bay, and are located in a Tsunami
Evacuation Zone.

This programmatic EIR adequately addresses
the topics raised in this comment:

While the area in question does not fall
within a FEMA 100-year floodplain, risks due
to coastal flooding are described on p. 3.5-11.

Tsunami risks are described on p 3.5-11 of
the DEIR. Impacts related to tsunami and
flooding required under CEQA (risk of release
of pollutants due to project inundation by
tsunami or flooding) are described in Impact

3.5-4 and include description of future sea
level rise. Numerous policies in the Safety
Element of the Proposed Project protect and
restrict new development in tsunami and
flood hazard zones with flood damage
prevention programs; facilitate the cleanup of
hazardous waste and toxic pollutants; and
enforce provisions of existing State codes and
regulations which minimize risk to life and
property in areas of flood hazard. Based on
compliance with local, state, and federal
regulations and implementation of the
policies in the Proposed Project, the potential
impact from release of pollution due to
project inundation by seiche, flooding, or
tsunamis is less than significant.

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Packet Pg. 1045 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 381
Letter Commenter Date Comment Combined Response
Individuals (C)
As shown in Figure 3.6-1, the site in question
is within a Seismic Hazard Zone for
liquefaction. As described on p. 3.6-18 and

3.6-19, The Seismic Hazards Mapping Act
requires the State Geologist to delineate
various seismic hazard zones and requires
cities, counties, and other local permitting
agencies to regulate certain development
projects within these zones. Before a
development permit is granted for a site
within a Seismic Hazard Zone, a geotechnical
investigation of the site must be conducted
and appropriate mitigation measures
incorporated into the project design.

Geotechnical investigations conducted
within Seismic Hazard Zones must
incorporate standards specified by the
California Geologic Society (CGS) Special
Publication 117. As described in Impact 3.6-1,
impacts from liquefaction would be
addressed through required geotechnical
investigation under the Seismic Hazard Zone
Mapping Act, CBC requirements and standard
industry practices, and proposed General
plan policies that contain seismic safety
requirements, such as referencing known
hazard areas that must contain measures to
resist ground failure. Additionally, policy SA-I2 would prohibit development in areas of very high liquefaction risk unless detailed site
investigation ensures risks can be reduced to
acceptable levels, which would include the
portion of the site shown on Figure 3.6-2.

Thus, the Proposed Project's potential
adverse effects due to liquefaction is less
than significant.

C53-11 Cherie and
Bruce Chan
3/8/22 Section 30255 Priority of coastal‐dependent
developments
Coastal‐dependent developments shall have
priority over other developments on or near the
shoreline. Except as provided elsewhere in this
division, coastal dependent developments shall
not be sited in a wetland. When appropriate,
coastal‐related developments should be
accommodated within reasonable proximity to
the coastal‐dependent uses they support. FULL
CONFLICT. Residential development is not
coastal‐dependent, and would infill the seasonal
wetlands in the lowland floodplain of the field.

Please see Master Response 6: ESHA and
Master Response 4: Undeveloped San Pedro
Ave Sites for more information on how
development on the undeveloped San Pedro
Ave site complies with Coastal Act policies.

C53-12 Cherie and
Bruce Chan
3/8/22 Environmental Justice
Equitable coastal access is encompassed in and
protected by the public access policies in Chapter
3 of the Coastal Act. The Coastal Act’s mandates
to provide maximum access and recreational
The comment is noted. See response to
comment C34-41.

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Packet Pg. 1046 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 382
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Individuals (C)
opportunities for all, and to protect, encourage,
and provide lower‐cost visitor and recreational
opportunities embody fundamental principles of
environmental justice.

CONFLICT:
“Pacifica is home to some of the San Francisco
Bay area’s best surfing beaches. Linda Mar State
Beach is one of the most popular beginner
surfing spots in the San Francisco area” This is
also the premier family‐friendly break within a
short distance from the San Francisco Bay Area.

C53-13 Cherie and
Bruce Chan
3/8/22 The City has Failed in its Obligation to Satisfy Section 30006 of the Coastal Act: Public
Participation by Excluding Facts and Participation
Presented by the Pedro Point Community Section
30006 of the Coastal Act also states that “the
public has a right to fully participate in decisions
affecting coastal planning, conservation and
development; that achievement of sound coastal
conservation and development is dependent
upon public understanding and support; and that
the continuing planning and implementation of
programs for coastal conservation and
development should include the widest
opportunity for public participation.”
The residents of Pedro Point have consistently
acted in good faith to work with the City and the
Owner to propose a Land Use Designation which
considers the unique coastal nature and reflects
our concerns over residential development on
this lowest‐lying parcel in the neighborhood,
both as a united neighborhood and by individual
neighbors.

The DEIR claims at page 16 that The Proposed
Project was developed in response to policy
direction provided by the City Council and the
Planning Commission as well as community
concerns identified through an extensive public
participation and outreach program, including
newsletters, community workshops and public
meetings in 2008-2010, and additional outreach
2019-2021.

Indeed, we attended many of these workshops,
including the Pedro‐Point Specific workshop held
at Soul Grind in the summer of 2019. The City’s
own consultant noted that neighborhood’s
strong preference for sustainable, Open Space,
and natural recreation‐based land‐uses: the
City’s proposed Land use Change to CRMU boldly
rejects the community’s input. Below are letters
from past Pedro Point Community Association
presidents: Danny Estrella (2011) expresses the
This comment is related to the planning
process under the Coastal Act, which applies
to the LCLUP. Because this comment is not
related to the adequacy of the DEIR, no
further response is required. Please see
Master Response 1.

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Packet Pg. 1047 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 383
Letter Commenter Date Comment Combined Response
Individuals (C)
community’s strong support for a land use
designation which retains uses of the field asis.

Bruce Ferry (2013) details the extensive steps the
Community has taken to facilitate meaningful
dialogue, and Joanne Gold who again expresses a
retention of Commercial Recreation or
Conservation Uses. These letters have been
followed with hostility from decision‐makers.

C53-14 Cherie and
Bruce Chan
3/8/22 Furthermore, an internal memo from the former coordinator of the General Plan Update to the City’s Planning Director, the City has known that the Pedro Point Fields is a wetlands which needs to be properly mapped, and should not be upzoned..

See Master Response 6:

ESHA and Master Response
4: Undeveloped San Pedro
Ave Sites regarding sensitive
habitat, sensitive species,
and ESHA on the San Pedro
Avenue sites.

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Packet Pg. 1048 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 384
C54: Christine Boles, 3/6/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C54-1 Christine
Boles
3/6/22 As I read the DEIR Chapter 3.14
Wildfire and General Plan Chapters

8.5 Fire Hazards and 8.6 Public Safety
and Emergency Management, I am
again concerned that we are using
old data, and that the required CEQA
analysis to determine less than
significant impacts have not been
properly analyzed, leaving residents
and properties at increased risks of
fire and of being trapped by not
being able to evacuate when
necessary.

Please see response to comment C50-4.

C54-2 Christine
Boles
3/6/22 My comments are based on the
January release for the DEIR as I had
already annotated it prior to the new
release the week of February 14th of
a revised DEIR. I would like to
request a detailed analysis of
whether other changes were made
with the new document issue,
beyond the addition of a Table of
Contents and the deletion of the
duplicated Fire Hazard Chapter.

The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR. Per public request, the DEIR was amended with an interactive table of contents. The duplicate chapter was removed to ensure a valid Table of Contents; no other changes were made to the document.

C54-3 Christine
Boles
3/6/22 Starting on page 1 of Chapter 3.14,
note that the numbering is not
typical of other DEIR Chapters. I
would have expected 3.14-1, not just

1. These pages will be renumbered in errata. They do not change findings of significance in the DEIR.

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Packet Pg. 1049 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 385
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Individuals (C)
C54-4 Christine
Boles
3/6/22 On page 1, the DEIR says, “In
California, most wildfire damage
occurs in wildland urban interface
areas, where homes and woodland
vegetation are directly adjacent. The
majority of wildfires are started by
human activity, such as campfires,
fireworks , faulty electrical facilities,
and residential and agricultural
burning, but wildfires can also be
incited by natural causes like
lightning strikes.”
These sections of the DEIR and
General Plan do not include any
maps of Wildland Urban Interface
Zones. OPR provides free data for
mapping these areas. Planning
consultants Terrel Watt and Jared
Ikeda took the GIS date from OPR
and made a map of Pacifica’s WUI
zones – see below. Please clarify why
the City chose not to follow OPR
guidance on this issue, or provide the
appropriate map with freely
obtained best currently available
data as required by CEQA. New
guiding and mitigation measure
policies will need to be written based
on this information as WUI
designations relate to specific
building code requirements for
construction. Legal and illegal
fireworks should also be addressed
with mitigation measures given the
high fire risk they pose and the city’s
current inability to enforce the use of
illegal fireworks.

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 of preparation. Please see more
information in Master Response 5: Wildfire.

The comment states the proposed General Plan should
address the risk of wildfires from fireworks, which are illegal in Pacifica. Enforcement of existing City of Pacifica Municipal code is beyond the necessary scope of the Draft EIR. Please see more information about fire hazard and threat mapping, descriptions, and policies that reduce the impacts. The Draft EIR is concerned with analyzing the risk to exposure from wildland fires, rather than providing a comprehensive list of causes of wildland fires, which include illegal fireworks.

C54-5 Christine
Boles
3/6/22 The 2010 Existing Conditions and Key
Issues Report that informed the 2014
draft General Plan discusses wildland
urban interface zones and makes the
following recommendations on pages
5-65 and 5-91 Please clarify how
these mitigation measures are
incorporated into the 2022 DEIR and
Draft General Plan and modify DEIR
policies and mitigation measures as
required to comply with these
recommendations.

Proposed Plan policies that address these recommendations made in the existing conditions report are as follows:

Reducing risk of fire: SA-I-94: Development Review; SA-I-95:

Plan Review in Fire-Prone Areas; SA-I-96: Fire Prevention Inspections.

Evacuation: SA-I-103: Emergency Access on New Roadways, SA-I-104: Areas that Lack Emergency Access
Coordination at state and local levels: SA-I-99: Multijurisdictional Approach.

Vegetation Management: SA-I-98: Vegetation Management.

Development in VHFHSZ: Subject to State regulations as
described on DEIR p. 3.14-5, and 3.14-6, as well as policies listed above in 'Reducing Risk of Fire'.

C54-6 Christine
Boles
3/6/22 Page one of the DEIR says, “About
two-thirds of Pacifica is undeveloped,
and nearly half is protected open
space. This undeveloped land is
This comment is noted. The following text is thereby
amended: " “About two-thirds of Pacifica is undeveloped, and nearly half is protected open space. This undeveloped land is mainly on the rugged ridges that form the City’s

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Packet Pg. 1050 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 386
Letter Commenter Date Comment Combined Response
Individuals (C)
mainly on the rugged ridges that
form the City’s eastern edge and
descend down to the ocean between
Pacifica’s valley communities. Coastal
scrub is the predominant vegetation
type, interspersed with annual
grassland. Significant areas of
eucalyptus forest and mixed
woodland are present in eastern
Sharp Park and on Cattle Hill and San
Pedro Mountain.” Please add “and
southern edge” to this description as
our entire southern border is also
composed of rugged ridges with high
fire risk and a lot of highly flammable
eucalyptus.
eastern and southern edge and descend down to the ocean between Pacifica’s valley communities. Coastal scrub is the predominant vegetation type, interspersed with annual
grassland. Significant areas of eucalyptus forest and mixed woodland are present in eastern Sharp Park and on Cattle Hill and San Pedro Mountain.” This change does not affect findings of significance.

C54-7 Christine
Boles
3/6/22 Continuing on Page 1 is a discussion
of Very High Fire Hazard Severity
Zones, which is a separate overlay
created by Cal Fire to map likely burn
areas in a certain period of time. The
DEIR says, “As shown on Figure 3.11-
2, in Section 3.11, Hazardous
Materials and Fire Hazards, 470 acres
along the southwestern perimeter
within the Sphere of Influence are
designated as Very High FHSZs
(VHFHSZs).”
And yet there are no VHFHSZ areas
indicated on this map. Please amend
map as required in concert with Cal
Fire requirement. Please note that
the 2014 draft General Plan Fire
Hazards map on the right shows
extensive VHFHSZ in the southern
edge and in the center of Pacifica,
some of which is in Local
Responsibility Areas (LRA). Please
explain the discrepancies in these
maps.

Please confirm requirements for site
planning, defensible space and
construction means and methods,
which are different for sites with this
designation. New guiding and
mitigation measure policies will need
to be written.

This comment contains an inaccuracy. Figure 3.11-2 shows VHFHSZ in the Sphere of Influence. Based on the latest and best available mapping from CAL FIRE, there are no areas of VHFHSZ in Pacifica City limits (LRA). This should not be interpreted to mean that Pacifica is devoid of fire risk. Please see Master Response 5: Wildfire for more information on the adequacy of mapping. 2014 maps were contained in the 2014 draft of the General Plan update and did not reflect the state-adopted versions of the maps. Thus, they did not
reflect officially-adopted information and the current draft has corrected the information to include the officiallyadopted map.

Development in areas in the VHFHSZ are subject to
regulations under the California Fire Code, California
Building Code, and the Public Resources Code Section 4291, as described on DEIR, p. 3.14-5 through 3.14-6.

C54-8 Christine
Boles
3/6/22 Continuing on page 1 the DEIR states,
“Most of the land within the
VHFHSZs is an urban reserve or park,
and land adjacent to these areas that
is within city limits is low- and verylow density residential development.

The following clarification is thereby made: "Most of the land within the VHFHSZs is an urban reserve or park, and land adjacent to these areas that is within city limits is lowand very-low density residential development. Per the 2021 MJ-LHMP, Pacifica (within city limits) had no population or structures within very high wildland fire severity zones.

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Packet Pg. 1051 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 387
Letter Commenter Date Comment Combined Response
Individuals (C)
Per the 2021 MJ-LHMP, Pacifica had
no population or structures within
very high, high, or moderate wildland
fire severity zones. Nevertheless,
these fire severity zones are on the
periphery of developed areas in
Pacifica and could present a fire risk
to development within the city.”
We know the Multi-Jurisdictional
Local Hazard Mitigation Plan was not
properly updated for fire risk in 2021,
City Manager Woodhouse and then
Mayor Beckmeyer admitted as much
at the council meeting on November
21, 2021 when it was adopted, so
please delete those references. No
accurate map of fire hazards was
presented in the LHMP and since
adoption and filing with the county,
all fire maps were removed in the
current documents on the county
website. The LHMP therefore cannot
be used as source material for the
DEIR or Safety Element.

We also cannot know if Pacifica has
no population or structures in
VHFHSZ areas without accurate
maps. Please update the maps and
provide a detailed analysis of
structures in these land designations.

The 2010 Existing Conditions Report
and Key Issues Report copied below
shows significant portions of the city,
included some developed areas with
buildings such as Higgins Way, Adobe
Drive and Grand Avenue in Very High
Fire Hazard Severity Zones. This
designation also seems to affect the
proposed Pacifica Highlands project.

Please correct the discrepancies
between the text and the maps and
update the maps as necessary.

Nevertheless, these fire severity zones are on the periphery of developed areas in Pacifica and could present a fire risk to development within the city.” This reflects the same
conclusion as the latest and best available CAL FIRE hazard mapping. Because the DEIR uses the latest and best available fire hazard mapping from CAL FIRE in addition to fire threat mapping, the impact remains less than significant.

C54-9 Christine
Boles
3/6/22 On page 2, the DEIR states, “All of
the VHFHSZs within the Planning
Area are designated State
Responsibility Areas (SRA), where the
State of California is financially
responsible for the prevention and
suppression of wildfires, while the
NCFA has primary responsibility for
Local Responsibility Areas (LRA)
within the City limit.” Again, we
cannot know if Pacifica’s VHFHSZ
The DEIR utlized the officially-adopted map of VHFHSZ in the City of Pacifica and sphere of influence. Please see response to C54-7 for more information on the adequacy of fire
mapping . More information can also be found in Master
Response 5: Wildfire

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Packet Pg. 1052 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 388
Letter Commenter Date Comment Combined Response
Individuals (C)
areas are all in SRA areas without
accurate maps. Please update the
maps and provide a detailed analysis
and breakdown of any areas in LRA
responsibility areas and correct the
DEIR and General Plan as required.

C54-10 Christine
Boles
3/6/22 On page 2 the DEIR also states,
“Based on past occurrences (note
only dates through 2015 are
mentioned) and the geography,
weather patterns, and vegetation in
the region, it is highly likely that
wildfires will continue to occur in San
Mateo County.” While this is true,
the city fails to analyze the increased
fire risks from extended droughts
and climate change that has plagued
the entire state of California and that
has altered our local climate patterns
in the last 15 years. These all have a
high degree of probability of
compounding our risks of wildfire in
our coastal region, as was seen by
the CZU Lightening Complex fire in
August 2020 in coastal San Mateo
County. Please add data from this
event and clarify how increasing fire
risk dangers are analyzed and
mitigated in this DEIR and General
Plan.

Please see Master Response 5: Wildfire. The MJ-LHMP
includes discussion of climate change impacts on wildfire risks, and this document is included by reference in the DEIR. The clarification regarding the CZ Lightning Complex is added in errata (please see response to comment C50-4) but does not change the findings of significance in the DEIR.

C54-11 Christine
Boles
3/6/22 According to a recent report from the
United Nations Environment
Program, risk of extreme wildfires
will increase 14% by 2030 and 30%
by 2050. They conclude that nations
spend too much time fighting fires
and not enough preventing them.

Also, the latest West Coast Plover
Conference has reported that coastal
fog has decreased 30%. We can’t
expect fog protection for our highly
burnable Eucalyptus trees as we go
into the future. We need serious
wildfire alternatives AND escape
routes other than Highway 1. Please
clarify how these recent and
pertinent studies that apply to
Pacifica’s microclimate and fire risk
changes will be incorporated into the
DEIR and General Plan.

Please see Master Response 1 for General Plan-related
comments and responses. The DEIR includes discussion of increased wildfire risk on p. 3.4-8, noting "Drought
conditions also result in increased frequency, intensity, and duration of wildfires. In these conditions, fires burn hotter and spread faster. According to the California Department of Forestry and Fire Protection, between January 1, 2017 and December 31, 2017 there were 7,117 fires in California, burning a total of 505,956 acres; this is significantly larger than the 4,835 fires in the five year average in the same time interval (47 percent increase). In addition to fatalities and property damage, smoke from wildfires impairs air quality and can cause acute and chronic health impacts."
The MJ-LHMP includes discussion of climate change impacts on wildfire risks, and this document is included by reference in the DEIR. Please see Master Response 7: Emergency
Access for more information on the adequacy of the
evacuation programmatic framework and project-level
analysis.

C54-12 Christine
Boles
3/6/22 I spoke with Dave Sapsis, a Wildland
Fire Scientist at Cal Fire on 2/18/22.

He indicated that Cal Fire was
currently updating fire maps in Local
Please see Master Response 1 for General Plan-related
comments and responses. While it is possible that
development could occur in the proximity of VHFHSZ and in areas that may face higher fire threat shown in Figure 3.11-2

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Packet Pg. 1053 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 389
Letter Commenter Date Comment Combined Response
Individuals (C)
Responsibility (LRA) areas and the
drafts would be issued for review in
May 2022. These studies will have
major changes to current approved
maps due to the dramatic changes in
fire patterns in California the last few
years with climate change induced
drought and related weather pattern
changes. Language should be added
that refers to these new policies so
that the General Plan Safety Element
can be revised to properly address
our current fire risks once the new
maps are adopted. A General Plan
amendment may be necessary in
2023. Cal Fire is also working at the
request of many municipalities to
tighten the restrictions for high fire
hazard areas in relation to increased
housing density allowed under SB9.

This will also be important language
to add to protect Pacifica once these
policies are finalized and is currently
specifically relevant to Pacifica
Highlands, Linda Mar Woods and
Cape Breton, and potentially to the
four projects already submitted
under SB9.
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. These State and local provisions provide a framework for proactively managing and reducing risk associated with wildfire in the Planning Area that is appropriate based on the programmatic nature of the DEIR.

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

C54-13 Christine
Boles
3/6/22 Dave Sapsis of Cal Fire also gave me
the link to their previous analysis of
High Fire Severity Zone mapping in
Pacifica from 2008. It can be found at
this link:
https://osfm.fire.ca.gov/media/6801
/fhszl06_1_map41.pdf Please note all
the red and orange fire risk areas,
many of which are in LRA areas.

While some of this data can be
negotiated with North County Fire, a
response to my outstanding PRA
document request 22-26 that I
believe was prematurely closed,
would provide insight into NCFA’s
positions that were apparently
negotiated with Cal Fire to lower the
actual fire risks in current maps.

Given climate change and increased
fire risks the last 15 years, the actual
risk today has significantly changed
since the current maps were
adopted, as evidenced by the CZU
Lightening Complex, and it would be
reasonable to include this map for
the DEIR and GP Safety Element until
Please see Master Response 5: Wildfire. Please also see Master Response 1 for more information on GP-related
comments. The DEIR characterizes wildfire hazards within the Planning Area on pages 3.11-4 through 3.11-6 and 3.14-1 through 3.14-4, making use of data and information from CALFIRE and from the Multi-Jurisdictional Local Hazard
Mitigation Plan (MJ-LHMP) for San Mateo County. The
characterization in the DEIR includes a description of
vegetation in the Planning Area, a history of wildfire
occurrence in the Planning Area, the probability of a fire occurring in the future, and identification of Fire Hazard Severity Zones designated by CALFIRE based on factors such as fuel, slope, and weather. Two maps are included:
• Figure 3.11-2, which shows Very High Fire Severity Zones for Local Responsibility Areas (LRAs), State Responsibility Areas (SRAs), and Federal Responsibility Areas (FRAs) as designated by CALFIRE pursuant to Government Code
Section 51175. By law CALFIRE is required to designate these Fire Hazard Severity Zones, land within which is subject to various requirements in the California Building Code for the design and construction of new buildings intended to reduce the risk of loss of life and property, including requirements for building materials, defensible space clearance, and other wildland fire safety practices; and
• Figure 3.14-1, which shows Fire Threat, a measure of fuel conditions and fire potential in the ecosystem, representing the relative likelihood of “damaging” or difficult to control

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the new LRA maps are available from
Cal Fire this spring.
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.

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

C54-14 Christine
Boles
3/6/22 Page 4 of the DEIR states, “NCFA has
established the following service
ratio and response time standards:
• Service ratio standard: one
responder per 1,500 population
• Response time standards for fire
service: Four-minute travel time to
90 percent of calls for fire service,
and eight-minute travel time for all
apparatus on-scene for fire calls for
service.
• Response time standard for
Emergency Medical Services (EMS):

Under seven-minute travel time
(6:59) for first response to 90 percent
of calls.”
There is no source or date given for
this information, please confirm both
and provide the data in an appendix
to the DEIR.

This comment is noted. Response time standards were
verified with then-Deputy Fire Chief Pomicpic in 2019 via email correspondence. A reference will be added as
footnote for clarification. The correct standards are
described in Public Services, p. 3-12-2. The following
changes on p.3.14-4 are thereby made for consistency:

Response time standards for fire service:
•Service ratio standard: one responder per 1,500 population •Four-minute travel time for first due fire company to 90 percent of calls for fire service, and eight-minute travel time for all apparatus on-scene for fire calls for service.
• Response time standard for Emergency Medical Services (EMS): Under seven-minute travel time (6:59) for first
response to 90 percent of calls.

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C54-15 Christine
Boles
3/6/22 To follow up on the item above, the
following data should be provided to
ensure that required levels of service
can be met:
a. Recent census information to
confirm Pacifica’s population.
b. Number of responders currently
working in Pacifica
c. Current information about level of
service and response times mapped
to all the areas of Pacifica. As
previously indicated in Comment
Letter #3, the General Plan Existing
Conditions and Key Issues Report
dated July 2010 is outdated and
deficient in addressing response time
as traffic data shows that traffic in
Pacifica has increased significantly
since 2010.
d. Identify completed and proposed
new construction since 2010 with
location mapping to clarify which fire
stations are impacted by current and
projected growth beyond what was
assessed in 2010.
e. Full buildout calculations including
required RHNA numbers.

Please refer to response C54-14 regarding the service station ratio and a clarification to the DEIR. The response time standards were verified in 2019 correspondence with NFCA (see response to comment C54-14). Policy CEQA impacts
require analysis of new needed facilities to meet service standards, but not the service standards themselves. As described on p.3.12-29, "though the Proposed Project
anticipates the construction or enhancement of fire
protection facilities to achieve service standards, the underlying need for these activities is pre-existing. 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). Given these considerations, and Proposed Project policies set forth below to support adequate levels of fire service, this impact is expected to be less than significant for fire services." Thus, the impact is less than significant.

Policy SA-I-91 addresses support of maintaining NCFA's
adequate response times. Please see response to comment C83-2 for more information about fire station planning and adequacy of evacuation planning.

C54-16 Christine
Boles
3/6/22 Further down on page 4 the DEIR it
says, “2008 study determined that
the Vallemar, West and East Fairway
Park, Rockaway Beach, and
Rockaway neighborhoods in central
Pacifica are beyond four-minute
travel distance from northern San
Mateo County fire stations,
corresponding with the standard
response time for firstdue fire
apparatus. The full assignment
response time standard cannot be
met in Pacifica from Vallemar south.”
This section references a 2008
“Emergency Services Consulting”.

Please provide a link or a copy of the
report from this consulting effort and
hopefully more recent consultant
data given our increased population
and traffic issues.

A link to this resource is available here:
https://www.cityofpacifica.org/government/city_manager/fi re_protection_options_analysis/default.asp
C54-17 Christine
Boles
3/6/22 The bottom of page 4 states that
“Population growth will increase
existing deficiencies in service
delivery. The Fire Authority considers
the City’s geography to be the
limiting factor for delivery of fire
service. According to NCFA, a third,
mid-point station in Pacifica with a
Please see response in to comment C83-2 for more
information on fire station planning. This issue is related to the GP and not related to the adequacy of the DEIR; please see Master Response 1. Additionally, please see Master
Response 7: Emergency Access for more information on the adequacy of evacuation planning.

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truck and engine company has been
discussed for some time. The area
that currently does not meet firstresponse time standards currently has a low density of development,
and so it has fewer persons and
structures threatened by fire.

However, a new station would be
needed if the central part of Pacifica
were to experience substantial new
development, for example at the
Quarry site.” There are several other
development projects currently
proposed and being reviewed in this
area across from the quarry,
including Pacifica Highlands. This site
is in a red zone, noted as highest fire
risk in the map shown in item 11.

Analysis should be required for this
and other future projects in the
quarry and on adjacent sites to
determine the point at which a new
fire station will be required. The DEIR
should add guiding policies and
mitigation measures to ensure that
fire service levels can start to be met
with the construction of a new fire
station. The Land Use Element Maps
should also be updated to include a
proposed location for a new fire
station.

C54-18 Christine
Boles
3/6/22 Page 5 of the DEIR states that, “Since
2005, the California Building Code
(CBC) (CCR Title 24, Part 2) has
required that all new buildings
located in any Fire Hazard Severity
Zone in SRAs, or any Very High Fire
Hazard Severity Zone in LRAs, use
building materials approved for use
in wildland/urban interface areas.

Subsequent editions of the code
have specified certain roof coverings,
fire resistive wall and ceiling-floor
assemblies, wall finish materials,
hardware, insulation, and other
building materials for use in high fire
hazard areas.”
The state code requires not just new
buildings, but remodels or additions
to existing buildings of a certain size
also be required to meet these
requirements. The DEIR and General
Plan should be updated accordingly
to include requirements for existing
buildings.

This comment is noted and the addition will be made in
errata. The sentence is thereby amended: "“Since 2005, the California Building Code (CBC) (CCR Title 24, Part 2) has required that all new buildings, remodels or additions to existing buildings of a certain size located in any Fire Hazard Severity Zone in SRAs, or any Very High Fire Hazard Severity Zone in LRAs, use building materials approved for use in wildland/urban interface areas. Subsequent editions of the code have specified certain roof coverings, fire resistive wall and ceiling-floor assemblies, wall finish materials, hardware, insulation, and other building materials for use in high fire hazard areas.” This clarification does not change the findings of significance.

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C54-19 Christine
Boles
3/6/22 Page 6 of the DEIR states, “Pacifica’s
HMP is an annex of San Mateo
County’s Multi-Jurisdictional Local
Hazard Mitigation Plan (MJ-LHMP),
most recently updated in 2021. The
plan identifies the City’s hazards and
provides strategies for preventing
hazards and minimizing damage. The
plan ranks wildfire as a medium risk
concern, under geologic and
hydrologic hazards, and identifies
several mitigation actions for
wildland fires in Pacifica. These
include updating the City’s
Emergency Operations Plan; pursuing
opportunities to preserve and
protect critical transportation
infrastructure; and developing and
delivering business programs and
public outreach programs to
promote resiliency and community
preparedness.

See previous comments about
inadequacy of Pacifica’s LHMP.

Pacifica’s current LHMP on the
county website was modified after
the City Council Meeting where the
document was approved and now
neglects to include ANY fire hazard
mapping.
https://cmo.smcgov.org/sites/cmo.s
mcgov.org/files/documents/files/San
%20Mateo%20HMP%20-
%20Volume%20II%20-
%20Final%20083016.pdf
Please provide a link to Pacifica’s
current Emergency Operations Plan
and provide detailed information
about when an update can be
expected.

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

Because of the sensitive nature of these documents, a
citation is added, but there is no available link. The
Emergency Operations Plan is available at the Police
Department counter.

C54-20 Christine
Boles
3/6/22 Page 6 of the DEIR states, “The
Pacifica All Hazards & Evacuation
Plans, updated in 2019, provides
steps that should be considered and
taken in case of evacuation. It grants
authority and responsibilities to
centralized emergency management
and divides the City of Pacifica into
14 evacuation zones, each of which
has its own evacuation operations
plan, detailing evacuation routes,
critical sites, traffic concerns, and
refuge areas.”
This comment is not related to the adequacy of the DEIR, thus no further response is required. Because of the
sensitive nature this document, a citation is added, but there is no available link. The All Hazards & Evacuation Plan is available at the Police Department counter.

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There is no link or citation for these
documents here or in the
Bibliography.

C54-21 Christine
Boles
3/6/22 The DEIR does not contain analysis
for road capacity, nor maps for
evacuation. Please note that this is
also a basic requirement of Safety
Elements as defined in Government
Code section 65302 (g) 1.
“(g) (1) A safety element for the
protection of the community from
any unreasonable risks associated
with the effects of seismically
induced surface rupture, ground
shaking, ground failure, tsunami,
seiche, and dam failure; slope
instability leading to mudslides and
landslides; subsidence; liquefaction;
and other seismic hazards identified
pursuant to Chapter 7.8
(commencing with Section 2690) of
Division 2 of the Public Resources
Code, and other geologic hazards
known to the legislative body;
flooding; and wildland and urban
fires. The safety element shall
include mapping of known seismic
and other geologic hazards. It shall
also address evacuation routes,
military installations, peakload water
supply requirements, and minimum
road widths and clearances around
structures, as those items relate to
identified fire and geologic hazards.”
The DEIR and Safety Element do not
meet all the requirements listed in
(g)(1). Please add the necessary
information and analysis and
recirculate for proper public and
agency review.

Thank you for your comment. Roadway capacity analysis and evacuation maps are not required CEQA topics; please see Master Response 1. Description of evacuation route
constraints and policies to address constraints are described in DEIR p. 3-14-8. Please see Master Response 7: Emergency Access for more information.

C54-22 Christine
Boles
3/6/22 Government Code Section 65302 (g)
3 also requires the following:
“Upon the next revision of the
housing element on or after January
1, 2014, the safety element shall be
reviewed and updated as necessary
to address the risk of fire for land
classified as state responsibility
areas, as defined in Section 4102 of
the Public Resources Code, and land
classified as very high fire hazard
severity zones, as defined in Section
51177. This review shall consider the
advice included in the Office of
This comment is related to General Plan requirements;
please see Master Response 1 for more information. Please see Master Response 5: Wildfire for more information on how the DEIR responses to analysis of questions required under CEQA.

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Planning and Research’s most recent
publication of “Fire Hazard Planning,
General Plan Technical Advice Series”
and shall also include all of the
following:
(A) Information regarding fire
hazards, including, but not limited to,
all of the following:
(i) Fire hazard severity zone maps
available from the Office of the State
Fire Marshal.
(ii) Any historical data on wildfires
available from local agencies or a
reference to where the data can be
found.
(iii) Information about wildfire hazard
areas that may be available from the
United States Geological Survey.
(iv) General location and distribution
of existing and planned uses of land
in very high fire hazard severity zones
and in state responsibility areas,
including structures, roads, utilities,
and essential public facilities. The
location and distribution of planned
uses of land shall not require
defensible space compliance
measures required by state law or
local ordinance to occur on publicly
owned lands or open space
designations of homeowner
associations.
(v) Local, state, and federal agencies
with responsibility for fire protection,
including special districts and local
offices of emergency services.
(B) A set of goals, policies, and
objectives based on the information
identified pursuant to subparagraph
(A) for the protection of the
community from the unreasonable
risk of wildfire.
(C) A set of feasible implementation
measures designed to carry out the
goals, policies, and objectives based
on the information identified
pursuant to subparagraph (B),
including, but not limited to, all of
the following:
(i) Avoiding or minimizing the wildfire
hazards associated with new uses of
land.
(ii) Locating, when feasible, new
essential public facilities outside of
high fire risk areas, including, but not
limited to, hospitals and health care

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facilities, emergency shelters,
emergency command centers, and
emergency communications
facilities, or identifying construction
methods or other methods to
minimize damage if these facilities
are located in a state responsibility
area or very high fire hazard severity
zone.
(iii) Designing adequate
infrastructure if a new development
is located in a state responsibility
area or in a very high fire hazard
severity zone, including safe access
for emergency response vehicles,
visible street signs, and water
supplies for structural fire
suppression.
(iv) Working cooperatively with
public agencies with responsibility for
fire protection.
(D) If a city or county has adopted a
fire safety plan or document
separate from the general plan, an
attachment of, or reference to, a city
or county’s adopted fire safety plan
or document that fulfills
commensurate goals and objectives
and contains information required
pursuant to this paragraph.”
Please provide the required analysis
and data and write new appropriate
policies and mitigation measures in
the DEIR and General Plan for
existing and new development in fire
hazard zones.

C54-23 Christine
Boles
3/6/22 On page 7, of the DEIR, Impact
Analysis, it says, “Implementation of
the Proposed Project could have a
significant impact if located in or
near state responsibility areas or
lands classified as very high hazard
severity zones” and then proceeds to
list the possible impacts. Without
proper maps of lands classified as
Very High Fire Hazard Severity Zones
this analysis cannot be done at this
point. The maps must be fixed,
analysis redone, and the information
recirculated for public and agency
review. Please confirm the City’s
intended process and timetable for
updating this critical life safety
information and required
mitigations.

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 CALFIRE-designated Fire Hazard Severity Zones Pacifica has a substantial risk of wildland fires, with many areas of high threat within the Planning Area. See Master Response 5: Wildfire for more information on the adequacy of mapping and analysis.

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C54-24 Christine
Boles
3/6/22 Further on age 7, it says,
“Consideration is given to potential
increases in development in WUI
zones, development in proximity to
the VHFHSZ in the City’s Sphere of
influence, new impervious surface
area, erosion associated with future
development-related construction
activities, hazards associated with
wildfire, as well as proposed policies
intended to minimize the impacts of
growth on fire services and
emergency evacuation access.”
Please provide a detailed explanation
of how this “consideration was
given”. I have seen no analysis in the
DEIR of fire hazards for possible
development in the city’s Sphere of
Influence on San Pedro Mountain for
example.

Please see Master Response 5: Wildfire. Impacts related to VHFHSZ (of which the San Pedro Mountain development
would be part of) The Sphere of Influence is within a SRA VHFHSZ. The City of Pacifica does not have permitting
jurisdiction in the Sphere of Influence. Should any land be annexed into the City of Pacifica, development would be subject to all state regulations regarding development in VHFHSZ, as well as Pacifica General Plan policies.

C54-25 Christine
Boles
3/6/22 Further on page 7, under
Methodology and Assumptions, the
DEIR says, “Subsequent CEQA review
at the project level may be required
to determine whether significant
environmental effects would result
from growth that may create
additional demand for emergency
services and critical infrastructure.

Project-level review will occur when
proposed development plans are
prepared.” My understanding is that
this is considered deferred analysis,
which is not legally allowed under
CEQA. Please provide a detailed
analysis with input from North
County Fire on the specific allowable
development increases under
existing conditions of two fire
stations. How many new units can be
built without compromising existing
services, and in which areas of town
can these be built? As shown in the
2010 Existing Conditions and Key
Issues map fire services were already
compromised in 2010 in the
communities of Rockaway, Vallemar
and Park Pacifica. Development
projects that were built since 2010 or
that are currently under
construction, have further
compromised these levels of service,
like Connemara, 801 Fassler,
Harmony@1 and the new hotels in
Policy CEQA impacts require analysis of new needed
facilities to meet service standards, but not the service standards themselves. As described on p.3.12-29, "though the Proposed Project anticipates the construction or
enhancement of fire protection facilities to achieve service standards, the underlying need for these activities is preexisting. 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). Given these
considerations, and Proposed Project policies set forth below to support adequate levels of fire service, this impact is expected to be less than significant for fire services." Thus, the impact is less than significant. Policy SA-I-91 addresses support of maintaining NCFA's adequate response times.

Please see response to comment C83-2 for more
information about fire station planning; and Master
Response 7: Emergency Access for the adequacy of
evacuation frameworks and policies.

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Rockaway.

At what point is a third fire station
triggered? How many units? In what
locations? Where might this new fire
station be built, and is the funding
secured? Is a new fire station
required under Project buildout of
990 units? Under RHNA of 1982
units? Under actual possible
maximum buildout, which I do not
see calculated anywhere in these
documents? We cannot continue to
further endanger the public by
allowing project after project to be
approved without a full
understanding of the cumulative
impacts that reduce the levels of
service that North County Fire is able
to provide.

C54-26 Christine
Boles
3/6/22 25. On pages 9 and 10, Proposed
policies that reduce the impact:

A. LU-1-25 Rockaway Quarry Plan
does not mention the need for a new
fire station. Please amend as
necessary, adding references to SA-I91.

C54-27 Christine
Boles
3/6/22 B. CI-G-7 “Congestion on Highway 1.

In consultation with Caltrans, seek
solutions to ease the traffic
congestion that occurs on Highway 1
near the Reina Del Mar, Fassler
Avenue, and Linda Mar Boulevard
intersections. Strive for the greatest
benefit with the least environmental
impact possible.” This is a deferred
measure, which is not allowed under
CEQA, especially if the measure can
do harm, such as by preventing the
timely response of emergency
services.

Congestion is note a required CEQA topic of analysis. This policy does not represent a mitigation measure, it
represents a beneficial impact to potential impacts on
evacuation routes. Highway 1 remains under the jurisdiction of Caltrans, which is beyond the City's sole scope of
authority to mitigate. As noted on DEIR p. 3-29, C/CAG is primarily responsible for administering the State-mandated Congestion Management Program (CMP). The C/CAGdesignated CMP roadway system components in Pacifica include Highway 1 (SR 1) and Skyline Boulevard (SR 35).

C/CAG’s LOS standard for roadway segments on these
roadways is LOS E or better. With buildout of the General Plan, none of the intersections along these two CMP
roadway segments would operate at LOS E or LOS F.

Congestion conditions that could impede emergency
evacuation do not exist right now, therefore it is appropriate to monitor and proactively coordinate with Caltrans until thresholds could potentially be reached. Potential
improvements to the roadway network could contribute to mitigating the impacts of additional traffic on emergency response times. Furthermore, traffic signal preemption
devices on emergency vehicles, as well as emergency sirens, will improve emergency response times even in instances of intersection congestion during peak commute periods.

C/CAG is also required to monitor the implementation of all elements of the CMP and prepare a monitoring report every other year. Thus, this does not represent a deferred
mitigation.

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Beyond Highway 1 congestion, 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. Guidance for evacuation routes and procedures 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 evacuation plans in the affected area. Implementation of the Proposed Project would not
interfere with any of the steps or procedures in the
Evacuation Plans. 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 will ensure that inadequate emergency is reduced to the extent practicable, and will result in a less than significant impact.

C54-28 Christine
Boles
3/6/22 C. CI-I-9 “SR 1 Improvements
Between South of Fassler and North
of Reina del Mar.

Continue to work with the California
Department of Transportation
(Caltrans) and the San Mateo County
Transportation Authority (SMCTA) to
improve operations along SR 1.” This
is a deferred measure, which is not
allowed under CEQA, especially if the
measure can do harm, such as by
preventing the timely provision of
emergency services.

Please see response to C54-27.

C54-29 Christine
Boles
3/6/22 D. CI-I-10 Manor Drive Overcrossing
Improvements
According to an email Deputy
Director of Public Works, Sam
The Manor Drive Overcrossing Project is an approved
project. Please see Master Response 7: Emergency Access for more information on the adequacy of Pacifica's
evacuation framework. Several policies in the Proposed Plan

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Bautista, sent to Vicki Sundstrom on
2/16/22 this project will take at least
6 years to complete, see below. I also
know it will necessitate public input
and there is already quite a lot of
controversy as many residents are
opposed to the new freeway onramp
at Milagra. Please add policy
language that prohibits large scale
development that decreases levels of
service for traffic, evacuations
routes, and fire access until such
improvements and traffic mitigation
measures have been completed.
include NCFA review and support, including SA-I-94
(Development Review), SA-I-91 (Response Time), and SA-I100 (Rockaway Quarry Service).

C54-30 Christine
Boles
3/6/22 E. CI-I-18 “Vehicle Level of Service on
Roadways Included in the Congestion
Management Program. Accept an
LOS E on SR 1 and SR 35, consistent
with the C/CAG Congestion
Management Program (CMP), in
planning improvements.” Please
provide a link to Pacifica’s Current
Congestion Management Plan so that
we can review assumptions as well as
data. Table 3.3-4 shows some
intersections on SR1 and SR 35
already have existing levels of service
of D and E, some of which are
expected to worsen under plan
buildout. Plan buildout only
considers 990 additional units of
housing, and does not include
current RHNA requirements of 1892
units which are required in January
2023, and does not include all
potential buildout under the
proposed project with current ADU
laws, much less SB9 and SB10. Please
confirm how the city plans to ensure
that levels of service of E are not
exceeded under full potential
buildout, how this will be monitored
over time as new projects are built,
and what mitigation measures to
improve traffic and firefighting
service times on these major
evacuation routes will be undertaken
if levels of service fall below E.

Please see response to comment C54-27 for more
information on how the City will coordinate with C/CAG
regarding emergency access. At time of NOP release, the 2019 C/CAG Congestion Management Plan represented the
latest and best available information. Congestion
Management Plans are available here:
https://ccag.ca.gov/programs/transportationprograms/congestion-management/.

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

Consistent with that guidance, DEIR buildout projections do not use the theoretical buildout of each parcel to the
maximum extent allowed under zoning because that would
not represent a reasonably foreseeable forecast. Parcel dimensions or the existence of environmental constraints will likely preclude many properties from being built out to the maximum intensity allowed and historical trends in the city indicated that developments are typically approved and constructed at densities and intensities below the maximum.

Therefore, it is impossible for every parcel in the city to be built out the maximum permitted under zoning.

Furthermore, using maximum theoretical buildout as the
basis for the CEQA analysis would exaggerate impacts and result in mitigation measures requiring the construction of road and utility infrastructure in excess of what is need to support growth resulting from the Proposed Plan. Therefore, the DEIR correctly used a reasonably foreseeable forecast of buildout under the Proposed Plan as the basis for the
environmental analysis. Please see Master Response 3:

Buildout and RHNA for more information about buildout
adequacy.

C54-31 Christine
Boles
3/6/22 F. “CI-I-19 Vehicle Level of Service for
Other Roadways and Intersections.

For all roadways and intersections
not included in the CMP network,
Impacts to Level of Service is not a required topic under CEQA. Please see Master Response 7: Emergency Access for more information about the adequacy of current

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strive to balance reducing VMT with
maintaining LOS D for vehicles during
peak periods.” Please note in the
chart above that some non-CMP
intersections already exceed level D
service, and several others are
projected to worsen to levels E and F
under the proposed project during
peak periods. And again, this does
not include actual full buildout. This
tells me that perhaps certain parts of
town cannot be rezoned to increase
density per the project buildout until
major improvements to
transportation and evacuation routes
are undertaken and completed.

Please provide detailed analysis and
overlays of land use analysis with
traffic levels of service to confirm
environmental impacts of increased
traffic near these critical
intersections. The DEIR and GP
should include additional language
with limitations to new development
tied to improvements of traffic to
ensure compliance with CEQA for
less than significant impacts. Again,
as these issues affect emergency
evacuation routes, these policies
could potentially cause harm, and
therefore deferred analysis is not
allowed.
programmatic-level evacuation plans and project-level
analysis, which reduce impacts to less than significant.

C54-32 Christine
Boles
3/6/22 G. CI-I-26 “Emergency Access.

Require developers to incorporate
emergency access needs consistent
with standards in Title 10 of the
Municipal Code.” Please clarify if this
measure includes both on and offsite
analysis of emergency access and
evacuation routes.

This policy is not a mitigation measure; the DEIR analyzes the potential beneficial impacts of policies in the Proposed Project. This represents on-site analysis. However,
compliance with programmatic regional and city-level
evacuation plans reduce impacts to less than significant; please see Master Response 7: Emergency Access for more information.

C54-33 Christine
Boles
3/6/22 H. “SA-G-11 “Disaster Preparation.

Make infrastructure investments,
enforce regulations, and disseminate
information that will improve
disaster response and recovery, with
the goal of minimizing damage to
people and property.” This language
seems very vague and not
enforceable. Please clarify how
disaster preparation will be
implemented in detail so that
damage to people and property is
minimized.

The MJ-LHMP is one way that the Safety Element is
implemented, in addition to policies in the Proposed Project.

Please see actions in the MJ-LHMP for more specific details.

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C54-34 Christine
Boles
3/6/22 I. SA-I-35 “Critical Transportation
Infrastructure.

The City will pursue opportunities to
preserve, protect, or relocate critical
local transportation infrastructure, or
provide alternative access, to
mitigate against isolation and
economic loss, and to ensure public
safety.” Again, vague, nonenforceable language, cannot be considered a real mitigation measure
without details and analysis.

This policy is not a mitigation measure; the DEIR analyzes the potential beneficial impacts of policies in the Proposed Project. Please see Master Response 1 for more information on how non-DEIR related impacts will be addressed. Please see MJ-LHMP, Section 5 and Appendix: Detailed
Methodology; and the 2018 Sea Level Rise Vulnerability
Assessment Appendix, which provide additional details on critical facilities locations in areas of hazard.

C54-35 Christine
Boles
3/6/22 J. SA-I-91 “Response Time.

Support efforts by North County Fire
Authority to meet its response time
standards throughout the City.” As
shown below from the 2010 Existing
Conditions and Key Issues Report,
NCFA’s response time standards
were already exceeded in 2009 in
several parts of town including
Rockaway, Vallemar and Park
Pacifica. Please clarify how the City of
Pacifica will provide additional
resources for a new fire station, new
equipment for the taller buildings in
Sharp Park, etc, that will allow NCFA
to be able to start to meet their
standards in all parts of Pacifica.

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

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

Please see response to comment C83-2 for more
information about fire services. As noted on DEIR p. 3.12-34, "Implementation of the SPSP will raise building heights in portions of the Planning Area. ISO standards call for a ladder truck within 2.5 miles of urban areas containing buildings three or more stories in height. Currently, Fire Station 71— within a four-minute travel area from the Planning Area— includes a ladder truck, and policies within the SPSP ensure adequate staff and equipment to serve future growth and development in Sharp Park."
C54-36 Christine
Boles
3/6/22 K. 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.”
“Develop a plan” is a deferred
mitigation measure and cannot be
used for critical life safety issues like
emergency egress per CEQA
requirements. Please provide a plan
as part of this plan, especially given
the increased development of
housing the city is proposing as part
of this Project in Pedro Point.

Please see Master Response 7: Emergency Access for more information about the adequacy of the regional and citywide emergency planning framework, in addition to project-level evacuation planning. This policy is not a mitigation measure; the DEIR analyzes the potential beneficial impacts of policies in the Proposed Project. Please see Master Response 1 for more information on how non-DEIR related impacts will be addressed.

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C54-37 Christine
Boles
3/6/22 L. 6-I-4 “Fire Services and Height.

Work with PFD to ensure fire services
have the capacity to serve four- and
five-story buildings prior to
construction of buildings of that
height.” I think you mean NCFA and
not PFD. Also, should we not be
certain that they can serve four and
five story buildings before we
approve the rezoning to allow these
height increases? Again, this seems
like deferred analysis of a critical life
safety impact, which is not allowed
per CEQA. These proposed height
increases are not only in Sharp Park,
but in other areas where Mixed Use
Center Zoning has been added, such
as Crespi in Linda Mar adjacent to
the Community Center.

Please see response to comment C54-35 for more
information about ISO standards. The following clarification is made: "Work with PFD NFCA to ensure fire services have the capacity to serve
four- and five-story buildings prior to construction of buildings of that height.” This represents a General Plan policy change; this policy is not a mitigation measure. Please see Master Response 1 for more information on General
Plan-related comments and responses.

C54-38 Christine
Boles
3/6/22 Chapter 7 of the DEIR states that
North County Fire last issued
responses on August 9, 2009. Please
confirm the latest date of their
review and comments of this DEIR
and Draft General Plan and provide
copies of the latest information and
comments from North County Fire in
an appendix to the General Plan so
the public, local and state agencies
have access to this data and
information.

The NCFA reviewed portions of the DEIR in 2019. The
bibliography will be changed to reflect this date.

C54-39 Christine
Boles
3/6/22 Chapter 3.11 Hazards and Hazardous
Materials also discusses wildfire risks
and evacuation routes. Figure 3.11-2
neglects to show fire hazard risk in
Local (LRA) or Federal (FRA)
responsibility areas. Please amend
figure to add this information.

This comment is incorrect. Please see response to comment C54-13 for more information on adequacy of mapping.

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C54-41 Christine
Boles
3/6/22 Page 3.11-13 Again discusses the MJLHMP. This text includes language about the threat of landslides on
Highway 1 that have the potential to
block critical evacuation routes.

Please 1) add this information to the
landslide maps and 2) propose action
and mitigation measures to address
this risk.

The MJ-LHMP is an adopted document; actions apply to
Planning Area. Policy SA-I-114 describes locating critical facilities away from hazard areas. As noted on DEIR p. 3.6- 21, the MJ-LHMP concludes that landslide/mass movements, which includes traditional landslides as well as coastal erosion, and earthquakes, with the potential to cause
ground shaking, liquefaction, and landslides, are Pacifica’s two highest priorities for the mitigation of geologic and seismic hazards. All goals and policies in the adopted MJLHMP are applicable to the Proposed Project, including those that concern geologic hazards. The MJ-LHMP include several actions that address erosion and landslide concerns, including update of the Emergency Operations Plan, pursue opportunities to preserve and protect critical transportation infrastructure (including Beach Blvd.), and seek to
replace/upgrade its seismically-vulnerable facilities to ensure provision of vital services following a hazard. Policies related to emergency services in instances of erosion
hazards include SA-I-114, Critical Facilities Location, which avoids locating structures necessary for protection of the public’s health and safety, public assembly, or emergency services in hazardous areas unless no reasonable alternative exists.

Please see Master Response 7: Emergency Access for more information.

C54-42 Christine
Boles
3/6/22 Page 3.11-12 of the DEIR under the
subheading California Wildland
Hazard/Building Code seems to
quote several outdated sources.

Please update as needed per current
codes and sources.

The comment is noted. Updates will be included in errata; this does not change findings of significance.

C54-43 Christine
Boles
3/6/22 Impact Analysis Criteria 6 - Impair
implementation of or physically
interfere with an adopted emergency
response plan or emergency
evacuation plan.

Again, please provide links to these
documents so we can evaluation
whether the proposed project may
impact these plans.

These documents are sensitive in nature and not posted on the City website; however, they are available for public review at the Pacifica Police Department counter.

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C54-44 Christine
Boles
3/6/22 Impact Analysis Criterion 7: Expose
people or structures to a significant
risk of loss, injury or death involving
wildland fires, including where
wildlands are adjacent to urbanized
areas or where residences are
intermixed with wildlands. And
below on page 3.11.14 in the Impact
Summary, it says, “In addition, the
exposure of people or structures to
wildland fires as a result of the
Proposed Project is not expected to
occur. The potential of the creation
of hazards or exposure to hazardous
materials under the Proposed Project
remains less than significant with
adherence to existing regulations and
implementation of the policies of the
Proposed Project.”
Nothing I have seen in the Fire
Chapters provides a clear path to be
able to jump to these conclusions
that the Project will not have
significant impacts to create
additional fire hazard and evacuation
risks. Please update document to
properly analyze risks and then
provide a detailed explanation to
justify a less than significant impact.

Please see response to comment C54-13 for more
information on mapping. Taken together, 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.

C54-45 Christine
Boles
3/6/22 Again, I object to Page 3.11-23 and
24 which states that no mitigation
measures are required to address
wildfire risk.
“3.11-7 Implementation of the
proposed Pacifica General Plan
would not expose people or
structures, either directly or
indirectly, to a significant risk of loss,
injury or death involving wildland
fires. (Less than Significant) Impact of
the General Plan As described above,
wildfire hazard is minimal in most of
Pacifica within city limits because it is
mostly urbanized.” Without proper
maps and updated analysis of fire
risk, we cannot at this point clearly
state that there is no additional
Please see response to comment C54-44.

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wildfire risk posed by the Proposed
Project. The experience of the last
several years is that urbanized areas
are decidedly not protected from
wildfires.

C54-46 Christine
Boles
3/6/22 SA-I-92 Adequate Peakload Water
Supply.

Work with the Water District to
maintain adequate water supply for
firefighting, including capacity for
peakload under a reasonable worst
case wildland fire scenario, to be
determined by the North County Fire
Authority. Again, under CEQA law,
this analysis cannot be deferred.

What is our peak load and do we
have the capacity to build the
Proposed Project while maintaining
and adequate amount of backup
water for firefighting?
The comment is noted. This represents a policy, not a
mitigation measure. Maintenance of peakload water supply is not a required topic of analysis under CEQA. Ensuring peakload water supply is requirement for General Plans.

However, the City is not a water purveyor/the responsible agency; the North Coast County Water District is the water authority. The city, can, however, coordinate with NCCWD as development occurs to ensure that adequate planning by the NCCCWD can take place as part of its Urban Water
Master Planning efforts. Thus, it does not represent a
deferred mitigation or analysis.

C54-47 Christine
Boles
3/6/22 Under SB 379 and California
Government Code Section 35602, a
climate change vulnerability
assessment must be undertaken, not
just for sea level rise, but for other
increased climate change related
hazards such as wildfire, flooding,
landslides, and coastal erosion. I
have not seen this analysis in the
DEIR except in relation to sea level
rise. Under SB379, cities and counties
within California are required to
integrate climate adaptation into
their general plans by January 1,
2022. As Pacifica recently adopted a
new Local Hazard Mitigation Plan in
November 2021, this work must be
done as part of the General Plan
Safety Element update. Please see
Alliance of Regional Collaborative for
Climate Adaptation for a description
of what is required.

I’ve also copied the text of California
Government Code Section 35602(g)
(4) for reference here below.

Please clarify when this work will be
done and the Safety Element
appropriately updated. “(4) Upon the
next revision of a local hazard
mitigation plan, adopted in
accordance with the federal Disaster
Mitigation Act of 2000 (Public Law
106-390), on or after January 1,
2017, or, if a local jurisdiction has not
adopted a local hazard mitigation
The comment is noted. The comment is not related to the adequacy of the DEIR, therefore no further response is
required in the FEIR. However, the comment addresses the content of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response: EIR comments for more information about GP- or SPSP-related responses. The general impacts and
consequences of climate change in California are described on DEIR p. 3.4-6, 7, and 8; and requirements for SB379 are 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).

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plan, beginning on or before January
1, 2022, the safety element shall be
reviewed and updated as necessary
to address climate adaptation and
resiliency strategies applicable to the
city or county. This review shall
consider advice provided in the
Office of Planning and Research’s
General Plan Guidelines and shall
include all of the following:
(A) (i) A vulnerability assessment that
identifies the risks that climate
change poses to the local jurisdiction
and the geographic areas at risk from
climate change impacts, including,
but not limited to, an assessment of
how climate change may affect the
risks addressed pursuant to
paragraphs (2) and (3).
(ii) Information that may be available
from federal, state, regional, and
local agencies that will assist in
developing the vulnerability
assessment and the adaptation
policies and strategies required
pursuant to subparagraph (B),
including, but not limited to, all of
the following:
(I) Information from the internet-
based Cal-Adapt tool. (II) Information
from the most recent version of the
California Adaptation Planning Guide.
(III) Information from local agencies
on the types of assets, resources, and
populations that will be sensitive to
various climate change exposures.
(IV) Information from local agencies
on their current ability to deal with
the impacts of climate change.
(V) Historical data on natural events
and hazards, including locally
prepared maps of areas subject to
previous risk, areas that are
vulnerable, and sites that have been
repeatedly damaged.
(VI) Existing and planned
development in identified at-risk
areas, including structures, roads,
utilities, and essential public
facilities.
(VII) Federal, state, regional, and
local agencies with responsibility for
the protection of public health and
safety and the environment,
including special districts and local offices of emergency services.

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(B) A set of adaptation and resilience
goals, policies, and objectives based
on the information specified in
subparagraph
(A) for the protection of the
community.
(C) A set of feasible implementation
measures designed to carry out the
goals, policies, and objectives
identified pursuant to subparagraph
(B), including, but not limited to, all
of the following:
(i) Feasible methods to avoid or
minimize climate change impacts
associated with new uses of land.
(ii) The location, when feasible, of
new essential public facilities outside
of at-risk areas, including, but not
limited to, hospitals and health care
facilities, emergency shelters,
emergency command centers, and
emergency communications
facilities, or identifying construction
methods or other methods to
minimize damage if these facilities
are located in at-risk areas.
(iii) The designation of adequate and
feasible infrastructure located in an
at-risk area.
(iv) Guidelines for working
cooperatively with relevant local,
regional, state, and federal agencies.
(v) The identification of natural
infrastructure that may be used in
adaptation projects, where feasible.

Where feasible, the plan shall use
existing natural features and
ecosystem processes, or the
restoration of natural features and
ecosystem processes, when
developing alternatives for
consideration. For purposes of this
clause, “natural infrastructure”
means using natural ecological
systems or processes to reduce
vulnerability to climate change
related hazards, or other related
climate change effects, while
increasing the long-term adaptive
capacity of coastal and inland areas
by perpetuating or restoring
ecosystem services. This includes,
but is not limited to, the
conservation, preservation, or
sustainable management of any form
of aquatic or terrestrial vegetated

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open space, such as beaches, dunes,
tidal marshes, reefs, seagrass, parks,
rain gardens, and urban tree
canopies. It also includes systems
and practices that use or mimic
natural processes, such as permeable
pavements, bioswales, and other
engineered systems, such as levees
that are combined with restored
natural systems, to provide clean
water, conserve ecosystem values
and functions, and provide a wide
array of benefits to people and
wildlife.
(D) (i) If a city or county has adopted
the local hazard mitigation plan, or
other climate adaptation plan or
document that fulfills commensurate
goals and objectives and contains the
information required pursuant to this
paragraph, separate from the general
plan, an attachment of, or reference
to, the local hazard mitigation plan or
other climate adaptation plan or
document.
(ii) Cities or counties that have an
adopted hazard mitigation plan, or
other climate adaptation plan or
document that substantially complies
with this section, or have
substantially equivalent provisions to
this subdivision in their general
plans, may use that information in
the safety element to comply with
this subdivision, and shall summarize
and incorporate by reference into
the safety element the other general
plan provisions, climate adaptation
plan or document, specifically
showing how each requirement of
this subdivision has been met. (5)
Upon the next revision of the
housing element on or after January
1, 2020, the safety element shall be
reviewed and updated as necessary
to identify residential developments
in any hazard area identified in the
safety element that do not
have at least two emergency
evacuation routes.
(6) After the initial revision of the
safety element pursuant to
paragraphs (2), (3), (4), and (5), the
planning agency shall review and, if
necessary, revise the safety element
upon each revision of the housing

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element or local hazard mitigation
plan, but not less than once every
eight years, to identify new
information relating to flood and fire
hazards and climate adaptation and
resiliency strategies applicable to the
city or county that was not available
during the previous revision of the
safety element.
(7) Cities and counties that have
flood plain management ordinances
that have been approved by FEMA
that substantially comply with this
section, or have substantially
equivalent provisions to this
subdivision in their general plans,
may use that information in the
safety element to comply with this
subdivision, and shall summarize and
incorporate by reference into the
safety element the other general
plan provisions or the flood plain
ordinance, specifically showing how
each requirement of this subdivision
has been met.
(8) Before the periodic review of its
general plan and before preparing or
revising its safety element, each city
and county shall consult the
California Geological Survey of the
Department of Conservation, the
Central Valley Flood Protection
Board, if the city or county is located
within the boundaries of the
Sacramento and San Joaquin
Drainage District, as set forth in
Section 8501 of the Water Code, and
the Office of Emergency Services for
the purpose of including information
known by and available to the
department, the agency, and the
board required by this subdivision.
(9) To the extent that a county’s
safety element is sufficiently detailed
and contains appropriate policies and
programs for adoption by a city, a
city may adopt that portion of the
county’s safety element that pertains
to the city’s planning area in
satisfaction of the requirement
imposed by this subdivision.
(h) (1) An environmental justice
element, or related goals, policies,
and objectives integrated in other
elements, that identifies
disadvantaged communities within

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the area covered by the general plan
of the city, county, or city and
county, if the city, county, or city and
county has a disadvantaged
community. The environmental
justice element, or related
environmental justice goals, policies,
and objectives integrated in other
elements, shall do all of the
following:
(A) Identify objectives and policies to
reduce the unique or compounded
health risks in disadvantaged
communities by means that include,
but are not limited to, the reduction
of pollution exposure, including the
improvement of air quality, and the
promotion of public facilities, food
access, safe and sanitary homes, and
physical activity.
(B) Identify objectives and policies to
promote civic engagement in the
public decisionmaking process.
(C) Identify objectives and policies
that prioritize improvements and
programs that address the needs of
disadvantaged communities.
(2) A city, county, or city and county
subject to this subdivision shall adopt
or review the environmental justice
element, or the environmental
justice goals, policies, and objectives
in other elements, upon the adoption
or next revision of two or more
elements concurrently on or after
January 1, 2018.
(3) By adding this subdivision, the
Legislature does not intend to
require a city, county, or city and
county to take any action prohibited
by the United States Constitution or
the California Constitution.
(4) For purposes of this subdivision,
the following terms shall apply:
(A) “Disadvantaged communities”
means an area identified by the
California Environmental Protection
Agency pursuant to Section 39711 of
the Health and Safety Code or an
area that is a low-income area that is
disproportionately affected by
environmental pollution and other
hazards that can lead to negative
health effects, exposure, or
environmental degradation.
(B) “Public facilities” includes public

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improvements, public services, and
community amenities, as defined in
subdivision
(d) of Section 66000. (C) “Low-
income area” means an area with
household incomes at or below 80
percent of the statewide median
income or with household incomes at
or below the threshold designated as
low income by the Department of
Housing and Community
Development’s list of state income
limits adopted pursuant to Section
50093 of the Health and Safety Code.
(Amended by Stats. 2021, Ch. 225,
Sec. 9. (AB 9) Effective January 1,
2022.)

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Individuals (C)
C55-1 Christine
Boles
3/6/22 I understand from Vicki Sundstrom that no new technical studies were found in the public records to assess our traffic conditions as part of this DEIR update, but I wanted to confirm that with you. It seems odd because DKS Associates is noted as a source in 2020 in the DEIR - see screenshot below. Please clarify.

Traffic counts were
conducted in 2018 and
2019, and analysis was
conducted in 2020 and
2021, in accordance
with the table
references in the DEIR.

Traffic study data is
included in Appendix B
of the DEIR. No further
response is required.

C55-2 Christine
Boles
3/6/22 Were any other technical studies required or prepared as part of the CEQA process to inform the DEIR? The NOP on page 14 says "The environmental assessment will utilize the most current CEQA Guidelines and for each issue area, including global warming and greenhouse gases/climate change."
Technical studies
prepared for the DEIR
included studies
related to VMT, GHG
emissions, and noise.

C55-3 Christine
Boles
3/6/22 A city planner friend tells me that you would normally find these technical studies in an appendix, but there is no appendix. I was pointed to Los Angeles County that had recently updated their general plan as a good example as they have a lot of the same issues we do with sensitive biology, steep hillsides, coastal erosion and sea level rise. Their website shows all these appendices and detailed technical documents. Am I missing something?
The comment is noted,
technical studies
related to VMT, GHG
emissions, and noise
were included in the
appendices of the DEIR
(pages A-49 onwards).

Studies in relation to
coastal erosion and sea
level rise are included
in the 2018 Sea Level
Rise vulnerability
report, included by
reference, and
addressed in the
LCLUP.

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C56: Christine Boles, 3/6/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C56-1 Christine
Boles
3/6/22 I read the agency comments on the EIR NOP today and wondered if there were written responses to those?
Responses to NOP
comments are not
required; notes on
comments are
incorporated into each
introductory paragraph
in the DEIR.

C56-2 Christine
Boles
3/6/22 I’m also really having trouble navigating the EIR. I couldn’t find a detailed index anywhere. Right now I’m specifically looking for information in the EIR on greenhouse gas emissions as called for in BAAQMD’s NOP comment letter. 1013 pages is too much to have to keep scrolling through on each topic I want to research… A DEIR with interactive
table of contents was
made available on the
Plan Pacifica website
on February 14, 2022.

1.f
Packet Pg. 1079 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 415
C57: Christine Boles, 2/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C57-1 Christine
Boles
2/17/22 Thank you Christian, but now I am more confused... Shouldn't this traffic data have been made available from the start of the 45 days as it impacts several sections of the DEIR? Now I feel like I have to go back and review the Land Use, Transportation, Air Quality, Greenhouse Gases and Noise sections again instead of moving on to review other sections as I had planned in my limited time. I would think other agencies like the Bay Area Air Quality Management District would have wanted that data too. Does this not trigger a new 45 day review period?
Availability of traffic
data modeling outputs
does not represent
significant new
information. Relevant
inputs were used for
GHG (CalEEMod,
included in the
Appendix), VMT
(included in the
Appendix) and noise
attenuation.

C57-2 Christine
Boles
2/17/22 And I appreciate the Council's extension of the deadline on Tuesday, but I have not noticed an email sent to the Plan Pacifica mailing list to alert people to the extension. Can you do that please? And will you also notify the state and local agencies?
This extension was
filed with the State
Clearinghouse, alerting
state agencies to an
extended period of
review.

C57-3 Christine
Boles
2/17/22 Same for the new pdfs that were quietly issued this week - can you send out a notification? I see some changes were made, like deleting the duplicate Wildfire Chapter. Were other changes made? How do we know? I noticed the date of the old DEIR document pdf and the new one are the same, January 7, 2022, but the State Clearing House, SCH numbers are different. The old one was 2020089010 and the new one is 2012022046. What does that mean? Does it indicate a whole new document?
A table of contents was
added to the DEIR per
the public's request.

1.f
Packet Pg. 1080 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 416
C58: Rich Nahass, 2/5/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C58-1 Rich Nahass 2/3/22 The current state of Pacifica’s planning documents does a grave disservice to our most capable and dedicated staff
• To release a poorly formatted online pdf DEIR that is logistically difficult to access, difficult to navigate and cannot be referenced (standard search, copy/paste functionality is broken.)
• To release a General Plan with no schedule, no provision for managing priority and risk nor recommendations for how to accommodate change • To have an end date for final approval with no process on how to get there.

The comment is noted.

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

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

C58-2 Rich Nahass 2/3/22 After the 45 day public evaluation period, the documents must be reworked for a second public ‘period of review.’
The comment is noted.

The DEIR review period
was extended on
February 14, 2022.

C58-3 Rich Nahass 2/3/22 City staff to figure out how to generate clean documentation like 99% of all other San Mateo County lead agencies.

This comment is noted.

C58-4 Rich Nahass 2/3/22 City staff to declare a date in the sand (e.g. Aug 15, 2022) when this focused project documentation review must complete and work backwards to develop realistic achievable tasks and schedule for that date, no matter what the letter of the law is.

C58-5 Rich Nahass 2/3/22 City staff to work with Council to select 3-6 (sic) of the hundreds of elements in the GP to prioritize those elements for more detailed planning by assessing effort vs impact vs other attributes city staff determines is best for assessing. This gives city staff focus and purpose.

It breaks the failure of management who make the chronic excuse that city staff is overworked or has too little time. In this way management can support city staff in this more focused endeavor and let the brilliance of city staff shine.

These concerns are
noted. The comment is
not related to the
adequacy of the DEIR,
therefore no further
response is required in
the FEIR. However, the
comment addresses
the content of the
Proposed Plan and will
be shared with
decision-makers in that
context. Please see
Master Response 1: EIR
Comments for more
information about GP1.f
Packet Pg. 1081 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 417
Letter Commenter Date Comment Combined Response
Individuals (C)
or SPSP-related
responses.

C58-6 Rich Nahass 2/3/22 If you should go this way, I would want one of those prioritized elements to be bus regional transit. If it is not, I may not like it, but I will understand, because based on city staff assessment I would see that it might be a higher priority to focus on the quarry or the frogs (doesn’t it always seem to be about the frogs?). And when it’s time to prioritize what to go deep on NEXT year (periodic prioritization might be spelled out in the GP) me and the rest of us will cajole, lobby, justify what we think is important and you, City staff, plus council will make the final decision on what’s next. You will LEAD.

C58-7 Rich Nahass 2/3/22 Now that I have you here let me provide you with some anecdotal attributes you might use for a deeper dive on a regional bus GP element • How does this solve an imminent issue - possibly reduces VMT and makes Pacifica better able to comply with state housing allocation levels or makes Pacifica better able to justify different housing allocation levels.

C58-8 Rich Nahass 2/3/22 How does the text in the GP empower our leadership to make Pacifica more competitive for funding. Mike O’Neill is on the Board of Directors as documented in the current San Mateo Countywide Transportation Plan 2040. How does the GP element empower Mike to be the biggest baddest cat in the room, backed by our local and county supervisors, to drive C/CAG to support Pacifica initiatives to the MTC? These concerns are
noted. The comment is
not related to the
adequacy of the DEIR,
therefore no further
response is required in
the FEIR. However, the
comment addresses
the content of the
Proposed Plan and will
be shared with
decision-makers in that
context. Please see
Master Response 1: EIR
Comments for more
information about GP1.f
Packet Pg. 1082 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 418
Letter Commenter Date Comment Combined Response
Individuals (C)
or SPSP-related
responses.

C58-9 Rich Nahass 2/3/22 How does this affect residents outside our jurisdiction? Would people on the mid coast, Connect the Coastside, benefit and might we engage them to find out? Somehow we need to change our governance practices to manage, simply, our priorities and focus to let the residents across all spectrums who care, want to conduct business or development do and deliver the justifications for their passions to the very capable and creative city staff
These concerns are
noted. The comment is
not related to the
adequacy of the DEIR,
therefore no further
response is required in
the FEIR. However, the
comment addresses
the content of the
Proposed Plan and will
be shared with
decision-makers in that
context. Please see
Master Response 1: EIR
Comments for more
information about GPor SPSP-related
responses.

1.f
Packet Pg. 1083 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 419
C59: Suzanne Moore, 3/5/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C59-1 Suzanne
Moore
3/4/22 I see in our DEIR that overlays are a suggested way to incentivize building. Although I do not have a
background to thoroughly understand pros/cons, I
understand that, by identifying areas in overlay
zones, contractors may be drawn to bid on projects
within the zone
These concerns are noted. The
comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the FEIR.

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

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

C59-2 Suzanne
Moore
3/4/22 It seems that areas on transportation corridors with pre-existing construction, in areas free from high
risk for erosion/landslides/fires/quakes, are all
areas that deserve to be designated as overlay
zones. I would appreciate more community and city
input to better explain this incentive. Retaining
Hillside Protection and habitat corridors are high
community priorities. Renewal of the Growth
Control Ordinance which expires in June should
occur. Please comment.

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

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

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

1.f
Packet Pg. 1084 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 420
C60: Dustin McGahan, 1/18/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C60-1 Dustin
McGahan
1/18/22 Can you please illustrate in detail the proposal for changing the City’s single height requirement with one
that changes by neighborhood, topography and other
relevant factors. Please describe in detail the new
proposed height requirement policy referenced in LU-I19.

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

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

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

C60-2 Dustin
McGahan
1/18/22 I see that this policy is based on community input. How can I participate in this conversation?
These concerns are noted. The
comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the FEIR.

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

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

1.f
Packet Pg. 1085 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 421
C61: Arlene Patton, 3/2/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C61-1 Arlene
Patton
3/2/22 My only serious, but obviously personal,
comment is the removal of GGNRA designation
for the Pedro Point Headlands for all of the
figures throughout all three documents. I know
this has been used in the past but it's not accurate
and from an Open Space lens not helpful. We (the
City as well as the Open Space Committee) should
be pursuing transfer of the property to all
possible entities and not hope that the GGNRA
will rescue us some day.

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

C61-2 Arlene
Patton
3/2/22 4-4
Undeveloped and Vacant Land: typo of acreage in
first sentence
The comment is noted. The text changes are
incorporated in the General Plan errata. They
do not relate to adequacy of DEIR analysis.

C61-3 Arlene
Patton
3/2/22 4-9
Mixed Use Center: Typo in third sentence
The comment is noted. The text changes are
incorporated in the General Plan errata. They
do not relate to adequacy of DEIR analysis.

C61-4 Arlene
Patton
3/2/22 Commercial Uses: Could you define the term "As
of Right"? I think I understand what it means but
am not sure.

The comment is noted. 'As-of-right' means it
specifically permits a proposed use and
development of land without the imposition
of special conditions or the necessity of
discretionary approval from a local zoning
board or commission.

C61-5 Arlene
Patton
3/2/22 4-32
LU-I-6: First sentence typo regarding acres per
dwelling unit. I'm sure some Pacificans would love
1010 acres per dwelling unit!
The comment is noted. The text changes are
incorporated in the General Plan errata. They
do not relate to adequacy of DEIR analysis.

C61-6 Arlene
Patton
3/2/22 5-2
4th paragraph "For trips from Pacifica more
people drive to Caltrans..." should be Caltrain.

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

C61-7 Arlene
Patton
3/2/22 Photo caption "SamTrans provides a Park-nRide...". Caltrans owns this site. SamTrans used to have a MOU but with the City's parking fee
program I would have to think the City must be
maintaining this site.

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

C61-8 Arlene
Patton
3/2/22 5-23
Paragraph starting with "GGNRA's Sweeny Ridge
Trails...Baquiano Trail" should be change to "Ahni
Trail joining Baquiano Trail".

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

C61-9 Arlene
Patton
3/2/22 5-28
Funding for Bike facilities: "Pursue potential
funding from San Mateo County.." probably
should be San Mateo County Transportation
Authority
The comment is noted. The text changes are
incorporated in the General Plan errata. They
do not relate to adequacy of DEIR analysis.

C61-10 Arlene
Patton
3/2/22 Transit Oriented Development: This parcel is
actually owned by Caltrans and is under a MOU
with SamTrans. It was one of the properties I
These concerns are noted. The comment is
not related to the adequacy of the DEIR,
therefore no further response is required in

1.f
Packet Pg. 1086 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 422
Letter Commenter Date Comment Combined Response
Individuals (C)
managed on behalf of SamTrans. As you know,
Caltrans has a field office on part of the property
and SamTrans uses it as a bus layover area. Any
change of use would have to take in consideration
relocation of these uses.
the FEIR. However, the comment addresses
the content of the Proposed Plan and will be
shared with decision-makers in that context.

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

C61-11 Arlene
Patton
3/2/22 OC-I-27
Extend the Baquiano Trail ...and Ahni Trail down
Fassler...as part of the Ohlone-Portola Heritage
Trail..."
This is a minor correction made to clarify and
does not affect the findings of the DEIR.

C61-12 Arlene
Patton
3/2/22 Finally, there's a picture of Nick's parking lot with a caption regarding Beach Parking. I think it's in
the DEIR but for the life of me I can't find it again.

I've assumed that this parking lot is private
parking. If so, a better picture would be to either
use the South or North Rockaway parking lot.

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

1.f
Packet Pg. 1087 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 423
C62: Clif Lawrence, 1/16/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C62-1 Clif
Lawrence
1/16/22 Draft General Plan 2022 entries in
Table Of Contents... NOT FOUND
• FIGURES A-1, A-2,A-3,A-4.... In
fact NO section "A"
These concerns are noted. The comment is not related to the adequacy of the DEIR, therefore no further response is
required in the FEIR. However, the comment addresses the content of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master Response 1: EIR Comments for more information about GP- or SPSPrelated responses. General Plan TOC will be fixed in errata.

C62-2 Clif
Lawrence
1/16/22 TABLE 10-1.... NO SECTION '10' These concerns are noted. The comment is not related to the adequacy of the DEIR, therefore no further response is
required in the FEIR. However, the comment addresses the content of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master Response 1: EIR Comments for more information about GP- or SPSPrelated responses. Chapter 10 is the "Implementation" Chapter of the General Plan.

C62-3 Clif
Lawrence
1/16/22 Previous City efforts were
friendlier.
• There is no inter-active index.

C62-4 Clif
Lawrence
1/16/22 Vast majority of "sources" 2009
.... why? That's 12 years ago
(good for scotch...not civic docs)
References in the bibliography will be updated to reflect the latest data used in DEIR analysis chapters, which represents the best and latest available sources. This does not change any findings of significance in the DEIR.

C62-5 Clif
Lawrence
1/16/22 D&B lists themselves as "source"
on many graphic materials, when
their source is also credited. So
why is D&H a "source"? Did they
make some modifications to the
doc they got elsewhere? If they
made modifications, why did they
not tell us what they changed,
and the source for that
"additional data"?
Dyett & Bhatia citation means that D&B was conducted map and figure compilation and analysis.

C62-6 Clif
Lawrence
1/16/22 Was the City aware that in 2017
OPR created templates and links
to assist Cities and others to
update their general Plans?
The DEIR ... well... for
starters...(initial reactions)
This comment is not related to the adequacy of DEIR analysis.

Thus, no further response is required.

C62-7 Clif
Lawrence
1/16/22 1. It's presented as ONE BLOB
FILE…
This comment is not related to the adequacy of DEIR analysis.

Thus, no further response is required.

C62-8 Clif
Lawrence
1/16/22 1. NO Table of Contents, No
Interactive Index
A DEIR with interactive table of contents was made available on the Plan Pacifica website on February 14, 2022.

C62-9 Clif
Lawrence
1/16/22 2. It feels like it was intended to
obfuscate its contents.

Please see response to comment C62-8. The public comment period was extended until March 8, 2022 to allow for
additional public review time.

1.f
Packet Pg. 1088 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 424
Letter Commenter Date Comment Combined Response
Individuals (C)
C62-10 Clif
Lawrence
1/16/22 2. It swelled from 600+ pages to
1000+ pages
This comment is not related to the adequacy of DEIR analysis.

Thus, no further response is required.

C62-11 Clif
Lawrence
1/16/22 3. The 2014-2015 presentation
was at least broken into a series
of properly labeled files. In any
other time, I would say this was a
tragic effort to thwart public
involvement. But today 35% of
the county is going to end the
Earth's oldest democracy...and a
mad man in North Korea wants to
send us a nuclear bomb. What's
the connection? This presentation
does not appear to have any
assistance to public involvement.

It another case of
disenfranchising "We The People"
This comment is not related to the adequacy of DEIR analysis.

Thus, no further response is required.

1.f
Packet Pg. 1089 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 425
C63: Stan Zeavin, 3/2/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C63-1 Stan Zeavin 3/2/22 p 469 0f 1001
Chapter Three: Settings, Impacts,
and Mitigation Measures

3.6: Geology, Soils, and Seismic Risk
Landslides and Slope Failure
(references USGS report dated
1997)
The most up-to-date mapping is represented in Figure 3.6-

1. The Landslide Zone data was released by the
Department of Conservation in 2021, the authoritative
source for mapping Zones of Required Investigation. As
noted in the map methodology, "As a part of the geologic data compilation, an inventory of existing landslides in the San Francisco South Quadrangle, San Mateo County was
prepared by analysis of shaded relief maps (various
illumination directions) and contour data, limited field reconnaissance, and a review of previously published
(Harding-Lawson, 1983; Bonilla, 1988; Jacobs Associates, 1999; Brabb and others, 2000; Wentworth and others,
1998) and unpublished geologic-landslide mapping.

Landslides were reviewed using the lidar shaded-relief
map (USGS, 2005), Google Earth Pro DigitalGlobe and
Historical Imagery, and stereo-paired aerial photos. For each landslide included on the map several characteristics (attributes) were collected and compiled in a
geodatabase. These characteristics include recency of
activity, type, thickness, associated geologic unit(s), and the confidence of interpretation (definite, probable, or questionable). The completed landslide map was
digitized, and the attributes were entered into a database.

Landslides rated as definite or probable were carried into the landslide zone..."
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.

C63-2 Stan Zeavin 3/2/22 p.470
Beaches and Erosion
“The long-term average erosion
rate for cliffs in this general area is
roughly 0.2m/year” “…1997-98
winter storms caused 50 years of
erosion,” removal of 12 homes
(References USGS reports from1983
and 2005)
2015 three 300 block apartment
bldgs evacuated/demolished
(2evacuated 2009-2010)
The comment is accurate; the following clarification is made: The long-term average erosion rate for cliffs in this general area was determined to be roughly 0.2 m/year
based on a 1983 study; and the winter storms of 1997–
1998 caused approximately 50 years worth of erosion at
the location where 12 homes were condemned."
C63-3 Stan Zeavin 3/2/22 >Replace out-dated information. In order for Pacificans to make
decisions about development that
will have a long-term benefit to our
beautiful coastal town we need to
understand the real risks. Shoreline
recession along the coast has
continued for thousands of years.

Pacifica’s cliffs consist primarily of
alluvial sediments, poorly
consolidated sandstones, and are
Shoreline recession, or coastal erosion, is described on DEIR p. 3.6-14 and 3.6-17. Information on coastal erosion cited on p. 3.6-17 uses information from the 2018 Sea
Level Rise Vulnerability study, which uses the best
available science to estimate coastal erosion projections.

The Seismic Hazards Mapping Act established the
requirement to identify and map areas prone to
earthquake hazards of liquefaction, earthquake-induced
landslides and amplified ground shaking. The Department of Conservation, the authoritative agency on this

1.f
Packet Pg. 1090 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 426
Letter Commenter Date Comment Combined Response
Individuals (C)
topped in many places by 10 feet of
uncemented dune sand.
mapping, confirmed that the 2021 maps represent the
latest and best available data.

C63-4 Stan Zeavin 3/2/22 No single average rate of erosion can adequately represent the
repeated episodic erosion events
that have shaped our coast. Moffatt
and Nichol February 2022 study for
Pacifica estimates an average bluff
recession along Esplanade from
1943 to 2020 of 0.5 feet/year to 2.5
feet/year.

Dramatic examples of extreme
erosion include:
• During the 1983 storms 100 feet
was lost from the northwest corner
of the Pacific Skies Mobil Home
Park. (Griggs and Savoy, Living with
the California Coast, Duke
University, Durham, N.C., 1985) • In
1998 bluff retreat mapped by USGS
since 1956 caused the removal of
twelve homes from the 500 block of
Esplanade following 30 feet of
erosion over two weeks. (Lajoie and
Mathieson, USGS, 1998)
• At the Lands End Apartments
(now Oceanaire) 100 feet of their
seaward lawn dropped off during
one storm in 2009. See before and
after photos (courtesy of a Land’s
End owner) below. > The Moffatt
and Nichols report prepared for the
400 Esplanade Infrastructure
Preservation Project, February
2022, is thoroughly researched and
contains useful maps, graphs and
information that are appropriately
up-to-date and would serve Pacifica
well if incorporated into the
GP/SPSP/DEIR. As M&N notes, Sea
Level Rise will increase erosion rates
in the future.

The report referenced was released after the publication of the NOP and DEIR.The EIR used the best available data for its analysis at the time of publication. As noted in the 2022 area-specific Moffatt and Nichol report, "However, bluff erosion is known to be highly episodic and irregular, and thus use of average rates of recession should be used for understanding overall trends; use of average rates of recession for future planning is not recommended, as a
single event can results in extensive and/or rapid bluff recession." These new projections or information do not change any findings of significance in the DEIR. As noted on DEIR p. 3.6-22, "The General Plan determines that sitespecific geotechnical studies are the best mitigation to address the hazard of coastal erosion, and density,
setback, and other requirements can be determined on a
case-by-case basis."

1.f
Packet Pg. 1091 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 427
C64: Christine Boles, 1/31/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C64-1 Christine
Boles
1/31/2
2 The DEIR references two Existing Conditions Reports, one done in 2010 and one done in 2019 for Sharp Park. think I found the one for Sharp Park here, please confirm this is current.
https://www.planpacifica.org/spsp-ecr
I cannot find the one for the whole city that was discussed at a public hearing in September 2010. Can you forward that to me or should I file a PRA request? And can you confirm if any updates were done for the city wide studies? I'm currently specifically looking for more recent traffic studies as 2010 was before the tunnel opened. Thank you and I appreciate a quick response as our review time is so limited.

This comment is not
related to the adequacy
of the DEIR. Traffic
counts were conducted
in 2018 and 2019, and
analysis was conducted
in 2020 and 2021. Thus,
findings of significance
and analysis that relies
on transportation
counts, such as VMT
analysis and air quality,
remain valid.

1.f
Packet Pg. 1092 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 428
C65: Patricia McGregor, 1/30/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C65-1 Patricia
McGregor
1/30/22 Please consider extending the review
deadline , by at least a couple of months,
of this very extensive and, not very well
organized document. I have just recently
become aware of this huge report, which
will take me some time to review. Several
of my neighbors would also like more time
to review.

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.

1.f
Packet Pg. 1093 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 429
C66: Stan Zeavin, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C66-1 Stan Zeavin 3/8/22 >> San Pedro Creek was completely reconfigured from west of the
convalescent hospital to the mouth, not
just restored. The creek banks were not
eroding in the stretch that was
reconfigured. The intent was to achieve
100 year flood protection from San Pedro
Creek flooding. However, western Linda
Mar continues to flood from storm drain
and sewage overflow. Current
calculations for sewer capacity based on

3.7 inches of rainfall do not consider how
climate change can be expected to
increase the likelihood of higher rainfall
and runoff. The simultaneous occurrence
of high tide, serious storm surge, and the
extreme rains that can be expected with
climate change will again put the creek at
risk of flooding. The rains alone can
overwhelm the storm/sewer system even
with the “retention” tank functioning, as
happened in October, 2021, and on
previous occasions when the pumps have
failed.

Please see response to comment C13-3 for more
information about flooding.

C66-2 Stan Zeavin 3/8/22 >> Document must accurately reflect all Linda Mar flooding history: 1962, 1972,
1983, 1996(?), 2014, October, 2021
The comment is noted. The DEIR describes flooding
events in Linda Mar on DEIR p. 3.5-8. The following
clarification is thereby amended: "Substantial
flooding in this area occurred in 1955, 1962, 1972,
1982, 1997, and 1998, 2014, and 2021. This does not
change findings of significance of the DEIR.

C66-3 Stan Zeavin 3/8/22 >> Managed retreat at the beach and reconfiguration of the creek do not
protect Linda Mar homes from continued
overflows of storm drains and sewers
during predicted increasingly frequent
rains.

Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan Update
to ensure coordination between the two
documents. The beneficial impacts of these shared
policies as they relate to reduction of potential
impacts required under CEQA, such as impacts
related to geology or hydrology, are analyzed in the
DEIR. The City has prepared a draft of the LCP
Update in 2019, approved by the City in 2020, and
which is currently under review for certification by
the California Coastal Commission. To the extent
the General Plan Update proposes any policies
beyond those which were sent to the California
Coastal Commission for review and certification, a
subsequent LCP amendment would be necessary to
make the LCP consistent with the General Plan. The
DEIR does include discussion of the Coastal
Commission requirements; please refer to response
to comment C123-42 for more information. See
response to comment C13-3 for more information
about coastal flooding and sea level rise.

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Packet Pg. 1094 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 430
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.

C66-4 Stan Zeavin 3/8/22 >> Continued fluvial flooding of homes must be addressed.

The comment is noted.

C66-5 Stan Zeavin 3/8/22 • 1% Annual Chance of flooding for much of Linda Mar north and south of San
Pedro Creek is a gross misrepresentation.

See history!
The comment states that a 1% annual chance of
flooding is inaccurate as shown on Figure 3.5-1.

The information shown in this figure is based on the
following sources:

National Flood Hazard Layer for San Mateo County,
FEMA, 2019; Tsunami Hazard Area for San Mateo
County, Department of Conservation, State of
California, 2020; U.S. Fish & Wildlife Service,
National Wetlands Inventory, 2019; ESA, 2009; City
of Pacifica, 2020; San Mateo County, 2020.

As described under Impact 3.5-5 starting on page

3.5-29, impacts from the redirection or impediment
of flood flow, water pollution, and exceedance of
stormwater infrastructure capacity are minimized
through the implementation of stormwater
management policies within the Proposed General
Plan, Local Coastal Program, the Pacifica Green
Infrastructure Plan, and policies in the SPSP; thus,
the impact would be less than significant.

C66-6 Stan Zeavin 3/8/22 • 1% Annual Chance of flooding for Beach Boulevard and Shoreview is
underestimated. Homes routinely have
water wash into garages/yards. Climate
change and sea level rise will increase the
likelihood of flooding.

The comment states that a 1% annual chance of
flooding is inaccurate as shown on Figure 3.5-1.

The information shown in this figure is based on the
following sources:

As described under Impact 3.5-5 starting on page

3.5-29, impacts from the redirection or impediment
of flood flow, water pollution, and exceedance of
stormwater infrastructure capacity are minimized

1.f
Packet Pg. 1095 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 431
through the implementation of stormwater
management policies within the Proposed General
Plan, Local Coastal Program, the Pacifica Green
Infrastructure Plan, and policies in the SPSP; thus,
the impact would be less than significant.

C66-7 Stan Zeavin 3/8/22 • 1% Annual Chance of flooding at Rockaway needs revision after restaurant
windows were broken by waves in 2017.

The comment states that a 1% annual chance of
flooding is inaccurate as shown on Figure 3.5-1.

The information shown in this figure is based on the
following sources:

As described under Impact 3.5-5 starting on page

C66-8 Stan Zeavin 3/8/22 • This very important section should be updated using more recent modeling
from the California Ocean Protection
Council and continuing studies
Please see response to comment C13-1 for more
information about the adequacy of mapping.

C66-9 Stan Zeavin 3/8/22 • The very real risk to Pacifica from sea level rise dictates the necessity of
planning for and managing inevitable
future adaptation and retreat.

Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan Update
to ensure coordination between the two
documents. The beneficial impacts of these shared
policies as they relate to reduction of potential
impacts required under CEQA, such as impacts
related to geology or hydrology, are analyzed in the
DEIR. The City has prepared a draft of the LCP
Update in 2019, approved by the City in 2020, and
which is currently under review for certification by
the California Coastal Commission. To the extent
the General Plan Update proposes any policies
beyond those which were sent to the California
Coastal Commission for review and certification, a
subsequent LCP amendment would be necessary to
make the LCP consistent with the General Plan. See
response to comment C13-3 for more information
about coastal flooding and sea level rise.

C66-10 Stan Zeavin 3/8/22 • Utilize the accurate hazard/vulnerability report funded by a grant from the CCC in
2018, and include the necessary
information
The DEIR utilizes the best available science from the
2018 Sea Level Rise Vulnerability Assessment,
including information on coastal erosion (DEIR p.

3.6-17) and sea level rise (p. 3.5-8 and 3.5-9).

C66-11 Stan Zeavin 3/8/22 • It is absolutely necessary that the most recent and dependable sea level rise
projections be used in every decision
about the coastal zone and those areas of
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

1.f
Packet Pg. 1096 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 432
Linda Mar that are predicted by COSMOS
to flood in the future. In addition, to avoid
costs to residents and for future litigation,
the city must take every precaution to
follow California State law and Coastal
Commission guidance. We can hope for
the best but we must protect the city and
plan for the worst.
policies in the LCLUP regarding sea level rise
monitoring.

1.f
Packet Pg. 1097 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 433
C67: Remi Tan, 1/5/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C67-1 Remi Tan 1/15/22 The planned housing quantity of 990 units by 2035 is inadequate and does not cover the job creation
of 1,470 jobs by 2040 and is also short of the 1,892
RHNA required housing units to be built by 2031.
(See excerpts from the Jan 2022 Public Comment
Draft General Plan and the ABAG RHNA.) Also
given that the majority of the jobs projected to be
created are in the retail and service sectors (which
is in line with the proposed increase in tourism),
and these jobs are typically low paying, we need to
add much more housing and most of this should
be affordable housing.

The comment is noted. Please see
response to comment C46-7 for more
information about RHNA, as well as Master
Response 3: Buildout and RHNA.

C67-2 Remi Tan 1/15/22 Given the recent astronomical rise in Pacifica real estate values, Pacifica needs to increase housing
quantities beyond the RHNA allocation to stabilize
prices by increase supply to meet demand.. The
City should work with other Bay Area cities and
counties and ABAG to engage a study by an
economist that would analyze job creation and
population increase in the Bay Area and determine
the amount of housing that needs to be built in
Pacifica (and the Bay Area) not only to
accommodate the new jobs within commutable
distance and population growth but to stabilize
rising prices by building enough housing so that
demand and supply are equalized.

C67-3 Remi Tan 1/15/22 This new housing should be accounted for in the new General Plan and should be located near
transit stops and shopping centers to reduce
traffic, and not located on hillsides and toes of hills subject to landslide, in erosion vulnerable coastal
edges, or in areas prone to flooding or high tide
inundation to avoid loss of life and property due to
more severe weather and sea level rise caused by
global warming. This may require increase in
density and height limits near the transit and
shopping centers to accommodate the housing.

The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response: EIR comments for more
information about GP- or SPSP-related
responses. As described on DEIR p. 2-10,
"The proposed Plan establishes a land use
pattern that reflects hazardous conditions,
such as steep slopes and coastal bluffs, and
includes policies to improve public safety
services and emergency management."
Impacts and policies to reduce impacts due
to hazards are described in DEIR chapters

3.5, 3.6, 3.11, and 3.14.

C67-4 Remi Tan 1/15/22 Given the dire rising cost situation with housing, and with all the effort and public input in the new
General Plan and subsequent zoning updates, all
housing projects as well as commercial projects
should have as-of-right zoning that minimizes
additional public, planning commission and city
council hearings and meetings to expedite the
planning process and the city should coordinate
with the Coastal Commission to make sure the
These concerns are noted. The comment is
not related to the adequacy of the DEIR,
therefore no further response is required
in the FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more

1.f
Packet Pg. 1098 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 434
Letter Commenter Date Comment Combined Response
Individuals (C)
General Plan and zoning is designed to make CC
approval as of right too.
information about GP- or SPSP-related
responses.

C67-5 Remi Tan 1/15/22 The city should have an expedited permit process in place and coordinate this expedited permit
process with the Coastal Commission for housing
locations in the Coastal Zone. Housing projects
with high affordability should be top priority in
permit expediting
These concerns are noted. The comment is
not related to the adequacy of the DEIR,
therefore no further response is required
in the FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more
information about GP- or SPSP-related
responses.

C67-6 Remi Tan 1/15/22 Please advise on next steps plans to take in incorporating increased housing and the above
measures into the new General Plan.

1.f
Packet Pg. 1099 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 435
C68: Patrick Mora, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C68-1 Patrick Mora 3/8/2
2 Repeat of C36 Please see comment
responses to letter C-

36. 1.f
Packet Pg. 1100 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 436
C69: Victor Carmichael, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C69-1 Victor
Carmichael
3/8/22 I have commented extensively on geology related
issues in my Comment Ltr #2. However this
section, Chapter 3.6 Geology, Soils and Seismic
Risk, is very much related since it specifically
focuses, on among other related issues geological
concerns, coastal erosion. Since coastal erosion is
an ongoing and controversial issue here in Pacifica,
it might have made more sense to treat it as a
separate entity rather than combine it with two
less timely issues, Soils and Seismic Risk. .In any
case I was glad to the two ravines that I brought up
my Comment Ltr # 2 were included in the Figure

3.6-3 although dismissively called “Gullies”.

In working through the material in this Chapter 3.6
I tried to zero in on matters that I believed were
the most important. However I found the
organization somewhat disjointed with much that
was relatively agreed upon and prosaic crowding
out what we hoped the GP-DIER process would
confront.

The comment is noted.

C69-2 Victor
Carmichael
3/8/22 In any case I found the section titled Beaches and Coastal Erosion ( Pg 3.5-14) contained useful and
interesting information. Northern California's and
specifically San Mateo County coastline's it turns
out is especially susceptible to severe erosion as
well as slope failure. It says our long term rate of
cliff erosion is “roughly 0.2m/year”. And
sometimes it happens all at once, like the loss of
50' in one year (1997-98). Other more recent
major collapses were mentioned like the 2016
losses on Esplanade Avenue. It goes on to state
that the Pacifica 2021 Annex to the San Mateo
Countys Multijurisdictional Local Hazard Mitigation
Plan (MJ-LHMP) identifies coastal erosion as the
top hazard in Pacifica. Also noted was that at least
eight significant coastal erosion events have
occurred since 1997. All of this is, of course, before
SLR was a burning issue.

The comment is noted.

C69-3 Victor
Carmichael
3/8/22 The section, Effects of Sea Level Rise (Pg 3.5-17), opens with this stark pronouncement: “Sea level
rise resulting from global climate change is
projected to cause more extensive erosion of
beaches, dunes, bluffs and cliffs.” Later in that
section a study is cited that states a majority of
dune coastline is currently accreding but this
process will dramatically reverse between 2050
and 2100. However the bluffs will continue to
erode and the erosion will increase dramatically
between 2025 and 2050. That is certainly within
our planning horizon.

Then they warn : “It is important to reiterate that
The comment is noted.

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Packet Pg. 1101 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 437
Letter Commenter Date Comment Combined Response
Individuals (C)
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.”
(underline added) In the next section, Shoreline
Protection Programs, soft pedals things with some
good but old news regarding the successful effort
in 2002 to purchase and remove houses at Pacifica
State Beach – 'managed retreat' before it was
demonized. Finally there is very cursory coverage
of our revetment status and the need for repair of
the battered seawall on Ocean Ave.

C69-4 Victor
Carmichael
3/8/22 Here, as my focus has been is on the DEIR's
treatment of coastal erosion issues, I have respond
on several Policy Elements that I found specifically
pertain to that area of concern.

CO-I-46 Pg 6-36 Shoreline Protection. Continue to
prohibit new development requiring shoreline
alterations.

Shoreline-altering construction such as
revetments, breakwaters, groins, channels,
seawalls, cliff retaining walls and similar structures
is permitted only when required to serve coastaldependent uses or to protect existing structures arid public beaches in danger of erosion. Such
structures, where permitted must be designed to
eliminate or mitigate impacts on local shoreline
sand supply. The problem is not more revetments.

The Coastal Commission has long since prohibited
new ones. The problem is enforcement (Pacific
Villa?) and maintenance. Once it's as harmful and
illegal it is, here to stay. The problem once a rock
revetment (or seawall) is in they are allowed to be
maintained . So they continue in perpetuity to rob
the beaches of their sand while the ocean often
gets around the revetment and continues to eat
into the bluff anyway.

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

C69-5 Victor
Carmichael
3/8/22 Northern Coastal Bluffs. Promote the permanent
conservation of private land on the Northern
Coastal Bluffs to protect sensitive natural
communities and protect against coastal erosion.

Managed protected land together with adjacent
GGNRA land.

The remaining private land north of the GGNRA
protected land probably in little danger of
development as it is facing a losing battle with
erosion. But it is gratifying that the DEIR recognizes
its value. If that were only the case with the Fish
and Bowl properties just east of the bluffs.

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

1.f
Packet Pg. 1102 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 438
Letter Commenter Date Comment Combined Response
Individuals (C)
C69-6 Victor
Carmichael
3/8/22 Bluff Drainage and Erosion.

The City will pursue feasible funding mechanisms
to investigate areas that may be significantly
contributing to groundwater flows to the bluffs
and determine whether improving drainage
and/or reducing irrigation could reduce bluff
erosion. Measures to improve drainage and
reduce over-watering shall be communicated to
the public and property owners as part of existing
water conservation outreach programs, and
included as conditions on new development where
applicable.

This element bears directly on the concerns I
addressed in Comments Ltr #2 with respect to the
Fairmont West coastal bluff (Northern Coastal
Bluffs) and their relationship to land areas east of
the bluffs.

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

C69-7 Victor
Carmichael
3/14/22 While much of the material presented regarding
coastal erosion in Chapter 3.6 Geology, Soils and
Seismic Risk is solid and science based, there
probably are more recent available data.

Nevertheless, what it here is enough for action.

But a call for action is not what this document
contains.

Please see response to comment C47-3 for
more information about the adequacy of
erosion
C69-8 Victor
Carmichael
3/8/22 What is plainly obvious is that this DEIR is not calling to task the General Plan for its lack of
dealing with one of most critical and central issues
facing Pacifica, policy for confronting SLR driven
coastal erosion. Pacifica is a coastal community in
the direct path of SLR. Already we have had
preview of it with our rapidly eroding shoreline
due our location and geology. But it will get worse.

Yet we are acting very ostrich-like to let the GPDEIR become a politically driven documents rather than use this opportunity to move forward with
something that addresses the future. This DEIR
should be reportting the environmental
implications of the General Plan especially in
relation to the Climate Crisis and SLR. It is not. It is not even close. If it were, this section and all of its policy elements would look much different. This is
sad because this may be our only opportunity to
get it right.

The DEIR describes the impacts of coastal
erosion and sea level rise on DEIR p. 3.6-17.

As noted in Impact 3.6-2, "The Planning Area
contains rugged coastline areas that are
susceptible to coastal erosion from wave
action. Whereas 30 to 50 years ago
engineering methods of introducing hard
barriers to protect shoreline improvements
were common, soft stabilization methods
have proven more effective in maintaining
natural systems of sand transport. Soft
stabilization methods include sand and
cobble beach fills which can more closely
mimic natural conditions and respond to
changes in wave action and would be
encouraged with implementation of the
proposed policies below. According to a
study done by the U.S. Geological Survey
following the heavy winter storms of 1982–
1983, the entire coastline of San Mateo
County contains areas susceptible to severe
erosion and slope failure. Coastal areas
within the Planning Area include locations
that the USGS have determined to have
critical erosion hazards and unstable
segments where the sedimentary rocks are
susceptible to failure from heavy wave
action. Areas within the Coastal Zone are
vulnerable to coastal erosion. Proposed

1.f
Packet Pg. 1103 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 439
Letter Commenter Date Comment Combined Response
Individuals (C)
development within the Coastal Zone would
be regulated by the Coastal Act and certified
Local Coastal Plans."
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. Therefore, the
potential for adverse erosion impacts
related to land use changes from
implementation of the proposed General
Plan is less than significant with
implementation of the proposed policies
and compliance with the Local Coastal
Program.

1.f
Packet Pg. 1104 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 440
C70: Rick Nahass, 2/6/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C70-1 Rick
Nahass
2/6/22 Repeat of C58 Please see comment
responses to letter C-58

1.f
Packet Pg. 1105 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 441
C71: Arlene Patton, 3/2/2022
Letter Commente
r
Date Comment Combined Response
Individuals (C)
C71-1 Arlene
Patton
3/2/2
2 First, thank you for the 15 day extension. I finally finished reading all three documents on Monday. Staff and Council have done a remarkable job on this long and difficult task and it is very, very good. I have a few minor comments which I will send to staff under separate cover. I am especially pleased with the addition of several parcels to the Hillside Preservation Designation for both safety and natural resource protection.

The comment is noted.

1.f
Packet Pg. 1106 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 442
C72: Pete Shoemaker, 2/2/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C72-1 Pete
Shoemaker
2/2/2
2 Here is the link to the file we should have had all along: Searchable EIR download. We have uncompressed the file, which allows it to be searched and cut & pasted, and added internal links so that it has a oneclick, interactive TOC. It is located on my Google Drive and easily downloaded, as you can see for yourself. It’s too big for Google to scan or preview, but it is the exact same document the City issued.

The comment is noted.

A DEIR with interactive
table of contents was
added and submitted to
the State Clearinghouse
on February 14, 2022.

C72-2 Pete
Shoemaker
2/3/2
2 Have you spent much productive time looking over the EIR before this? Like most of us, you probably tried to do your duty but gave up after being overwhelmed and confused—because the document the Planning Department gave us is unusable, and everyone knows it. We’ve been given the minimum time to look it over and we’ve already lost half of that. Can't you see why we’re asking for an extension?
You’ve volunteered you time on this Commission because you care about our community, and we’ll all very grateful. I know you want to do your jobs well and analyze this document as best you can. You need to have ample time to do this, so please, join with us and ask for more time.

Demand it, as you are a critical link in the approval chain.

We understand that the Planning Department has been understaffed and dealing with Covid and relocation issues. But that doesn’t excuse issuing a substandard document—one of the most important to our city—and rushing it through. It’s enough that we citizens have to spend hours of time filling in for the Planning Department. We should at least get acknowledgment and have our reasonable request for more time honored.

Please see response to
comment C62-8. The
public comment period
was extended until
March 8, 2022 to allow
for additional public
review time.

1.f
Packet Pg. 1107 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 443
C73: Erin Macias, 1/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C73-1 Erin Macias 1/20/22 What transpired last night is concerning and I am forwarding a copy of an email to
Mayor Bier below. I had no intention of
speaking on the project, I only wanted to
omment on the General Plan update.

Because it was a public hearing, it captured
my attention and I pulled up the parcel
map. I was stunned by the map and
scrambled to repare a comment. Wildfire
was one part of my concern (this parcel is
very similar to the one behind me and we
had a fire that threatened our homes on
the 4th of July a ew years ago.) The parcel
behind me is one of many already
fragmented parcels and as a result, we
have many forms of wildlife using the
streets and side yards as corridors to get
between these fragments and out to open
space. The fragmentation issue warrants
the attention of the decision makers in our
City.

The DEIR analyzes impacts to wildlife movement
corridors under Impact 3.7-4 on p. 3.7-61 and found
that "Implementation of the Proposed Project
(General Plan) 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. The following policies support this finding:
(LU-G-7) Open Space Conservation and Habitat
Protection. Protect beaches, oceanfront bluffs,
ridgelines, hillside areas adjacent to existing open
space, and areas that support critical wildlife
habitat and special status species.
(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) should be used as a guide.
(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-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.

While the comment is about a particular
development project and does not address the
adequacy of the DEIR, the General Plan does include
policies for wildlife movement corridors.

C73-2 Erin Macias 1/20/22 Please take a look at the circled areas on the attachments. We are in the midst of a
General Plan update and I was told we are
only allowed four amendments per year.

So, the draft presented for public comment
is one, the amendment with this project
would be another. So that limits us to two
more amendments to our general plan for
the remainder of 2022? That really restricts
our ability to approve the plan and make
The comment is noted and relates to a specific
project that is not a part of the General Plan
Update. The comment does not address the
adequacy of the environmental analysis contained
in the DEIR. Please see Master Response 1.

1.f
Packet Pg. 1108 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 444
Letter Commenter Date Comment Combined Response
Individuals (C)
amendments rapidly vs delaying the
approval of the entire plan.

C73-3 Erin Macias 1/20/22 We have a map of the vegetation that pairs with the EIR. We also have a map of the
sensitive and critical habitat that also pairs
with the EIR. So, now look at the project
that was just approved. The PC decision
landlocked greenspace and fragmented it. I
am not opposed to new construction, I
welcome it, but what this odd project did
was perch a house in HPD, with a variance
and an amendment to the GP while cutting
off a corridor that was never even
analyzed: how this could be CEQA exempt?
There is video footage of a mountain lion
using the space less than 700 feet away
from this project. This is an active wildlife
corridor.

The comment is noted and relates to a specific
project that is not a part of the General Plan
Update. The comment does not address the
adequacy of the environmental analysis contained
in the DEIR.

C73-4 Erin Macias 1/20/22 Looking at this in context of other developments, what type of precedent
does this set? We are allowing
fragmentation of sensitive and critical
habitat so why wouldn’t any other
developer legally challenge a PC decision
that deprived them of doing the same
thing? The consequences of such an
amendment to the General Plan are severe
and have broader implications. I am very
hopeful that in your capacity as our
Planning Director you would have some
jurisdiction over this major issue affecting
our city particularly in how it could impact
the BOV project and the one by the
Montessori School too. I have emailed each
council member to take a look at this
concern, OSPAC says it is out of their
jurisdiction. Now it is in the hands of
council and the staff who helps shape the
decisions. PLEASE take a good look at this
and consider the consequences to our City
with a General Plan Amendment such as
this.

The comment is noted and relates to a specific
project that is not a part of the General Plan
Update. The comment does not address the
adequacy of the environmental analysis contained
in the DEIR. Please see Master Response 1.

C73-5 Erin Macias 1/20/22 The Planning Commission just approved a project that fragmented high habitat value
as identified in the new General Plan and
referenced in the existing General Plan.

C73-6 Erin Macias 1/20/22 am providing a resource to peruse. We need to focus carefully on the issue of
fragmentation in our General Plan update.

We need to add to our maps to identify the
corridors currently in use and write a plan
for prevention and mitigation of
fragmentation
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

1.f
Packet Pg. 1109 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 445
Letter Commenter Date Comment Combined Response
Individuals (C)
http://wildlife.org/wpcontent/
uploads/2016/04/FS_WildlifeHabitatFragm
entation_FINAL.pdf
C73-7 Erin Macias 1/20/22 I am appealing to you because I know you are very interested in our natural
environment. I attended the planning
commission meeting last night to comment
on the General Plan update. There was a
public hearing on the agenda so I looked up
the parcel out of curiosity. I was not
planning on speaking, but I was stunned
that the City was amending the General
Plan and approving a variance for a project
at the top of Talbot. The approval of a
single family home last night, “fragmented”
a connector between open space in what
has already been identified as high value
open space threatened by fragmentation.

This is a really big deal. They landlocked
greenspace. Not one planning
commissioner flinched last night. It’s very
disturbing that this is not a concern of our
appointed Planning Commissioners.

We have a General Plan update in front of
us. This MUST be addressed in our General
Plan and in the EIR. What is the point of
having a Hillside Preservation District and
planning and land use codes along with
ordinances and policies if we toss them out
the window when architects and
developers convince our staff and officials
to legally change the playing rules –
amending the general plan and approving a
variance to accommodate a developer: let
that sink in!
I am truly stunned this took place last
night. PLEASE help advocate for our draft
General Plan to stop fragmentation and
prevent the amendment of our General
Plan, policies and ordinances to
accommodate developers. In summary, the
Planning Commission approved a single
family home that cuts off wildlife from
nearly 4 acres of open space. Somehow this
project claims it was CEQA exempt. I
cannot believe this is even possible. If you
look at the diagram of the parcel map you
will notice the blue highlighted parcel. That
is a steep hillside and a house perched
upon it, it cuts off parcel A from parcel B
and now animals now must go through the
side yards of that parcel, 722 Talbot or 712
Canyon. The first two diagrams are from
The comment is noted and relates to a specific
project that is not a part of the General Plan
Update. The comment does not address the
adequacy of the environmental analysis contained
in the DEIR; please see Master Response 1. The
General Plan does include policies to address these
concerns, including:

CO-I-33 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 of the
proposed General Plan.
• Designated Critical Habitat for Endangered or
Threatened Species;
• Potentially Environmentally Sensitive Habitat Area
(ESHA);
• High Habitat Value/Threatened by Fragmentation;
• Wildlife Movement Corridor; and
• High Value/Further Analysis Needed Prior to
Development.

1.f
Packet Pg. 1110 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 446
Letter Commenter Date Comment Combined Response
Individuals (C)
our proposed General Plan Update.

More fragmentation of these high value
greenspaces means animals have less space
to breed, hunt, roam, find refuge, raise
their young and they will be forced into
private residences, public roads and into
dangerous encounters with humans, pets
and cars.

1.f
Packet Pg. 1111 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 447
C74: Elizabeth Rubenstein, 1/19/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C74-1 Elizabeth
Rubenstein
1/19/2
2 I love the proposals for improving Palmetto Ave!
We have long needed a cohesive design and
leadership to create a vital downtown area.

C74-2 Elizabeth
Rubenstein
1/19/2
2 Wondering how this development is impacted
by current managed coastal retreat plans?
Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan Update
to ensure coordination between the two
documents. The beneficial impacts of these shared
policies as they relate to reduction of potential
impacts required under CEQA, such as impacts
related to geology or hydrology, are analyzed in
the DEIR. The City has prepared a draft of the LCP
Update in 2019, approved by the City in 2020, and
which is currently under review for certification by
the California Coastal Commission. To the extent
the General Plan Update proposes any policies
beyond those which were sent to the California
Coastal Commission for review and certification, a
subsequent LCP amendment would be necessary
to make the LCP consistent with the General Plan.

Please see Master Response 1.

C74-3 Elizabeth
Rubenstein
1/19/2
2 Where are all those mature trees coming from? The comment is not related to the adequacy of the DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

1.f
Packet Pg. 1112 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 448
C75: Peter K, 1/18/2022
Letter Commen
ter
Date Comment Combined Response
Individuals (C)
C75-1 Peter K 1/18/2
2 I notice that Sharp Park plan doesn't
actually address sea level rise. It does not
that sea level rise is an issue, but has not
one plan address issues.

Sea level rise is discussed in Chapter 3.5. Please see
response to comment C47-7 for more information.

C75-2 Peter K 1/18/2
2 Issues like:
- Spending tons of money to beautify Sharp Park, and
do nothing to protect that investment.

C75-3 Peter K 1/18/2
2 The pier has been damaged at least twice in the last
decade. This is only going to get worse with sea level
rise. How does the plan protect the pier, which the plan notes is a precious resource?
Issues related to coastal resources are addressed in
the LCLUP. Although the LCLUP is a separate
planning document, the LCLUP policies and relevant
narratives are included in the General Plan Update
to ensure coordination between the two
documents. The beneficial impacts of these shared
policies as they relate to reduction of potential
impacts required under CEQA, such as impacts
related to geology or hydrology, are analyzed in the
DEIR. The City has prepared a draft of the LCP
Update in 2019, approved by the City in 2020, and
which is currently under review for certification by
the California Coastal Commission. To the extent
the General Plan Update proposes any policies
beyond those which were sent to the California
Coastal Commission for review and certification, a
subsequent LCP amendment would be necessary to
make the LCP consistent with the General Plan. The
DEIR does include discussion of the Coastal
Commission requirements; please refer to response
to comment C123-42 for more information. Please
also see Master Response 1.

C75-4 Peter K 1/18/2
2 The properties near the end of the sea wall are getting damaged by the water forces being directed there by
sea wall. Those residents might have a claim against the city. Sea walls are known for causing damage in
adjacent areas:
https://linkprotect.cudasvc.com/url?a=https%3a%2f%2
fbeachapedia.org%2fShoreline_Structures&c=E,1,_NdQ
bVxX6SQCsmTldFJcURFWI0RYNcJuRM7H_n638B49D6R
KAAnGfK4qFk_MFkovYFlvZTNymh2ryC1e0vyYfe80O
1o5i2DBd-Td5WBwKQ,,&typo=1
What is Pacifica doing to protect these homes in the
Sharp Park plan?
Issues related to coastal protection are addressed in
the LCLUP. Although the LCLUP is a separate
planning document, the LCLUP policies and relevant
narratives are included in the General Plan Update
to ensure coordination between the two
documents. The beneficial impacts of these shared
policies as they relate to reduction of potential
impacts required under CEQA, such as impacts
related to geology or hydrology, are analyzed in the
DEIR. The City has prepared a draft of the LCP
Update in 2019, approved by the City in 2020, and
which is currently under review for certification by
the California Coastal Commission. To the extent
the General Plan Update proposes any policies
beyond those which were sent to the California
Coastal Commission for review and certification, a
subsequent LCP amendment would be necessary to
make the LCP consistent with the General Plan. The
DEIR does include discussion of the Coastal

1.f
Packet Pg. 1113 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 449
Letter Commen
ter
Date Comment Combined Response
Individuals (C)
Commission requirements; please refer to response
to comment C123-42 for more information. Please
see Master Response 1.Please also see Master
Response 1.

C75-5 Peter K 1/18/2
2 How is Pacifica protecting itself from the legal liabilities around building a seawall next to private property?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR.

C75-6 Peter K 1/18/2
2 Also, what is Pacifica going to do about the buildings that are literally falling into the ocean, and at risk of doing of falling into the ocean? Not just the Esplanade fiasco, but also the residences just north of the sea wall.

Please see response to comment C69-8 for more
information on erosion hazards and policies that
reduce impacts that could occur as result of
implementing the Proposed Plan to less than
significant.

C75-7 Peter K 1/18/2
2 And when there are high sea waves, building facing the ocean get damaged, one place has had it garage door
blown in at least twice in my memory. How much taller
does the wall need to be, versus how tall the plan is?
Which is to ask, why doesn't the Sharp Park Plan
include data about how tall the sea wall needs to be?
Deciding how tall to making the sea wall without
knowing how tall it needs to be seems stupid.

Issues related to coastal protection are addressed in
the LCLUP. Although the LCLUP is a separate
planning document, the LCLUP policies and relevant
narratives are included in the General Plan Update
to ensure coordination between the two
documents. The beneficial impacts of these shared
policies as they relate to reduction of potential
impacts required under CEQA, such as impacts
related to geology or hydrology, are analyzed in the
DEIR. The City has prepared a draft of the LCP
Update in 2019, approved by the City in 2020, and
which is currently under review for certification by
the California Coastal Commission. To the extent
the General Plan Update proposes any policies
beyond those which were sent to the California
Coastal Commission for review and certification, a
subsequent LCP amendment would be necessary to
make the LCP consistent with the General Plan. The
DEIR does include discussion of the Coastal
Commission requirements; please refer to response
to comment C123-42 for more information. Please
also see Master Response 1.

C75-8 Peter K 1/18/2
2 During major storms, the Sharp Park golf course floods, and two things happen that are environmental issues:
-- They pile sand up next to the "illegal" berm
protecting the golf course. Is that permitted from an
environmental standpoint?
-- The golf course pumps out flood water into the
ocean. The water from the golf course is polluted with
herbicides and pesticides. Does the Sharp Park have a
permit to pollute Pacifica's coast waters like that?
The earthen berm is permitted in Sharp Park and is
described under the Hydrology paragraph on page
A-43. Impact 3.5-4 starting on page 3.5-36 analyzes
whether implementation of the Proposed Project
would risk release of pollutants due to projection
inundation by seiche, tsunami, or flood. As
described under the impact, numerous policies in
the Safety Element of the Proposed Project protect
and restrict new development in tsunami and flood
hazard zones with flood damage prevention
programs; facilitate the cleanup of hazardous waste
and toxic pollutants; and enforce provisions of
existing State codes and regulations which minimize
risk to life and property in areas of flood hazard.

Based on compliance with local, state, and federal
regulations and implementation of the policies in
the Proposed Project, the potential impact from
release of pollution due to project inundation by
seiche, flooding, or tsunamis is less than significant.

1.f
Packet Pg. 1114 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 450
Letter Commen
ter
Date Comment Combined Response
Individuals (C)
C75-9 Peter K 1/18/2
2 This snapshot of the Sharp Park plan shows that they
don't even know the scope of the problem of sea level
rise.

This comment is noted. The Sharp Park Specific Plan
area is within the Coastal Zone. 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.

1.f
Packet Pg. 1115 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 451
C76: David Patton, 2/15/2022
Lett
er
Comm
enter
Date Comment Combined Response
Individuals (C)
C76-
1 David
Patton
2/15/22 Please do not allow urban sprawl in our
quaint beach community. It will bring
traffic and noise like you can’t imagine….

We like our town the way it is. I need my
right to “quiet enjoyment”
Traffic congestion is not a required topic of analysis under CEQA; please see Master Response 1. Noise is addressed in Chapter 3.10.

New development under the Proposed Project may temporarily increase noise and groundborne vibration levels due to
construction activities. Development under the Proposed Project would be required to comply with the imitations on construction activity included in Chapter 10 of the Pacifica Municipal Code.

Compliance with these provisions and noise polices in the Proposed Project, is mandatory and will ensure that construction impacts, while potentially a temporary nuisance, are less than significant.

With development under the Proposed project, an incremental increase in the amount of land where noise sensitive uses could be subject to community noise levels above normally acceptable levels is expected. However, only a very small amount of land would be subject to “clearly unacceptable” noise levels, while elsewhere noise could be reduced to less than significant levels by state and local building standards supported by Proposed Project policies.

1.f
Packet Pg. 1116 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 452
C77: Sue Digre, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C77-1 Sue Digre 3/8/22 Executive Summary Section.

1. "The Proposed Project " was developed in
response to policy direction by...as well as
community concerns .."
..Report to Residents in the DEIR for full
disclosure and for comparison purposes. who
the City is determing are Stakeholders.
..State the % of input from each designated
stakeholder.

C77-2 Sue Digre 3/8/22 A Gen Plan is supposed to be a Constitution for residents of a City. It is their choice of who, what
they want to be.

IF we are mistaken , a clarification is necessary.

C77-3 Sue Digre 3/8/22 2. Diversity of Housing.
"The Plan aims ...and ensure adequate housing
options for people of all ages & incomes by
providing enough sites at a higher density....

Input:

That is a sweeping statement buried in the
paragraph and calls for a dramatic change from
the operative ,long respected GP. Explain how it
is appropriate to increase the height of buildings
beyond the usual 35' in the designated Historical
Area. We are determing the chatacter of our
Community. This statement is buried in a
paragraph appears disrespectful to the
electorate
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.

C77-4 Sue Digre 3/8/22 Input:
..Infrastructure Improvements.

Nothing is mentioned about 21st Century traffic
management strategies .

The City negotiated for and got two. The GP
should addess that and be dedicated to ensuring
that they are operative accountable as expected.
( CalTrans insisted that they were capable and
we had to abandon a potential contract with
Rhythmn Emgineering.)
The GP should indicate that the City needs to
insist on procuring more ITS signals to keep
traffic moving through the City, through the
Tunnel and through Midcoast. The GP should
state that the City collaborate with midcoast and
CalTeans & County for the most effective
mobility management. If the movement of traffic
is not consistent there will ne negative CO2 and
other health consequences.

The comment is noted. Congestion is not a
required topic for CEQA analysis and the DEIR
correctly analyzed and mitigated VMT impacts
on pages 3-40 to 3-43. Comments regarding
proposed General Plan polices do not pertain
to the adequacy of the DEIR, thus no further
response is required. 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.

1.f
Packet Pg. 1117 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 453
Letter Commenter Date Comment Combined Response
Individuals (C)
C77-5 Sue Digre 3/8/22 3. Protections from Natural Hazards. E-3@@ ...The.GP should state that Our Commumity
vision & goals must be grounded on data that
was produced in the most recent dates
.Presently that would be 2022. .

If that data is not available from reliable sources
immediately, then the GP should state that once
new data is available it will be studied and
applied as an update to the certified GP.
(The present 1980 GP did have an 1981 update
in it.)
..The date of data used for this GP should be the
most recent scientific.data available and must
state the date and source.

Please see response to comment C22-10 for
more information on how the DEIR uses the
latest and best available mapping for analysis.

C77-6 Sue Digre 3/8/22 4. Public input too must be based on the most recent scientific data available today .
..Outreach must be made to inform the public of
the most recent data and the city should enable
public dialogue of the most recent data.

Please see response to comment C22-10 for
more information on how the DEIR uses the
latest and best available mapping for analysis.

C77-7 Sue Digre 3/8/22 5.The GP should state that Ample funding should be used to ensure a thorough outreach to the
Public at large and to enable Public Dialogue at
Public Forums . Digital media is important but
equally important is outreach to non-techy
persons and non-mobile persons throughout tge
City.

C77-8 Sue Digre 3/8/22 6. The Gen Plan should also incorporate such best practices in its policies.

C77-9 Sue Digre 3/8/22 7. Sharp Park Specific Plan p E-4 Again this section is a bit disengenuous
,dismissive of the Public Voice and the Voter.

Ch 3."...where significant change may be
expected to occur...."
...A change in height limit from 35ft to 5 stories
high is in the Draft Sharp Park Plan.

And this 5 story high density is to.be built in a
City designated HISTORICAL area.

A City draft Gen Plan must be very transparent to
the Public at large, the Voters, before it is
adopted and.for Public Dialogue
A Gen Plan is a local constitution for the
residents.

C77-10 Sue Digre 3/8/22 Ch 5. P E4 &5
"...compatibility with existing development.."
...Once again the Sharp Park Draft plan
determines that 5 story high density buildings
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

1.f
Packet Pg. 1118 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 454
Letter Commenter Date Comment Combined Response
Individuals (C)
will be in the already City designated Historical
area of Pacifica. This language in p E4&E5 lacks
clarity and full information.
city with height limits that vary by zone, future
development will be subject to regulation and
review mechanisms to ensure there is no
substantial adverse effect on scenic
vistas...The land use changes in the Proposed
Project will not substantially degrade the
existing visual character or quality of Pacifica
and would not conflict with applicable zoning
and regulations governing scenic views. All
existing open space areas are preserved and
scenic resources are protected under the
Proposed Project. Future development in
Pacifica may occur at a higher density and
height than currently exists in the city. 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."
C77-11 Sue Digre 3/8/22 ..Table ES-1...housing units..

Source: C/CAG TDM DEPT FINANCE
Imput
...Wait..A GP is the Constitution for Pacifica
residents/ voters .

The electeds of OUR Community should stand up
for Voter's Rights.

The Source for our constitution is Our Voice.

The State can speak for itself outside of this
document.

C77-12 Sue Digre 3/8/22 The rights of Voters is protected by the US Constitution & by the California Constitition.
..The local Constitution, the chosen Gen Plan
must be in agreement with the US Constitution.

The local Voter rights should not be mandated
away by Electeds in Sacramento.

C77-13 Sue Digre 3/8/22 ...Re housing:
....Those of us who consistently worked hard for
years and years for inclusionary housing ,for
TRULY AFFORDABLE Housing also
want.to.protect ths civil rights of Voters to work
things out together with truth and civility.

C77-14 Sue Digre 3/8/22 E5
INPUT
..The present operative GP.1980 states that the
The comment is not related to the adequacy of
the DEIR, therefore no further response is
required in the FEIR. However, the comment

1.f
Packet Pg. 1119 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 455
Letter Commenter Date Comment Combined Response
Individuals (C)
City is " built out"!
Again, this is writing in The i update of the Gen
Plan of 1980 does not address facts.

The operative GP 1980 is clear,
the City is " built out".
**There are extreme negative impacts if this fact
is not made know and addressed.
..Address the fact that in 1980 the GP declared
that Pacifica was built out.
that data honestly, clearly, fairly and publically.
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.

C77-15 Sue Digre 3/8/22 E6
...Alternatives to the " Proposed Gen Pl" p E-6
Alternative 1. Strong Center at Quarry Site.

Imput:
...On what basis can this following deduction be
made???
Quote
"...and the least amount of development on
underutilized sites elsewhere."
Input
This section makes a lot of assumptions without
explanation. It is somewhat confusing. And
actually the last 3 sentences make Alternative 1
to be the most ideal
But there is a a question, what does the
following statement mean?: "..facilitating higherdensity housing at appropriate locations". ...What qualifies as "appropriate locations"
The CEQA Guidelines require EIRs to describe a
reasonable range of potentially feasible
alternatives to a proposed project or program.

That is, the EIR needs to analyze those
alternatives that will help decision-makers
make reasoned choices. The range of
alternatives shall include those that “would
feasibly attain most of the basic objectives of
the project but would avoid or substantially
lessen any of the significant effects of the
project” (CEQA Guidelines, Section
15126.6(a)). “Feasible” means that the
alternatives “are capable of being
accomplished in a successful manner within a
reasonable period of time, taking into account
economic, environmental, legal, social and
technological factors" (CEQA Guidelines,
Section 15364). The alternatives contain
different land use categories, densities, and
intensities along Palmetto and at the Quarry
site. The differences between the alternative
concepts are described on p. 4-2: Alternative
A, Strong Center at Quarry Site, establishes
one major mixed-use and visitor-oriented
center for Pacifica, and a series of commercial
nodes throughout the city; while Alternative B,
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".

Descriptions of the alternatives' land use are
found in Chapter 4, p. 4-3, 4-4, and 4-12.

Development potential is based on land uses in
each of these alternatives. The Quarry site
alternative does not propose major land use
changes to underutilized commercial areas;
thus, it is assumed that most of these
underutilized commercial areas would not

1.f
Packet Pg. 1120 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 456
Letter Commenter Date Comment Combined Response
Individuals (C)
redevelop.
"Higher density housing in appropriate
locations" are areas that align with the General
Plan objectives on p. 2-9, including clustered
development, in areas with good transit access
and in walkable, mixed-use areas.

C77-16 Sue Digre 3/8/22 E8
Alternative 2 also sounds ideal.

Input
One confusion, it uses the term "
redevelopment". The technical term,
REDEVELOPMENT was cancelled by the State. So
this is a very confusing statement. Clarify it.
***This statement also makes no
acknowledgement that the Quarry can only build
residences IF there is a Vote of the People.
**This fact about the need for.a Public Vote for
the Quarry must be expressed clearly. The Voice
of the Voter's must be protected.

Please see response to comment C30-7, which
describes analysis of Alternatives as required
under CEQA. The remainder of the comment is
not related to the adequacy of the DEIR, thus
no further response is required. 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.

C77-17 Sue Digre 3/8/22 E8
No Project Alternative.

Input
This is confusing & inaccurate. Again it makes no
mention of ths existence of a Voter requirement.

It also alludes to " large sections of Pacifica are
designated as 'Special Area'...."
And it states " ...including recent proposals to
limit development at the Quarry site..." Both are
very confusing statements. ..the GP DREIR need
to be transparent.

The requirement that any housing must be
allowed only by Public vote is essential. It is true
data. It is in the operative Gen Plan of 1980.
..This other language suggests that " Special
Areas" are negative designations. But they are in
the operative Gen Plan 1980, because the Public
wanted them. The type of writing must be
transparent. The City must protect and enable
the Public Vote, not ignore , negate or
circumvent the facts .
*** The GP must define what "Special Area"
means. List where, what the existing "Special
Areas" are in the operative Gen Plan 1980.

None of the uses in the Alternatives at the
Quarry anticipate residential development but
description of a voter requirement is thereby
added for clarity. "Any residential
development on the Quarry site would require
a voter approval requirement for rezoning to
allow residential use is derived from City
Council Ordinance No. 391-C.S" Description of
Special Areas is added for clarity: "As described
in the 1980 Pacifica General Plan, "Special
Area" is defined as "An area, as described in
the text, within which special physical or
economic problems exist and for which more
than one use would be acceptable, based on
the land use designation in the Plan
description and the findings of the
Environmental Impact Report, site plan, and
other required evaluation."
C77-18 Sue Digre 3/8/22 E8 Transportation.
...Input
Without traffic being able to.move consistently
there wll.be negative impacts. C02 and othee
health issues Input: The 21C Intelligent Traffic
Strategies/Signals should be acknowleged to
exist and where and their function described.
..The GP should be clear abour the City being
proactive about achieving adequate public
This comment is not related to the adequacy
of the DEIR. Traffic counts were conducted in
2018 and 2019, and analysis was conducted in
2020 and 2021. Thus, findings of significance
and analysis that relies on transportation
counts, such as VMT analysis and air quality,
remain valid.

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Packet Pg. 1121 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 457
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Individuals (C)
transportation in, around and through Pacifica. It
should require a follow through marketing plan
too.

C77-19 Sue Digre 3/8/22 Coastal Concerns.

Input
.. Constant drainage from the coastal ranges
must be acknowledged and explained as to how
it affects coastal erosion.
..The GP should direct.the City to be responsible
in facing planning for potential funding coasts to
adjust to coastal erosion and maintenance.
..The GP should direct the City to learn about
Insurance best practices and provide that timely
imformation to assure comonsense stewardship
on the part of City decision makers , planners ,
tax payers, private property owners and
businesses.

Please see response to comment C69-8 and
C110-2 for more information on where the
DEIR addresses coastal erosion. Impacts to
drainage are addressed on Deir Impact 3.5-3.

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 hat 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.

C77-20 Sue Digre 3/8/22 E8
Input
Land Use, define "Sphere of Influence and list
the sites.

The Sphere of influence is defined on DEIR p.
9-17.

C77-21 Sue Digre 3/8/22 E9
Input
The GP should make clear that there is
..on-going drainage from the coastal range
contributes to hillside & coastal erosion
The comment is not related to the adequacy of
the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed 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.

C77-22 Sue Digre 3/8/22 ES3
CD-1-14 Design Review.

Input
Where should the present Hillside Preservation
District District be noted?
..The updated GP should be clear too and
represent the will of the People, OUR
Community.
....The GP.update should be clear.like The
1980GP is clear about the importance of
Hillsides, ridges , trees and neighborhoods, to
our sense of character , who,we are & aspire to
be and to our economic sustainability because of
it.

C77-23 Sue Digre 3/8/22 Noise.

Input
..NEGATIVE NOISE impacts are HEALTH ISSUES.
...The GP should direct the City to.monitor
all.noise causing sources carefully and alert
residents & neighborhoods to.pending negative
impacts.
..the GP should be clear about negative noise
having being a definite HEALTH Hazard
..the GP should clearly address Air flight patterns
Noise impacts are analyzed in Ch. 3.10. Please
see response to comment C76-1 for more
information on potential noise impacts and
regulations and policies that reduce impacts to
less than significant. DEIR p. 3.10-26 describes
potential for noise intrusion from airports; no
part of the Planning Area is currently within
the 65 dB CNEL noise contour, according to
SFO’s 2019 land use contour maps. Should the
65 db noise contour expand in the future to

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Packet Pg. 1122 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 458
Letter Commenter Date Comment Combined Response
Individuals (C)
that can affect residents, historical, large parks,
cultural, school and visitor serving areas .
(The FAA was supposed to contact cities
regarding such areas prior to agreeing to the
NextGen plans. There are no records to show
that they did).

New technologies are being researched today for
planes ( super sonics, vertical vehicles), and flight
plans .

The same for autos and trucks.
..There will be negative environmental impacts
to our residents and our visitor serving economy
again if GP does not set clear goals to.monitor
and be engaged in oversight & accountability.
..our GP should include incorporating up to date
equipment to monitor noise measurements and
standards that avoid prople from being exposed
to negative Health Impacts.
.. The GP.should be clear that flights are up.high
over Pacifica ,out over the Ocean away from our
shores and hills.
include part of the Planning Area, those areas
would meet the current eligibility threshold for
noise-affected sensitive uses to receive
funding through SFO’s Residential Sound
Insulation Program.

SFO’s Aircraft Noise Abatement Office
maintains a noise abatement program that
integrates parts of the approved Noise
Compatibility Plan; City and County of San
Francisco resolutions; stated goals of the San
Francisco International Airport/Community
Roundtable; and air traffic control
requirements. The program includes a ix of
regulatory and voluntary actions that together
minimize the impacts of noise on communities
while ensuring safety. This program, together
with existing regulations supported by
Proposed Project policies, would reduce the
potential impact of conditionally acceptable
noise levels to a less than significant level.

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Packet Pg. 1123 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 459
C78: Sue Digre, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C78-1 Sue Digre 3/8/2
2 Repeat of C77 Please see comment
responses to letter C-77

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Packet Pg. 1124 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 460
C79: Pete Shoemaker, 2/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C79-1 Pete
Shoemaker
2/17/22 1. The City issued the DEIR on Jan. 7. It was
essentially unusable, not a legitimate document for
public review, as we’ve all talked about.

2. People immediately protested, and on Jan. 13 I
sent out the video that pointed out the difficulties
and showed what needed to be done (how to make
an interactive table of contents, etc.).

3. The City, with City Manager as spokesperson,
defended the document and repeatedly said that
there would be no extension. People’s frustration
mounted, and angry emails were sent to Council
and staff.

4. I spent hours of my time doing repetitive wordprocessing to create a workaround document that would be reviewable, and everyone who was trying
to do a review was very appreciative.

Please see response to comment C62-8. The public
comment period was extended until March 8,
2022 to allow for additional public review time.

C79-2 Pete
Shoemaker
2/17/22 5. Outside agencies also noted the inadequacies of the DEIR, with Fish and Wildlife asking for an
extension, which was denied.

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

C79-3 Pete
Shoemaker
2/17/22 6. Finally, with the support of Council, an extension was granted on Feb. 14, one month after my video.

7. In his remarks before the extension vote, the City
Manager casually mentioned that there was a new,
upgraded document with interactivity. I’ve looked
this over, and it is exactly the format that we’ve
asked for all along. The table of contents itself is 12 pages long, including Figures and Tables, reaffirming
the complexity of the DEIR and how absurd it is to
expect someone to review such a document
without an index or ability to search.

8. This document is the first legitimate DEIR the City
has issued, therefore the 45-day review period
should begin anew on Feb. 14. As it currently
stands, with the extension deadline of March 8, the
public will have 22 days to review a legitimate
document, less than half the legally-required
minimum.

The comment is noted. 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.

C79-4 Pete
Shoemaker
2/17/22 Is this in the best interest of the community of Pacifica? Will this help us solve the serious
challenges that face us? This is my whole focus. My
questions to you are, "How much staff time did it
take to turn the original unusable document into
the usable one?"; and “Why was this new document
not issued right away instead of 30 days later, losing
valuable review time and increasing public
frustration, mistrust and so-called “staff abuse”?
Word-processing software is set up to automatically
produce an interactive TOC, as I showed in my
video. I know that the DEIR was set up that way
because in that ill-advised “fix” when they put out
the 23 separate Word files, you can see it. You can
open any of those files, put the cursor at the
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR.

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Packet Pg. 1125 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 461
Letter Commenter Date Comment Combined Response
Individuals (C)
beginning, then click on the TOC menu and a fully
interactive TOC will appear. I know that I could have
created that new DEIR in less than an hour, because
I did it the hard way in about 8 hours. Why did it
take staff 30 days?
Someone, and all signs point to the City Manager,
made a decision to defend the original mistake
instead of admitting it and correcting it right away.

They prioritized saving face over the greater good of
the community, causing anger and polarization in
the community and embarrassing us to other cities
and agencies. And THAT’s why I’m going on about
this. Because it’s very likely that this will continue to happen unless this person is held responsible.

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Packet Pg. 1126 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 462
C80: Christine Boles, 1/16/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C80-1 Christine
Boles
1/16/22 Thank you so much for speaking
with me yesterday. I was very
surprised that you mentioned not
having seen any draft documents
of the General Plan Safety
Element cross your desk since
you started work in this position
about a year and a half ago (did I
get that right?). The City
specifically lists the North Coast
Fire District as one of the key
stakeholder agencies. I actually
got a hold of the Planning
Department's Distribution list for
the General Plan and strangely
North County Fire is not on
it...see attached. I've just emailed
Christian Murdock and Kevin
Woodhouse to see if this might
be an oversight.

In terms of the fire maps I
mentioned yesterday in the
Safety Element, here is the
current map from the recently
released General Plan, which
seems to only show fire danger in
state responsibility areas. And
here is the map from the
previous 2014 draft Safety
Element that seems like it
actually has real data, though it
seems somewhat dated from
2004/2009 based on the source
information at the bottom. Is this
current data? I am guessing that
the city realized that Cal Fire is
updating maps for LRA areas as
you said, but instead of using
current maps and adding a note
indicating that they should be
updated when they are available
from Cal Fire, they mistakenly
neglected to include any
information...

This obviously needs your
department's input as soon as
possible as it affects other
sections of the General Plan, like
the Land Use Element, which
identifies potential land uses and
areas of growth. I believe these
will need your agency's detailed
Please see Master Response 5: Wildfire. The DEIR characterizes wildfire hazards within the Planning Area on pages 3.11-4 through

3.11-6 and 3.14-1 through 3.14-4, making use of data and information from CALFIRE and from the Multi-Jurisdictional Local Hazard Mitigation Plan (MJ-LHMP) for San Mateo County. The characterization in the DEIR includes a description of vegetation in the Planning Area, a history of wildfire occurrence in the Planning Area, the probability of a fire occurring in the future, and identification of Fire Hazard Severity Zones designated by CALFIRE based on factors such as fuel, slope, and weather. Two maps are included:

Figure 3.11-2, which shows Very High Fire Hazard Severity Zones for Local Responsibility Areas (LRAs), State Responsibility Areas (SRAs), and Federal Responsibility Areas (FRAs) as designated by CALFIRE pursuant to Government Code Section 51175. By law CALFIRE is required to designate these Fire Hazard Severity Zones, land within which is subject to various requirements in the California Building Code for the design and construction of new buildings intended to reduce the risk of loss of life and property, including requirements for building materials, defensible space clearance, and other wildland fire safety practices; and
Figure 3.14-1, which shows Fire Threat, a measure of fuel conditions and fire potential in the ecosystem, representing the relative likelihood of “damaging” or difficult to control wildfire occurring for a given area. Fire Threat is not a risk assessment by itself, but can be used to assess the potential for impacts on various assets and values susceptible to fire. Impacts are more likely to occur and/or be of increased severity for the higher threat classes. Please see Master Response 5: Wildfire for more information. Both CAL FIRE datasets/maps used for analysis, including VHFHSZ (Figure 3.11-2) and Fire Threat (Figure 3.14-1), incorporate measures related to wildfire fuel conditions and fire potential. Policy SA-I-98: addresses Vegetation Management, included in Impact 3.14-1.

Analysis in the 2021 MJ-LHMP and the safety element of the Proposed Project identifies areas of the city that have constrained emergency access. Reliance on Highway 1 as a north-south connection causes challenges for timely fire response, and the Vallemar, West and East Fairway Park, Rockaway Beach, and Rockaway neighborhoods in central Pacifica are beyond four-minute travel distance from northern San Mateo County fire stations, meaning that a new station would be needed if the central part of Pacifica were to experience substantial new development.

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Packet Pg. 1127 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 463
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review as well. How can we start
to plan for growth without first
understanding our hazards?
Would you, or someone at Cal
Fire be able to help us
understand what the focus of the
LRA updates are and get an
opinion of what type or degree of
changes to the current Pacifica
data/maps might be likely given
the increasing drought
conditions? If there is something
that may well alter the Pacifica
maps in a substantive way, we
may need to add some policy
statements added to the General
Plan.

If your department is feeling
overwhelmed with reviewing
Pacifica's 1000 page EIR and
other General Plan documents in
the remaining 39 day period,
then I'd encourage you to make
that known right away to Mr.

Murdock. Other agencies may
have similar issues. For example,
if you're not up to
speed/sufficiently aware due to
major processing time gaps, and
thereby need more time to get
up to speed and review, you
could request time extensions.

Perhaps the pandemic's effect on
your own staffing and resource
availability also makes this short
review process difficult.
meet adopted emergency access standards; and ensure adequate fire, police, and emergency service in line with any new development, including in Central Pacifica where service times do not currently meet NCFA’s standards, and in areas that have less than two evacuation routes north of the VHFHSZ (Proposed General Plan Implementing Policy SA-I-104) Future development would be required to adhere to all policies, goals, and standards in the MJ-LHMP, Pacifica Municipal Code, and CBC, including vehicular access and emergency access. Implementation of the following Proposed Project policies will ensure that inadequate emergency access does not occur, and will result in a less than significant impact.

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Packet Pg. 1128 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 464
C81: Margaret Goodale, 1/25/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C81-1 Margaret
Goodale
1/25/22 When all accessible tools are finally at hand, that would be the appropriate time to BEGIN a public review period for engaged citizens who wish to perform their civic duty.

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

C81-2 Margaret
Goodale
1/25/22 In 2014, I sat at a round cafeteria table at IBL along with many other people at that and other tables who were there to discuss the new draft General Plan. If you read a little way into the current set of plans you may have noticed a photo of me at that meeting. In 2014, however, far less information was available about the climate and ocean conditions that seem suddenly to be upon us. Many of us who attended that meeting are paying even better attention now as we see more of the effects of these changes.

If you have bothered to read the current documents released late Friday night January 7, you encountered the same problems of inaccessibility that we did. If you did not immediately give up, you no doubt share the frustration experienced by those of us attempting to understand how Pacifica will respond to the very real challenges of the future. Does it matter to you that attempting to search for or correlate topics in the DEIR to the GP without even a table of contents, becomes ridiculously complicated? How were you able to fully understand the differing references and source dates between the GP, SPSP and the DEIR?
I ask that you show some respect for the citizens who elected you and do not breech their trust. If you force staff to meet your artificial timeline and goal, you have betrayed all of us as well as future Pacificans.

Council, you can still fix this impossible situation and allow staff to do their best work.
• Cancel the 45 day public review period.
• Reorganize the DEIR with a table of contents.
• Make it searchable.
• Cross-check the dates for the most current studies.
• Give staff time to make the documents accessible then rerelease them.

Please see response to
comment C62-8. The
public comment period
was extended until
March 8, 2022 to allow
for additional public
review time.

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Packet Pg. 1129 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 465
C82: Vicki Sundstrom, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C82-1 Vicki
Sundstrom
3/8/22 Based on page 1-3 of Plan Pacifica DEIR, the
existing condition and key issues report was
published in July 2010. It is not clear in reviewing
the DEIR if or when the existing conditions,
specifically traffic and parking data and related
analysis were updated to 2019 (pre-pandemic)
conditions. Please clarify which portions of the
report have accounted for the traffic & parking
growth through 2019 and if mitigation measures
are based on 2019 conditions.

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. Traffic study
data is included in Appendix B of the DEIR. No
further response is required.

C82-2 Vicki
Sundstrom
3/8/22 E-13: Design guidelines are referenced. The
design guidelines found on the Pacifica website
dated 1990 are obsolete and have not served
Pacifica well. Additionally, the guidelines do not
reference standards or codes. They could, in
lacking specificity, contribute to engineering and
environmental compliance issues.

C82-3 Vicki
Sundstrom
3/8/22 There is an error in the DEIR with respect to
growth in the housing units. At the San Mateo
County Housing seminar (April 2021), both you
and Josh presented housing growth requirement
of 1892 units. Whereas the DEIR indicates 990.

Please clarify which is correct. Also please
explain where this growth is planned for if this
document is to take us into 2040.

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

C82-4 Vicki
Sundstrom
3/8/22 With respect to the circulation element -

4. See appendix A, a table prepared based on
Caltrans traffic census. While the population in
Pacifica has grown by 3%, traffic has grown from
13% to 57%. The DEIR clearly indicates existing
conditions based on 2010. Given the substantial
growth in traffic volumes, any traffic analysis,
conclusions and mitigation measures are not
usable.

C82-5 Vicki
Sundstrom
3/8/22 Traffic intersections included in the DEIR address the intersections along highway 1 but there is no
analysis for any local streets in Pacifica. Local
intersections are experiencing increasing
congestion, some meriting traffic (signals and
signs) warrant analysis. The traffic roadway
system, as a whole, is failing to deliver adequate
level of service – with or without the project.

This comment is noted. Congestion and level
of service analysis is not a required under
CEQA. Traffic volumes on all roads were
considered in the noise analysis and no
substantial permanent increase in the
ambient noise level would occur from vehicle
traffic as analyzed under impact 3.10-1 on
page 3.10-18. 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. Traffic study data is included in
Appendix B of the DEIR. No further response
is required.

C82-6 Vicki
Sundstrom
3/8/22 Given that community engagement meeting for
the General Plan took place in 2009, the
The comment is not related to the adequacy
of the DEIR, therefore no further response is

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Packet Pg. 1130 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 466
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community in current day Pacifica was not
engaged in the cirulation element to discuss the
priorty of addressing the traffic and related
safety concerns in Pacifica. Please explain how
this will be rectified.
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.

C82-7 Vicki
Sundstrom
3/8/22 The deterioration of many Pacifica local street
has effectively lowered the capacity and level of
service. This too is not accounted for in any
analysis based on 2010 “existing conditions”.

Please explain how this will be accounted for.

C82-8 Vicki
Sundstrom
3/8/22 See Appendix D, please explain why existing
condition level of services have changed with
4/21 & 2/22. Also please explain why cations
have changed. Discrepancies in analysis for the
same locations. Also one location has been
eliminated.

Traffic congestion analysis is no longer
required under CEQA. The referenced table
uses a table from the DEIR in 2014, which was
not certified. This represents outdated
conditions. Traffic analysis measurements for
2018 and 2019 did not include this
intersection.

C82-9 Vicki
Sundstrom
3/8/22 Implementation of complete streets and mode
shift to bicycles require additional study before
being included in these documents.

Implementation of ‘complete streets’ to support
mode shift to bicycle usage is not a viable
congestion management solution for Pacifica.

Given:
- Pacifica terrain and lack of local roadway
network connectivity between communities will
not allow for enough of a mode shift to allow
any significant improvements to traffic
congestion.
- Unless Pacifica wishes to implement an e-bike
program, bike mode shift is only successful on
flat terrains for rides within 7 miles or 20
minutes.
- Implementation of complete streets (separate
bike facilities specifically), while admirable, will
contribute to substantial roadway capacity
issues on many Pacifica streets. And it will result
in inadequate emergency access on some
streets.
- Between on-street parking, bike lanes and
existing traffic, traffic congestion will increase
and further impact evacuation/emergency
response routes.
- On-street parking and dedicated bike facilities
are not compatible – cities that have
The comment is not related to the adequacy
of the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed Plan
and will be shared with decision-makers in
that context. Please see Master Response: EIR
comments for more information about GP- or
SPSP-related responses. Policies related to
Complete Streets are required by State law,
AB 1358. Please see response to comment
C15-2 for response related to emergency
access.

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Individuals (C)
implemented bike facilities safely and
successfully have done so by eliminating bike
parking or providing substantial buffers to
separate the two.

C82-10 Vicki
Sundstrom
3/8/22 With respect to the complete streets design
approach, LOS must be maintained or improved
while implementing complete streets.

Guidelines and standards as implemented by the
State of California or better are to be utilized in
the implementation of the program.

This comment is noted. Changes to LOS is not
a required topic of analysis under CEQA.

Therefore, no further response is required in
the FEIR. However, the comment addresses
the content of the Proposed Plan and will be
shared with decision-makers in that context.

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

C82-11 Vicki
Sundstrom
3/8/22 Between visitors and increased car ownership,
Pacifica on-street parking utilization has
increased. Visitor parking in private lots (Taco
Bell, Grocery Outlet etc) has also increased. The
data provide does not account for the overflow
of parked vehicles into residential area or vice
versa. Conduct a parking utilization studies to
review on-street & off-street (private and public)
parking capacity and utilization. Account for
future growth into 2040. Plan for displaced
parking and parking growth in each Pacifica
neighborhood.

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

EIR Comments for more information about
GP- or SPSP-related responses. Please also
see Master Response 3: Buildout and RHNA
for more information.

C82-12 Vicki
Sundstrom
3/8/22 With respect to Congestion Management
Program & Transportation Demand
Management– - Pacifica lacks a Congestion
Management Plan, as required by the State and
the County.

Pacifica has not observed required traffic
analysis in the permitting process to understand
congestion attributed to any development or
change. Nor does Pacifica conduct traffic counts
or analysis to understand traffic changes. All of
which add to not having any measures in place
for such a program – which ultimately is why
Pacifica continues to see unmitigated traffic
growth/congestion.
- Transportation Demand Management goals
and objectives are based on roadway system
capacity, existing demand, and project related
growth. The municipality must establish the
goals (percentage trip reduction in general and
during peak periods, parking rations), it is up to
the project or business to develop programs that
eet the required goals. Traffic impact fees are
assessed on any trips over the established goal.

The programs do not work without clearly
defined goals (trip reduction), overage fees and
monitoring.
- Given the roadway capacity constraints and
limited financial resources available to Pacifica
This comment is noted. The comment is not
related to the adequacy of the DEIR,
therefore no further response is required in
the FEIR. However, the comment addresses
the content of the Proposed Plan and will be
shared with decision-makers in that context.

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

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to address said constraints, all projects (non
residential, residential, schools, churches etc)
should be subject to some transportation
demand management measures, parking ratios
and traffic impact fees.
- Monitoring is required by the State. Implement
traffic count and speed monitoring programs via
intelligent transportation technology. Free
parking is the biggest deterrent to
Transportation Demand Management Programs
and should be considered as an option both for
Congestion Management and Economic
Development.
- Stated TDMs options read like a textbook of
available strategies rather than targeted policy
to meet objectives. Please provide targeted
strategies appropriate to our community and
identify programs based on type of property
(residential, commercial, etc)
C82-13 Vicki
Sundstrom
3/8/22 Circulation element – How does the city plan to
reduce congestion on roadways before reducing
roadway capacity to implement complete
streets?
The comment is noted. Congestion is no
longer a required topic 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. Please also see Master Response
3: Buildout and RHNA for more information.

C82-14 Vicki
Sundstrom
3/8/22 Before subjecting Commuter Trip Reduction
programs expenses onto employers in Pacifica,
please quantify how many people ommute
long/er distances to Pacifica and would use said
programs. Also quantify how many of these jobs
can be done remotely. These programs appear
to add cost to doing business in Pacifica without
any real impact to congestion.

This comment is noted. The comment is not
related to the adequacy of the DEIR,
therefore no further response is required in
the FEIR. However, the comment addresses
the content of the Proposed Plan and will be
shared with decision-makers in that context.

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

C82-15 Vicki
Sundstrom
3/8/22 Given that the Sharp Park Specific Plan related
community meetings were limited to Sharp Park,
the items stated below should be addressed
with the greater Pacifica as it relates to all of
Pacifica.

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

C82-16 Vicki
Sundstrom
3/8/22 At the time the GPU/DEIR were issued for
review (3/2022), Pacifica is looking at a budget
shortfall for a few years to come, has paid fines
for sewer spills, and is looking at increasing
sewer rates. The City of Pacifica did not have the
funds to adequately prepare this report with
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:

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current data. Pacifica cannot financially
accomplish much of what is stated in this report,
including addressing any of the hazards we have,
with or without the project. Any development in
hazardous areas should include policy to hold
the City of Pacifica harmless for loss of life
should hazards occur. Developer, realtors and
homeowners in the new developments should
fund safety and maintenance programs.

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

C82-17 Vicki
Sundstrom
3/8/22 Any policy that limits access to the coast by
residents, please explain how the City will work
with the residents to address access issues.

Please see response to comment C131-4.

C82-18 Vicki
Sundstrom
3/8/22 Fire response/Safety

18. Evacuation routes/Implementation of the
Proposed Project would not result in adequate
emergency access. With or without project,
there is inadequate emergency access in Pacifica
unless all the roads are cleared (see 8/21/2022
press release). While clearing the road may have
been an option during the pandemic, it will not
also be possible. Also clearing the roads for
emergency access would prohibit evacuations.

The planned update does not address existing
(2022) reality, nor does it address 2040
conditions
Please see response to C54-27 for more
information about highway congestion and
evacuation routes. the C/CAG congestion
management plan addresses conditions in
2019, prior to COVID reducing traffic levels,
and thus represents a conservative estimate.

The DEIR analyzes impacts of implementation
of the Proposed Project at the programmatic
level until 2040. Please see Master Response
7: Emergency Access for more information.

C82-19 Vicki
Sundstrom
3/8/22 Fire map discrepancies
There are discrepancies between the fire risk
maps in these documents and those published
by the state and PGE. They have been provided
in Appendix C. Please explain. How will this be
rectified?
The data and information referenced in the
DEIR, including the data used to prepare the
above referenced maps, was the latest and
most current available at the time the NOP
was released and remains the most current
available as of publication of this FEIR. Please
see Master Response 5: Wildfire for more
information.

C82-20 Vicki
Sundstrom
3/8/22 Why does the map fire risk map shown in the
Pacifica documents only show in color the state
owned risk areas?
According to CAL FIRE, maps for LRA only
show Very High Fire Hazard Severity Zones.

C82-21 Vicki
Sundstrom
3/8/22 Please elaborate on how response time will be
improved. This should be accounted for in this
GPU and DEIR. Without addressing this concern,
there is a significant impact to emergency
response from this project and related
development.

Please see Master Response: EIR comments
for more information about GP- or SPSPrelated responses. Analysis pertaining to whether the implementation of the Proposed
Project would result in substantial adverse
physical impacts associated with fire response
times is discussed under criterion 3.12-1,
specifically on pages 3.12-28 to 3.12-29.

Though the Proposed Project anticipates the
construction or enhancement of fire
protection facilities to achieve service

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Packet Pg. 1134 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 470
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standards, the underlying need for these
activities is pre-existing. 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). Given these considerations,
and Proposed Project policies (SA-G-8, SA-G9, SA-I-91, SA-G-11, and SA-I-101 to SA-I-115) to support adequate levels of fire service and
response times, this impact is expected to be
less than significant.

C82-22 Vicki
Sundstrom
3/8/22 Conservation Element, Wetlands Preservation –
implement citywide policy to train staff to
recognize wetlands. Implement policy and fines
in support of preservation.

EIR Comments for more information about
GP- or SPSP-related responses. Please also
see Master Response 3: Buildout and RHNA
for more information.

C82-23 Vicki
Sundstrom
3/8/22 There is not enough information in the DEIR or
GPU to substantiate that the implementation of
the proposed project would not interfere with
the movement of wildlife. Please explain how
the sea wall planned at Sharp Park impacts sea
life. Given that the existing conditions are from
2010 and much has changed, please explain how
existing conditions will be addressed.

Please see Master Response: EIR comments
for more information about GP- or SPSPrelated responses.

The Proposed Project outlines multiple
policies to protect the movement of wildlife,
including:
(LU-G-7) Open Space Conservation and
Habitat Protection. Protect beaches,
oceanfront bluffs, ridgelines, hillside areas
adjacent to existing open space, and areas
that support critical wildlife habitat and
special status species.
(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-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.

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Packet Pg. 1135 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 471
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Individuals (C)
The survey will be used to determine the
exact location of habitat areas and to
recommend mitigation measures that
minimize potential impacts.

The majority of the seawall planned at Sharp
Park is existing, the General Plan supports
maintaining, replacing, and repairing it as
needed in order to protect life and property
and keep it as a community resources. Due to
its programmatic nature, the General Plan
does not assess the outcome of specific
projects as no specific project (like a new sea
wall) is proposed. it describes future
development goals and policies without
assessing any individual projects, which might
require a Project EIR.

C82-24 Vicki
Sundstrom
3/8/22 May policies (examples below) are ambiguous
and require further definition. Actions such as
“support”, “work with”, “continue coordination”
have left us with a community that is sitting in
traffic and please be specific. What action, to
accomplish what and the timeline. I recently
spoke to Sam Bautista about the Manor Bridge
repairs and he gave me CalTrans schedule but
the traffic is bad and continues to get back and
there are no interim measures for at least the
next 4 years – that kind of “coordination” really
doesn’t fix anything. Please also provide clarity
on how much funding is required and
realistically what can and can be accomplished
based on Pacifica’s finances. Use SMART
methodology to clearly define objectives.

EIR Comments for more information about
GP- or SPSP-related responses. Please also
see Master Response 3: Buildout and RHNA
for more information.

C82-25 Vicki
Sundstrom
3/8/22 Examples from San Luis Obispo – The comment is not related to the adequacy of the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed Plan
and will be shared with decision-makers in
that context. Please see Master Response 1:

EIR Comments for more information about
GP- or SPSP-related responses. Please also
see Master Response 3: Buildout and RHNA
for more information.

C82-26 Vicki
Sundstrom
3/8/22 San Luis Obispo – TDM policy and monitoring
program
Belmont – Residential TDM
The comment is not related to the adequacy
of the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed Plan
and will be shared with decision-makers in
that context. Please see Master Response 1:

EIR Comments for more information about
GP- or SPSP-related responses. Please also
see Master Response 3: Buildout and RHNA
for more information.

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Packet Pg. 1136 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 472
C83: Erin Macias, 1/18/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C83-1 Erin Macias 1/18/22 General Plan Draft
Area of Concern: 7-35 identifies increased wildfire
risk. 8-35 identifies responsibility. Figure 8-7 maps
State Responsibility Areas.

Comment: The City of Pacifica should include a
map of our own high risk zones in the General
Plan and formulate a long term plan for
homeowners to create defensible space to
increase the chances of successfully protecting life
and property. Currently, there are large groves of
unmanaged eucalyptus trees and areas with dead,
diseased and dying trees and vegetation. These
areas cannot be accessed by fire engines or
firetrucks and hoses must be connected and
carried down hills. The lack of accessibility to
these sites threatens life and property. From what
I see in the General Plan draft and associated
policies in the DEIR, there is no plan to address
this other than NCFA education and outreach: in
the 25 years I have lived here, NCFA nor the City
of Pacifica have addressed the eucalyptus groves
in my neighborhood nor required the property
owner to create defensible space. One
unmanaged property creates risks for larger
geographic areas. The City places this burden on
adjacent homeowners to go after neighbors civilly
and requires expensive arborist reports from
residents who have concerns (email between Erin
Macias and the City of Pacifica on file.) The
absence of a plan to address these high risk
conditions is evident in the General Plan Draft and
in the language found in the DEIR on pages E-136
through E-140.

Please see Master Response 5: Wildfire.

The DEIR characterizes wildfire hazards
within the Planning Area on pages 3.11-4
through 3.11-6 and 3.14-1 through 3.14-4,
making use of data and information from
CALFIRE and from the Multi-Jurisdictional
Local Hazard Mitigation Plan (MJ-LHMP)
for San Mateo County. The
characterization in the DEIR includes a
description of vegetation in the Planning
Area, a history of wildfire occurrence in
the Planning Area, the probability of a fire
occurring in the future, and identification
of Fire Hazard Severity Zones designated
by CALFIRE based on factors such as fuel,
slope, and weather. Two maps are
included:

Figure 3.11-2, which shows Very High Fire
Hazard Severity Zones for Local
Responsibility Areas (LRAs), State
Responsibility Areas (SRAs), and Federal
Responsibility Areas (FRAs) as designated
by CALFIRE pursuant to Government Code
Section 51175. By law CALFIRE is required
to designate these Fire Hazard Severity
Zones, land within which is subject to
various requirements in the California
Building Code for the design and
construction of new buildings intended to
reduce the risk of loss of life and property,
including requirements for building
materials, defensible space clearance, and
other wildland fire safety practices; and
Figure 3.14-1, which shows Fire Threat, a
measure of fuel conditions and fire
potential in the ecosystem, representing
the relative likelihood of “damaging” or
difficult to control wildfire occurring for a
given area. Fire Threat is not a risk
assessment by itself, but can be used to
assess the potential for impacts on various
assets and values susceptible to fire.

Impacts are more likely to occur and/or be
of increased severity for the higher threat
classes. Please see Master Response 5:

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

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Packet Pg. 1137 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 473
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Individuals (C)
included in Impact 3.14-1.

Analysis in the 2021 MJ-LHMP and the
safety element of the Proposed Project
identifies areas of the city that have
constrained emergency access. Reliance on
Highway 1 as a north-south connection
causes challenges for timely fire response,
and the Vallemar, West and East Fairway
Park, Rockaway Beach, and Rockaway
neighborhoods in central Pacifica are
beyond four-minute travel distance from
northern San Mateo County fire stations,
meaning that a new station would be
needed if the central part of Pacifica were
to experience substantial new
development.

Potential improvements to the roadway
network could contribute to mitigating the
impacts of additional traffic on emergency
response times. Furthermore, traffic signal
preemption devices on emergency
vehicles, as well as emergency sirens, will
improve emergency response times ven in
instances of intersection congestion during
peak commute periods. The Proposed
Project provides for improved emergency
access through policies that promote
mobility connections between
communities; provide additional access
routes; require new streets and
developments meet adopted emergency
access standards; and ensure adequate
fire, police, and emergency service in line
with any new development, including in
Central Pacifica where service times do not
currently meet NCFA’s standards, and in
areas that have less than two evacuation
routes north of the VHFHSZ (Proposed
General Plan Implementing Policy SA-I104) Future development would be required to adhere to all policies, goals,
and standards in the MJ-LHMP, Pacifica
Municipal Code, and CBC, including
vehicular access and emergency access.

Implementation of the following Proposed
Project policies will ensure that inadequate
emergency access does not occur, and will
result in a less than significant impact.

C83-2 Erin Macias 1/18/22 Area of Concern: 8-37 identifies areas within Pacifica that are a challenge for fire response.

Comment: This is based on a 14 year old study.

This study does not consider the volume of new
homes and built south of the tunnel and more
commuters added to our roadways. It also does
The standards of coverage study from
2008 represents the best available
information at this time.

This comment contains an inaccuracy;
DEIR p. 3-44 notes that "Implementation

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Packet Pg. 1138 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 474
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not factor in the rapidly growing and unmanaged
groves of eucalyptus trees. The Tom Lantos
Tunnel was opened in 2013. The traffic after
opening the new tunnel increased dramatically in
the past 8-9 years and the challenge for fire
suppression has changed.
of the proposed General plan and
increases in regional travel passing
through Pacifica would increase the
amount of vehicular traffic in and around
Pacifica and may therefore increase the
number of potential emergency access
conflicts."
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 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

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Packet Pg. 1139 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 475
Letter Commenter Date Comment Combined Response
Individuals (C)
(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. 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-than-significant impact. Please see
Master Response 7: Emergency Access for
more information.

C83-3 Erin Macias 1/18/22 Area of Concern: DEIR Wildfire: CI-G-7 Congestion on Highway 1.

Comment: There is no avoiding the congestion as
the vote was taken and the road cannot be
widened and we have no control over the volume
of development south of Pacifica. “Strive for the
greatest benefit with the least environmental
impact possible” does not provide the plan,
framework, or identify the possible impact. This
does not factor in the tunnel’s impact on
congestion since the study and the steady
increase in commuter traffic with more
development south of Pacifica. What can be done
to the existing infrastructure and Sweeney Ridge
trail systems to create an emergency evacuation
route? The connection between the trail system
and certain residential streets would provide for
weekend/holiday use of a recreational path so
residents and visitors can walk or bike into
Pacifica without the need for cars while at the
same time offering a much needed evacuation
route. The environmental impact of paving an
existing trail would be minimal.

The suggestion is noted. Please see
response to comment C83-2 and Master
Response 7: Emergency Access for more
information about evacuation planning.

See response to comment C54-27 for more
information about congestion
management on Highway 1.

C83-4 Erin Macias 1/18/22 Area of Concern DEIR Wildfire: CI-I-15 Strategies to Reduce School Related Peak Hour Auto
Congestion
Comment: staggering times does not eliminate
congestion, it increases the length of the
congestion along SR1. The only solution to reduce
school related peak hour auto congestion is to
work with the PSD and JUHSD to adopt a formula
for neighborhood schools where residents within
a specific radius of a school campus are
guaranteed enrollment into that school (so they
can walk and bike to school, thus eliminating
commuting by car entirely.) The auto congestion
from school related traffic is a direct source of air
pollution (gas powered vehicles) and also Toxic Air
Please see response to comment C54-27
for more information on congestion
management and other policies that
address impacts of wildfire. Please also see
Master Response 7: Emergency Access.

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Packet Pg. 1140 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 476
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Contaminants (diesel work trucks used to
commute students) as identified in table 3.3-4 on
page 3.3-12 and 3.3-13 Staggering traffic does not
do anything to relieve the congestion problem on
SR1 in the event of a wildfire during these peak
hours, it only exacerbates the problem.

C83-5 Erin Macias 1/18/22 The Environmental Impact of an inadequate Wildfire section in the General Plan is concerning
and includes but is not limited to loss of life for
humans and animals, loss of habitat for humans,
wildlife including protected and endangered
species, contaminated soil, contaminated water
(ocean, ground, creeks, marshes/wetlands, and
the San Pedro Watershed overall,) air pollution,
and other permanent consequences too lengthy
to list here.

The comment is noted. Please see Master
Response 5: Wildfire for more information.

C83-6 Erin Macias 1/18/22 The DEIR says to simply update the Emergency Plan without any specific language as to what that
entails. Please provide me with a copy of the
existing emergency plan pertaining to wildfires in
the City of Pacifica.

Because of its sensitive nature, existing
Emergency Operations Plan is not available
online but is available for review at the
Pacifica Police Department.

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C84: Rick Nahass, 1/30/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C84-1 Rick Nahass 1/30/22 There are two problems regarding transportation in the DEIR: (a) there are no details on how the
elements/bullets (e.g., CI-I-13) were determined
and used to calculate changes to Vehicle Miles
Travelled (VMT) and (b) those calculations ONLY
include “Land Use” and not “Circulation”
elements. See the highlighted items table below
from the General Plan-Sharp Park Draft EIR - 4
Alternatives section.

The comment is noted. As described on
DEIR p. 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. The model is not sensitive to
additional policies in the General Plan
Circulation Element that support reduction
of VMT (such as connectivity in
neighborhoods, presence of bicycle and
pedestrian facilities, and transportation
demand management (TDM) measures)
and are not reflected in these estimates.

Thus, the VMT estimates in this analysis
are conservatively high." Put simply, the
model only accounts for differences in land
use changes between the Alternatives
analyzed in Chapter 4.

C84-2 Rick Nahass 1/30/22 Pacifica has no formal Transportation Demand Management (TDM) Program but relies on the
San Mateo County Congestion Management Plan
(CMP) which is late in transitioning to VMT per
Senate Bill SB 743, which was required to happen
by July 2020.

Once Pacifica does create separate TDM Program
documents then VMT should be used as the
primary metric for evaluating and prioritizing
action. Both LOS and VMT in the DEIR serve the
purpose of highlighting the state of traffic
congestion on state route 1 in Pacifica. Formally
Pacifica TDM currently rolls up to the San Mateo
County 2040 TDM where the following bullets on
page 121 “Proposed RTP Projects” mention
Pacifica [my commentary in brackets]:
• Manor Drive Overcrossing Improvement and
Milagra On-Ramp Project – [RickN - Also partially
mentioned in Pacifica Bike and Ped Plan]
• Route 1 San Pedro Creek Bridge Replacement
and Creek Widening Project - [RickN - this was
already done but remains as a proposed project.

Might a pedestrian underpass be added for safely
traversing under state route 1 as a project in a
Pacifica TDM]
• Palmetto Avenue Streetscape Project
• Construct Route 1 (Calera Parkway) northbound
and southbound lanes from Fassler Avenue to
Westport Drive in Pacifica – [RickN - This was part
of the Caltrans state route 1 widening proposal
which was turned away by citizens. It’s good that
it is STILL on the County TDM 2040 plan, because
we might still be able to have Caltrans convince
The comment is noted. The comment is
not related to the adequacy of the DEIR,
therefore no further response is required
in the FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more
information about GP- or SPSP-related
responses.

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Packet Pg. 1142 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 478
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Individuals (C)
the citizenry to either widen or reconfigure the
busiest intersections in Pacifica according to US
DOT and Caltrans, Vallemar and/or Rockaway,
based on sound VMT metrics.]
C84-3 Rick Nahass 1/30/22 The following are suggested General Plan changes that should be referenced in the DEIR. General
Plan Section 5.1 Circulation Framework TDM is
mentioned in the General Plan, but no
action/element/policy calls out for the creation of
a separate TDM plan. Add the implementation
policy element:
• CI-I-x Transportation Demand Management
Program. Formally establish a comprehensive
Transportation Demand Management (TDM)
program that reduces Vehicle Miles Traveled
(VMT)/Single-Occupant Vehicle trips by
supporting transit and improves the safety and
mobility for Pacifica residents, businesses, and
visitors by recommending a suite of projects,
policies, and programs to address current and
future transportation conditions.

The above policy should also be included in
Section 4 Land Use. Some details might be
included, for example other cities require every
new development project to consider VMT. For
single residents it might be “not applicable” with
a check box, but for larger multi-unit sites,
depending on size, the ask for providing VMT
impact might increase.

The comment is noted. Congestion is not a
required topic for CEQA analysis and the
DEIR correctly analyzed and mitigated VMT
impacts on pages 3-40 to 3-43. The
comment is not related to the adequacy of
the DEIR, therefore no further response is
required in the FEIR. However, the
comment addresses the content of the
Proposed Project and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

C84-4 Rick Nahass 1/30/22 General Plan Section 5.2 Existing Travel Patterns Add the implementation policy element:
• CI-I-X Equitable and Accessible Public Transit
Develop and document a breakdown of public
transportation usage by paratransit riders and
those that cannot drive (elderly, students, low
income, etc.) Include the relationship between
who depends on transit vs who if anyone uses
public transit, because they choose to not use
other forms of transit.

C84-5 Rick Nahass 1/30/22 General Plan Section 5.3 Roadway Network and Planned Improvements
The EIR and General Plan should specifically state
that all off and on ramps (arterial roads) to state
route 1 are vehicle prioritized and should be
upgraded to provide bicycle and pedestrian
safety. There are issues with the following
statement because it omits on/off ramp safety
• (also in DEIR Page 3-2 Arterials) “Along certain
arterials, notably Palmetto Avenue, Esplanade
Avenue, and sections of Oceana Boulevard,
Paloma Avenue and Manor Drive, the pedestrian
environment is prioritized”
The comment is noted. The comment is
not related to the adequacy of the DEIR,
therefore no further response is required
in the FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more
information about GP- or SPSP-related
responses.

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Packet Pg. 1143 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 479
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o The most evident example of this omission is in
the recommendation on pages 61 and 87 of the
Pacifica approved Bicycle & Pedestrian Master
Plan (Feb 2020) for reconfiguring the Palmetto
Avenue Highway 1 ramp and crosswalk.

C84-6 Rick Nahass 1/30/22 General Plan Section 5.4 Pedestrian and Bicycle Network
Add the implementation elements:
• CI-I-XX Reconfigure the State Route 1 Palmetto
South on Ramp near the Milagra overpass to
allow safe bicycle and pedestrian crossing (e.g.,
hard left and right turns and stop signs before
entering the highway)
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses. Please also see Master Response 3: Buildout and RHNA for more
information.

C84-7 Rick Nahass 1/30/22 • CI-I-XX Connect and maintain bicycles and pedestrian trails from Linda Mar to the Mori Point
trail ending at the Devil’s slide trail to create a
seamless connection to the midcoast trails south.

This allows bicycles and pedestrians to bypass the
narrow road leading to the tunnels south.

C84-8 Rick Nahass 1/30/22 General Plan Section 5.5 Public Transportation and Demand Management
There should be separate elements for local vs
regional public transportation. SamTrans is
responsible for operating local public transit, and
the Metropolitan Transit Commission (MTC) is
responsible for ‘facilitating’ regional bus transit.

C84-9 Rick Nahass 1/30/22 Update element CI-I-50 Transportation Demand Management to use VMT metrics and thresholds
or to wait until the CMP migrates from LOS to
VMT, because all agency calls for project transit,
environment and land use funding in California
will be prioritized based on VMT. Also consider
moving this element to the General Plan Section

5.1 The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses. Please also see Master Response 3: Buildout and RHNA for more
information.

C84-10 Rick Nahass 1/30/22 Update the following element with the highlighted text:
• CI-G-17 Improved Public Transit. Advocate for
SamTrans locally, the MTC regionally and other
public transit providers to improve transit service
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with

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Packet Pg. 1144 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 480
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Individuals (C)
and facilities, to enable trips to be made without
use of a car. In particular, advocate for the
expansion of public transit services and facilities
to improve public access and recreation
opportunities along the coast.
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses. Please also see Master Response 3: Buildout and RHNA for more
information.

C84-11 Rick Nahass 1/30/22 Current law, SB 743, calls for “land use and transportation planning decisions and
investments that reduce vehicle miles traveled
(sic VMT) and contribute to the reductions in
greenhouse gas emissions required in the
California Global Warming Solutions Act of 2006
(Division 25.5 (commencing with Section 38500)
of the Health and Safety Code). Similarly, the
California Complete Streets Act of 2008 (Chapter
657 of the Statutes of 2008) requires local
governments to plan for a balanced, multimodal
transportation network that meets the needs of
all users of streets, roads, and highways for safe
and convenient travel.” The text goes on to
prioritize qualification for VMT as “within one-half
mile of a major transit stop or high-quality transit
corridor included in a regional transportation
plan.” And provides this definition “a highquality
transit corridor means a corridor with fixed route
bus service with service intervals no longer than
15 minutes during peak commute hours.”
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses. Please also see Master Response 3: Buildout and RHNA for more
information.

C84-12 Rick Nahass 1/30/22 Assuming DEIR VMT calculations are based on the proximity of the population to BART and Caltrans
(both high-quality transit orridors), the biggest
impact to reducing VMT in the DEIR Land Use and
Housing and Alternatives sections would be to
add the Add the following element to the General
Plan with references in the DEIR:
• CI-I-xx Regional Coastside Bus Corridor Request
from the MTC priority to facilitate and prioritize
the establishment of a high-quality regional bus
corridor on state route 1 from Half Moon Bay into
Marin County in compliance with Senate Bill SB
743. Interpret weekend congestion hours as
included in the SB 743 definition of “commute
hours.”
This comment is noted. VMT Methodology
is described in Appendix B.

C84-13 Rick Nahass 1/30/22 An additional transit element should be added for Shuttles on Sharp Park Road should a transit
corridor be eventually established:
• CI-I-xx Sharp Park Road Public Transit. Work
with the SMCTA to support and promote direct
bus/shuttle routes on Sharp Park Road east to
Skyline College, Caltrain, San Bruno/SSF BART and
SFO Airport.

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Packet Pg. 1145 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 481
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Individuals (C)
C84-14 Rick Nahass 1/30/22 And finally, not related to Circulation…General Plan Section 7.5 Energy and Greenhouse Gases
Add the following element on Solar Power to the
General Plan:

CO-I-xx Encourage Solar and Renewable Battery
Storage. Promote the use of battery storage for
local renewable energy generation, such as solar,
where energy generation exceeds immediate
need. Support and promote technologies, such as
power sharing via micro-grid, introduced by
public utilities (e.g., PGE) and other public and
private entities.

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Packet Pg. 1146 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 482
C85: Erin Macias, 1/18/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C85-1 Erin Macias 1/18/22 Area of Concern: Creating a New Civic Center p.6-32
Comment: The impact of creating a New Civic
Center contradicts the General Plan to develop
affordable housing and affordable rental units
(page 4-16) because the cost will be passed on to
the taxpayers in the form of bonds or other
means of taxation, the result is higher rents and
less affordability in the City. A centrally located
Civic Center further has a direct environmental
impact as it increases ir pollution by creating
additional traffic that also exacerbates ingress
and egress in Pacifica during an emergency. It
also risks isruption to all city services and risks
major loss of records in the event of a natural
disaster event such as an earthquake, tsunami or
ire. All your eggs in one basket is not a good
strategy.

The relationship between construction of
public facilities and affordable housing is
not a topic required for DEIR analysis.

Congestion is not a required topic for CEQA
analysis and the DEIR correctly analyzed
and mitigated VMT impacts on pages 3-40
to 3-43. As discussed in Impact 3.2-4,
project level review required by the City
includes site access review for emergency
vehicles and traffic control plans as needed
that account for emergency vehicles. Thus,
new development would be required to
comply with Municipal Code requirements
for emergency access to the site and LHMP
and Emergency Plan implementation will
reduce impacts to the maximum extent
practicable. In addition, new development
would be subjected to policies listed under
Impact 3.2-4 as well as the existing
programmatic framework to reduce impacts
of evacuation to less than significant level.

Please see Master Response 7: Evacuation
Routes for more information regarding
emergency access. Cumulative air quality
impacts due to increased traffic are
included as part of evaluation of Impact 3.3-

2. C85-2 Erin Macias 1/18/22 Area of Concern: Implemented policies Linda Mar regarding expanding the Pacifica
Community Center (p.3-5) and Creating a New
Civic Center (p.6-32)
Comment: there is no update to the general plan
that recognizes or plans for the modernization
within its existing footprint for the least
environmental impact. Expanding implies
extending use of the Community Center parcel
outside the building footprint. Expanding the
Community Center to add a park and more
recreational outdoor space creates more traffic,
parking problems, and directly impacts the
adjacent wetlands with litter and trespass onto
environmentally sensitive areas. There is a need
to maintain these existing buildings and
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Project and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related
responses.

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Packet Pg. 1147 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 483
Letter Commenter Date Comment Combined Response
Individuals (C)
modernize them so services are fairly and evenly
distributed across the city providing equitable
access to all residents. The suggestion to include
a teen center adjacent a wetlands has a negative
environmental impact as the skate park does
now. The litter generated and blowing around
the parking area and in the wetlands is an
ongoing problem. The need to commute to a
centrally located facility generates pollution,
affects traffic and contributes to the concerns of
ingress and egress in an emergency and cuts off
critical services to our most vulnerable
populations.

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Packet Pg. 1148 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 484
C86: Christine Boles, 1/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C86-1 Christine
Boles
1/20/2
2 I’m having trouble ascertaining whether the city is
using up to date scientific data, so I thought to
research one item, Greenhouse gasses (GHD) as
that is one section that the city identified as
needing to be updated. In fact the Bay Area Air
Quality Management District, BAAQMD,
commented during the NOP about this in
particular, see image below.

This was my morning for the last few hours… The
EIR has a Bibliography, let’s see what it says.

Chapter 6, oh look, it lists the documents
referenced and even provides links, how helpful!
Scroll for BAAQMD, huh? only one document from
2010, a source inventory…no mention of the
documents required in the letter. Ok, well, let’s
look at the source inventory. Darn the link does
not work. Go through a BAAQMD internet search
and find the current document. What’s the date?
Published in 2014 from 2011 data.
https://www.baaqmd.gov/about-airquality/research-and-data/emissioninventory/climate-forcing-pollutants So, the Bibliography is wrong, but maybe the GP is right. I
go to the GP to see what it says. From the index it
looks like chapter 7-5 Energy and Greenhouses
gasses might be right. Scroll scroll scroll…
Got it. Read it, it’s short! Still looking for
references to 2017 documents, don’t see anything
about the Clean Air Plan here either…
Ok, let’s look for BAAQMD’s Source inventory of
Greenhouse Gas Emissions. Here it is in the first
paragraph. What date did they use?
The first paragraph on 7-35 mentions 2008, wait,
that’s old. The next page mentions inventory
reports through 2017, good…ok this refers to
BAASQA’s report 2014(from 2011 data) Good
that’s current, maybe they just forgot to update
the first paragraph and the bibliography, keep
reading, it is a short section after all. Ok, on the
last page, the table at the bottom also refers to a
BAAQMD study; what is it and when was it done?
Hmm, it doesn’t say…but wait, the heading
describes it as data from 2006! I’m ready to give
up…wait I’ve come this far, let’s try to see this
through. Ok, maybe the General Plan is just not
updated for Greenhouse Gas Emissions, but surely
the correct information is in the EIR. Let’s look at
the index of the EIR and see if we can find that
References will be updated to reflect the
latest data used in analysis. This does not
change any findings of significance in the
DEIR.

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Packet Pg. 1149 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 485
Letter Commenter Date Comment Combined Response
Individuals (C)
section. Oh wait, there is no index…
Scroll scroll…
Wait, I’m so lucky, one of my friends actually made
a rough index of the 1013 page DEIR with page
numbers for me - I actually have an advantage that
other residents and agencies don't have - I have to
figure out how to share this with the public,
maybe tomorrow... ??? Maybe chapter 3? Impacts
and Mitigation Measures Sounds good. OMG that
chapter is 603 pages long...Lets see if there is a sub
index on page 199.

Scroll scroll, Chapter 3 should be right behind 2.58.

Screenshot - wait, the title isn't even the same as
the index on page 158! Land Use Population and
Housing? That's not what I want... Did I actually
accomplish anything in the three hours I just
donated to the city, no. And I have such a splitting
headache that I can’t focus anymore. If I can’t do
this and this is my line of work, what does this
mean for the average Pacifican? It sure feels like
the city does not really want our input…
Mayor Bier, Mayor Pro-Tem Bigstyck and City
Council members, we are counting on you to
ensure that the public can be properly engaged.

That is your primary job as our elected
representatives and it is completely in your power
to instruct staff to do so. I urge you to have staff
update the documents to break them up to
manageable sizes and to provide indexes as well as
a proper bibliography.

C86-2 Christine
Boles
1/20/2
2 It is in all of our interests to complete a proper
update of the General Plan as soon as possible
that can guide us through our next 20+ years. For
example, Vista Mar becomes HPD in this update
and that is in my personal interest! HPD language
is strengthened in this document, wonderful! But
that is not enough for me to ignore things like
greenhouse gasses, missing fire risk information
for my neighbors near San Pedro Mountain, or
missing sea level rise information for my neighbors
in Sharp Park.

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

Impacts related to greenhouse gases are
adequately addressed in Ch. 3.4; impacts are
found to be less than significant with
mitigation. Please see discussion of the
adequacy of fire hazard and threat mapping
in Master Response 5: Wildfire. Please see
response to comment C13-3 for more
information on sea level rise. Development in
flood-prone areas would be required to
comply with proposed policies related to sea
level rise, best available science, and
vulnerability identification and mapping (SA1.f
Packet Pg. 1150 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 486
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Individuals (C)
G-5 and SA-I-28); flood map review and
floodplain management (SA-I-18 and SA-I-19);
flood hazard reductions (SA-I-20); and flood
control structures (SA-I-23). Please see also
response to C13-3 for more information on
sea level rise.

C86-3 Christine
Boles
1/20/2
2 You have a willing pool of free labor! Let the public help you make sure these documents are up to
date and consistent. If the documents are not,
then I'm afraid it could leave the city exposed to
legal challenges by developers, environmental
groups and residents. I am not a lawyer, but from
what I understand, legal challenges to the General
Plan and EIR could be directly against the city, not
through a developer's project, so the city may not
be shielded. I assure you that none of the
Pacificans I've spoken with want to go there. But I
also assure you that we are not willing to allow
these documents to stay in their current form.

Approval of these documents as they stand would
be:
• a disservice to our community, to the creatures
we share this land with, and even to the
developers we want to court
• a slap in the face to all the people affected by
our previous disasters as we seem to have not
learned from our history
• a threat to current and future residents for a lack
of analysis and understanding of our hazards
• and an affront to all of us taxpayers for all the
money we have paid to staff and consultants over
the years for this update.

So what would the process look like to update
some of these major issues like missing fire maps?
Has the fire department even reviewed this draft
before it was issued? The EIR says North County
Fire was interviewed in 2009! So much has
changed since then with climate change and
droughts. I need updated fire information before I
can understand proposed land use changes and
properly review that section of the GP. Would this
happen before the public hearings start? Would
state agencies also need to be given more time to
review major changes? I really have no idea and I
am not getting answers to these basic process
questions from planning staff or the City Manager.

The comment is noted. Adequacy of hazard
mapping is described in response to
comment C22-10. Adequacy of fire mapping
and analysis is described in Master Response
5: Wildfire. Correspondence with NCFA
occurred in 2019; the bibliography will be
updated accordingly.

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Packet Pg. 1151 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 487
C87: Christine Boles, 2/10/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C87-1 Christine
Boles
2/10/22 I am trying to understand the calculation
of Buildout per the draft General Plan. See
screenshot below from Page 4-29. The
whole DEIR is based on this maximum
buildout number to assess environmental
impacts for a project of 990 new units, so I
wanted to clarify how these numbers
were obtained.

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. Buildout
estimates represent a potentiality rather than a
definitive figure, 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 land availability, property
owner interest, and regional real estate and labor
markets, and other long-term economic and
demographic trends.

Other commenters assert that impacts of the
Proposed Project are underestimated because
buildout does not account for Pacifica’s regional
housing needs allocation (RHNA) number of 1,892
housing units. 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.

C87-2 Christine
Boles
2/10/22 I am assuming that you have in your files
or in Dyett & Bhatia's the detailed
calculations that informed these numbers
that would list specific properties and
their acreage that were included in each
of these land use categories.

Please see Master Response 3: Buildout and RHNA
for more information on how buildout was
calculated.

C87-3 Christine
Boles
2/10/22 If I need to file another PRA request,
please let me know specifically what to
ask for so I can better guide poor Sarah.

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

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Packet Pg. 1152 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 488
C88: Jim Louderback, 1/16/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C88-1 Jim
Louderback
1/16/2
2 Hi, in the general plan you show the open area
bound by Danmann and San Pedro avenue as
zoned for residential/commercial and open for
building up to 5 or so structures per acre.

Based on the official California Tsunami
Hazard Area Map that property is located
directly in the hazard zone. The recent Tonga
tsunami is a warning that building here would
be a very bad idea. I don’t want to see people
die or property destroyed next time there’s a
tsunami in Pacifica.

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.

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Packet Pg. 1153 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 489
C89: Bill Collins, 2/21/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C89-1 Bill Collins 2/21/22 Oceana Blvd needs a bike lane, esp for high school students. It's now unsafe for cyclists
to share the road with cars in both
directions as well as parked cars.

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

C89-2 Bill Collins 2/21/22 Painting "bike lane" on the street does not make it safe.

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

C89-3 Bill Collins 2/21/22 Pacifica should enforce the Vehicle Code so cars are not blocking sidewalks.

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

C89-4 Bill Collins 2/21/22 We need more diverse transportation options.

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

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Packet Pg. 1154 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 490
C90: Necesse, 1/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C90-1 Necesse 1/20/22 Concern: City is operating on a Sewer Master plan that is outdated and inadequate.

Comments: Revision of a master plan is
necessary to meet the ongoing needs of the
community. We are operating on a master plan
that is already outdated and does not mandate
sewer lateral replacement that directly
contributes to contamination of fresh water
sources in the City of Pacifica and places a
higher burden on our wastewater treatment
plant. Lateral replacement is being mandated
in many cities where residents have a specified
number of years to comply. The slow methods
in our plan will never be achieved in our
lifetimes.

See response to comment C9-13.

C90-2 Necesse 1/20/22 Environmental impact: the impact of leaking laterals is a recognized major concern for the
City of Pacifica. The repaving project and the
consequential disturbance of these newly
repaved or resurfaced roads to do
infrastructure repairs as is evidenced by poor
planning on Crespi Drive in late 2021/early
2022 and was avoidable. Digging adversely
affects underground freshwater sources, and
may exacerbate lateral problems on
surrounding properties; it generates gravel,
dirt and dust that ends up in the storm drains
and in wastewater collection systems. The
patch jobs from these repairs damage the
newly paved/resurfaced streets creating
uneven wear again and shortening the life of
the resurfacing work. This adds more
contaminants and exacerbates problems with
our old infrastructure.

The comment is noted. See response to
comment C9-2.

C90-3 Necesse 1/20/22 Concern: the absence of an emergency response plan to prevent flooding and SSOs in
the Sewer Master Plan
Comments: Preventing SSO’s should be a high
priority of our General plan because we have
been sued and fined over this issue. The EQ
basin does not prevent flooding and does not
stop raw sewage from entering the public right
of way. We need a written comprehensive
emergency response plan as other cities have
adopted.

The comment is noted. The DEIR
acknowledges the exceedance of the City's
stormwater capacity and describes its storm
drainage system on pages 3.5-30 to 3.5-32.

Based on 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.

C90-4 Necesse 1/20/22 The environmental impact is absent from the DEIR.

See response to comment C90-3.

C90-5 Necesse 1/20/22 Recommendations:

1. Require periodic review and amendments to
the Sewer Master Plan so it is kept current
The comment is noted. The comment is not
related to the adequacy of the DEIR,
therefore no further response is required in

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

C90-6 Necesse 1/20/22 2. Actively seek federal and state funding to address these critical infrastructure problems
we face
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.

C90-7 Necesse 1/20/22 3. Require the creation of an emergency response plan to prevent both flooding and
SSOs during wet weather events
The comment is noted. The comment is not
related to the adequacy of the DEIR,
therefore no further response is required in
the FEIR. However, the comment addresses
the content of the Proposed Project and will
be shared with decision-makers in that
context. Please see Master Response 1: EIR
Comments for more information about GP- or
SPSP-related responses.

C90-8 Necesse 1/20/22 4. Revise the Assurance Alternatives of the sewer master plan to change the language
from private lateral replacement as a
“disadvantage” and change it to an
“advantage.”
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.

C90-9 Necesse 1/20/22 5. Mandate sewer lateral replacement citywide and offer repaving prioritization as an incentive to streets in full compliance
The comment is noted. The comment is not
related to the adequacy of the DEIR,
therefore no further response is required in
the FEIR. However, the comment addresses
the content of the Proposed Project and will
be shared with decision-makers in that
context. Please see Master Response 1: EIR
Comments for more information about GP- or
SPSP-related responses.

C90-10 Necesse 1/20/22 6. Create a long term lateral plan by residential district beginning with areas with more
orangeburg pipe and areas with the highest I/I
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.

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Packet Pg. 1156 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 492
C91: Suzanne Buckley, 2/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C91-1 Suzanne
Buckley
2/9/22 I am one of the many Pacifica residents chiming in to ask for a re do of the Draft Environmental Plan recently released. It is an ill conceived document and really challenging to read - and I am a professional educator and editor. Please listen to the many responses of our community. We need a General Plan that is workable, reflective of the current time and the future - and respects the wishes of our citizens.

The comment is noted; a DEIR
with an interactive table of
comments was released on
February 10th, and the public
comment period extended to
March 8, 2022. Please see Master
Response 1 for more information
on General Plan-related
responses.

C91-2 Suzanne
Buckley
2/9/22 I also request that examples of successful plans from other cities be included for review. It is always best to be able to compare and contrast so that lay people can make informed decisions.

This comment is not related to
the adequacy of the DEIR.

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Packet Pg. 1157 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 493
C92: Necesse, 1/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C92-1 Necesse 1/20/2
2 Repeat of C90 Please see comment
responses to letter C-90.

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Packet Pg. 1158 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 494
C93: Necesse, 1/19/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C93-1 Necesse 1/19/22 One of the main concerns I have with the DEIR and GP for Public Comment is the
difficulty in aligning the sections of the two
documents. When something is missing
from the DEIR and is mentioned in the GP,
there is no section of the DEIR to reference
in my comments. It is very difficult to search
both documents and the absence of indexes
or a glossary makes this cumbersome for the
public to review and comment.

The comment is noted. It does not relate to the
adequacy of the DEIR or GP/SPSP content, thus
no further response is required.

C93-2 Necesse 1/19/22 I am reviewing the Section of the General Plan related to Biological Resources and the
policies and mitigation measures associated
with that section, but from my lenses there
are no policies or mitigation measures in
place or proposed that adequately address
the wildlife corridors and the very serious
issue of fragmentation. This gets a brief nod
in the documents and fragmentation is only
listed in three places in a 1013 page
document.

Please see response to comment A2-4 for
more information on wildlife movement
corridors.

C93-3 Necesse 1/19/22 Concern: Wildlife Movement Corridors found on page 7-23 of the Draft General
Plan, “Corridors typically range from 100 to
400 feet in width, within which habitat is
continuous and suitable for wildlife
movement.”
Comment: Corridors (as a general term) do
not ‘typically range from 100 to 400 feet in
width’ and I would like to know where this
data originates. Corridors depend on various
factors and should not be generalized in
such a manner. The environmental impact of
the limitations of the section ‘wildlife
movement corridor’ is not contained in the
EIR. “While a wildlife movement corridor is
needed somewhere within the area
designated on Figure 7-3, the entire area
need not be designated as a wildlife
movement corridor.” This is not addressed
in the EIR and it is necessary to identify them
or they are not afforded protection unless
there is a species that warrants protection.

On page E-70 high habitat value threatened
by fragmentation is mentioned under CO-I33 but there is only one identified wildlife corridor in the entire General Plan. The
Gypsy Hill wildlife corridor is one of many
and all of these are threatened by
fragmentation without appropriate guiding
and implementing policies in place.

Please see response to comment A2-4 for
more information on wildlife movement
corridors.

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Packet Pg. 1159 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 495
Letter Commenter Date Comment Combined Response
Individuals (C)
C93-4 Necesse 1/19/22 Recommendations:

1. Extend the comment period until a
reasonable outreach is made to the
community.

The public comment period was extended until
March 8, 2022 to allow for additional public
review time.

C93-5 Necesse 1/19/22 2. Better define the term wildlife movement corridor and appropriately represent the
different types of wildlife corridors in the
City of Pacifica: birds, small mammals and
amphibians as one, and larger animals as
another.

Please see response to comment A2-4 for
more information on wildlife movement
corridors.

C93-6 Necesse 1/19/22 3. Include the goal of mapping out wildlife movement corridors in Pacifica. The absence
of such a goal is also absent of its
environmental impact.

Please see response to comment A2-4 for
more information on wildlife movement
corridors.

C93-7 Necesse 1/19/22 4. Adopt policies that require developers to mitigate IN PACIFICA when their projects
adversely impact parcels within the City
limits and disallow any trading or exchange
of environmental credits for projects outside
Pacifica (in other words, if they damage
habitat in Pacifica, they should be required
to restore habitat in the city limits not in
some other state or city.)
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.

C93-8 Necesse 1/19/22 5. Establish a committee to Identify sites and habitats in our city or within our scope of
influence that developers can restore or
mitigate (to accomplish #4.)
The comment is not related to the adequacy of
the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed Plan
and will be shared with decision-makers in that
context. Please see Master Response 1: EIR
Comments for more information about GP- or
SPSP-related responses.

C93-9 Necesse 1/19/22 6. Require wide buffer zones on parcels that abut open space regardless if animals using
the parcel have special designations: the
interactions between species and open
space is complex.

C93-10 Necesse 1/19/22 7. Adopt strong policies and expand the influence of OSPAC to prevent
fragmentation of greenspaces within the city
and between public and privately held lands.

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C94: Rick Nahass, 2/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C94-1 Rick Nahass 2/20/22 Please consider the following changes to the city General Plan and DEIR: (1) For Public Transit and
Transportation Demand anagement: Replace the
text 'SamTrans' with 'San Mateo County Transit
Authority (SMCTA) and the Metropolitan Transit
Commision (MTC).' The SMCTA encompasses both
SamTrans and Commute.org bus operators as well
as various Bicycle, Pedestrian programs. The MTC
originally established for regional transit
coordination has recently been given regional
authority to mandate fare integration (AB-629)
and authority through SB-917, Seamless Transit
Transformation Act, to develop standards and
processes to manage a single Bay Area transit
network and requires the 27 Bay Area Operators
to comply. State route 1 on the Coastside is
already congested eyond population and visitor
capacity.

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

C94-2 Rick Nahass 2/20/22 (2) Establish a Vehicle Miles Travelled (VMT) Mitigation Bank - see
https://www.fehrandpeers.com/wpcontent/uploads/2020/04/VMTFees_Exchanges_Banks- White-Paper_Apr2020.pdf - to manage future growth per vehicle miles
travelled (VMT) SB-743 environmental impact
mandate.

C94-3 Rick Nahass 2/20/22 For each new housing unit require a 1 time developer fee based on miles to the nearest high
quality transit stop (e.g., $2100 x 6 miles to Colma
BART = $12,600 per unit)
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

C94-4 Rick Nahass 2/20/22 For each new housing unit require a yearly owner fee (tariff) based on miles to the nearest high
quality transit stop (e.g. $160 x 6 miles to Colma
BART = $960 per year)
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

C94-5 Rick Nahass 2/20/22 SB-743 definition says "a high-quality transit corridor means a corridor with fixed route bus
service with service intervals no longer than 15
minutes during peak commute hours." Add
specifications 'specific' to the coastside, for
example: Limited stops (3 from HMB to Montara, 2
in Pacifica to BART, possibly continuing to GG
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

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Packet Pg. 1161 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 497
Letter Commenter Date Comment Combined Response
Individuals (C)
Bridge), Coastside Commute Hours (M-F morning
and evening, Sat-Sun 10AM-3PM) - don't want a
bus operator to add another bus to an existing
route that takes 45 minutes to and hour to get to
BART or Caltrain and call it satisfying the SB-743
requirement.
more information about GP- or SPSPrelated responses.

C94-6 Rick Nahass 2/20/22 Possible exemptions or fee relief for low-income housing development
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

C94-7 Rick Nahass 2/20/22 Councils sit on the commute.org Board. As housing development is approved and potential fees
identified, a budget can be forecast for
establishing and growing a shuttle program based
on capital income (one time developer fee) and
yearly operating income (yearly owner fee)
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

C94-8 Rick Nahass 2/20/22 If a coastside transit corridor is established per the General Plan definition, then the fees are reduced.

See attached illustrative worksheet for Pacifica
stops.

C94-9 Rick Nahass 2/20/22 This makes housing growth mandates (RHNA ABAG) dependent on both developers' willingness
to pay to reduce VMT and Regional Transportation
Operators and Caltrans ability to deliver a high
quality transit corridor to the coastside. Also
serves to mitigate GHG, Climate and Circulation
elements of the GP.

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Packet Pg. 1162 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 498
C95: Mark Hubbell, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C95-1 Mark
Hubbell
3/8/22 Having said that, the absence of opportunities for current citizen participation in the process is clearly evident and rather disappointing. Particularly disturbing is the safety element failure in addressing the likelihood of devastating wildfires throughout the Park Pacifica and eastern Linda Mar neighborhoods with a presentation of specific,
comprehensible, and effective plans for the prevention of and protection from these deadly hazards.

Thank you for your comment. The
adequacy of the DEIR in addressing
wildfire hazards is addressed in
Master Response 5: Wildfire.

C95-2 Mark
Hubbell
3/8/22 HISTORY:

Thirty years ago, the Oakland Hills firestorm – Tunnel Fire -- of 1991, swept through a nearby residential neighborhood with surprisingly similar terrain and autumn weather
conditions as the Back Of The Valley neighborhoods in
Pacifica, burning through 1520 acres; killing 25 people and injuring 150 others; destroying 2,843 single-family homes and 437 apartment and condominium units. The economic
loss from the fire was estimated at $2.59 billion in 2020 dollars. Division Chief Riley and Oakland Police Officer John Grubensky were killed while trying to help citizens escape the fire. Both Chief Riley and Officer Grubensky were found with the remains of those people they were trying to help. (Source: Wikipedia)
Let’s also dispel the notion that eucalyptus trees aren’t flammable: “The leaves produce a volatile highly
combustible oil, and the ground beneath the trees is
covered with large amounts of litter which is high in
phenolics, preventing its breakdown by fungi. Wildfires burn rapidly under them and through the tree crowns. It has been estimated that other than the 3,000+ homes that burned in California’s 1991 Oakland Hills Fire, about 70 percent of the energy released was through the
combustion of eucalyptus” — Bill Gabbert (Author of
Wildfire Today) Why is there is no mention of city support and assistance for fire mitigation through tree removal and replacement with less flammable native foliage in this
General Plan? Most likely, the opportunity for community participation would have brought this to The City’s
attention.

In 2021, a record number of wildfires burned across the western states. As of December 16, 2021, a total of 8,619 fires had been recorded, burning 2,569,009 acres across California. So far in just the first couple months of 2022, there have already been two significant fires, the Alpine Fire on the Sonoma Coast and The Colorado Fire near
Camel By The Sea, burning a combined 700 acres of nearby coastal area, in the middle of winter, in what is normally the rainy season.

The first two months of 2022 are shaping up to be the
driest January and February in California history, prompting state officials to warn of dire water conditions ahead.

Please see response to comment
C7-1 for more information on how
vegetation/fuel is included in fire
mapping. Please see Master
Response 5: Wildfire for more
information.

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Packet Pg. 1163 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 499
Letter Commenter Date Comment Combined Response
Individuals (C)
“There’s no precipitation forecast through the remainder of February. And there’s very little precipitation in the longrange forecast for March,” Erik Ekdahl, a deputy director with the State Water Resources Control Board, said at a board meeting Tuesday. “All this is pointing to, again, some pretty dire conditions statewide for drought.” In the 1970s, Pacifica, as did many other California cities, started TreesFor-ADollar campaigns with Planting Parties. Many trees were planted in the indefinable spaces between fence lines weaving through hillside neighborhoods.

Today, most of those trees are dead or dying tinder-towers, and they are fire and falling hazards costing from $5,000 to $9,000 apiece for the individual homeowner to remove. If only it had been a more enlightened program providing
fire-resistant native species, like coastal live oaks or redwood trees, we wouldn’t be having this problem. Many years later, it is hard to get neighbors to agree on
responsibility; so the trees become an increased danger for everybody.

Somehow and soon, those trees will have to be equitably removed for the safety of residents in these
neighborhoods.

C95-3 Mark
Hubbell
3/8/22 Understandably, it is challenging to extrapolate current conditions with data trends decades into the future. But isn’t that the point of creating The 2040 General Plan? So the question for validating this Environmental Impact
Report is:

What will The City do over the next few years to potentially ensure the safety of thousands of citizens, as well as
firefighters and police for decades to come, by eradicating these life-threatening conditions?
Please see Master Response 5:

Wildfire for more information on
how the DEIR analyzes impacts of
future development under the
Proposed Project.

C95-4 Mark
Hubbell
3/8/22 CURRET HAZARD ASSESSMENTS:

The City has very recently been distributing inconsistent versions of its wildfire hazard maps. Map ‘A’ below is the map included in this DEIR. This map does seem to represent the actual concerning levels of wildfire severity in the Park Pacifica / East Linda Mar neighborhoods. Map ‘B’ is
incorporated into the General Plan tethered to this same DEIR project is substantially different by eliminating the actual severity of most wildfire threats within the Pacifica City limits – an obvious inconsistency. Map ‘C’ was provided By The City last summer to the San Mateo County Hazard
Risk Ranking program, possibly by accident, yet assuring them that Pacifica is indeed fireproof. Image ‘D’ is the response from The County acknowledging that the risk of wildfire in Pacifica is less than “dams breaking,” even though there are no dams in Pacifica.*
Please see Master Response 5:

Wildfire for more information on
data used for mapping. Map D is a
map from the 2014 DEIR that was
not certified; it does not use the
2008 CAL FIRE Recommended LRA
maps and thus do not represent the
latest and best available data.

C95-5 Mark
Hubbell
3/8/22 For the sake of accuracy, here are the actual Cal Fire percentages.

The comment is noted.

C95-6 Mark
Hubbell
3/8/22 *Note: Dam Failure -- There are no dams within or above Pacifica, and therefore the city is not at risk from a
seismically induced dam failure. However, water tanks
The comment is noted. Proposed
General Plan policy SA-I-13 has the
City work with the NCCWD to

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Packet Pg. 1164 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 500
Letter Commenter Date Comment Combined Response
Individuals (C)
located in the hills above populated areas could burst and inundate areas below due to a seismic event. (Pacifica
Planning Dept.)
determine areas potentially
affected by flooding from ruptured
water tanks in the event of a
seismic event and inform property
owners. In addition, analysis under
Impact 3.13-1, specifically on pages

3.13-6 to 3.13-7 states that
NCCWD’s current Capital
Improvement Plan focuses on
minimizing the risk to the water
supply that could result from a
major seismic event.

C95-7 Mark
Hubbell
3/8/22 Earthquake damage facts show fires caused by earthquakes are the second most common hazard. Earthquake fires start when electrical and gas lines are dislodged due to the
earth’s shaking. Gas is set free as gas lines are broken and a spark will start a firestorm (Source: Cal Fire). The main natural gas pipeline (blue line) running into Pacifica is an extension of the one that exploded in San Bruno, 2010. As you can see, the pipeline crosses the San Andreas Fault, which moves northward at the rate of 4 to 6 cm (1.6 to 2.4 inches) per year since the early 20th century. Parts of the fault line moved as much as 6.4 meters (21 feet) during the 1906 earthquake. (Source: Enc. Britannica, Feb 7, 2022) The comments is noted. The
addition of "fires that could result
from earthquake" will be added to
errata. This addition does not
change findings of significance in
the DEIR.

C95-8 Mark
Hubbell
3/8/22 The good news is that there are many grant funding programs available for areas in high wildfire threat areas:

Cal Fire: Urban and Community Forestry Grant Programs – Reforesting With More Fire Resilient Foliage
PG&E: The10,000-mile Undergrounding Program –
Undergrounding Utility Lines In High Treat Wildfire Areas FEMA: Fire Service Grants and Funding -- Assist fire
prevention programs and
support firefighter health and safety research and
development.

C95-9 Mark
Hubbell
3/8/22 So the question for validating this Environmental Impact Report is: Why not come clean about our situations to
qualify for available resources, instead of hiding or
confusing the hazards that threaten us?
The DEIR uses the latest and best
available data regarding hazards in
the DEIR. Please see Master
Response 5: Wildfire for more
information.

C95-10 Mark
Hubbell
3/8/22 FIREWORKS:

Senator Dianne Feinstein’s office can speak to that:
“The drought in California has created dangerous
conditions for wildfires this summer. And the risk will spike this weekend as millions celebrate the July 4 holiday. I urge all Californians to leave fireworks to the professionals this year.
“Last year we saw how much damage irresponsible use of
fireworks can cause. The San Francisco Fire Department
reported at least 100 grass fires, Fresno saw at least 135 fires and the Los Angeles Fire Department responded to
The comment states the proposed
General Plan should address the risk
of wildfires from fireworks, which
are illegal in Pacifica. Enforcement
of existing City of Pacifica Municipal
code is beyond the necessary scope
of the Draft EIR. Please see more
information about fire hazard and
threat mapping, descriptions, and
policies that reduce the impacts.

The Draft EIR is concerned with
analyzing the risk to exposure from

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Packet Pg. 1165 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 501
Letter Commenter Date Comment Combined Response
Individuals (C)
nearly 400 fires, many started by fireworks.
“Fireworks at one party in Yucaipa last September sparked a wildfire that burned more than 20,000 acres. Just last week, firefighters in Fresno County responded to a brush fire caused by illegal fireworks.
“The bottom line is that with the hot, dry conditions
California is currently experiencing, using fireworks risks sparking destructive and deadly wildfires. And using illegal fireworks can lead to fines of up to $50,000 and a year in jail. Parents are also liable for any damage or injuries caused by their children using fireworks.
“Do your part to prevent wildfires and celebrate the holiday safely by skipping fireworks at home and instead watch a public show in your community.”
wildland fires, rather than providing
a comprehensive list of causes of
wildland fires, which include illegal
fireworks.

C95-11 Mark
Hubbell
3/8/22 Pacifica may not be able to qualify for wildfire prevention grants. So the question for validating this Environmental Impact Report is: Would any safe and sane professional
person approve grant funding for wildfire safety to a city offering legal fireworks?
This comment inaccurately states
that fireworks are legal in Pacifica;
they are illegal. See response to
comment C95-10
C95-12 Mark
Hubbell
3/8/22 EVACUATION:

In the event of a wildfire emergency, it would be a very bad idea for hundreds or potentially thousands of families in cars to try evacuating to the beaches via only two available routes for sanctuary. The Zonehaven Evacuation program
seems to be a brilliant solution to avert a horrible disaster.

So the question for validating this Environmental Impact Report is: Why won’t The City concentrate on promoting
this program more effectively?
Thank you for your comment. As
stated in the DEIR, The Safety
Element of the General Plan
provides policies that address
conformance with local emergency
response programs and continued
cooperation with emergency
response service providers. For
example, policies have been
developed to ensure that all
applicable disaster plans are
updated regularly and a
coordinated emergency response
system is maintained with other
agencies. As such, implementation
of the Proposed Project would not
physically impede the response
times of emergency response
vehicles or delay implementation of
an evacuation plan, resulting in a
less than significant impact."
Policies that reduce the impacts of
evacuation deficiencies include
those described under Impact 3.11-

6. The Zonehaven program is also
addressed in Pacifica's MJ-LHMP
Annex, incorporated by reference in
the DEIR.

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Packet Pg. 1166 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 502
C96: Judy Yamahiro, 1/26/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C96-1 Judy
Yamahiro
1/26/2
2 Please fix the documents as Mr. Shoemaker described via next door Linda Mar to make them more easily accessible and please extend the deadline for review. As a resident, my tax dollars are being used to compose this document and all residents deserve good value for our tax dollars.

Please see response to
comment C62-8. The
public comment period
was extended until
March 8, 2022 to allow
for additional public
review time.

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Packet Pg. 1167 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 503
C97: Christine Boles, 1/29/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C97-1 Christine
Boles
1/29/22 I tried working with the word documents today in parallel with the pdfs and it just added to the cumbersome, time consuming task you have so disrespectfully dumped on the public. Page numbers don’t even match. Now I have to scroll thorough multiple windows at once, with a third window for writing my comments and a fourth window for checking references online, because so many are outdated.

I think I made it through 5 whole pages of the DEIR on seismic risks today and already have two pages of comments. Only 1008 pages to go…
Do you not understand that we actually want to help you improve these documents so that the General Plan can be properly used for the next 20 years? The many errors and inconsistencies in these documents leave the city exposed to litigation not just by the public and environmental groups, but also by developers. Is that the legacy and risk this council wants to leave the city saddled with? As Tygar said so eloquently at the last Council meeting, this is your decision, and you need take the responsibility. The buck stops with you; Staff is just waiting for the word from the 5 of you, who were elected to represent us. Remember your names will be on this document for posterity.

And planning commissioners, please, you have a voice too. Have you started your own review? Are these documents good enough for you and for those who will follow you in those seats to do the jobs to ensure the public and our environment are protected? Can you please put the General Plan discussion on your agenda for February 7? I really want to hear what you think.

We’ve already been waiting 43 years, we can wait a few more months.

Do the right thing. Fix the documents into one searchable pdf, provide an index, update the bibliography and links, and reset the clock.

Please see response to
comment C62-8. The
public comment period
was extended until
March 8, 2022 to allow
for additional public
review time.

References will be
updated to reflect the
latest data used in
analysis. This does not
change any findings of
significance in the DEIR.

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Packet Pg. 1168 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 504
C98: Christine Boles, 1/7/2022
Letter Commenter Date Comment Combined
Response
Individuals (C)
C98-1 Christine
Boles
1/7/2
2 Both the Tribune and the City’s website say the General Plan review process starts today, but I can’t find the documents on the city website. The links given are circular. Can you confirm that the review process will be extended as necessary so that we have the full minimum 45 days?
https://www.cityofpacifica.org/civicax/filebank/blobdload.aspx?t=62428.95&BlobI D=19363
Please confirm when the documents will be made available.

I am really disappointed to read that there will be no public launch giving an overview of the documents and explaining how residents and businesses can best contribute. My guess is that most Pacificans don’t even know what a General Plan is, much less understand its importance. The fact that after 40+ years the General Plan release is not even an item for discussion on the City Council’s agenda for Monday leads me to believe that the city lacks the desire for public education and engagement on the future vision of our city.

I understand that staff resources are limited and that the City Manager would want to minimize their time and expense, but Council Members, I ask you as elected representatives to question whether this is the right decision. It is obviously your call to make, not that of staff.

Documents
were posted on
1/7/2022; the
review period
was extended
to 3/8/2022.

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Packet Pg. 1169 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 505
C99: Michelle Pitte, 2/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C99-1 Michelle Pitt 2/17/22 After watching a Docu-Series on Netflix, Down To Earth, where they traveled around the world for healthy and sustainable ways to live I have put together this bulleted list of what I hope for the future of this town based on what I saw:
-Greenery walls along with every building Site, rooftops, sidewalks, or gathering areas.
-No plastic water bottles, no plastic anything
-Filtered Water fountains everywhere
-Sustainable building
-Carbon sequestering gardens
-More walking/biking/shuttle options
-Energy efficiency, those small windmills,
-Communities to live, work and shop in the same center or -Live, shop, and access to smart commuting
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 GPor SPSP-related
responses. Please also
see Master Response
3: Buildout and RHNA
for more information.

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Packet Pg. 1170 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 506
C100: Shona Keating, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C100-1 Shona
Keating
3/8/22 I am writing with some input and concerns about the general plan.

The walking path that connects Pacifica is a wonderful asset to all of the communities in our city and so many visitors to our area. I am grateful for its ease of accessibility from nook to neighborhood and all of it’s beautiful views and
stretches in between.

My concerns come from those neighborhoods that are
intersected by the path, and how we can best direct the public's use, with the least impact on the people who live here. My specific concerns are about the verbiage and lack of continuity between areas in the Pedro Point district, that leave room for interpretation as well as some confusion and possible misuse of private properties in this plan. Here is a list of my concerns. The walking path that connects Pacifica is a wonderful asset to all of the communities in our city and so many visitors to our area. I am grateful for its ease of accessibility from nook to neighborhood and all of it’s beautiful views and stretches in between.

1. Pg. 97, LU-I-28 PedroPoint Shopping Center.
“Maintain beach access along Shoreside Drive.”
Shoreside Drive is a privately owned “driveway” that
enables it’s resident’s to access their homes by car and foot, there is no public access point here. I believe the access you are indicating is the San Pedro Creek access at the north east end of the shopping center parking lot. This is the safest, most convenient, least impactful, and only public access South of the San Pedro Creek. The public
(especially visiting Public) should have clear signage
directing them towards this access. By using the terms
"access along Shoreside Drive” you give the impression that there is public access on or at Shoreside Dr.

C100-2 Shona
Keating
3/8/22 LU-I-29 Undeveloped San Pedro Ave site.
"Establish a Coastal Recreational Mixed use zoning district." I am opposed to any rezoning of this property without
further study, updated EIR reports and traffic reports, and neighbors, and until the safety (or lack of) for ingress and egress by current Pedro Point residents is addressed. This is a one way in, one way out community which has been held hostage in the past when a tragedy has occurred. If there is any unforeseen issue, where San Pedro Ave is blocked
The comment is noted. Congestion
is not a required topic for CEQA
analysis and the DEIR correctly
analyzed and mitigated VMT
impacts on pages 3-40 to 3-43.

Comments regarding land use
designations do not pertain to the
adequacy of the DEIR, thus no
further response is required.

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anywhere before Danman Ave, there is no other way out
for a majority of the community. I am concerned about the weight of new development here, the amount of cars and
people this will bring, and how this small area can handle it.

I plea for deep consideration that you listen to and consider all residents of the neighborhood, and for you to truly weigh out and choose the least impactful designation.

However, the comment addresses
the content of the Proposed Project
and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or
SPSP-related responses. See
response to comment C15-2
regarding emergency access.

C100-3 Shona
Keating
3/8/22 Coastal trail
Where is the precise location of this "connection and
improved segment" you refer to throughout this plan? The use of differing names and terminology for the same site and or or landmark is confusing and not suitable language for a City plan to be adopted and be referred to for clarity for years to come. It is equally unclear on the 6-2 Trail System map on pg. 152, way to much room for
interpretation. I have given more detail on these concerns below.D312
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.

C100-4 Shona
Keating
3/8/22 Coastal Trail at Devil’s Slide and Between Pacifica and Devil’s Slide
I am concerned about the verbiage used in connecting the Pedro Point Shopping center path and Devils slide trailhead.

The wording is unclear and image of the trail map 6-2 pg. 152 clearly shows Grand Ave., but not the shopping center.

Are you planning to keep the trail in front of the shopping center where it should stay go bring it behind through
multiple layers of private property and into our residential area? There is no reason to have the trail continue west, through the privately owned shopping center, along the
privately owned Shoreside Drive, through the privately
owned field, to end at San Pedro Ave., and The Anchor Inn.

This is all Privately owned, and the “Colts Property “ section of the Devils slide trail does not begin here, it begins at the South East side of Ace Hardware.

I am with hopes that the trail is developed, crossing
SanPedro Ave., from the ocean side path to the Mountian side trail, where the path nears it’s end and turns towards the ocean. well before Ace Hardware. There is a long
straight-away on the frontage road section of San Pedro ave. here, with a clear view of, and for, all oncoming traffic.

On the Hwy 1 side there is a “No parking” zone, and a well used path under the highway that connects with the Old
Coast Rd. If at this point, there was a crosswalk and
sidewalk created, pedestrians could easily and safely cross over the frontage road in clear view of all oncoming traffic, to access both the Devil Slide and headland trail as well as the Old Coast Road. Please see image below.

C100-5 Shona
Keating
3/8/22 #24 “Improve new segment of coastal trail along former railroad berm.”
The only existing railroad berm ends near the end of
Shoreside Dr. A privately owned drive. This again needs to The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment

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be more clear, are you meaning on the East side of San
Pedro Creek or where the old Fassler house once stood?
There was old railroad berm there at one point but has
eroded to almost beach level. What and where is this “New segment “ you are referring to? This statement leaves much room for interpretation as well as possibly directing the public towards and through private property for no reason.

This trail needs to end at the San Pedro Creek outlet,
thoughtfully dissuading parking in, and trampling through, this single entrance and exit neighborhood. The map seems to show it staying adjacent to Hwy 1, which makes sense however the language does not match the map.
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses. Please also
see Master Response 3: Buildout
and RHNA for more information.

C100-6 Shona
Keating
3/8/22 #24 North Side PedroPoint Shopping Center
#25 Ocean Shore Railroad Berm
This coincides with my concerns stated above. #24 Again you state “ Improve new segment of Coastal Trail along
former railroad berm”. Where exactly are you referring to, the map and description do not match.
#25, "Ocean Shore Railroad Berm", is also referred to as "Shoreside Drive” in other segments of this plan, these two are one in the same, yet the titles are used as if they are different points. This is confusing and lacks continuity and clarity. This land is privately owned and has never had public beach access, but because of the use of “Railroad Berm”, the exact location and section of trail you are
referring to is muddled, leaves room for interpretation.

There is confusion, frustration and sometimes anger from the public, as well as residents, who do not have knowledge and or signage giving them the proper direction to tread lightly, on publicly designated trails and accesses, while respecting and avoiding the privately owned property.

There should not be any new "improved segment" through
privately owned land, although signage is greatly needed.

C100-7 Shona
Keating
3/8/22 Implementing Policies
-Maintenance of Public Coastal Access
Require a public or private entity to be responsible for required public access ways. Until such an entity agrees to be responsible for liability and maintain maintenance of such access ways, they are not required to be open for
public use. Dedicated public access ways should be
designated to provide views as well as access connections or along the shore.

Shoreside Dr. Has been designated as an overlook point, ( I apologize for not having the exact table to give you) which creates overuse and dangerous conditions for the public as well as residents of this privately owned area. The
incredible number of visitors has increased at an alarming, overwhelming rate in the past two years of the pandemic.

The impact on those who live there, most of whom are
elders, has had a chrushing impact to their emotional and mental health, as well as creating a physically dangerous situation for them as well as the general public. People climbed up and between houses, used the private decks
and paths as bathrooms, allowed kids and dogs to run
THROUGH the homes and yards, left litter, dangerously
The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses. Please also
see Master Response 3: Buildout
and RHNA for more information.

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Packet Pg. 1173 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 509
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parked and blocked the one way narrow dirt driveway,
preventing our ingress/egress. We were vocal to the city during that time, and were given cones and temporary
signage to alert visitors and protect the property with.

These measures were respected by only a small few. We
were also asked by Pacifica PD, during beach closures, to try and eliminate any arteries of access that might be used to get to the beach in order to support their efforts. This has been and continues to be a constant struggle.

The families who live her, should not be required or "be responsible for liability and maintain maintenance” of this area for the pleasure of others many of whom are
completely unaware others who feel entitled to its use.

Please do not advertise this as a public area.

Thank you for this opportunity, let's keep our residents and visitors on our beautiful trails, off private land and keep them, and the property owners safe.

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Packet Pg. 1174 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 510
C101: Christine Boles, 1/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C101-1 Christine Boles 1/11/2
2 Could you please forward a copy of the instructions to the State Clearinghouse, OPR along with the distribution list to responsible and optional agencies that will be reviewing the City's DEIR? The NOC is available
on the State
Clearinghouse website,
which includes a list of
reviewing agencies.

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Packet Pg. 1175 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 511
C102: Patricia R. McGregor, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C102-1 Patricia R.

McGregor
2/11/22 I am writing to you again to ask that the time to review and accept comments on the General Plan be extended beyond the February 21st deadline. I, and several others, need more time to read all of the large amount of material.

The public comment
period was extended
until March 8, 2022 to
allow for additional
public review time.

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Packet Pg. 1176 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 512
C103: Alex Strachan, 1/19/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C103-1 Alex
Strachan
1/19/22 Hello, First off, the document is pretty hard to navigate. If you need help putting together hyperlinked documents, i'm more than willing to help.

Please see response to
comment C62-8.

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Packet Pg. 1177 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 513
C104: Penelope Keating, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C104-1 Penelope
Keating
3/8/22 The Old Railroad Berm also known as Shoreside Dr. is a privately owned driveway that is of a delicate
(though gritty) nature and cannot serve the greater
general public without safety issues as well as
degradation to either the public or this somewhat
frail area.

Particularly through the pandemic but also growing
due to other trends, the south end of San Pedro
Beach has been overwhelmed overt he past several
years. This south end is separated from the Pacifica
State Beach by the San Pedro Valley Creek and is a
rather private and delicate area. The old railroad
berm is merely compacted earth which is subject to
erosion as in crumbling along its edge from end to
end. To direct any of the general public to that area
is to cause unnessessary harm to that area and
potentially to the public encouraged to access it.

No. 25 should not encourage the public to this area.

A small earthen path for the owners of the property
has been abused by a large number of individuals
from all over and even outside the Bay Area.

Neither the City nor the resident’s are willing or
able to take the responsibility of liability and thus
should not be in a public plan. No area of the old
Railroad Berm, Shoreside Dr., should be used for
access or Bluff top viewing due to these issues.

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.

C104-2 Penelope
Keating
3/9/22 I am also against making decisions on use of the Calson Field until traffic challenges are remedied.

Pedro Point is particularly victim to any emergency
especially focused at the entrance/exit to our
hillside area.

The comment is noted. Please see
response to comment C46-31.

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Packet Pg. 1178 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 514
C105: Kathi Porter, 1/19/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C105-1 Kathi Porter 1/19/22 I tried to read the new General Plan, couldn’t really get to any content other than photos. I have heard it can be challenging to navigate once you find some information. We all want what’s best for our city, and need to have some input. Please make corrections so that we all can navigate this very important information.

Please see response to
comment C62-8.

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Packet Pg. 1179 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 515
C106: Debbie Young Lynch, 1/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C106-1 Debbie Young
Lynch
1/17/2
2 I’m trying to read the General Plan and the EIR that the City made available last week. If the goal was to make it as tedious and frustrating to use, mission accomplished. I am trying to do what is right as a resident of Pacifica. The very least you can do is make that a bit easier for us but making it user friendly. No index or search functions? Really? Please correct this and do it in a timely fashion.

There are lots of us interested in being informed on what is in the 1013 page document. I’m still scrolling through it, but there is no reason it should have been made this difficult to navigate.

Please see response to
comment C62-8.

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Packet Pg. 1180 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 516
C107: Ellen Natesan, 3/6/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C107-1 Ellen
Natesan,
PhD
3/6/22 General Comment - DEIR and GP Policy Discrepancies The policies in the General Plan do not always match those in the DEIR. Not only are there textual differences, but the numbering seems to have changed. For example – CO-G-10 appears as a policy about “Other Environmentally Sensitive Areas” on page E70 of the DEIR but also as a policy about “Trees” on page 3.3-34 of the DEIR. CO-I-26 in the DEIR is a “Sanitary Sewer Discharge” policy but CO-I-26 in the General Plan is about “Protection of Biological Resources
with New Development.”
When I inquired about these discrepancies to the Pacifica Planning Department, I was instructed (in an email from Christian Murdoch dated January 29, 2022) to use the Policies in the General Plan as the basis for my comments. My comments below are therefore focused on the versions of the Policies found in the General Plan. Where possible I have attempted to refer to the corresponding policy in the DEIR. All of my comments should also be considered to be comments to the DEIR, except where I specify “General Plan Only.”
These policies will be renumbered
in errata. They do not change
findings of significance.

C107-2 Ellen
Natesan,
PhD
3/6/22 Policy OC-G-5 – Open Space Preservation - DEIR and General Plan Recommended Edits:

Open Space Preservation. Preserve open space that protects natural resources, visual amenities, and public health and safety.

The top priority areas for conservation are beaches, oceanfront bluffs, ridgelines, hillsides areas adjacent to existing open space, and areas that support critical wildlife important habitat for special status and endangered species. See Figure 6-1.

Rationale:

The way this is written it is overly narrow. There are many special status plants, wildlife, and butterflies found in Pacifica with no designated critical habitat. Critical habitat has a specific and narrow legal meaning that would currently only apply to California red-legged frog within the planning area. The intent of this policy should be to protect important habitat for all special status species, whether or not the Fish and Wildlife Service has formally designated critical habitat. The word “critical” should not be used to avoid confusion. Please also see my comments on Policy CO-G-7 below.

C107-3 Ellen
Natesan,
PhD
3/6/22 Policy OC-I-28 - Highway 1 Over-Crossing at Mori Point - General Plan Only
Recommended Edits:

Highway 1 Over-Crossing at Mori Point. Support the development of a new wildlife friendly over-crossing between Shelldance Nursery and Mori Point, in coordination with GGNRA and Caltrans to enhance visitor facilities in Pacifica. Pacifica should also encourage GGNRA and Caltrans to place wildlife barriers at strategic locations in this area to reduce roadkill and risk of wildlife collisions on Highway 1. Underpasses such as the Calera Creek underpass could potentially be modified to improve wildlife passage and connectivity between habitats. Pacifica should encourage Caltrans to improve these structures whenever The comment is not related to the
adequacy of the DEIR, therefore
no further response is required in
the FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses. Please see
Master Response 1: EIR Comments

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Individuals (C)
these road segments are upgraded or replaced. As an interim alternative, strengthen signage and safe connections to the existing Sharp Park Golf Course undercrossing in the East Fairway Park neighborhood.

Rationale:

Highway 1 is a prominent feature running through Pacifica that has heavy traffic which is built at-grade with insufficient safety barriers and insufficient over- and under- passes. Currently, getting across Highway 1 presents dangers to both humans and wildlife. Safety improvements (for both people and wildlife) should be addressed whenever the opportunity presents itself, which is most likely to be when Caltrans is doing maintenance or upgrades. A safe crossing allowing people to safely cross Highway 1 and connect trails above Shelldance Nursery and Mori Point is urgently needed. It is likely that such a structure could be made in a way to be useable to at least some wildlife, particularly larger mammals. Pacifica should work with Caltrans and encourage them to identify the most dangerous areas (Mori Point being a good example of this) and install safe crossing structures for people and wildlife.
for more information about GP- or
SPSP-related responses.

C107-4 Ellen
Natesan,
PhD
3/6/22 Policy CO-G-7 - Protect Habitat for Special Status Wildlife - DEIR and General Plan
Recommended Edits:

CO-G-7 Protect Habitat for Special Status Wildlife and Critical Habitat. Conserve and protect indigenous threatened,
endangered, and other special status species by preserving critical habitat that is important for the protection of these species. 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.

Rationale:

The term “critical habitat” has a specific regulatory meaning, namely, habitat that has been designated as critical habitat by the United States Fish and Wildlife Service. Many special status wildlife species, including those listed as threatened or endangered by the Fish and Wildlife Service and California Department of Fish and Game, do not have designated critical habitat. Currently, the only species with critical habitat designated in the project area is California redlegged frog.

California red-legged frog is definitely not the only special status species in Pacifica with a need for habitat protection. The intent of this policy should be to protect important habitat for all special status species, and so the term “critical habitat” should not be used to avoid confusion.

C107-5 Ellen
Natesan,
PhD
3/6/22 Policy CO-G-10 – Trees – DEIR and General Plan (note also appears as Policy CO-G-9 in DEIR)
Recommended Edits:
*NOTE – this policy should be edited in both the DEIR and General Plan. The numbering seems to be incorrect in the DEIR and so the numbers should also be updated in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure
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

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consistency between the two documents.

CO-I-10 Trees. Conserve trees and encourage native forestation and planting of appropriate trees and vegetation in areas identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan. In areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan, limit planting of trees to riparian areas or other areas known to have historically supported trees, to avoid impacts to special status plant and animal habitat, to non-tree dominated plant
communities (such as prairie, chaparral, and wetlands), and to the invertebrates and wildlife that depend on these habitats.

Rationale:

In general, the trend on the San Francisco Peninsula has been towards increased afforestation rather than deforestation. Most of the region’s sensitive and special status species depend on grassland and shrubland communities, which are being lost through time to afforestation. Planting trees (even native trees) should be considered an impact except in the narrow
circumstances of urban planting or planting in areas known to historically support trees. For more background information on these ecological trends see the Peninsula Watershed Historical Ecology Study here:
https://www.sfei.org/documents/peninsula-watershed-historicalecology-study Response 1: EIR Comments for
more information about GP- or
SPSP-related responses.

Numbering of policies in the DEIR
will be corrected in a redline
version.

C107-6 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-1 - Creek Protection and Restoration - DEIR and General Plan
Recommended Edits:
*NOTE – The edits below are to the version of Policy CO-I-1 in the General Plan which is different from the version of Policy CO-I-1 in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.

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

Numbering of policies in the DEIR
will be corrected in a redline
version.

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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. A Qualified Hydrologist with professional experience evaluating natural creek geomorphology shall evaluate the potential for impacts in coordination with a Qualified Biologist with professional experience evaluating the riparian and freshwater aquatic ecosystems found in the project area. This analysis shall be provided in writing and shall consider impacts to creek form and function, aquatic species, and to riparian habitat. 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.

Rationale:

Analysis of potential for impacts of a development adjacent to a creek channel should be performed by someone with knowledge and experience analyzing creek hydrology and geomorphology. A biologist alone would not be able to predict the changes to creek form and
function which will drive any biological impacts. A biologist however is needed to understand potential for impacts to special status species, riparian communities, and creek aquatic habitats.

The results of the analysis should be available in the form of a report or memo to staff, Planning Commission, and the public.

C107-7 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-11 - Protect Water Quality through Best Management Practices - DEIR and General Plan
Recommended Edits:

CO-I-11 Protect Water Quality through Best Management
Practices. Continue to require the use of best management practices to reduce water quality impacts from construction and development. Measures include:
• Site Design and Source Control. Ensure that all new
development incorporates site design and source control BMPs into the project design in order to pre- serve the infiltration, purification, and retention functions of each site’s natural drainage systems, and to prevent or minimize the runoff of pollutants, sediments, waste, and pathogens from the site. • Construction Pollution Control. Require all construction projects to adopt measures to avoid when possible, or minimize erosion and runoff of pollutants and sediments from construction-related activities, and to limit activities that result in the disturbance of land or natural vegetation.
• Construction projects will be required to use appropriate erosion prevention techniques, sediment control measures, and best management practices in accordance with City specifications and the San Mateo Countywide Water Pollution Prevention Program.
• Treatment Control. Require that new development implement treatment control BMPs (or structural treatment BMPs) where As noted on DEIR p. 3.5-20,
"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." The DEIR describes how
"adherence to the Construction
General Permit under the NPDES
program would require that a
SWPPP with best management
practices (BMPs) be prepared for
construction sites; it would include
measures to protect water quality
of stormwater that is discharged

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the combination of site design and source control BMPs is not sufficient to protect water quality and comply with applicable water quality permits.
• Site Design and Source Control. Ensure that all new
development incorporates site design and source control BMPs into the project design in order to preserve the infiltration, purification, and retention functions of each site’s natural drainage systems, and to prevent or minimize the runoff of pollutants, sediments, waste, and pathogens from the site. • Runoff Capacity Management: Ensure that new developments do not cause flooding for communities downstream. Evaluate downstream drainage capacity for runoff that cannot be captured on-site during large storm events (100 year storms). If a development will increase peak runoff volumes during large storms (because of increased impervious surfaces or other factors), downstream capacity improvements should be part of the project, using a design standard of 100 year storm.

Stormwater treatment systems must meet the numeric sizing criteria established in the NPDES Permit, and must be operated and maintained in compliance with the NPDES Permit.

Rationale:

New developments should not cause downstream flooding. For example, new developments in the San Pedro Creek watershed should consider flooding at Adobe Drive, which is already prone to flooding during large storm events. The water conveyance capacity at Adobe Drive should be increased as a part of any new development project that would increase peak runoff to prevent the project from causing flooding in the neighborhood in the vicinity of Adobe Drive and San Pedro Creek. When undersized water conveyance structures like this are overtopped during storms, there is increased risk to the creeks of streambank failures, sedimentation, and a flush of contamination (such as from motor oil, tire wear particles, and litter) washing into the creeks.

Climate change is expected to increase the frequency of atmospheric rivers and high intensity precipitation events and so designing to a 100 year storm standard is a bare minimum. This measure might be more appropriate as a standalone new
mitigation/policy.
offsite and practices to limit
erosion or unintentional releases
of hazardous materials used
during construction. Additionally,
any development that would occur
under the Proposed Project would
be subject to the erosion and
runoff control provisions described
in the regional Basin Plan."
It also describes how " in general,
existing local stormwater
management plans and policies,
and State Water Board
regulations, which implement
federal Clean Water Act
requirements, would prevent
these potential impacts from rising
to a level of significance under
CEQA through requirements that
minimize the creation of pollution
generating surfaces. Clean Water
Act Section 402 NPDES MS4
Permit, which covers many Bay
Area jurisdictions including the
City of Pacifica, requires
stormwater management plans,
which in turn require source and
treatment control measures. In
many cases, as part of the NPDES
program to reduce the severity of
impacts, stormwater drainage
control/Low Impact Design (LID)
measures may be required as
standard conditions of approval
and building permit application
submittals, along with compliance
with RWQCB Municipal Regional
Stormwater Permit Order No.
2011-0083 Provision C.3 (Provision
C.3).

Site-specific stormwater
management planning is also
required, as noted on DEIR p. 3.5-
30 and 3.5-31: "The increasing
incorporation of stormwater
management in site planning [as
described in policy CO-I-16] will
further reduce the need for
development of new storm
drainage infrastructure." Finally,
the DEIR notes on p. 3.5-31 that
"flood flows may change over the
horizon of the Proposed Project
due to sea level rise caused by

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climate change; the proposed
General Plan includes policies from
the Local Coastal Land Use Plan
which commit to using the best
available science to plan for sea
level rise, as well as continuing to
monitor and map changes in flood
flows and high water marks." Thus,
the impact remains less than
significant.

C107-8 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-26 – Protection of Biological Resources - General Plan and DEIR (see Policy
CO-I-27 in DEIR)
Recommended Edits:
*NOTE –This Policy does not appear in the DEIR (and it should), however Policy CO-I-27 in the DIER may be an earlier version of this policy. This policy should be added to the DIER. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure
consistency between the two documents.

CO-I-26 Protection of Biological Resources with New
Development or Other Earth Disturbing Projects. 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 habitat during the development review process in a manner consistent with Policy CO-G-7.

2. Pre-construction Conduct plant and wildlife surveys prior to vegetation clearing or earth disturbing activities: Project applicants shall engage a qualified biologistQualified Botanist and Qualified Wildlife Biologist (as defined below) 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 identifiedcommencement of work in areas not identified as “Urban and Non Urban with Little or No Habitat Value” 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, dusky footed woodrat nests, sensitive plant communities, special status plants, and sensitivespecial status butterfly host plants, wetlands, or other sensitive and special
status natural resources to avoid disturbance and direct impacts to these resources during construction. If no special status species or plant communities are detected during surveys, then construction-related or earth disturbing 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. Incorporate bird, bat, and wildlife impact avoidance measures into vegetation removal activities. Prior to felling, prune trees to increase detectability of nesting birds, and disturb trees (eg. with 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.

Numbering of policies in the DEIR
will be corrected in a redline
version.

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axe or chainsaw) and then observe for 10-15 minutes. Near San Francisco garter snake or California red-legged frog habitat, tall vegetation can be cut to 1 foot in height to improve visibility for biologists and encourage wildlife to move out of the area, and then cleared to the ground.

4. Require biological resource assessments be conducted prior to approval for any development within 300 feet of creeks, wetlands, or other areas not identified as “Urban and Non Urban with Little or No Habitat Value” sensitive habitat areas shown on Figure 7-3 of the proposed General Plan.

5. Require on-site monitoring of biological resources by a qualified biologist throughout the duration of construction activity.

5.6.For projects taking place in areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan, require that equipment arrive on site for construction visibly clean of dirt and organic matter to minimize the risk of introducing new plant pathogens, pests, or invasive plants to the area.

Prior to approval and prior to any earth disturbance, grading, grubbing, vegetation clearing, staging or other temporary or permanent project-associated impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3, a Qualified Botanist will conduct pre-project botanical surveys to determine the potential for impacts to special status plants, plant communities, or special status butterfly (such as Mission blue butterfly) host plants. The Qualified Botanist shall conduct botanical field surveys in a manner which maximizes the likelihood of locating special status plants and sensitive natural communities that may be present. The botanical survey must take place during the appropriate season during which the target species can be readily detected and accurately identified.

Botanical surveys should generally take place while target plants are in bloom. Multiple years of surveys may be required to accurately assess the location of or determine the absence of short-lived plant species or plants species with a persistent seed bank. Botanical field surveys should be floristic in nature, meaning that every plant taxon that occurs in the project area is identified to the taxonomic level necessary to determine rarity and listing status.

A Qualified Botanist must meet the following requirements:
• Knowledge of plant taxonomy and natural community ecology; • Familiarity with plants of the region, including the plants targeted for survey and any special status plants (or host plants of special status insects) that may occur in the survey area; • Familiarity with natural communities of the region, including California Sensitive Natural Communities;
• Experience with the CNDDB, BIOS, and Survey of California Vegetation Classification and Mapping Standards;
• Experience conducting floristic botanical field surveys; • Familiarity with federal, state, and local statutes and regulations related to plants and plant collecting; and • Experience analyzing the impacts of projects on native plant species and sensitive natural communities.

If a project will involve earth disturbance, grading, grubbing, staging or other temporary or permanent impacts to areas not

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mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the General Plan, a Qualified Wildlife Biologist will survey for special status wildlife species and their habitat. A qualified wildlife biologist must be familiar with identification of essential physical and biological features for special status wildlife species, including space for individual and population growth and for normal behavior; cover or shelter; food, water, air, light, minerals, or other nutritional or physiological requirements; sites for breeding and rearing offspring; and habitats that are protected from disturbances or are
representative of the historical geographical and ecological distributions of the species.

A Qualified Wildlife Biologist must meet the following
requirements:
• Demonstrated professional experience identifying all of the target wildlife species at all life history stages;
• Experience and knowledge of the natural history, habitat affinities and wildlife species needs;
• Familiarity with federal, state, and local statutes and regulations; and
• State and federal handling permits (as needed).

C107-9 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-27 - Page E-65 of DEIR and Page 7-26 of General Plan Recommended Edits:
*NOTE – The edits below are to the version of Policy CO-I-27 in the General Plan which is different from the version of Policy COI-27 in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.

CO-I-27 Verification of Environmentally Sensitive Habitat Areas (ESHA) within the Coastal Zone and identification of sensitive habitats or special status species that should be protected outside of the Coastal Zone. Prior to any proposed development or other earth disturbing project in an ESHA or potential ESHAin areas not identified as “Urban and Non Urban with Little or No Habitat Value” Figure 7-3 of the proposed General Plan, require that a habitat survey be conducted by a Qqualified Bbotanist or Qualified Wildlife Bbiologist. The habitat survey will verify whether the site is an ESHA or has special status under CEQA, and document the extent of the sensitive resources, document potential negative impacts to the habitat, and recommend appropriate mitigation measures. Verification of an ESHA or special status plant communities, plant or animal species, or habitat 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 a designation of 1B (rare or endangered in California or elsewhere) or 2 (rare, threatened, or endangered in California, but more common 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.

Numbering of policies in the DEIR
will be corrected in a redline
version.

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elsewhere) by the California Native Plant Society.
• Presence of coastal waterways.
• Presence of drainages or wetlands.
• Integrity of the habitat and its connectivity to other natural areas.

If a project will involve earth disturbance, grading, grubbing, staging or other temporary or permanent impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the General Plan, a Quali ied Wildlife Biologist will survey for special status wildlife species and their habitat. A qualified wildlife biologist must be familiar with identification of essential physical and biological features for special status wildlife species, including space for individual and population growth and for normal behavior; cover or shelter; food, water, air, light, minerals, or other nutritional or physiological requirements; sites forbreeding and rearing offspring; and habitats that are protected from disturbances or are representative of the historical geographical and ecological distributions of the species.

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A Qualified Wildlife Biologist must meet the following
requirements:
• Demonstrated professional experience identifying all of the target wildlife species at all life history stages;
• Experience and knowledge of the natural history, habitat affinities and wildlife species needs;
• Familiarity with federal, state, and local statutes and regulations; and
• State and federal handling permits (as needed).

Rationale:

This policy is currently redundant to CO-I-31 and CO-I-26. It probably would make sense to combine these, however, if it is required to have a separate policy specific to ESHA under the Coastal Act, I have added the same recommended language to both CO-I-26 and CO-I-27. Preproject (and pre-approval) biological survey requirements should be the same inside and outside of the Coastal Zone in Pacifica since special status species and plant communities have high potential to occur in Pacifica both within and outside of the Coastal Zone. Figure 7-3 of the General Plan is an appropriate figure to use, and all of the areas not mapped as “Urban and Non- Urban with Little or No Habitat Value” have sufficient potential for rare and special status species and their habitats to require a biological survey.

Any earth disturbing activity, and even off-road access in some cases, has the potential to damage or destroy sensitive habitat and species. For example, Mission blue butterfly is on or near its host plants in some life stage year-round, even when the host plant is dormant, low to the ground, and difficult to detect. “Take” of this endangered species could occur by any activity that would crush or destroy the host plants. Earth disturbing activities also have the potential to destroy the seed bank of special status plant species. Pacifica should consider any earth disturbing project-related activities to require biological surveys prior to authorization.

Planners and project applicants should be aware that biological surveys for special status plants and butterfly host plants often have a seasonally narrow window during which they can take place and plan accordingly. For example, Western leatherwood (Dirca occidentalis) a CRPR 1B.2 shrub found in Pacifica, is generally difficult to identify outside of January or February, while some grassland annual plants may not be identifiable until mid-summer. A project proposed in late-summer without
biological surveys in hand may need to wait until the following summer so that surveys can be completed. Anticipating this need and performing surveys proactively will prevent project delays and reduce frustration on the part of applicants. A
coordinated voluntary program for private landowners to pay into and participate in a coordinated larger-scale biological resource survey would be very valuable. Qualifications for a Qualified Botanist and Qualified Wildlife Biologist should be spelled out explicitly since the effectiveness of this Policy hinges on the professional qualifications of these individuals.

For additional supporting information see:

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https://www.cnps.org/wp-content/uploads/2019/10/BotCert_2018-CDFW-Plant-and-Vegetation-Survey-Protocols-LR.pdf C107-
10 Ellen
Natesan,
PhD
3/6/22 CO-I-32 – Monitoring Requirements – General Plan and DEIR (not found in DEIR)
Recommended Edits:
*NOTE – This policy is an extremely important component of impact reduction and it should be added as a mitigation requirement to the DEIR.

CO-I-32 - Restoration and Monitoring Requirements. Require a Restoration and Monitoring Proposal for any proposed habitat restoration or mitigation. The Proposal should describe the methods and practices to be employed, and include:
• A clear statement of the goals of the restoration or mitigation for all habitat types;
• Sampling of reference habitat, with reporting of resultant data; • Designation of a qualified biologist as the Restoration or Mitigation Manager responsible for all phases of the restoration; • A specific grading plan, if the topography must be altered; • A specific erosion control plan, if soil or other substrate will be disturbed during restoration, which should utilize erosion control materials free of invasive species (including invasive plant seeds), plastic microfibers and materials that are free of weed seeds, pests, pathogens, and other invasive species;
• An invasive species introduction avoidance plan to minimize introduction of new weeds, pests, or pathogens to the site. This should include
- a plan to clean equipment and vehicles before they arrive on site, and inspections to confirm that equipment and vehicles are free of soil, organic material, and vegetative debris prior to entering the work site,
- a plan to reject seed lots that contain invasive species that are not already present on the site or adjacent areas so they will not introduce new invasive species to the area, and
o a plan to require that all imported organic materials such as mulch, compost, and erosion control materials be free of new invasive species including invasive plants, animals, pests, or pathogens;
• A weed eradication plan designed to eradicate existing a specified list of target weeds (non-native invasive plant species expected to interfere with the restoration goals such as all CalIPC high and moderate species that form monocultures) and control future invasion by exotic species maintaining target invasive plant cover below 5% total
absolute cover site-wide of target invasive plant species (unless restoration goals or reference sites justify a higher percent cover);
• A planting plan based on the natural habitat type using seeds wherever possible and using best management practices for avoiding introduction of plant pests and pathogens if container plants must be used;
• An irrigation plan that describes the method and timing of watering and ensures removal of watering infrastructure by two years prior to the end of the monitoring period;
• An interim monitoring plan with annual reporting and a 5 year The comment requests that the
noted policy be added as a
mitigation requirement. The
policy will be added to the DEIR
Impact 3.7-1 as a policy that
reduces the impact and does not
need to be added as a mitigation
measure. The addition of this
measure would not change
findings of significance and would
only serve to amplify conclusions
of "less than significant" for
potential biological resource
impacts.

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minimum reporting period with performance goals, assessment methods, and a schedule; and
• A final monitoring planperformance criteria to determine whether the restoration has been successful.

Rationale:

Restoration is an extremely important component of impact mitigation and this measure should be robust (and in the DEIR!).

Ecological restoration is complex and difficult and if done poorly, not only will fail, but can actually have significant impacts to surrounding natural areas. Incorporating the specific added guidance I suggest above into the DEIR will help these restoration projects be successful.

Many erosion control materials contain plastics. The natural fibers in these materials degrade, while the plastic fibers do not.

These bundles of loose plastic fibers pose wildlife entrapment hazards for special status and non-special status wildlife. For more information see:
https://documents.coastal.ca.gov/assets/waterquality/permits/WildlifeFriendly_Netting_in_Erosion_&_Sediment_ControlFactsheet_r5_Sept_2016.pdf Not all invasive species can be controlled, for example, some CalIPC high and moderate nonnative perennial grasses generally grow intermixed with native plant species in such a way that controlling them could be excessively destructive and undermine the success of a restoration project. Non-native invasive plant species should be selected for control depending on
controllability, presence in San Mateo County (not just the site), and the restoration goals. Once selected, presence of these target species should be maintained so that the sum-total of the absolute cover by all target invasive plant species is less than 5% absolute cover. This is an achievable objective that keeps the seed bank, rhizomes, or other propagules of invasive plant species sufficiently under control so that the native plant species have room to become established.

To make sure the restoration plantings are self-sustaining, the irrigation should be stopped 2 years before the end of the performance monitoring period. Although I did not include this in the Policy as an edit, there should also be some restriction on replacement planting or re-seeding efforts during the final years of the performance monitoring period to ensure that the site is selfsustaining, however, you don’t want to disallow replanting completely since it can be a valuable site management strategy that improves outcomes.

Introducing a new invasive plant species, plant pest or pathogen to a restoration site has the potential to not only undermine the success of the restoration project but devastate surrounding natural areas. Planting should be done using direct seeding (not rooted plants) as much as possible to avoid unintentional introduction of invasive species. Imported materials should be free of invasive species to the degree possible as well and

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equipment and vehicles should be inspected as they arrive on site and only allowed to enter if they are free of organic matter. Also see my comments on CO-I-36 below.

Best management practices for avoiding spread of plant
pathogens during restoration projects
can be found here:
http://www.suddenoakdeath.org/welcome-to-calphytos-orgphytophthoras-in-nativehabitats/#WG More information about how restoration activities have
introduced destructive plant pathogens into natural areas in California and the Bay Area can be seen here:
https://www.mdpi.com/1999-4907/11/12/1291
C107-
11 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-36 – Minimizing Introduction of Invasive Plant Species Through Plantings (see CO-I-38 of DEIR)
CO-I-36 Minimizing Introduction of Invasive Plant Species Through Plantings. Encourage planting of locally appropriate native plants directly from seed. If direct seeding is not possible, encourage sourcing of plants from nurseries which use
techniques that minimize the risk of accidental introduction and spread of invasive species (such as, plant pests, plant pathogens, and invasive insects). Prohibit the use of invasive plant species (i.e., any California Invasive Plant Council (Cal- IPC)-listed species with a status of high or moderate, or identified such as locallythreatened under the limited, alert, or watch status).

Rationale:

Planting rooted plants grown in containers is a surprisingly risky activity. It is easy to accidentally introduce and spread invasive species. Invasive species that can move in plant containers include plant disease, plant pests, and other invasive invertebrate species. For example, Argentine ants thrive in plant nurseries and while they don’t attack plants, they do displace native ants where they are introduced.

Use of container plants in restoration has been documented as an introduction pathway for plant pathogens in California and the Bay Area. For more information see Phytophthora Introductions in Restoration Areas: Responding to Protect California Native Flora from Human-Assisted Pathogen Spread at the link below:
https://www.mdpi.com/1999-4907/11/12/1291
Best practices for avoiding spread of plant pathogens during restoration projects can be found here:
http://www.suddenoakdeath.org/welcome-to-calphytos-orgphytophthoras-in-nativehabitats/#WG 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.

C107-
12 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-37 – Beach Grooming – DIER and General Plan (See DEIR CO-I-39)
Recommended Edits:

Note: The numbering seems to be incorrect in the DEIR, the numbering in the DEIR should be updated to reflect the
numbering in the General Plan
These inconsistencies are
corrected in errata. These
clarifications do not change
findings of significance in the DEIR.

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C107-
13 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-37 – Beach Grooming. Work with the State of California, GGNRA, and other partners in the management of beaches in Pacifica to ensure biological resources are NOT adversely affected by beach grooming. Specifically, protect beach wrack (the piles of plant and animal debris that wash ashore), which plays an important role in the beach ecosystem.

Rationale: This appears to be a typo.

This comment is noted. The policy
text edit mentioned in the
comment is not required.

DEIR p. 3.12-58: "CO-I-39 Beach
Grooming. Work with the State of
California, GGNRA, and other
partners in the management of
beaches in Pacifica to ensure
biological resources are not
adversely affected by beach
grooming. Specifically, protect
beach wrack (the piles of plant and
animal debris that wash ashore),
which plays an important role in
the beach ecosystem."
C107-
14 Ellen
Natesan,
PhD
3/6/22 Policy SA-I-95 DEIR and General Plan
Recommended Edits:

Plan Review in Fire-Prone Areas. Continue to request the North County Fire Authority participation in plan review of new buildings in potentially fire-prone areas. New construction in fire prone areas shall be required to incorporate appropriate additional fire protections to minimize risk of fire and to minimize the need for fuel reduction, vegetation clearing, and destruction of habitat in adjacent wildland areas. Potentially fire prone areas are shown in Figure 8-7 of the General Plan.
*NOTE – Figure 8-7 of the General Plan must be updated to show the fire hazard throughout the study area (for more information see my comment on Figure 8-7 below).

Rationale:

It should be clear to planners when this measure should be implemented. A map would be the clearest way to show what areas are potentially fire prone and where Policy SA-I-95 would be applicable and required. Requiring new structures to be designed to be as fire resistant as possible would protect surrounding open space areas and reduce potential future cost to Pacifica (and society more broadly) in two ways:
(1) by reducing the likelihood that structures are a source of ignition and cause of a-seasonal, overly frequent, or otherwise unnatural wildfire, and
(2) by reducing the need to remove fuels (plants) from natural areas to protect structures. Fuel breaks are expensive to maintain, of limited efficacy in many situations, and can be destructive of natural habitats. It is better to build new structures to resist and withstand fire.

C107-
15 Ellen
Natesan,
PhD
3/6/22 San Pedro Creek watershed – Page 3.5-4 of DEIR
Recommended Edits: Please add two more special status fish species to the list for San Pedro Creek
• Pacific lamprey (Entosphenus tridentatus) which is a CDFW Species of Special Concern and is mentioned in the General Plan as being present in San Pedro Creek; and
• northern tidewater goby (Eucyclogobius newberryi) which has been detected in San Pedro Creek (Sutter and Kinziger, 2019) and The comment is noted. The
following clarification is thereby
made in the first paragraph on
page 3.7-14: "Fish species that
may be present, as identified by
the San Pedro Creek Conservancy,
include the prickly sculpin (Cottus
asper), the Pacific lamprey
(Lampetra tridentate), and the

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is listed as Endangered under federal ESA by the Fish and Wildlife Service
threespine stickleback
(Gasterosteus aculeatus)."
However, no records of these fish
have been identified in the CNDDB
database at time of survey (June
2021).

This clarification does not change
findings of significance in the DEIR.

The Pacific lamprey is also not
identified in an updated May 2022
CNDDB survey.

No occurrences of northern
tidewater goby were identified at
the time of CNDDB survey, or in
updated CNDDB data from May
2022. The commenter makes
reference to a 2019 study; official
guidance from the US Fish and
Wildlife Service Tidewater Goby
Survey Protocol
(https://www.fws.gov/sites/defaul
t/files/documents/surveyprotocol-for-tidewater-goby.pdf) did not recognize eDNA as a
recommended survey.

San Pedro Creek is designated as a
potential ESHA. While the
compliance with federal, state,
and local regulations for sensitive
biological resources such as the
Pacific lamprey and northern
tidewater goby, including FESA,
CESA, and the Coastal Act. The
beneficial impacts of Proposed
Project policies to protect and
restore creeks (CO-I-I), preserve
wetlands (CO-I-4), maintain
biological activity (CO-I-38), verify
and manage ESHA (CO-I-27 and
CO-I-28), preserve habitat (CO-I31), requirement of a Restoration and Monitoring Proposal for an
proposed habitat mitigation (CO-I32), and protection of biological resources with new development
(CO-I-26), which would require
biological resource assessments to
be conducted for any
development within 300 feet of
creeks would reduce impacts to
less than significant.

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C107-
16 Ellen
Natesan,
PhD
3/6/22 Annual Grasslands - Page 3.7-2 of DEIR and Page 7-16 of General Plan
Recommended Edits:

Annual Grasslands
Annual Grasslands in Pacifica often occur most often in a mosaic pattern with coastal scrub and are dominated by non-native annual grass species and a variety of other non-native weeds. The presence of these grasslands in Pacifica is limited and generally occurs in highly disturbed areas. Damage to grasslands is a result ofSome of Pacifica’s grasslands have been damaged by
unauthorized vehicle activity, which resulting in off-road trails on hillsides. Many of Pacifica’s grasslands contain a mix of native and non-native grasses and forbs. Although some of the grasslands in Pacifica have been highly disturbed, other grasslands within Pacifica are known to support red fescue (Festuca rubra) prairie, and intact stands of California fescue (Festuca californica), needle grass (Stipa pulchra), Pacific reed grass (Calamagrostis nutkaensis), and blue wild rye (Elymus glaucus). The grasslands and prairies within Pacifica are also known to support a number of special status rare plant species. The grassland communities in Pacifica have not been surveyed extensively, however, grasslands in coastal California are known to support a high native component of native perennial grass species relative to inland California grasslands.

Grasslands provide essential basking, foraging, and sheltering habitat for reptiles and amphibians including the federally protected (Threatened) California red-legged frog, and state and federally protected (Endangered) San Francisco garter snake.

Grassland communities with higher proportions of native species support more complex biological community of insects, over a wider range of seasonal conditions, and are therefore a better source of food for insectivorous wildlife such as adult California red-legged frog and Sierran tree frog, which are both important prey species for the San Francisco garter snake.

Rationale:

Referring to the grasslands within the study area as “annual” and “highly disturbed” presumes a low ecological value that is misleading and inaccurate. Pacifica’s grasslands and prairies, like almost all of California’s grasslands, do contain non-native annuals, however, many of these areas within Pacifica contain a significant component of native grassland and forb species. The grasslands and prairie in Pacifica provide essential refugia for native, rare, and special status grassland plant species in addition to habitat for special status wildlife.

For more information about the relative importance and rarity of grasslands in California, please also see the California Native Grassland Association (CNGA) website which points out, “To date, our state has already lost 99% of our native grasslands. With only 1% of our native grassland remaining statewide it is critical that we protect every remaining acre.”
https://cnga.org/Conservation#:~:text=The%20California%20Nati ve%20Grassland%20Association,UC%20Santa%20Cruz%20East%2 0Meadow.&text=To%20date%2C%20our%20state%20has,99%25
The comment is noted. Please see
response to comment C1-7.

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Packet Pg. 1196 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 532
Letter Commenter Date Comment Combined Response
Individuals (C)
%20of%20our%20native%20grasslands
In the absence of a complete survey of existing grasslands within the study area, this DEIR should not assume the absence of remnant patches of special status grasslands (CDFW designated California Sensitive Natural Communities) or special status native grassland and for species.

Grasslands typically are complex and can contain within them mosaic patterns at a very fine scale that can only be detected through appropriately timed botanical surveys in the field.

Grassland communities with a native component should be prioritized for protection when possible over communities that are exclusively non-native.

The following species are ranked as California Rare Plants in CalFlora and are present or likely to be present in Pacifica.

Although these species are mostly only documented in protected areas of Pacifica, the lack of observations in unprotected areas are likely due to lack of surveys rather than lack of actual presence on privately owned lands.

1. Centromadia parryi ssp. parryi, a dicot, is an annual herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 1B.2 (rare, threatened, or endangered in CA and elsewhere). Present Mori Point, Aramai Point

2. Chorizanthe cuspidata var. cuspidata, a dicot, is an annual herb that is native to California, and endemic (limited) to California.

California Rare Plant Rank: 1B.2 (rare, threatened, or endangered in CA and elsewhere).

3. Leptosiphon rosaceus, a dicot, is an annual herb that is native to California. California Rare Plant Rank: 1B.1 (rare, threatened, or endangered in CA and elsewhere).

4. Silene scouleri ssp. scouleri, a dicot, is a perennial herb that is native to California, and also found elsewhere in western North America. Present PPH California Rare Plant Rank: 2B.2 (rare, threatened, or endangered in CA; common elsewhere)

5. Arabis blepharophylla, a dicot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.3 (limited distribution). Present PPH* and Milagra Ridge

6. Erysimum franciscanum, a dicot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.2 (limited distribution) Present PPH* and Milagra Ridge

7. Piperia michaelii, a monocot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.2 (limited distribution). Present PPH* and Aramai Point
See also Appendix below for a list of native grassland species that have been observed in Pacifica and documented in the iNaturalist database.

C107-
17 Ellen
Natesan,
PhD
3/6/22 Vegetation Map - Figure 3.7-1 - Page 3.7-4 of DEIR & Figure 7-2 on Page 7-15 of General Plan
Recommended Edits:

The comment is noted. Please see
response to comment C1-7 .

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Packet Pg. 1197 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 533
Letter Commenter Date Comment Combined Response
Individuals (C)
Change the label on the legend and map from “Annual
Grasslands” to “Grasslands/Prairie.” Update the landscape and vegetation map using recent GIS layers available for San Mateo County through the Fine Scale Vegetation Map and Landscape Database Project. See links and explanation below.

Rationale:

The term “Annual Grasslands” is an inaccurate and misleading title for the grasslands and prairie in the study area. Pacifica’s grasslands and prairie, like almost all of California’s grasslands do contain non-native annuals, however, many grasslands within Pacifica contain remnant patches of native grassland
communities, as well as individual native grassland and forb species. These grasslands are essential refugia for native, rare, and special status grassland species. Re-labeling to
“Grasslands/Prairie” would be a more accurate label for the grasslands in the study area that reflects our currently incomplete knowledge and the potential for important native biotic communities to occur within these areas.

For more information about the importance of using the correct terminology in CEQA documents for Grassland and Prairie see:

PRAIRIES AND GRASSLANDS: WHAT’S IN A NAME? by Glen
Holstein):
https://cnps.org/wpcontent/uploads/2018/03/FremontiaV39.2_39.3.pdf More accurate mapping data is available for Pacifica as a part of recent work to develop landform and fine scale vegetation maps for San Mateo County. Updating the map with this upto-date data would provide a more accurate and defensible basis for this General Plan and EIR.

For more information and access to this data, please see the websites below.
https://www.nps.gov/articles/vegetation-mapping-projectsunderway.htm https://www.nps.gov/articles/000/new-draft-lifeform-mapavailable-for-san-mateo-county.htm

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Packet Pg. 1198 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 534
Letter Commenter Date Comment Combined Response
Individuals (C)
C107-
18 Ellen
Natesan,
PhD
3/6/22 Comment on the Regulatory Setting (in General Plan and DEIR) Please cross check and update special status of species named in the conservation chapters and include all special status species found in Pacifica. Specific examples include:
• tricolored blackbird is listed as Threatened under California ESA and is mentioned in the General Plan as present in Pacifica but its special status is not mentioned
• Pacific lamprey is a CDFW Species of Special Concern and is mentioned in the General Plan as present in San Pedro Creek but its special status is not mentioned
• monarch butterfly was not mentioned but is a candidate for listing under federal ESA and is likely present in Pacifica • mountain lion is not mentioned and is a candidate species under California ESA
• northern tidewater goby (Eucyclogobius newberryi) has been detected in San Pedro Creek (Sutter and Kinziger, 2019) and is listed as Endangered under federal ESA by the Fish and Wildlife Service and should be mentioned (currently is not mentioned in the General Plan or DEIR)
The tricolored blackbird is
described on DEIR p. 3.7-9. There
no recorded occurrences in the
CNDDB during the time of survey.

The tricolored blackbird will be
added to Appendix D. The General
Plan references this appendix.

Please see response to comment
C107-15 for more information on
the Pacific lamprey.

Monarch butterflies are included
on p. 3.7-21. Please see response
to comment A2-12 for more
information on additional policies
to address monarch butterflies.

No occurrences of mountain lion
were found in the CNDDB. Please
see response to comment A2-10
for more information on additional
policies to address mountain lions.

The northern tidewater goby is
described in Appendix D. please
see response to comment C107-18
for more information about the
northern tidewater goby.

These changes do not represent
significant new information or
change findings of significance in
the DEIR.

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Individuals (C)
C107-
19 Ellen
Natesan,
PhD
3/6/22 Fire Hazards and Public Safety Services - Figure 6.11-3 on page

3.11-4 of DEIR and Figure 8-7 on Page 8-36 of General Plan Recommended Edits:

Please expand the fire hazard mapping to include all undeveloped areas in the plan area. This figure currently has no information about fire hazard outside of the State Responsibility Area, which means there is no information shown for most of the plan area.

This should be corrected. The GIS layers available for San Mateo County through the Fine Scale Vegetation Map and Landscape Database Project include a 5 m fuels model as well as LiDAR slope data. These should be combined to generate a basic fire hazard map for the undeveloped portions of Pacifica. Additional refinements could be added later. This fire hazard map should be calibrated to use similar criteria for hazard classifications used by CalFire so the mapping is consistent throughout the plan area.

This map should be reviewed by the North County Fire Authority prior to finalization. For more information about the 5 m fuels and LiDAR data see links below.
https://www.nps.gov/articles/vegetation-mapping-projectsunderway.htm https://www.nps.gov/articles/000/new-draft-lifeform-mapavailable-for-san-mateo-county.htm 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 (MJ-LHMP) for San
Mateo County. The
characterization in the DEIR
includes a description of
vegetation in the Planning Area, a
history of wildfire occurrence in
the Planning Area, the probability
of a fire occurring in the future,
and identification of Fire Hazard
Severity Zones designated by
CALFIRE based on factors such as
fuel, slope, and weather. Two
maps are included:

Figure 3.11-2, which shows Very
High Fire Hazard Severity Zones for
Local Responsibility Areas (LRAs),
State Responsibility Areas (SRAs),
and Federal Responsibility Areas
(FRAs) as designated by CALFIRE
pursuant to Government Code
Section 51175. By law CALFIRE is
required to designate these Fire
Hazard Severity Zones, land within
which is subject to various
requirements in the California
Building Code for the design and
construction of new buildings
intended to reduce the risk of loss
of life and property, including
requirements for building
materials, defensible space
clearance, and other wildland fire
safety practices; and
Figure 3.14-1, which shows Fire
Threat, a measure of fuel
conditions and fire potential in the
ecosystem, representing the
relative likelihood of “damaging”
or difficult to control wildfire
occurring for a given area. Fire
Threat is not a risk assessment by
itself, but can be used to assess
the potential for impacts on
various assets and values
susceptible to fire. Impacts are
more likely to occur and/or be of

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Packet Pg. 1200 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 536
Letter Commenter Date Comment Combined Response
Individuals (C)
increased severity for the higher
threat classes. Please see Master
Response 5: Wildfire for more
information.

C107-
20 Ellen
Natesan,
PhD
3/6/22 Appendix
Additional native species below are confirmed in Pacifica’s grassland/prairie communities according to iNaturalist, Calflora, and as compiled by *Kramer Botanical, Vascular Plant Species within the Pedro Point Headlands Trail Improvement and
Restoration Project Area, February 2016.
https://www.calflora.org//app/ipl?vrid=ce891&bloom=t
https://www.inaturalist.org/check_lists/3273-Mori-Point-CheckList?iconic_taxon=47126&without%5B%5D=page&without%5B% 5D=q
https://www.inaturalist.org/check_lists/5529-Milagra-RidgeCheckList?iconic_taxon=47126&without%5B%5D=page&without%5B% 5D=q
Native plants commonly present on grassland/prairie in Pacifica Alliaceae Allium dichlamydeum Coast Onion
Anacardiaceae Toxicodendron diversilobum Pacific Poison Oak Apiaceae Angelica hendersonii Henderson's Angelica
The comment is noted. As noted
on DEIR p. 3.7-49, the DEIR used
the California Native Plant Society
Inventory of Rare and Endangered
Plants (online edition, v8-02).

California Native Plant Society.

Sacramento, CA. This database
was accessed on June 11, 2021.

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Packet Pg. 1201 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 537
Letter Commenter Date Comment Combined Response
Individuals (C)
Daucus pusillus American Wild Carrot
Heracleum maximum Cowparsnip
Lomatium utriculatum Lomatium
Sanicula arctopoides Footsteps of Spring
Sanicula crassicaulis Pacific Sanicle
Agavaceae Chlorogalum pomeridianum Wavy-leafed Soap Plant Dipterostemon capitatus Blue Dicks
Triteleia laxa Ithuriel's Spear
Asteraceae Achillea millefolium Common Yarrow
Anaphalis margaritacea Pearly Everlasting
Centromadia parryi ssp. parryi Papoose Tarplant 1B.2
Cirsium occidentale Cobweb Thistle
Circium quercetorum Brownie Thistle
Grindelia stricta Pacific Gumplant
Lasthenia californica Goldfields
Lasthenia minor Coastal Goldfields
Layia platyglossa Tidytips
Madia sativa Coast Tarweed
Pseudognapthalium californicum California Cudweed
Pseudognaphalium ramosissimum Pink Everlasting
Solidago velutina ssp. californica Goldenrod
Symphyotrichum chilense Pacific Aster
Wyethia angustifolia Narrowleaf Mule-Ears
Boraginaceae Amsinckia menziesii Coast Fiddleneck
Phacelia californica California Phacelia
Phacelia malvifolia Stinging Phacelia
Brassicaceae Arabis blepharophylla Coast Rockcress 4.3
Erysimum franciscanum San Francisco Wallflower 4.2
Caryophyllaceae Silene scouleri ssp. scouleri Scouler Catchfly 2B.2 Convolvulaceae
Calystegia purpurata ssp
purpurata Smooth Westerng Morning glory
Calystegia subacaulis Hill Morning Glory
Curcurbitacea Marah fabacea California Manroot
Marah oregonus Coast Manroot
Fabaceae Astragalus nuttallii Bladder Pod
Lupinus nanus Sky Lupine
Lupinus variicolor Varied Lupine
Lupinus albifrons Silver Lupine
Lupinus bicolor Miniature Lupine
Vicia gigantea Giant Vetch
Iridaceae Iris douglasiana Douglas Iris
Iris longipetala Central Coast Iris
Sisyrinchium bellum Western Blue-eyed Grass
Lamiaceae
Clinopodium douglasii (Satureja
douglasii) Yerba Buena
Monardella villosa Coyote Mint
Stachys bullata Hedgenettle
Salvia spathacea Hummingbird Sage
Liliaceae Calochortus albus White Fairy-lantern
Fritillaria affinis Checker Lily
Toxicoscordion fremontii Fremont's Deathcamus
Malvaceae Sidalcea malviflora Checkerbloom
Onagraceae Clarkia rubicunda Ruby Chalice Clarkia
Taraxia ovata Sun Cup

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Packet Pg. 1202 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 538
Letter Commenter Date Comment Combined Response
Individuals (C)
Orchidaceae Piperia michaelii Michael's Rein orchid 4.2 Orobanchaceae
Castilleja densiflora ssp
densiflora Dense Flower Owl Clover
Castilleja exserta ssp exserta Purple Owl's Clover
Castilleja wightii Wight’s Paintbrush
Orobanche californica ssp
californica California Broomrape
Triphysaria pusilla Dwarf Owl's Clover
Papaveraceae Eschscholzia californica California Poppy
Plantaginaceae Plantago erecta Dotseed (Dwarf) Plantain Poaceae Agrostis pallens Leafy Bentgrass
Agrostis exarata Spike Bentgrass
Bromus carinatus California Brome
Bromus sitchensis var. maritimus Maritime Brome
Calamagrostis nutkaensis PacificReed Grass
Danthonia californica California Oatgrass
Deschampsia cespitosa Tufted Hair Grass
Elymus glaucus ssp. Glaucus Blue Wild Rye
Elymus triticoides Beardless Wild Rye
Festuca californica California Fescue
Festuca rubra Red Fescue
Hordeum brachyantherum Meadow Barley
Hordeum depressum Dwarf Barley
Koeleria macrantha Junegrass
Leymus triticoides Beardless Wildrye
Melica californica California Melicgrass
Melica torreyana Torrey's Melica
Stipa pulchra Purple Needlegrass
Stipa lepida Foothill Needlegrass
Poa unilateralis San Francisco Bluegrass
Polemoniaceae Navarretia squarrosa Skunkweed
Leptosiphon rosaaceus Rose Leptosiphon 1B.1
Polygonaceae Eriogonum latifolium Seaside Buckwheat
Chorizanthe cuspidata sp
cuspidata San Francisco Spineflower 1B.2
Portulacaceae Calendrinia ciliata Red Maids
Ranunculaceae Ranunculus californicus California Buttercup Rosaceae Acaena pinnatifida Biddy-biddy, Sheepburr
Horkelia californica California Horkelia
Rubus ursinus Califonria Blackberry
Themidaceae Triteleia laxa Ithuriel's spear

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Packet Pg. 1203 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update) 539
C108: John Keener, 2/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C108-1 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 The board of the Pacifica Land Trust has the
following comments on and proposed changes
to the General Plan Update. They center around
inaccuracies regarding trails at Pedro Point
Headlands. The current text is shown in bold.

The comment is noted.

C108-2 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-3 Fig 6-1 Parks and Open Space System,

Page 6 ends

Pacifica City CouncilJune 25, 2022

Pacifica City Council
June 25, 2022