Pacifica City Council
June 25, 2022

form can be found at the following link: https://wildlife.ca.gov/Data/CNDDB/SubmittingData#44524420-pdf-field-survey-form. The completed form can be mailed electronically to CNDDB at the following email address: The types of
information reported to CNDDB can be found at the following link:
https://wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

FILING FEES
CDFW anticipates that the Project will have an impact on fish and/or wildlife, and assessment of filing fees is necessary (Fish & G. Code, section 711.4; Pub. Resources Code, section 21089). Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW.

Thank you for the opportunity to comment on the Project’s DEIR. If you have any questions regarding this letter or for further coordination with CDFW, please contact Will Kanz, Environmental Scientist, at (707) 337-1187 or or Wesley Stokes, Senior Environmental Scientist (Supervisory), at Sincerely,
Erin Chappell
Regional Manager
Bay Delta Region
cc: State Clearinghouse #2020090171
REFERENCES:

Billy M. Teels, Charles A. Rewa, & Myers, J. 2006. Aquatic Condition Response to Riparian Buffer Establishment. Wildlife Society Bulletin (1973-2006), 34(4), 927– 935.

California Department of Fish and Wildlife. February, 1996. Steelhead Restoration and Management Plan for California.

California Department of Fish and Wildlife. July 2009. California Salmonid Stream Habitat Restoration Manual, Part XII.

CDFW. 2020. Notice of Findings - Mountain Lion ESU declared a candidate species.

Available online at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=178623&inline DocuSign Envelope ID: FE837397-619A-404C-ADB9-2F3D70DEF00E

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Packet Pg. 1406 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Mr. Christian Murdock
City of Pacifica
March 8, 2022

CDFW. 2015. California Landowner Incentive Program (Phase 2). Agricultural Riparian Buffers Initiative. Available online at: https://wildlife.ca.gov/Lands/CWHP/PrivateLands-Programs/Landowner-Incentive-Program/Phase-2 Colding, J., Lundberg, J., Lundberg, S., & Andersson, E. (2009). Golf Courses and Wetland Fauna. Ecological Applications, 19(6), 1481–1491.

Dellinger J. A., K. D. Gustafson, D. J. Gammons, H. B. Ernest, S. G Torres. 2020.

Minimum habitat thresholds required for conserving mountain lion genetic diversity. Ecology and Evolution. 10:10687–10696.

Federal Highway Administration (FHWA). March, 2011. Wildlife Crossing Structure Handbook; Design and Evaluation in North America.

Gallant, A. L., Klaver, R. W., Casper, G. S., & Lannoo, M. J. 2007. Global Rates of Habitat Loss and Implications for Amphibian Conservation. Copeia, 2007(4), 967–979.

Gustafson K.D., Gagne R.B, Vickers T.W, Seth P. D. Riley, Christopher C. Wilmers, Vernon C. Bleich, Becky M. Pierce, Marc Kenyon, Tracy L. Drazenovich, Jeff A.

Sikich, Walter M. Boyce, Holly B. Ernest. 2018. Genetic source–sink dynamics among naturally structured and anthropogenically fragmented puma populations.

Conservation Genetics. 2019. 20:215–227. https://doi.org/10.1007/s10592-018- 1125-0
Marczak, L. B., Sakamaki, T., Turvey, S. L., Deguise, I., Wood, S. L. R., & Richardon, J.

S. 2010. Are forested buffers an effective conservation strategy for riparian fauna? An assessment using meta-analysis. Ecological Applications, 20(1), 126– 134.

National Marine Fisheries Service – Southwest Region. September 2001. Guidelines for Salmonid Passage at Stream Crossings.

Pelton, E. M., Schultz, C. B., Jepsen, S. J., Black, S. H., and Crone, E. E. 2019.

Western Monarch Population Plummets: Status, Probable Causes, and Recommended Conservation Actions. Frontiers in Ecology and Evolution. 7:258.

Price, S. J., Guzy, J., Witczak, L., & Dorcas, M. E. 2013. Do Ponds on Golf Courses Provide Suitable Habitat for Wetland-Dependent Animals in Suburban Areas? An Assessment of Turtle Abundances. Journal of Herpetology. 47(2): 243–250.

San Francisco Bay Regional Water Quality Control Board. July 2004. Local Government Riparian Buffers in the San Francisco Bay Area. Available online at:

DocuSign Envelope ID: FE837397-619A-404C-ADB9-2F3D70DEF00E

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Packet Pg. 1407 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Mr. Christian Murdock
City of Pacifica
March 8, 2022

https://www.waterboards.ca.gov/sanfranciscobay/water_issues/available_docum ents/bufferreport0704old.pdf
Senate Bill 790: Wildlife Connectivity Actions: Compensatory Mitigation Credits, October 11, 2021. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id =202120220SB790
Senate Bill 857: An act to amend Section 5901 of the Fish and Game Code, and to add Article 3.5 (commencing with Section 156 of the Streets and Highways Code) to Chapter 1 of Division 1 of, the Streets and Highways Code, relating to fish passages, October 6, 2005. https://leginfo.legislature.ca.gov/faces/billNavClient. xhtml?bill_id=200520060SB857
Thompson, R.C., A.N. Wright, and H.B. Shaffer. 2016. California Amphibian and Reptile Species of Special Concern. University of California Press and California Department of Fish and Wildlife.

Trombulak, S. C., and C. A. Frissell. 2000. Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology 14:18–30.

Vos, C. C., and J. P. Chardon. 1998. Effects of habitat fragmentation and road density on the distribution patter of the moor frog Rana arvalis. Journal of Applied Ecology 35:44–56.

U.S. Fish and Wildlife Service. 1985. Recovery Plan for the San Francisco Garter Snake (Thamnophis Sirtalis Tetrataenia). U.S. Fish and Wildlife Service, Portland, Oregon. 77 pp.

U.S. Fish and Wildlife Service. 2002. Recovery Plan for the California Red-legged Frog (Rana aurora draytonii). U.S. Fish and Wildlife Service, Portland, Oregon. viii + 173 pp.

U.S. Fish and Wildlife Service. 2007. Species Account San Francisco Garter Snake (Thamnophis Sirtalis Tetrataenia). U.S. Fish and Wildlife Service, Sacramento, California.

U.S. Fish and Wildlife Service. 2017. Species Account for California Red-legged frog.

December 2017. Zweifel, R. G. 1955. Ecology, distribution, and systematics of frogs of the Rana boylii group. University of California Publications in Zoology 54 (4):207–292. https://www.fws.gov/sacramento/es_species/Accounts/Amphibians Reptiles/ca_red_legged_frog/
White, C. L., & Main, M. B. 2005. Waterbird Use of Created Wetlands in Golf-Course Landscapes. Wildlife Society Bulletin (1973-2006). 33(2): 411–421.

DocuSign Envelope ID: FE837397-619A-404C-ADB9-2F3D70DEF00E

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Packet Pg. 1408 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Mr. Christian Murdock
City of Pacifica
March 8, 2022

Xerces Society Western Monarch Thanksgiving Count (2019). Western Monarch Thanksgiving Count Data from 1997–2018. Available online at:
www.westernmonarchcount.org
Xerces Society Website 2020. https://xerces.org/press/western-monarch-butterflypopulation-still-at-critical-level. Accessed February 5, 2021 DocuSign Envelope ID: FE837397-619A-404C-ADB9-2F3D70DEF00E

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Packet Pg. 1409 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) From: Frost, Erik@DOC [
Sent: Tuesday, February 1, 2022 4:18 PM
To: Murdock, Christian [[email protected]]
CC: McCrink, Tim@DOC [ Wilson, Rick@DOC
[ OPR State Clearinghouse
[ OLRA@DOC [
Subject: Comments - NOC for City of Pacifica General Plan Update and Sharp Specific Plan (SCH 2020089010)
[CAUTION: External Email]
Mr. Murdock,
The California Geological Survey (CGS) has received a Notice of Completion regarding the Draft Environmental Impact Report (DEIR) for the City of Pacifica’s General Plan Update and Sharp Specific Plan. This letter conveys the following suggestions and recommendations from CGS concerning geologic and soils issues relevant to the planning area:

1. Earthquake Hazard Zones
Numerous potential earthquake hazards exist within the planning area:
a) Fault Rupture, Liquefaction and Landslide Hazards
The DEIR includes figures depicting the most up-to-date Earthquake Zones of Required Investigation produced under the Alquist-Priolo Earthquake Fault Zoning Act and the Seismic Hazards Mapping Act. The City may also wish to provide in the Safety Element links to CGS websites that will be updated as maps are published and revised:
https://maps.conservation.ca.gov/cgs/informationwarehouse/regulatorymaps/ https://maps.conservation.ca.gov/cgs/informationwarehouse/apreports/ https://maps.conservation.ca.gov/cgs/EQZApp/app/
b) Tsunami Hazards
The DEIR includes the most recent Tsunami Hazard Area maps for evacuation planning, which were updated in 2020. Within the next couple years, CGS will be completing new Tsunami Hazard Zones under the Seismic Hazard Mapping Act. These new Tsunami Hazard Zones will use the same area of the 2020 Tsunami Hazard Area maps to delineate the overall hazard zone but will include within it an additional Engineering Analysis Subzone, which will be delineated by probabilistic tsunami hazard analyses. When these new Tsunami Hazard Zones are released, the City of Pacifica will be responsible for requiring site-specific investigations and reviewing investigation reports for development projects, in the same manner as the other Earthquake Hazard Zones. CGS will reach out to the City of Pacifica close to the time Preliminary Tsunami Hazard Zones are released.

2. Geologic Hazards
a) Landslides

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Packet Pg. 1410 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) The DEIR currently includes a figure depicting the relative density of existing landslides (“mostly landslides,” “few landslides,” and “not landslide prone”) throughout the planning area. The City should also consider providing a map of specific landslides. CGS has compiled an inventory of landslides in the planning area (as shown in Seismic Hazard Zone Reports 128 and 133), and we recommend this inventory be shown in an appropriate figure. The GIS data for this landslide inventory will be transmitted separately. b) Debris Flows
Shallow, rainfall-triggered landslides, described in the DEIR as debris flows, are a known hazard within the City of Pacifica. The DEIR mentions debris flow hazards but does not provide much information on where this hazard exists nor where it has occurred in the past. CGS recommends that the Final EIR and Safety Element include debris flow hazard maps and information prepared by the USGS (USGS OFR 97-745 E; USGS Professional Paper 1434 including Plate 8). In particular, the City should consider using these references to help identify existing developments subject to debris flow hazards and determine what new development areas should have geotechnical site investigations prepared prior to project approval.

Please let us know if you have any questions or concerns with the comments in this letter.

Sincerely,
Erik
Dr. Erik Frost
Senior Engineering Geologist | Seismic Hazards Program
California Geological Survey
715 P Street, MS 1901, Sacramento, CA 95814
(916) 205-8255
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 1411 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) From: Adrianne Carr [
Sent: Tuesday, March 8, 2022 4:24 PM
To: Public Comment [
CC: Stephanie Dalton [ Woodhouse, Kevin
[[email protected]]
Subject: Comments on Plan Pacifica from NCCWD
Attachments: Plan Pacifica_NCCWD_Comment Letter_3_8_22.pdf [CAUTION: External Email]
Hi ChristianPlease see the attached comment letter.

Best regards,
Adrianne
Adrianne Carr, Ph.D.

General Manager
North Coast County Water District
2400 Francisco Boulevard
Pacifica, CA 94044
Tel: (650) 355-3462
Fax: (650) 355-0735
On the web at www.nccwd.com
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 1412 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) March 8, 2022 VIA EMAIL
Christian Murdock, AICP
Deputy Director of Planning
540 Crespi Drive
Pacifica, CA 94044
RE: Plan Pacifica
Dear Mr. Murdoch,
Thank you for the opportunity to comment on the City of Pacifica’s Plan Pacifica documents, including the Draft General Plan, the Draft Sharp Park Specific Plan, and the Draft Environmental Impact Report (EIR)
I have reviewed the relevant sections of the above reference documents with regard to the NCCWD and water supply and conservation issues and provide the following comments:

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

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

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

4. The District welcomes coordination efforts proposed by the City in it’s measures CO-I20, CO-I-21, CO-I-22, CO-I-23, SA-I-13, SA-I-92, and SA-I-108.

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Packet Pg. 1413 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 1414 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 1415 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) COMMISSIONERS: MIKE O’NEILL, CHAIR, CITY ▪ ANN DRAPER, VICE CHAIR, PUBLIC ▪ HARVEY RARBACK, CITY ▪ DON HORSLEY, COUNTY ▪ WARREN SLOCUM, COUNTY ▪ JOSHUA COSGROVE, SPECIAL DISTRICT ▪ RIC LOHMAN, SPECIAL DISTRICT ALTERNATES: KATI MARTIN, SPECIAL DISTRICT ▪ DIANA REDDY, CITY ▪ JAMES O’NEILL, PUBLIC ▪ DAVE PINE, COUNTY STAFF: ROB BARTOLI, INTERIM EXECUTIVE OFFICER ▪ TIM FOX, LEGAL COUNSEL▪ ANGELA MONTES, CLERK March 8, 2022
Sent Via Email
Mr. Christian Murdock, Deputy Planning Director
City of Pacifica Planning Department
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica General Plan Update, Sharp Park Specific Plan and Draft Environmental Impact Report
Mr. Christian Murdock,
Thank you for the opportunity to comment on the for a City of Pacifica General Plan Update, Sharp Park Specific Plan and Draft Environmental Impact Report.

The Local Agency Formation Commission (LAFCo) is a state mandated local agency established in every county to oversee the boundaries of cities and special districts. San Mateo LAFCo has jurisdiction over the boundaries of the 20 cities, 22 independent special districts, and many of the 33 active county and city governed special districts serving San Mateo County.

The Draft Land Use section for the General Plan Update and the NOP accurately states that the City’s Sphere of Influence includes unincorporated areas to the south of the existing City boundaries around the area of San Pedro Mountain and Pedro Point Headland, including Shamrock Ranch. The 2022 Draft General Plan designates this land as Urban Reserve which is intended for agriculture and residential development.

LAFCo has the following comments:

Please clarify the allowed Urban Reserve density. Policy LU-I-4 in the DEIR states that the City should “coordinate with San Mateo County to ensure that new development in unincorporated areas occurs at a maximum density of five acres per unit.” Policy LU-I-4 in the Draft General Plan states that the development in the Urban Reserve is “maximum density of 10 acres per unit.” DEIR Policy LU-I-6 states that density for the Urban Reserve is a “minimum lot area of 10 acres per dwelling unit.”
For Policy LU-I-4, is it the City’s intent to have the County undertake a master plan for a subdivision of 50 acres or more located in the City’s Sphere of Influence or it is proposed that

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Packet Pg. 1416 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) March 8, 2022

the master plan would be part of the City’s annexation process? In addition to any City process and entitlements needed for annexations, LAFCo will need to review and approve any proposed boundary change.

that “Sites within the Urban Reserve land designation that are annexed into the City of Pacifica should receive a land use designation consistent with the applicable density prior to annexation.” For parcels that are annexed to the City, would the parcels retain the Urban Reserve land designation, or would they receive a different land use designation? Table 4-1 in the Draft General Plan lists Urban Reserve as a land use, but does not show a density. However, Table 4-1 shows Urban Reserve as having a density of 0.1 or less.

Policy LU-I-6 in the Draft General Plan states that the minimum lot area is 1010 acres and appears to be a typo.

Page G-10 of the Draft General Plan defines a Sphere of Influence as “The ultimate service area of an incorporated city, as established by San Mateo County.” The Sphere of Influence is established by San Mateo LAFCo not the County.

The majority of the General Plan planning area is served by North Coast County Water District for water service. LAFCo encourages the City to continue to engage with the district throughout this update process, particularly if water service is proposed to be expanded beyond the District’s existing boundaries for potential development.

San Mateo LAFCo looks forward to reviewing all future environmental and planning documents related to the General Plan Update.

Sincerely,
Rob Bartoli
Interim Executive Officer

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Packet Pg. 1417 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) From: KoppmanNorton, Julia@Coastal [
Sent: Tuesday, March 1, 2022 4:42 PM
To: Public Comment [[email protected]]
CC: Rexing, Stephanie@Coastal [
Subject: General Plan Update & Sharp Park Specific Plan - DEIR Comments Attachments: FW: NOP - Pacifica GP Update & Sharp Park Specific Plan - Comments; CCC Comment Letter 2018.08.31.pdf; CCC Comment Letter 2018.10.19.pdf; CCC Comment Letter 2019.11.22.pdf; CCC Comment Letter 2020.02.19.pdf; CCC Comment Letter 2018.08.29.pdf; Pacifica LCP Post-Consultation Draft Letter 2020.02.19.pdf [CAUTION: External Email]
Hello,
Thank you for the opportunity to provide comments on the DEIR for the City’s General Plan Update and Sharp Park Specific Plan. I’ve attached our prior correspondence on this matter, all of which we would like to be incorporated into the comment record for the DEIR and project. Broadly, and as indicated prior, the General Plan Update and Sharp Park Specific Plan, as well as this associated DEIR, must be consistent with the certified LCP. As the LUP update has been submitted to the Coastal Commission but has not yet been certified, the originally certified LCP is the standard with which the GP/SPSP must be consistent. Once an updated LUP is certified, the GP/SPSP would have to be updated to then be consistent with the updated LCP. As such, generally, it may make the most sense to coordinate timing of the GP/SPSP for after the LUP is certified, given the outstanding nature of the LUP certification.

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

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Packet Pg. 1418 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Please let me know if you have any questions.

Best,
Julia
_______
Julia Koppman Norton
North Central Coast District Supervisor
California Coastal Commission
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 1419 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) From: KoppmanNorton, Julia@Coastal
Sent: Friday, November 13, 2020 9:12 AM
To: Rexing, Stephanie@Coastal
Subject: FW: NOP - Pacifica GP Update & Sharp Park Specific Plan - Comments Attachments: City Council 7/20 - Sharp Park Specific Plan Guiding Policy Framework Discussion
From: "KoppmanNorton, Julia@Coastal" <
Date: Wednesday, September 9, 2020 at 1:07 PM
To: "Murdock, Christian" <[email protected]>
Subject: NOP - Pacifica GP Update & Sharp Park Specific Plan - Comments Hi Christian,
Please add this email to the record for comments on the NOP for the General Plan Update and Sharp Park Specific Plan.

As noted in the attached email dated July 16, 2020 on the City Council’s framework discussion regarding the Sharp Park Specific Plan, as the Sharp Park Specific Plan proposes to increase height and density allowances within the Sharp Park neighborhood, the CEQA analysis should thoroughly analyze potential visual impacts of development as provided through the Specific Plan on the character of the surrounding area and on views through the neighborhoods of the ocean, impacts to community character as designated and provided in the LCLUP, impacts on public access and recreation, and impacts of potential geotechnical and coastal hazards on development that per the current proposal would be of increased height and density than currently allowed. More specifically, the analysis should include visual simulations, height and density alternatives, explanations of the hazards within this particular neighborhood, and the benefit to the public with regard to priority uses in this coastal area, and should consider:
• Potential impacts if the proposed maximum height is reduced in areas in which tall buildings (up to 55 feet in height) will impact the visual character of surrounding areas as well as public views to and from the ocean in visually sensitive areas, and
• Performing a thorough geotechnical analysis, including an evaluation of the potential hazards to this neighborhood (landslides and shoreline erosion) as well as a wave uprush study for the area. Such a wave uprush study should include an assessment of the potential hazards caused by 100-year storm events (cumulative with high tide events, as well as projected sea level rise impacts and given a typical eroded beach condition).

In addition, any new General Plan and Sharp Park Specific Plan policies will need to be consistent with the LCP, and should not lessen protections or conflict with policy protections for coastal resources in the LCP. Please let me know if you have any questions. We look forward to continuing to work with the City on this CEQA process.

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Packet Pg. 1420 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Thanks,
Julia
____________
Julia Koppman Norton
Coastal Planner
North Central Coast District
California Coastal Commission
(415) 904-5292

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Packet Pg. 1421 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) From: KoppmanNorton, Julia@Coastal
Sent: Thursday, July 16, 2020 2:59 PM
To: Murdock, Christian
CC: Tina Wehrmeister
Subject: City Council 7/20 - Sharp Park Specific Plan Guiding Policy Framework Discussion Hi Christian,
Please add the following to the record for the Sharp Park Specific Plan Guiding Policy Framework Discussion that is on the City Council agenda on Monday, July 20th. The comments reiterate concerns and comments raised by Commission staff during a phone call with Commission and City staff on April 3, 2020.

As the Sharp Park Specific Plan proposes to increase height and density allowances within the Sharp Park neighborhood, a thorough analysis should be conducted in terms of visual impacts of development as provided through the Specific Plan on the character of the surrounding area and on views through the neighborhoods of the ocean, impacts to community character as designated and provided in the LCLUP, and impacts of potential geotechnical and coastal hazards on development that per the current proposal would be of increased height and density than currently allowed. Any allowed uses in the Specific Plan should prioritize low-cost visitor-serving, recreational uses and public access. In addition, the Specific Plan would need to provide for increased coastal resource protections in order to ensure consistency with the Coastal Act, and documentation should be provided including visual simulations, height and density alternatives, explanations of the hazards within this particular neighborhood, and the benefit to the public with regard to priority uses in this coastal area. More specifically, the City should consider:
• Reducing the proposed height in areas in which tall buildings (up to 55 feet in height) will impact the visual character of surrounding areas as well as public views to and from the ocean in visually sensitive areas, and
• Performing a thorough geotechnical analysis, including an evaluation of the potential hazards to this neighborhood (landslides and shoreline erosion) as well as a wave uprush study for the area. Such a wave uprush study should include an assessment of the potential hazards caused by 100-year storm events (cumulative with high tide events, as well as projected sea level rise impacts and given a typical eroded beach condition).

We look forward to continuing to work with the City on this Specific Plan throughout the City’s drafting and review process. Thank you.

Best,
Julia
____________
Julia Koppman Norton
Coastal Planner
North Central Coast District
California Coastal Commission
(415) 904-5292

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Packet Pg. 1422 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 1423 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G BROWN JR , GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
August 31, 2018
Tina Wehrmeister
Planning Director
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Draft Land Use Plan (LUP) Hazard Policies Dear Ms. Wehrmeister:

This letter is in response to the City of Pacifica’s request for comments on the “Proposed Updated Draft LUP Hazard Policies” provided to us in a memo from ESA to the City (entitled “Sea-Level Rise Policy Options for Pacifica LCP Update” and dated August 24, 2018). We note that we received this document just this week, and you have requested comments by today. As discussed with you, due to that abbreviated timeline of just a few days, we won’t be able to provide final or comprehensive comments, but we are happy to provide some preliminary thoughts and some broader observations regarding the current proposed policies. We look forward to continued dialogue on the policies, including with respect to refinements identified herein.

Overall, the proposed policies appear to provide a solid framework for advancing the City’s sea level rise adaptation efforts, which will be critically important in the coming decades. As is identified in its Sea Level Rise Vulnerability Assessment (June 2018), the City of Pacifica is already vulnerable to storm and wave impacts, including as evidenced by the loss of residential structures in recent years, and efforts to protect against such impacts have resulted in narrowed or completely inundated beaches backed by armoring where access can be largely unavailable at higher tides. These hazards are only expected to increase as sea levels rise, resulting in significant loss of public recreational beach resources and shoreline-area habitats, as well as damage to and loss of residential and commercial structures, and transportation, stormwater, and wastewater infrastructure. In particular, given its beaches are a fundamental backbone and significant part of the City’s social fabric and economic engine, it is critically important for the policies to reflect the importance of the City’s beaches, and to be transparent (and provided appropriate mitigations) where the policies might lead to increased impacts to same.

To this end, the proposed policies address the need to ensure that new development is sited and designed to be safe from coastal hazards and to avoid the need for armoring, and the policies provide many key mechanisms for future steps to take as sea level rise advances over time, including interim protection measures, beach nourishment, and eventual managed retreat in

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Packet Pg. 1424 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 2 certain locations. We want to commend the City for tackling such difficult issues head-on, and for starting to identify practical and substantive measures to address such issues moving forward.

At the same time, although many important sea level rise planning provisions are addressed in the proposed policies, and they provide a good foundation for the LCP update, we also believe that many important details will require refinement moving forward, including to ensure that the proposed policies are logical, feasible, realistic, and consistent with the Coastal Act. We look forward to working together with the City to refine this work so that it achieves Coastal Act and City objectives related to minimizing hazards and protecting coastal resources, even as sea level rises.

In the interim, and in drilling down a bit into the proposed policies, the current draft includes effective and important policies that address planning and accounting for coastal hazards longer term, but appear to require some focus on the shorter term horizon. For example, the “Standard Policies for New Development,” “Shoreline Structures,” and “Coastal Flooding and Other Hazards” sections provide policies for long-term planning throughout the City that should help ensure new development will be safe from current and future vulnerabilities and protective of coastal resources. However, we continue to have the same concerns that we have previously relayed to the City regarding how existing development will be addressed going forward in a manner that ensures beaches, habitat, public access, and recreation will be preserved for current and future generations, as required by the Coastal Act. Part of the challenge before us in refining the policies will be to make sure that the shorter term and longer term policies interact and seamlessly move towards similar objectives, and aren’t somehow at cross-purposes.

In addition, as you know we have previously identified issues associated with potential policy preparation as the City has worked through its Draft Adaptation Plan (including through meeting with you and your staff throughout this year as well as letters dated June 12, 2018 and August 29, 2018). One of our primary concerns was ensuring that such policy preparation was based on a detailed assessment of the feasibility and costs/benefits of different adaptation alternatives, and it is not clear that this sort of information has been fully developed. No matter what policies are ultimately proposed, it will be critical for decision-makers, both at the City and Commission level, to have the benefit of that sort of information as they weigh potential policy approaches.

We would be happy to work with you and your staff as this effort proceeds locally to ensure that such background is clearly provided.

In terms of more specific comments on the draft policies, here are some preliminary observations:
 The proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support it as a primary adaptation strategy through the proposed policies. In short, we think that policies that rely so heavily on nourishment, particularly in the shorter term, need to be

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Packet Pg. 1425 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 3 supported by more thorough data.
 The proposed policies refer to developing a “Shoreline Mitigation Program” in the future to address impacts associated with hazard response. The policies are going to need to be able to be structured to address such impacts now, and many policies seem to imply that is their intent. It may be appropriate to identify development of a future mitigation program as a refinement and a next step, but it needs to be clear that this does not negate the need for mitigation in the interim.
 It may be appropriate to reformat and reorganize the policies. For example, the “Standard Policies” sections from pages 14-19 account for the overarching approach for new development and substantial improvements to existing development, in all areas throughout the City, and in both the short- and long-term. It may make better sense to move these to the beginning. Additionally, although we understand the policy construct that suggests that general policies may be superseded by more specific policies for each sub-area, we are concerned that some of the more specific policies appear to be making prescriptions for outcomes that are not based on analysis (e.g., allowed armoring). It is not appropriate, in our view, to have policies state conclusions that have not yet been supported by analysis, and it may be that the overarching policies are required to take precedence in that regard unless and until conclusions can be drawn in that manner.
 The policies appear to be looking to the 2040 horizon as ‘longer term’, and this seems an appropriate framework. We would encourage a close review to ensure that policies referring to other time frames (e.g., 20-year approvals) are understood in terms of this horizon, including to ensure that development years out also times to the same horizon.  It appears that some critical policy language is missing from some of the draft policies.

Please ensure that the following are addressed:
o Please provide design standards for the construction of shoreline protection devices (e.g., they must: blend with natural environment; avoid significant habitat areas; minimize footprint; protect, and where feasible, provide public access; control erosion from surface and groundwater flows; etc.).
o Please identify specific details regarding how proportional mitigation for all unavoidable impacts of shoreline protection devices to coastal resources (e.g., shoreline sand supply, recreation, public views, and water quality) is to be measured and applied. o Please ensure that the policies require removal of shoreline protection devices when they are no longer required to protect existing structures in danger from erosion, including when structures are demolished and then rebuilt, or redeveloped. o Please define what constitutes “substantial improvements” to ensure that current development is brought into compliance with the policies as it is renovated and redeveloped. We have previously identified appropriate standards for such a definition, and would be happy to provide that again.
 Certain themes, concepts, and terms used throughout the draft policies need to be better defined, including as follows:
o Please better describe how the triggers would be implemented (e.g., trigger for when armoring/nourishment etc. would be implemented when the bluff offset reaches the

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Packet Pg. 1426 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 4 specified distance, or whether the specified distance triggers a different approach). In addition, please explain how the years and amounts of sea level rise pertain to the offset values and describe how beach width and bluff offsets will be measured. o Please explain how the hazard areas referenced in the policies will be defined, including the coastal hazard zones, coastal hazard maps, flood hazard zones, and tsunami run-up zones. In addition, for particular hazard areas that will be mapped, we recommend that the City add timeframes for how often these maps must be updated and include contingencies in the event that they are not updated by the prescribed deadline. o Please discuss how height limitations will be accounted for if/when structures need to be elevated to meet FEMA base flood levels in some areas.
o Please further expound upon what constitutes current “best available science” and whether there is a different standard for what amount of sea level rise should be evaluated in geotechnical studies versus what amount of sea level rise new development must be sited/designed to be safe from. For example, consider specifying that all new development must evaluate, at a minimum, the medium-high projection scenario (from the 2018 OPC Sea-Level Rise Guidance and in line with the Draft 2018 Science Update to the CCC SLR Policy Guidance) over its anticipated lifetime, but that if new development cannot be sited to avoid impacts over that time period certain minimum standards must be met (similar to the policies related to takings). We would be happy to work with the City on this topic.
o References to hazard policies are made without those specific policies’ reference numbers included. Please update the references accordingly.

Again, we appreciate and commend the City on developing these draft policies and the related policy framework, and look forward to helping to refine the policies and approach through our ongoing collaboration on the City’s LCP update. It is clear from these policies that the City is taking the issues and problems associated with coastal hazards seriously, and in a way that advances the City’s approach to sea level rise and LCP planning. We hope these comments help move us forward in that regard. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me or Patrick Foster of my staff. Again, we greatly appreciate the ability to be a part of this important planning process and look forward to continued coordination and discussion of this important effort.

Sincerely,

Jeannine Manna
North Central Coast District Manager
California Coastal Commission
cc: Bonny O’Connor, City of Pacifica Planner

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Packet Pg. 1427 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G BROWN JR , GOVERNOR

CALIFORNIA COASTAL COMMISSION NORTH CENTRAL COAST DISTRICT OFFICE 45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
October 19, 2018
Tina Wehrmeister
Planning Director
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Draft Land Use Plan (LUP) Hazard Policies Dear Ms. Wehrmeister:

This letter is in response to the City of Pacifica’s request for comments on the “Proposed Updated Land Use Plan Coastal Hazards Policies” provided to us in a memo from ESA to the City (entitled “Sea-Level Rise Policy Options for Pacifica LCP Update” and dated August 24, 2018). As you know, we previously provided comments on a memo from ESA to the City with the same title and date (see attachment 1 for that memo, and see attachment 2 for our comments on it in a letter to the City dated August 31, 2018). We were surprised to see that the second memo (see attachment 3) was substantially different than the first memo and did not respond to the majority of our suggestions. Regardless of why the City may have chosen this approach, with respect to the second memo, many of our previous comments still stand, and are repeated below as appropriate. We have also suggested specific modifications to the policies and text within the new memo, including indicating where we believe that language from the first memo we reviewed should be re-inserted (see attachment 3). It is our understanding that the City Council will be considering these draft hazard policies by themselves now, but it is ultimately the City’s intention to incorporate them into an overall draft LCP update for consideration sometime in 2019. As such, although we provide some preliminary comments and suggestions here, it appears that there will also be future junctures when further refinement and comment is possible. Toward that end, we look forward to continued dialogue on the proposed policies, and to working with City staff to further develop this policy language in conjunction with the rest of the LCP update as the draft moves forward, including as it is modified in light of public and City Council input.

When we commented on the first memo we noted that we believed that the proposed policies began to provide a solid foundation and framework for advancing the City’s sea level rise adaptation efforts. As the Coastal Commission has routinely stated, clear, proactive policies for addressing sea level rise are critically important. This is undoubtedly true in Pacifica where, as is identified in the City’s Sea Level Rise Vulnerability Assessment (June 2018), the City is already vulnerable to storm and wave impacts. Such impacts are evidenced by the loss of blufftop residential structures in recent years, and by the fact that efforts to protect against such impacts have resulted in narrowed or completely inundated beaches backed by armoring where beach

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Packet Pg. 1428 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 2 access can be largely unavailable at higher tides. These hazards are only expected to increase as sea levels rise, resulting in a significant loss of public recreational beach resources and shorelinearea habitats, as well as damage to and loss of residential and commercial structures, and transportation, stormwater, and wastewater infrastructure. In particular, given its beaches are a fundamental backbone and significant part of the City’s social fabric and economic engine, it is critically important for the policies to reflect the importance of the City’s beaches, and to be transparent (and provide appropriate mitigations) where the policies might lead to increased impacts to same.

To this end, we are concerned that both the removal of some proposed policies from the first memo and the addition of new language in the second memo will result in policies that do not clearly state the need to ensure that new development and redevelopment be sited and designed to be safe from coastal hazards and to avoid the need for armoring. We also continue to have the same concerns that we have previously relayed to the City regarding how existing development will be addressed going forward in a manner that ensures beaches, habitat, public access, and recreation will be preserved for current and future generations, as required by the Coastal Act. In addition, we previously identified concerns associated with policy preparation based on a lack of technical and feasibility information as the City worked through its Adaptation Plan (including through meeting with you and your staff throughout this year as well as letters dated June 12, 2018 and August 29, 2018). One of our primary concerns was, and remains, ensuring that policies which prescribe specific adaptation measures (like armoring and beach nourishment with the use of sand retention structures) are based on a clear and detailed assessment of the environmental, technical, and economic feasibility of such alternatives. It is not clear that such information has been fully developed.

We do continue to recognize that addressing new and existing development in a place like Pacifica is a complex challenge given the scope of current and future hazards combined with existing patterns of development and shoreline armoring and uncertainties about future sea level rise and future conditions on the ground. As we have previously explained in meetings with and letters to City staff, there are policy approaches that would allow for continued reliance on armoring for certain development over a specified time horizon, including as identified in the City’s current sub-area policies. However, such policy approaches still need to ensure that impacts to other coastal resources would be mitigated, and need to build in an understanding that other adaptation options may be necessary if and when armoring (and/or beach nourishment) can no longer provide adequate protection for both development and coastal resources. Part of the challenge before us is to refine the policies and strike an appropriate balance in order to protect the range of coastal resources and development, while ensuring that short and long term policies interact and seamlessly move towards similar objectives.

In any case, we want to commend the City for tackling difficult sea level rise issues and for starting to identify practical and substantive measures to address such issues moving forward. To be sure, the proposed policies provide many key mechanisms for future steps to take over time as sea level rise advances, including interim protection measures, beach nourishment, monitoring of changing conditions, and periodic updates to the City’s Adaptation Plan to respond to such changes. Although many important coastal hazard planning provisions are addressed in the proposed policies and they provide a good foundation for the LCP update, we also believe that

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Packet Pg. 1429 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 3 many important details will require refinement moving forward, including to ensure that the proposed policies are logical, feasible, realistic, and consistent with the Coastal Act. We continue to look forward to working together with the City to refine this work so that it achieves Coastal Act and City objectives related to minimizing hazards and protecting coastal resources, even as sea level rises.

In terms of some more specific comments on the draft policies in the second memo, here are some preliminary observations:
• The previous memo included a summary with details of how the City has dealt with the impacts of shoreline erosion and coastal flooding for decades. We recommend including a similar setting description in the LUP itself to speak to the broad purpose of the proposed coastal hazard policies and to provide context for their future implementation. • The proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously with City staff, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support it as a primary adaptation strategy through the proposed policies. In short, we think policies that rely so heavily on nourishment, particularly in the shorter term, need to be supported by more thorough data. Similarly, the use of sand retention structures can alter ocean waves, currents and sand movement, potentially exacerbating erosion on one side or the other of the structure (e.g., depending on currents, littoral drift, etc.). These potential impacts should be evaluated accordingly if sand retention structures are planned to be used in conjunction with beach nourishment.
• The proposed policies refer to developing a “Shoreline Mitigation Program” in the future to address impacts associated with hazard response. The policies need be structured to address such impacts now, and many policies seem to imply that is their intent. It may be appropriate to identify development of a future mitigation program as a refinement and a next step, but it needs to be clear that this does not negate the need for mitigation in the interim. Accordingly, given the Shoreline Mitigation Program is not yet complete, we recommend removing reference to implementation of the Program in the policies, instead of referencing only that it will be developed in the future. Until the Program is fully developed, mitigation should be implemented consistent with the type of requirements found in proposed Hazard Policy 60. • It may be appropriate to reformat and reorganize the policies. For example, the “Standard Policies” sections from pages 12-16 account for the overarching approach for new development in all areas throughout the City, and in both the short- and long-term. It may make better logical, and document-flow sense to move these, along with the definitions section, to the beginning of the document. Additionally, although we understand the policy construct that suggests that general policies may be superseded by more specific policies for each sub-area, we are concerned that some of the more specific policies appear to be making prescriptions for outcomes that are not based on analysis (e.g., allowed armoring). It is not

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Packet Pg. 1430 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 4 appropriate, in our view, to have policies state conclusions that have not yet been supported by analysis, and it may be that the overarching policies are required to take precedence in that regard unless and until more definitive conclusions can be drawn. • It appears that some critical policy language is missing from some of the proposed draft policies. Please ensure that the following are addressed:
o Please provide design standards for the construction of allowable shoreline protection devices (e.g., they must: blend with natural environment; avoid significant habitat areas; minimize footprint; protect, and where feasible, provide public access; control erosion from surface and groundwater flows; etc.).
o Please identify specific details regarding how proportional mitigation for all unavoidable impacts of shoreline protection devices to coastal resources (e.g., shoreline sand supply, beaches, public recreational access areas and amenities, public views, water quality, etc.) is to be measured and applied. Please ensure that the policies require removal of shoreline protection devices when they are no longer required to protect existing structures in danger from erosion (including when structures are demolished and then rebuilt, or redeveloped) when such removal and restoration can be accomplished without endangering existing principal structures or existing public facilities on adjacent sites. o Please discuss how height limitations will be accounted for if/when structures need to be elevated to meet FEMA base flood levels in some areas.
o The siting and design policies for hazard areas no longer address substantial improvements to existing development (or ‘redevelopment’) in the second memo. We recommend the City develop specific language for how the siting and design of structures will be addressed when they are redeveloped in situations where there is existing, legally authorized shoreline protection and in cases where there is a natural bluff or shoreline fronting the proposed development. In addition, we recommend including separate policies to address new development on vacant lots that are fronted by existing, legally authorized shoreline armoring and in places where there is a natural bluff or shoreline. In cases where new development/redevelopment cannot be located safe from hazards without reliance on existing and/or new armoring or cannot meet the required setbacks, any approval for such development should include triggers for eventual removal in response to coastal hazards (e.g., when declared unsafe for occupancy and/or use; when the development encroaches onto current or future public trust land and the State Lands Commission denies a grant, lease, or other legal mechanism to allow the development to remain in place; when access and utilities are no longer available to serve the development and cannot be restored; when the blufftop edge erodes to the minimum setback line; when removal is required by subsequent adaptation planning; etc.), as well as propose ways in which the new and redeveloped structures will mitigate for that armoring’s impacts to coastal resources.
o Please provide a policy that outlines how the City will address development that becomes unsafe for occupancy and a public nuisance due to coastal hazards.

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Packet Pg. 1431 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 5 • Certain themes, concepts, and terms used throughout the draft policies need to be better defined or explained in order for us to better evaluate the intent and application of the proposed policies, including as follows:
o Please define “existing structure,” as it is used often in the policies in relation to shoreline armoring. We recommend that it be defined as a structure legally authorized prior to the effective date of the Coastal Act on January 1, 1977, including as is identified in the Commission’s Sea Level Rise Policy Guidance.
o Instead of only a reliance on “new development”, please also define “redevelopment” to ensure that current development is brought into compliance with the policies as it is substantially changed over time. Please establish clear thresholds for when repair, maintenance, improvement, or other work is conducted to the extent that a structure needs to be reviewed against all current standards, including for coastal hazards.

Typically, such thresholds would at the least include alteration (including demolition, renovation or replacement) of 50% or more of major structural components. o Please further describe what constitutes current “best available science” and whether there is a different standard for what amount of sea level rise should be evaluated in geotechnical studies versus what amount of sea level rise new development must be sited/designed to be safe from. For example, consider specifying that all new development must evaluate, at a minimum, the medium-high projection scenario (from the 2018 OPC Sea-Level Rise Guidance and in line with the Draft 2018 Science Update to the Commission’s Sea Level Rise Policy Guidance) over its anticipated lifetime, but that if new development cannot be sited to avoid impacts over that time period certain minimum standards must be met (similar to the policies related to takings). We would be happy to work with the City on this topic.
o Please explain how the hazard areas referenced in the policies will be defined, including the coastal hazard zones, coastal hazard maps, flood hazard zones, and tsunami run-up zones. The current definition of hazard zone refers to the City’s current maps, but it is not clear to what maps that refers. Any maps referred to in the policies should be included as part of the LCP. In addition, for particular hazard areas that will be mapped, we recommend that the City add timeframes for how often these maps must be updated and include contingencies in the event that they are not updated by the prescribed deadline. o Proposed Hazard Policy 5 states that the City will implement a monitoring program for sea level rise to establish thresholds for reassessing the City’s Adaptation Plan. Please describe the type of thresholds that will be identified. Additionally, the current sub-area policies refer to triggers, but do not explain how the triggers would be implemented. For example, clarify whether armoring/nourishment etc. would be implemented when the bluff offset reaches the specified distance, or whether the specified distance triggers a new approach. Please also explain how beach width and bluff offsets will be measured. o Proposed Hazard Policy 7 states that the Shoreline Mitigation Program will identify priority improvements for maintaining and enhancing coastal shoreline resources, particularly public access and recreation. Please further describe what types of

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Packet Pg. 1432 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 6 improvements the City is contemplating in this regard and provide relevant examples. o Proposed Hazard Policy 8 refers to funding for “adaptation strategies”. Please outline what kind of strategies this refers to, and specify if this will include voluntary removal or relocation of development.
o Proposed Hazard Policy 9 calls for identifying areas where densities and heights may be increased using TDR credits, including to facilitate affordable housing. Please describe how such determinations will be made, including which specific criteria will be evaluated.
o Proposed Hazard Policy 11 states that the City will preserve, protect, or relocate hazard prone infrastructure to maintain critical services and the environment. Given that these two goals will often conflict, please specify what criteria will be evaluated in determining the preferred option for infrastructure projects. Also, given similarities and overlap, please consider combining with proposed Hazard Policy 10. o Please clarify the intent of proposed Hazard Policy 50. Presumably redevelopment of existing development will require the entire structure to conform to applicable LCP standards, but the policy is not clear on this point.
o Proposed Hazard Policy 52 requires sea level rise buffer areas be added to new development if necessary to allow for the migration of wetlands and other shoreline habitats. Please describe how such buffer areas will be delineated, applied, and protected as same.
o The definition of shoreline within the hazard policies appears to exclude shoreline properties adjacent to rivers, streams and creeks, as well as properties that will be impacted by erosion and/or flooding by large storm events or over longer time periods due to rising sea levels. We recommend that the policies instead refer to coastal hazard areas so that properties that are potentially subject to coastal flood and erosion hazards both now and in the future will be reviewed for consistency with the hazard policies.

Again, we appreciate and commend the City on developing these draft coastal hazard policies and the related policy framework, and look forward to helping to refine the policies and approach through our ongoing collaboration on the City’s LCP update. It is clear from these policies that the City is taking the issues and problems associated with coastal hazards seriously, and in a way that advances the City’s approach to sea level rise and LCP planning. We hope these comments help move us forward in that regard. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me or Patrick Foster of my staff. Again, we greatly appreciate the ability to be a part of this important planning process and look forward to continued coordination and discussion of this important effort.

Sincerely,

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Packet Pg. 1433 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 7 Jeannine Manna
North Central Coast District Manager
California Coastal Commission
cc: Bonny O’Connor, City of Pacifica Planner
Attachments:

Attachment 1 – ESA memo to the City dated August 24, 2018 (memo 1) Attachment 2 – CCC comments on memo 1 dated August 31, 2018 Attachment 3 – ESA memo to the City also dated August 24, 2018 (memo 2)

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Packet Pg. 1434 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
November 22, 2019
City of Pacifica Planning Department
Attn: Tina Wehrmeister
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Consultation Draft Local Coastal Program Land Use Plan Update Dear Ms. Wehrmeister:

Thank you for the opportunity to review and comment on the City’s proposed draft update to the Local Coastal Program (LCP) Land Use Plan (LUP). As you know, the LUP is a key regulatory tool that implements the statewide goals and policies specified in the California Coastal Act to protect, restore, and enhance coastal resources at the local level, including by specifying the kinds, locations, and intensities of allowed development and applicable coastal resource protection requirements. Once the LUP and an accompanying Implementation Plan (IP) are certified by the Coastal Commission,1thus certifying an updated LCP overall, the updated LCP forms the basis and standard of review for future development within the City’s Coastal Zone.

Accordingly, the City’s current LCP update process offers an exciting opportunity to holistically and comprehensively envision Pacifica’s future and craft the process for how to achieve that vision. Given that importance, Commission staff has been actively and directly engaged with you and your staff to identify issues early and provide recommendations on how to approach the many complicated coastal resource policy decisions facing the City. We acknowledge the substantial time and energy the City has invested in developing this draft document and we greatly appreciate the efforts to coordinate and discuss with Commission staff.

In that vein, we are hopeful that these comments are understood in the manner in which intendednamely to provide as much helpful guidance from our perspective as possible at this juncture. As such, this letter provides a summary of some of the key issues we’ve identified thus far in our review of the draft document, as well as some broad recommendations for how to address these issues. Some of these issues we have discussed with you to-date, while others will be introduced for the first time in this letter.

Specific comments, as well as some line-edits, have been provided on each of the draft LUP chapters in the attached documents. However, given our limited review time, these comments and edits should not be considered final or comprehensive. Lastly, this letter is intended to respond to the City’s letter dated October 31, 2019 to clarify Commission staff’s general perspective regarding the consultation process thus far.

1 The standard of review for an LUP is Chapter 3 of the Coastal Act, and for an IP is the certified LUP.

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Packet Pg. 1435 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
2 Consultation Process
With regard to the letter sent to Commission staff regarding the LCLUP consultation process, we note that the City of Pacifica originally initiated the LCLUP Update process by developing a Consultation Draft in 2014. While this draft document was transmitted to Commission staff for initial review, the City halted the LCLUP process due to time and budgetary constraints. As a result, Commission staff did not conduct a thorough review nor provide written comments to the City at that time. The City began to reengage in the LCLUP update process again in 2018 through the development of an administrative draft of the LUP Coastal Hazards Chapter in conjunction with the development of a vulnerability assessment and adaptation plan. Throughout the multiple rounds of review prior to City action, Commission staff sent three comment letters (dated August 29, 2018, August 31, 2018, and October 19, 2018) on the Hazard Policy Update, all within the abbreviated timeframes requested by City staff, as well as attended a number of public meetings. Through all of these communications, Commission staff noted a willingness to work with the City to identify alternative, context-specific approaches to resolve significant concerns with the hazard policies as drafted (see included attachments). Other than a few coordination calls, Commission staff did not receive specific requests from the City to meet staff-to-staff to further engage at that juncture. Following action by the City Council approving the draft hazard policies for incorporation into the full LCLUP update, no further progress was made on the LCP update, as reflected in LCP grant progress reports received from the City during early 2019.

In summer and early fall of 2019, the City began to recirculate a new LCLUP Consultation Draft, starting with the version originally developed in 2014, incorporating the latest draft Hazards Policy Chapter approved by the City Council. While the City initially emailed Commission staff in August regarding their plans for revising the draft LCLUP recirculation schedule, there was no further discussion with Commission staff regarding the revised timeline to ensure it would be workable and provide for adequate review and staff to staff coordination prior to the draft going before the City Council and Planning Commission for feedback. In an effort to improve coordination on the LUP update process to ensure adequate and meaningful consultation could occur, Commission staff reached out to the City about the anticipated schedule and how to accommodate essential timeframes for both agencies.

At that time, the City relayed that they were sticking to an accelerated timeline to meet grant requirements, but did agree to modify the deadline for comments so as to provide Commission staff with 30-working days to review the draft document as opposed to 30-calendar days. During this review period City and Commission staff have met various times, both in-person and over the phone, and agreed the meetings have been productive. Commission staff continues to commend City staff for the hard work and coordination to-date, and it is our hope this cooperative process can continue. In our experience, this type of early coordination helps to ensure a smoother LCP certification process, including streamlining review and resolution of issues upon ultimate submittal to the Coastal Commission. As such, we will continue to honor our commitments to provide feedback to the City as requested, as we have previously done, regardless of existing workload constraints and staff turnover.

Draft LCLUP Update Feedback and Recommendations
First, in general, the proposed LUP update provides a good starting point by which the City can evaluate development in the coastal zone through assessing up-to-date information and revised policies that address current issues facing the City and reflect the City’s present day vision. However, at a broad level, the document requires numerous clarifications and details added to the policy language to make

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Packet Pg. 1436 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
3 the LUP as user-friendly as possible, manage development expectations in certain areas of the City with known constraints, and ensure consistency with the resource protection policies of the Coastal Act.

Additionally, there is significant overlap between policies in different chapters that creates redundancy, most notably between the Natural Hazards and Coastal Resilience Chapters. In our view, with added refinements and focus, the LUP will offer more clarity and ease of use, ensure adequate protections for sensitive habitats and public access to the beach, and minimize hazard risks to new development. We strongly recommend that the document be reviewed to add detail and clarify language where needed, eliminate policy redundancies, both within and among chapters, and to group related policies accordingly, as discussed in meetings and addressed in this letter and in the attached document edits.

Additionally, in 2019, the Coastal Commission unanimously adopted its first environmental justice policy to provide guidance for Commissioners, staff, and the public on how the Commission will implement its environmental justice authority and integrate the principles of environmental justice, equality, and social equity into all aspects of the Commission’s program and operations. While the current draft LUP mentions environmental justice in terms of the City Council’s Goals and in policy CR-I-2, we recommend the City consider adding additional policies that will more fully address environmental justice issues that pertain to coastal resources as well as participation in the decision making process to help to reduce disparate impacts on vulnerable communities resulting from new development.

In terms of the Land Use and Development chapter, we recommend: 1) ensuring that all figures, numerical references, and maps regarding existing and proposed land use patterns are accurate and upto-date; 2) adding language regarding maps/diagrams to indicate that they are illustrative and for planning purposes only; 3) adding directive policies requiring new development to demonstrate that there are adequate public services to serve such development, examples of which were previously provided to the City; 4) adding up-to-date neighborhood-specific traffic, hazard, visual character, and coastal planning constraints as outlined in the 1980 version of the LUP; 5) including further detail about sites with known development constraints (i.e. the Quarry and Pedro Point field); 6) prohibiting increases in density of land use in hazard and sensitive resource areas; 7) redesignating areas with severe development constraints to the Conservation land use designation, including lots adjacent to the bluff edge where homes and apartments were recently removed; and 8) providing a figure that indicates all proposed changes to existing certified land use designations. With regard to the Public Access Chapter, we recommend: 1) adding more policies that specifically bolster and speak to coastal access, as opposed to public access more generally; 2) ensuring that coastal access will be able to adapt in response to coastal hazards including in areas with and without shoreline protection; and 3) including all existing coastal access points throughout the City including lateral and vertical trails required as CDP requirements, and public parking lots.

Within the Environmental and Scenic Resources Chapter, in general, more recent sources and information should be referenced, and internal references should only be made to maps and documents that are part of the LUP rather than to other City documents. More specifically, the relationship between wetlands and environmentally sensitive habitat areas (ESHA) warrants further discussion. For example, while not all wetlands are ESHA, wetland policies are applied to all wetland areas, which should be stated explicitly. Further, the draft LUP should cite and recognize Coastal Commission regulations that

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Packet Pg. 1437 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
4 more clearly articulate the requirement for a one-parameter criteria for wetland delineations which is applied in the coastal zone, contrasting this with the USACE three-parameter approach. It should also be noted that because the National Wetlands Inventory (and similarly, any map provided or prepared by the City) are not all comprehensive, on-the-ground conditions will prevail. Discussions on ESHA should also: 1) include policies on ‘especially valuable habitat’ as defined by the Coastal Act, which captures natural resources not considered rare but that have some other particular value (e.g. unusually pristine conditions, vegetation supporting other sensitive species, wildlife corridors, etc.); 2) remove references to degrees of habitat value without definition, as an area can be severely degraded and still constitute ESHA if it can be restored and/or is supporting sensitive resources; 3) categorically designate dune habitats as ESHA; 4) reorganize and bolster the ‘Plant Communities and Wildlife Habitats’ section for consistency in terms of vegetation types and levels of specificity and relevance; 5) consider habitat not defined by vegetation communities including bluff faces, offshore rocks and islets, and dunes; 6) articulate why seasonal wetlands are included under ESHA; and 7) explain that all riparian habitat should be treated as ESHA, while clearly articulating the differences between streams, creeks, riparian vegetation, and riparian corridors.

In addition, minimum buffer requirements should be established for sensitive habitat areas including wetlands and ESHA, including streams, and any uses allowed within such buffers should be specified.

Moreover, a defined limit should be established for any exceptions to such minimum buffer requirements resulting in a buffer reduction. 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 wetland and/or ESHA and will be compatible with the continuance of the wetland and/or 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 wetland and/or ESHA. For both perennial and intermittent streams, buffers should be measured from the outer edge of riparian vegetation where it exists; if it does not, the buffer should be measured from the edge of the bank; and if there is no bank, the buffer should be measured from the mid-line of the watercourse. With respect to impacts and mitigation, impacts to coastal resources must always first be avoided to the maximum extent feasible, then minimized, then mitigated for. As such, compensatory mitigation requirements for impacts to sensitive habitats that cannot be avoided should be addressed in this document. Further, the City should consider defining temporary versus permanent impacts- where temporary impacts are those that would be resolved within 12 months, and do not include earthwork or other significant disturbance, with impacted vegetation restored to equal or better including that similar age/size structure of the community is restored.

The Environmental and Scenic Resources Chapter should also reference both perennial and nonperennial resources in any discussion on creeks and other waterways, should further develop the discussion and policies on marine resources (including beaches, rocky intertidal and reef habitats, softbottom habitats, and offshore rocks), and should avoid referencing “restoring” beaches unless it is intended to include ecological, as well as mineral and physical, resources. Additionally, instead of referencing restrictions on invasive plant species, we recommend prohibiting the use of any California Invasive Plant Council (Cal-IPC)-listed species with a status of high or moderate, or identified as locally-threatening under the limited alert or watch status, and to establish requirements for their

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Packet Pg. 1438 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
5 abatement from sites on a project-by-project basis as well as through broader restoration efforts. Lastly, there is the potential to frame some of the issues in the chapter under a theme of ‘water security,’ including concepts such as groundwater recharge, use of recycled water, etc.

As mentioned above, there are numerous redundancies between the “natural shorelines” section in the Environmental and Scenic Resources chapter and the content of the Natural Hazards and Coastal Resilience chapters. We recommend instead framing the protection of natural shorelines as “preservation of natural shore dynamics.” In addition to these redundancies, feedback on adaptation and hazard policies expressed in the aforementioned comment letters in 2018 (enclosed) was not incorporated into the draft policies, and as such the main themes are reiterated here. Specific details on policy language that should be incorporated can be found in the enclosed letters, including topics such as design, mitigation, and removal of shoreline protection structures, as well as triggers for removal of threatened development.

In general, the hazard and coastal resilience policies seem to recommend an approach for protecting development throughout the City with hard armoring, supplemented by potential beach nourishment, with no policies that would allow the City to prepare to relocate structures out of hazardous areas. The emphasis on armoring would likely result in the loss of beaches and their associated public access, recreation, economic, and habitat benefits as sea levels rise, and would leave the City unprepared for sea level rise in the long term. While armoring may protect existing development in the short- to mediumterm, such an approach may not be technically or economically feasible in all areas and/or over longer timeframes, and would not, by itself, be consistent with Coastal Act requirements to ensure protection of coastal resources. Policies should be framed to better balance the dual Coastal Act goals of ensuring safe development and protecting coastal resources such as beaches, habitat, and public access and recreation, as sea level rises over time. As discussed in our previous comment letters and in recent coordination calls, Commission staff would be happy to work with City staff in developing a more appropriate balance of short- and long-term approaches, including those that would consider the use of shoreline armoring.

Additionally, the proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue if technically feasible, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support such an approach as a primary adaptation strategy in this proposed LCP update. In short, we think that policies that rely so heavily on nourishment, particularly in the shorter term, need to be supported by more thorough quantitative data.

In addition, we have previously identified appropriate definitions of “redevelopment” and “existing structures” or “existing development” that should be incorporated into the draft. “Existing development” should be defined as a structure legally authorized prior to the effective date of the Coastal Act, i.e.- January 1, 1977, including as it is identified in the Commission’s Sea Level Rise Policy Guidance.

Instead of defining redevelopment, the draft defines ‘new development’ as development on a previously

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Packet Pg. 1439 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
6 vacant parcel, which would mean no current structures would ever have to be brought into compliance with policies if substantially redeveloped and as such does not align with the Coastal Act or the Commission’s guidance on sea level rise planning.

Finally, as discussed above, we have reviewed each of the draft LUP chapters and provided City staff with our suggestions and recommendations via in person meetings and phone calls on each chapter. In closing, we again thank you and your staff for the thoughtful and collaborative work done to date, and appreciate and commend the City for moving forward with the sometimes difficult, but important, task of updating the LCP’s LUP. We also very much look forward to continued collaboration, and helping the City to refine the draft LUP, and a future draft IP, including in the ways identified in this letter. We hope these comments help move us forward to this end. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me.

Sincerely,
Julia Koppman Norton
Coastal Planner
North Central Coast District Office
California Coastal Commission
cc: Kevin Woodhouse, City of Pacifica City Manager
Encl.: CCC Letter to City, dated August 29, 2018
CCC Letter to City, dated August 31, 2018
CCC Letter to City, dated October 19, 2018
LCP Draft Update, Ch. 1-6 & Appendices, with edits

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Packet Pg. 1440 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
February 19, 2020
City of Pacifica Planning Department
Attn: Tina Wehrmeister
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Post-Consultation Draft Local Coastal Program Land Use Plan Update Dear Ms. Wehrmeister:

Thank you for the opportunity to review and comment on the City’s Local Coastal Program Land Use Plan (LCLUP) post-consultation draft. We would like to commend you for the hard work that went into preparing this draft and acknowledge the effort made to respond to comments we submitted in our previous letter to you dated November 22, 2019 (attached). We recognize that the City has carefully gone through the aforementioned comments and line-item edits and has modified the draft LCLUP to accept some of our recommendations. This letter is intended to provide a summary of the remaining key issues we’ve identified in the post-consultation draft. The items discussed below should not be considered final or comprehensive given our limited review time, but are meant to provide guidance on the more challenging topics at this point in the process of our ongoing effort to coordinate with the City.

It is our understanding that the City Council will be considering the post-consultation draft at the public hearing on February 24, 2020. As such, please deliver this comment letter to the City Council for consideration prior to the hearing in question.

As indicated above, we understand City staff has incorporated some, but not all, of Commission staff’s edits and feedback into the LCLUP post-consultation draft. We continue to recommend that any additional outstanding edits and comments provided in our November letter be incorporated and/or addressed in the final draft LCLUP approved by the City Council. In particular, recommendations and specific language provided on the Environmental and Scenic Resources Chapter should be used to further modify the information and policies as currently drafted. Specifically, we recommend that the City include the more nuanced language we recommended regarding the following topics: recognition of non-perennial resources within the creeks, wetlands, and coastal waters implementing policies, riparian buffers (ER-I-1), potential environmentally sensitive habitat area (ESHA) designation (Section 4.3, “Plant Communities & Wildlife Habitat”), intermittent creeks and streams (ER-G-7), verification of ESHA (ER-I-23), and management of ESHA (ER-I-24) to ensure protection of sensitive habitats and species throughout the City consistent with the Coastal Act resource protection policies.

With regards to the natural hazards and coastal resilience policies (Chapters 5 & 6), the City has modified and/or added new definitions for “new development,” “existing structure,” “substantial exterior structural modification (SESM)” (the City’s proposed definition to qualify the concept of “redevelopment”), and “shoreline.” The application of these new definitions throughout the proposed policies raises inconsistencies with Coastal Act hazard policies 30253 and 30235 which require new

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Packet Pg. 1441 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
2 development to ensure long-term structural integrity, minimize future risk, and to avoid landform altering protective measures; and, with the exception of coastal-dependent uses, limit the construction of shoreline protection structures to that required to protect existing structures or public beaches in danger from erosion when designed to eliminate or mitigate adverse impacts to shoreline sand supply.

Specifically, these new definitions limit application of the City’s hazard policies depending on the nature and location of the proposed development, and expand allowances for shoreline protection as further described below.

First, the definition of “shoreline” as currently presented would only include bluff edges and beach areas at the intersection of the ocean or sea with land. As such, policies that reference “development on the shoreline” (CR-I-42: Technical Reports) or “shoreline development” (CR-I-43: Siting and Design and CR-I-44: Assumption of Risk by Private Landowners) would be limited to shoreline protection structures or similar development located in this very narrowly defined area. However, as we understand through discussions with you and your staff, the City intends for these policies to apply to development located on any parcels that have a shoreline frontage, and as such, we recommend the City modify the definition and the corresponding policies to better reflect this intent. However, even with such clarifications, CR-I-42 would not apply to development located on low-lying shoreline or blufftop land inland of shorefront parcels even if the development would be subject to coastal hazards over its anticipated life. Therefore, development proposals in these areas would be permitted without adequately accounting for potential coastal hazards through a technical evaluation, demonstrating such development will avoid and minimize hazards, and mitigating for any effects the development may have on coastal resources over time, inconsistent with Coastal Act hazard policies. We continue to recommend that any development proposed in coastal hazard zones, defined as anywhere mapped by the City’s coastal vulnerability maps, evaluate such hazards consistent with the requirements of CR-I-42. Further, this policy should be expanded so that the required evaluation examines hazards posed to the development with and without any existing shoreline protection structures.

Second, we commend the City for including language in CR-I-43 requiring that new development be sited and designed safe from coastal hazards for 100 years without shoreline protection structures, and include conditions waiving rights to shoreline protection, and where necessary, removal and restoration.

However, as drafted, this policy would only apply to new development on vacant shoreline properties, which are extremely limited in Pacifica. In addition, similar to CR-I-42 discussed above, this policy would not apply to new development on vacant land just inland of shorefront parcels if separated by a public road, or other lands, even if the development would be subject to known hazards over its anticipated life, inconsistent with Coastal Act hazard policies. Further, the definition of “new development” specifically excludes structures authorized pursuant to the SESM exclusions such as nonstructural improvements to existing structures, any development already protected by an existing shoreline protection structure, existing structures replaced pursuant to Section 30610, and complete demolition and rebuild of single family residences. Thus, this policy would not apply to improvements or redevelopment of existing structures in the majority of the City. This will essentially result in a continued pattern of development and redevelopment in hazardous areas both with and without existing shoreline protection.

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Packet Pg. 1442 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
3 Even if it is the City’s intent to continue to allow existing development to redevelop in hazardous areas, the assumption of risk policy (CR-I-44) similarly only applies to development on shorefront lots. Thus, redevelopment of and improvements to existing structures will continue in hazard areas without the property owners being required to accept the full risk of such development and without providing for adequate mitigation to ensure the development will not impact coastal resources over time. Thus, we continue to recommend that CR-I-43 and CR-I-44 apply to all development proposed in coastal hazard zones. If the City would like to allow for exceptions to setbacks, we recommend accomplishing this goal by first evaluating the hazard, examining siting and design options to avoid or minimize the hazard, allowing for exceptions pursuant to CR-I-49 (Protection of Private Property in Hazard Areas), and then including adequate mitigation for impacts to coastal resources over time by requiring an expanded version of CR-I-44 (Assumption of Risk by Private Landowners) that recognizes the development is located in a hazardous area, or in an area that may become hazardous in the future, assumes the risks of injury and damage from such hazards in connection with the permitted development, unconditionally waives any claim of damage or liability against the City, indemnifies and holds the City harmless with respect to approval of the project, recognizes the property owner has no rights under Coastal Act Section 30235 and related LCP policies to shoreline armoring in the future, that sea level rise could render it difficult or impossible to provide services to the site, that the boundary between public tidelands and private land may move inland causing the structure to be located on public land and thus subject to removal, that any future encroachment must be removed unless determined legally permissible pursuant to the Coastal Act, and that the structure may need to be removed or relocated if it becomes unsafe or substantially damaged.

Third, the definition of “existing development” refers to development constructed or permitted prior to the certification date of this LCLUP and the definition of “SESM” measures modifications to existing structures cumulatively from the same date. In addition, the exclusions provided in the definition of “SESM” and the reference to these exclusions in both the “existing structure” and “new development” definitions in effect allow the vast majority of development in the City a new or expanded entitlement to shoreline protection, including reconstruction of existing protection, and preclude such development from the need to mitigate for unavoidable coastal resource impacts caused by new construction or perpetuation of shoreline protection structures. Lastly, the City has included an exclusion for shoreline protection itself within the SESM definition which allows for reconstruction, repair, and maintenance of shoreline protection structures as long as the height and length are not expanded more than 10 percent.

As we understand, under these proposed definitions and associated policies, the City would allow for unlimited redevelopment on sites built or permitted prior to certification of this drafted LCLUP that are protected by an existing shoreline protective structure. Further, the proposed policies would allow new, redeveloped and augmented shoreline protection structures for all existing development defined as those structures constructed or permitted prior to the certification date of the LCLUP or authorized pursuant to the SESM exclusions. Lastly, the policies would allow for full reconstruction of existing shoreline protection in perpetuity without conforming to the proposed hazard policies as long as it does not increase the height or length by 10 percent.

These definitions and associated policies are inconsistent with the goals of the Coastal Act, which, as discussed in the Commission’s adopted Sea Level Rise Policy Guidance, provide that new development or redevelopment constructed after January 1, 1977 is not entitled to shoreline protection and must be

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Packet Pg. 1443 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
4 built safe from coastal hazards for its anticipated life. As such, Commission staff continues to recommend that the City define existing structure for the purpose of shoreline protection as a structure legally authorized prior to the effective date of the Coastal Act (i.e. January 1, 1977). In addition, existing structures redeveloped since that date should not be entitled to shoreline protection themselves, even though they may de facto be protected by an existing shoreline protective device.

As has been discussed throughout this process, Commission staff is open to discussing options for exceptions to allow for continued reliance on shoreline armoring for structures built or redeveloped after 1977 in certain circumstances. However, such exceptions will require a case by case evaluation considering factors such as: up and down coast patterns of development and existing shoreline protection, existing public infrastructure, access to support the development, alternatives to address the hazards including relocation, options for short and long term planning, and takings of private property.

Further, any exception would be contingent upon specific adaptation and policy options that ensure that coastal resources would be protected over time. These include at a minimum, an expanded assumption of risk, waiver of liability, and disclosures that shoreline armoring may not be able to provide safety in perpetuity, that the City may not be able to continue to provide services to hazardous locations, and that development may need to be removed at some point in the future to ensure safety and/or to meet other adaptation goals. Additional options may include requirements for continued planning, development of specific phased adaptation approaches along with necessary funding mechanisms, and requirements for alternative public access (e.g., integrating lateral access with shoreline armoring).

Additional comments on the revised Natural Hazards and Coastal Resilience Chapters include:
 Accurate neighborhood-specific hazard information should be incorporated into each neighborhood section, as indicated in our previous November comment letter. While some information was added to this end, additional details regarding erosion rates and patterns as demonstrated in the 1980 version of the LUP should be incorporated and updated, where necessary.
 Section 6.6. The sub-area policies and programs include triggers by which each of the policies are intended to be implemented. The introductory statement indicates that the triggers do not account for regulatory permitting, approvals, or financing, and that planning should be conducted in advance of the triggers. Alternatively, Commission staff recommends this document include triggers for planning purposes.
 CR-I-8, CR-I-9, CR-I-55. All policies should stipulate that the “least environmentally damaging alternative” be implemented, as indicated in prior edits. While some policies refer back to Coastal Act Section 30235 which stipulates the least environmentally damaging alternative is preferred, not all do, so Commission staff recommends each of these policies explicitly state as much.
 CR-I-2. The City intends to implement its Sea Level Rise Adaptation Plan through the policies in this chapter. Part c) of this policy stipulates that development in Coastal Vulnerability Zones may be approved consistent with the sub-area policies if the “project will not pose unacceptable risks to life or property.” Commission staff recommends that Part c) be amended to state that the “project will not pose unacceptable risks to life or property for the anticipated life of the development.” In addition, Commission staff recommends removing the italics as they constitute the bulk of this policy.

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Packet Pg. 1444 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
5  CR-I-3. Thresholds for reassessing the City’s Adaptation Plan through monitoring shoreline change should account for adequate setbacks from inland development based on erosion rates and a factor of safety.
 CR-I-5. The City intends to adopt a Shoreline Mitigation Program to address the coastal resource impacts of existing and future shoreline protection projects in the City within three years of LCLUP certification. Input from the Commission and the public will be important for the development of this program consistent with Coastal Act requirements and the public’s vision.

Please amend this policy to indicate the Shoreline Mitigation Program shall be reviewed and certified by the Commission through an LCP amendment. We also recommend that the City consider requiring the development of public access facilities or in-lieu fees as mitigation for approval of new, reconstruction, and repair and maintenance of shoreline protection structures, as part of the proposed Program.
 “Sharp Park, West Fairway Park and Mori Point” sub-area & CR-I-22. Commission staff notes that the levee that protects the Sharp Park Golf Course was built in the 1940’s, rather than the 1980’s as indicated in this draft. In addition, policy language should not reference specific permit provisions, but rather should speak to compliance with prior permit conditions and/or existing legal obligations pursuant to the California Coastal Act as is more generally done in Policy CR-I14.  CR-I-14. Please note there are two versions of CR-I-14. The policy on regional sediment management should indicate who will participate (i.e. The City).  CR-I-44. The majority of the edits made to the “Assumption of Risk by Private Landowners” were struck out by the City. Commission staff continues to recommend the City broaden the assumption of risk and waiver of liability per prior edits.  CR-I-49. Commission staff understands the City’s intent to protect private property in hazardous areas to allow for the minimum economic use of a property so as to avoid an unconstitutional taking of private property, but recommends adding that this is subject to development maintaining safe access and assuring there is infrastructure to serve it for the anticipated life of the development.
 CR-I-52. This policy should also apply to condominium development.  CR-I-54. This policy states that existing shoreline protection structures may be repaired and maintained until the development they are protecting is removed or no longer requires shoreline protection. Please amend this to account for redevelopment/substantial exterior structural modification. In addition, Commission staff notes this policy language is internally inconsistent, as it references Section 30235 of the Coastal Act, in which “existing structures” is evaluated as prior to January 1, 1977 rather than prior to certification of this LCLUP.  CR-I-57. Edits to this policy direct that new or reconstructed shoreline protection structures fully mitigate for coastal resource impacts where impacts are unavoidable. However, reconstruction of shoreline protection structures is included in the exceptions clause of the “substantial exterior structural modification” definition. Please ensure that both new and reconstructed shoreline protection is mitigated for by removing reconstruction of shoreline protection structures from the list of exceptions.
 Definitions. The City should clarify whether or not the exceptions in SESM definition apply throughout the City or just in coastal hazard areas.

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Packet Pg. 1445 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
6  NH-I-10. Requires geotechnical studies for areas within 50 feet of a coastal bluff, but this should be clarified and expanded to account for increased erosion from sea level rise both with and without existing shoreline protection for development within 300 feet of a bluff edge.  NH-I-17. More generally includes similar requirements to the Coastal Act, but again, with the proposed definition of “new development” would limit application of this policy to areas where there is no existing development.

Lastly, it has come to our attention that there are numerous shoreline protection structures in the City, both publicly and privately owned, that are unpermitted and/or have existing permits that have since expired. Please take note of this in considering policies regarding shoreline protection structures that provide allowances for active, permitted shoreline protection structures specifically.

As discussed above, this letter is not an exhaustive list of comments on the post-consultation draft of the LCLUP, but rather provides an overview of overarching feedback at this time. We again thank you and your staff for the thoughtful and collaborative work done to date, and appreciate and commend the City for moving forward with the sometimes difficult, but important, task of updating the LCP’s LUP. We look forward to continued collaboration, and helping the City to refine the draft LUP, and a future draft IP, including in the ways identified in this letter. We hope these comments help move us forward to this end. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me.

Sincerely,
Jeannine Manna
District Manager
North Central Coast District Office
California Coastal Commission
cc: Kevin Woodhouse, City of Pacifica City Manager
Encl.: CCC Letter to City, dated August 29, 2018
CCC Letter to City, dated August 31, 2018
CCC Letter to City, dated October 19, 2018
CCC Letter to City, dated November 22, 2019

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Packet Pg. 1446 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 1448 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 1449 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 1451 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 1452 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
February 19, 2020
City of Pacifica Planning Department
Attn: Tina Wehrmeister
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Post-Consultation Draft Local Coastal Program Land Use Plan Update Dear Ms. Wehrmeister:

Thank you for the opportunity to review and comment on the City’s Local Coastal Program Land Use Plan (LCLUP) post-consultation draft. We would like to commend you for the hard work that went into preparing this draft and acknowledge the effort made to respond to comments we submitted in our previous letter to you dated November 22, 2019 (attached). We recognize that the City has carefully gone through the aforementioned comments and line-item edits and has modified the draft LCLUP to accept some of our recommendations. This letter is intended to provide a summary of the remaining key issues we’ve identified in the post-consultation draft. The items discussed below should not be considered final or comprehensive given our limited review time, but are meant to provide guidance on the more challenging topics at this point in the process of our ongoing effort to coordinate with the City.

It is our understanding that the City Council will be considering the post-consultation draft at the public hearing on February 24, 2020. As such, please deliver this comment letter to the City Council for consideration prior to the hearing in question.

As indicated above, we understand City staff has incorporated some, but not all, of Commission staff’s edits and feedback into the LCLUP post-consultation draft. We continue to recommend that any additional outstanding edits and comments provided in our November letter be incorporated and/or addressed in the final draft LCLUP approved by the City Council. In particular, recommendations and specific language provided on the Environmental and Scenic Resources Chapter should be used to further modify the information and policies as currently drafted. Specifically, we recommend that the City include the more nuanced language we recommended regarding the following topics: recognition of non-perennial resources within the creeks, wetlands, and coastal waters implementing policies, riparian buffers (ER-I-1), potential environmentally sensitive habitat area (ESHA) designation (Section 4.3, “Plant Communities & Wildlife Habitat”), intermittent creeks and streams (ER-G-7), verification of ESHA (ER-I-23), and management of ESHA (ER-I-24) to ensure protection of sensitive habitats and species throughout the City consistent with the Coastal Act resource protection policies.

With regards to the natural hazards and coastal resilience policies (Chapters 5 & 6), the City has modified and/or added new definitions for “new development,” “existing structure,” “substantial exterior structural modification (SESM)” (the City’s proposed definition to qualify the concept of “redevelopment”), and “shoreline.” The application of these new definitions throughout the proposed policies raises inconsistencies with Coastal Act hazard policies 30253 and 30235 which require new

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Packet Pg. 1453 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
2 development to ensure long-term structural integrity, minimize future risk, and to avoid landform altering protective measures; and, with the exception of coastal-dependent uses, limit the construction of shoreline protection structures to that required to protect existing structures or public beaches in danger from erosion when designed to eliminate or mitigate adverse impacts to shoreline sand supply.

Specifically, these new definitions limit application of the City’s hazard policies depending on the nature and location of the proposed development, and expand allowances for shoreline protection as further described below.

First, the definition of “shoreline” as currently presented would only include bluff edges and beach areas at the intersection of the ocean or sea with land. As such, policies that reference “development on the shoreline” (CR-I-42: Technical Reports) or “shoreline development” (CR-I-43: Siting and Design and CR-I-44: Assumption of Risk by Private Landowners) would be limited to shoreline protection structures or similar development located in this very narrowly defined area. However, as we understand through discussions with you and your staff, the City intends for these policies to apply to development located on any parcels that have a shoreline frontage, and as such, we recommend the City modify the definition and the corresponding policies to better reflect this intent. However, even with such clarifications, CR-I-42 would not apply to development located on low-lying shoreline or blufftop land inland of shorefront parcels even if the development would be subject to coastal hazards over its anticipated life. Therefore, development proposals in these areas would be permitted without adequately accounting for potential coastal hazards through a technical evaluation, demonstrating such development will avoid and minimize hazards, and mitigating for any effects the development may have on coastal resources over time, inconsistent with Coastal Act hazard policies. We continue to recommend that any development proposed in coastal hazard zones, defined as anywhere mapped by the City’s coastal vulnerability maps, evaluate such hazards consistent with the requirements of CR-I-42. Further, this policy should be expanded so that the required evaluation examines hazards posed to the development with and without any existing shoreline protection structures.

Second, we commend the City for including language in CR-I-43 requiring that new development be sited and designed safe from coastal hazards for 100 years without shoreline protection structures, and include conditions waiving rights to shoreline protection, and where necessary, removal and restoration.

However, as drafted, this policy would only apply to new development on vacant shoreline properties, which are extremely limited in Pacifica. In addition, similar to CR-I-42 discussed above, this policy would not apply to new development on vacant land just inland of shorefront parcels if separated by a public road, or other lands, even if the development would be subject to known hazards over its anticipated life, inconsistent with Coastal Act hazard policies. Further, the definition of “new development” specifically excludes structures authorized pursuant to the SESM exclusions such as nonstructural improvements to existing structures, any development already protected by an existing shoreline protection structure, existing structures replaced pursuant to Section 30610, and complete demolition and rebuild of single family residences. Thus, this policy would not apply to improvements or redevelopment of existing structures in the majority of the City. This will essentially result in a continued pattern of development and redevelopment in hazardous areas both with and without existing shoreline protection.

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Packet Pg. 1454 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
3 Even if it is the City’s intent to continue to allow existing development to redevelop in hazardous areas, the assumption of risk policy (CR-I-44) similarly only applies to development on shorefront lots. Thus, redevelopment of and improvements to existing structures will continue in hazard areas without the property owners being required to accept the full risk of such development and without providing for adequate mitigation to ensure the development will not impact coastal resources over time. Thus, we continue to recommend that CR-I-43 and CR-I-44 apply to all development proposed in coastal hazard zones. If the City would like to allow for exceptions to setbacks, we recommend accomplishing this goal by first evaluating the hazard, examining siting and design options to avoid or minimize the hazard, allowing for exceptions pursuant to CR-I-49 (Protection of Private Property in Hazard Areas), and then including adequate mitigation for impacts to coastal resources over time by requiring an expanded version of CR-I-44 (Assumption of Risk by Private Landowners) that recognizes the development is located in a hazardous area, or in an area that may become hazardous in the future, assumes the risks of injury and damage from such hazards in connection with the permitted development, unconditionally waives any claim of damage or liability against the City, indemnifies and holds the City harmless with respect to approval of the project, recognizes the property owner has no rights under Coastal Act Section 30235 and related LCP policies to shoreline armoring in the future, that sea level rise could render it difficult or impossible to provide services to the site, that the boundary between public tidelands and private land may move inland causing the structure to be located on public land and thus subject to removal, that any future encroachment must be removed unless determined legally permissible pursuant to the Coastal Act, and that the structure may need to be removed or relocated if it becomes unsafe or substantially damaged.

Third, the definition of “existing development” refers to development constructed or permitted prior to the certification date of this LCLUP and the definition of “SESM” measures modifications to existing structures cumulatively from the same date. In addition, the exclusions provided in the definition of “SESM” and the reference to these exclusions in both the “existing structure” and “new development” definitions in effect allow the vast majority of development in the City a new or expanded entitlement to shoreline protection, including reconstruction of existing protection, and preclude such development from the need to mitigate for unavoidable coastal resource impacts caused by new construction or perpetuation of shoreline protection structures. Lastly, the City has included an exclusion for shoreline protection itself within the SESM definition which allows for reconstruction, repair, and maintenance of shoreline protection structures as long as the height and length are not expanded more than 10 percent.

As we understand, under these proposed definitions and associated policies, the City would allow for unlimited redevelopment on sites built or permitted prior to certification of this drafted LCLUP that are protected by an existing shoreline protective structure. Further, the proposed policies would allow new, redeveloped and augmented shoreline protection structures for all existing development defined as those structures constructed or permitted prior to the certification date of the LCLUP or authorized pursuant to the SESM exclusions. Lastly, the policies would allow for full reconstruction of existing shoreline protection in perpetuity without conforming to the proposed hazard policies as long as it does not increase the height or length by 10 percent.

These definitions and associated policies are inconsistent with the goals of the Coastal Act, which, as discussed in the Commission’s adopted Sea Level Rise Policy Guidance, provide that new development or redevelopment constructed after January 1, 1977 is not entitled to shoreline protection and must be

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Packet Pg. 1455 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
4 built safe from coastal hazards for its anticipated life. As such, Commission staff continues to recommend that the City define existing structure for the purpose of shoreline protection as a structure legally authorized prior to the effective date of the Coastal Act (i.e. January 1, 1977). In addition, existing structures redeveloped since that date should not be entitled to shoreline protection themselves, even though they may de facto be protected by an existing shoreline protective device.

As has been discussed throughout this process, Commission staff is open to discussing options for exceptions to allow for continued reliance on shoreline armoring for structures built or redeveloped after 1977 in certain circumstances. However, such exceptions will require a case by case evaluation considering factors such as: up and down coast patterns of development and existing shoreline protection, existing public infrastructure, access to support the development, alternatives to address the hazards including relocation, options for short and long term planning, and takings of private property.

Further, any exception would be contingent upon specific adaptation and policy options that ensure that coastal resources would be protected over time. These include at a minimum, an expanded assumption of risk, waiver of liability, and disclosures that shoreline armoring may not be able to provide safety in perpetuity, that the City may not be able to continue to provide services to hazardous locations, and that development may need to be removed at some point in the future to ensure safety and/or to meet other adaptation goals. Additional options may include requirements for continued planning, development of specific phased adaptation approaches along with necessary funding mechanisms, and requirements for alternative public access (e.g., integrating lateral access with shoreline armoring).

Additional comments on the revised Natural Hazards and Coastal Resilience Chapters include:
 Accurate neighborhood-specific hazard information should be incorporated into each neighborhood section, as indicated in our previous November comment letter. While some information was added to this end, additional details regarding erosion rates and patterns as demonstrated in the 1980 version of the LUP should be incorporated and updated, where necessary.
 Section 6.6. The sub-area policies and programs include triggers by which each of the policies are intended to be implemented. The introductory statement indicates that the triggers do not account for regulatory permitting, approvals, or financing, and that planning should be conducted in advance of the triggers. Alternatively, Commission staff recommends this document include triggers for planning purposes.
 CR-I-8, CR-I-9, CR-I-55. All policies should stipulate that the “least environmentally damaging alternative” be implemented, as indicated in prior edits. While some policies refer back to Coastal Act Section 30235 which stipulates the least environmentally damaging alternative is preferred, not all do, so Commission staff recommends each of these policies explicitly state as much.
 CR-I-2. The City intends to implement its Sea Level Rise Adaptation Plan through the policies in this chapter. Part c) of this policy stipulates that development in Coastal Vulnerability Zones may be approved consistent with the sub-area policies if the “project will not pose unacceptable risks to life or property.” Commission staff recommends that Part c) be amended to state that the “project will not pose unacceptable risks to life or property for the anticipated life of the development.” In addition, Commission staff recommends removing the italics as they constitute the bulk of this policy.

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Packet Pg. 1456 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
5  CR-I-3. Thresholds for reassessing the City’s Adaptation Plan through monitoring shoreline change should account for adequate setbacks from inland development based on erosion rates and a factor of safety.
 CR-I-5. The City intends to adopt a Shoreline Mitigation Program to address the coastal resource impacts of existing and future shoreline protection projects in the City within three years of LCLUP certification. Input from the Commission and the public will be important for the development of this program consistent with Coastal Act requirements and the public’s vision.

Please amend this policy to indicate the Shoreline Mitigation Program shall be reviewed and certified by the Commission through an LCP amendment. We also recommend that the City consider requiring the development of public access facilities or in-lieu fees as mitigation for approval of new, reconstruction, and repair and maintenance of shoreline protection structures, as part of the proposed Program.
 “Sharp Park, West Fairway Park and Mori Point” sub-area & CR-I-22. Commission staff notes that the levee that protects the Sharp Park Golf Course was built in the 1940’s, rather than the 1980’s as indicated in this draft. In addition, policy language should not reference specific permit provisions, but rather should speak to compliance with prior permit conditions and/or existing legal obligations pursuant to the California Coastal Act as is more generally done in Policy CR-I14.  CR-I-14. Please note there are two versions of CR-I-14. The policy on regional sediment management should indicate who will participate (i.e. The City).  CR-I-44. The majority of the edits made to the “Assumption of Risk by Private Landowners” were struck out by the City. Commission staff continues to recommend the City broaden the assumption of risk and waiver of liability per prior edits.  CR-I-49. Commission staff understands the City’s intent to protect private property in hazardous areas to allow for the minimum economic use of a property so as to avoid an unconstitutional taking of private property, but recommends adding that this is subject to development maintaining safe access and assuring there is infrastructure to serve it for the anticipated life of the development.
 CR-I-52. This policy should also apply to condominium development.  CR-I-54. This policy states that existing shoreline protection structures may be repaired and maintained until the development they are protecting is removed or no longer requires shoreline protection. Please amend this to account for redevelopment/substantial exterior structural modification. In addition, Commission staff notes this policy language is internally inconsistent, as it references Section 30235 of the Coastal Act, in which “existing structures” is evaluated as prior to January 1, 1977 rather than prior to certification of this LCLUP.  CR-I-57. Edits to this policy direct that new or reconstructed shoreline protection structures fully mitigate for coastal resource impacts where impacts are unavoidable. However, reconstruction of shoreline protection structures is included in the exceptions clause of the “substantial exterior structural modification” definition. Please ensure that both new and reconstructed shoreline protection is mitigated for by removing reconstruction of shoreline protection structures from the list of exceptions.
 Definitions. The City should clarify whether or not the exceptions in SESM definition apply throughout the City or just in coastal hazard areas.

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Packet Pg. 1457 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
6  NH-I-10. Requires geotechnical studies for areas within 50 feet of a coastal bluff, but this should be clarified and expanded to account for increased erosion from sea level rise both with and without existing shoreline protection for development within 300 feet of a bluff edge.  NH-I-17. More generally includes similar requirements to the Coastal Act, but again, with the proposed definition of “new development” would limit application of this policy to areas where there is no existing development.

Lastly, it has come to our attention that there are numerous shoreline protection structures in the City, both publicly and privately owned, that are unpermitted and/or have existing permits that have since expired. Please take note of this in considering policies regarding shoreline protection structures that provide allowances for active, permitted shoreline protection structures specifically.

As discussed above, this letter is not an exhaustive list of comments on the post-consultation draft of the LCLUP, but rather provides an overview of overarching feedback at this time. We again thank you and your staff for the thoughtful and collaborative work done to date, and appreciate and commend the City for moving forward with the sometimes difficult, but important, task of updating the LCP’s LUP. We look forward to continued collaboration, and helping the City to refine the draft LUP, and a future draft IP, including in the ways identified in this letter. We hope these comments help move us forward to this end. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me.

Sincerely,
Jeannine Manna
District Manager
North Central Coast District Office
California Coastal Commission
cc: Kevin Woodhouse, City of Pacifica City Manager
Encl.: CCC Letter to City, dated August 29, 2018
CCC Letter to City, dated August 31, 2018
CCC Letter to City, dated October 19, 2018
CCC Letter to City, dated November 22, 2019

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Packet Pg. 1464 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G BROWN JR , GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
August 31, 2018
Tina Wehrmeister
Planning Director
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Draft Land Use Plan (LUP) Hazard Policies Dear Ms. Wehrmeister:

This letter is in response to the City of Pacifica’s request for comments on the “Proposed Updated Draft LUP Hazard Policies” provided to us in a memo from ESA to the City (entitled “Sea-Level Rise Policy Options for Pacifica LCP Update” and dated August 24, 2018). We note that we received this document just this week, and you have requested comments by today. As discussed with you, due to that abbreviated timeline of just a few days, we won’t be able to provide final or comprehensive comments, but we are happy to provide some preliminary thoughts and some broader observations regarding the current proposed policies. We look forward to continued dialogue on the policies, including with respect to refinements identified herein.

Overall, the proposed policies appear to provide a solid framework for advancing the City’s sea level rise adaptation efforts, which will be critically important in the coming decades. As is identified in its Sea Level Rise Vulnerability Assessment (June 2018), the City of Pacifica is already vulnerable to storm and wave impacts, including as evidenced by the loss of residential structures in recent years, and efforts to protect against such impacts have resulted in narrowed or completely inundated beaches backed by armoring where access can be largely unavailable at higher tides. These hazards are only expected to increase as sea levels rise, resulting in significant loss of public recreational beach resources and shoreline-area habitats, as well as damage to and loss of residential and commercial structures, and transportation, stormwater, and wastewater infrastructure. In particular, given its beaches are a fundamental backbone and significant part of the City’s social fabric and economic engine, it is critically important for the policies to reflect the importance of the City’s beaches, and to be transparent (and provided appropriate mitigations) where the policies might lead to increased impacts to same.

To this end, the proposed policies address the need to ensure that new development is sited and designed to be safe from coastal hazards and to avoid the need for armoring, and the policies provide many key mechanisms for future steps to take as sea level rise advances over time, including interim protection measures, beach nourishment, and eventual managed retreat in

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Packet Pg. 1465 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 2 certain locations. We want to commend the City for tackling such difficult issues head-on, and for starting to identify practical and substantive measures to address such issues moving forward.

At the same time, although many important sea level rise planning provisions are addressed in the proposed policies, and they provide a good foundation for the LCP update, we also believe that many important details will require refinement moving forward, including to ensure that the proposed policies are logical, feasible, realistic, and consistent with the Coastal Act. We look forward to working together with the City to refine this work so that it achieves Coastal Act and City objectives related to minimizing hazards and protecting coastal resources, even as sea level rises.

In the interim, and in drilling down a bit into the proposed policies, the current draft includes effective and important policies that address planning and accounting for coastal hazards longer term, but appear to require some focus on the shorter term horizon. For example, the “Standard Policies for New Development,” “Shoreline Structures,” and “Coastal Flooding and Other Hazards” sections provide policies for long-term planning throughout the City that should help ensure new development will be safe from current and future vulnerabilities and protective of coastal resources. However, we continue to have the same concerns that we have previously relayed to the City regarding how existing development will be addressed going forward in a manner that ensures beaches, habitat, public access, and recreation will be preserved for current and future generations, as required by the Coastal Act. Part of the challenge before us in refining the policies will be to make sure that the shorter term and longer term policies interact and seamlessly move towards similar objectives, and aren’t somehow at cross-purposes.

In addition, as you know we have previously identified issues associated with potential policy preparation as the City has worked through its Draft Adaptation Plan (including through meeting with you and your staff throughout this year as well as letters dated June 12, 2018 and August 29, 2018). One of our primary concerns was ensuring that such policy preparation was based on a detailed assessment of the feasibility and costs/benefits of different adaptation alternatives, and it is not clear that this sort of information has been fully developed. No matter what policies are ultimately proposed, it will be critical for decision-makers, both at the City and Commission level, to have the benefit of that sort of information as they weigh potential policy approaches.

We would be happy to work with you and your staff as this effort proceeds locally to ensure that such background is clearly provided.

In terms of more specific comments on the draft policies, here are some preliminary observations:
 The proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support it as a primary adaptation strategy through the proposed policies. In short, we think that policies that rely so heavily on nourishment, particularly in the shorter term, need to be

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Packet Pg. 1466 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 3 supported by more thorough data.
 The proposed policies refer to developing a “Shoreline Mitigation Program” in the future to address impacts associated with hazard response. The policies are going to need to be able to be structured to address such impacts now, and many policies seem to imply that is their intent. It may be appropriate to identify development of a future mitigation program as a refinement and a next step, but it needs to be clear that this does not negate the need for mitigation in the interim.
 It may be appropriate to reformat and reorganize the policies. For example, the “Standard Policies” sections from pages 14-19 account for the overarching approach for new development and substantial improvements to existing development, in all areas throughout the City, and in both the short- and long-term. It may make better sense to move these to the beginning. Additionally, although we understand the policy construct that suggests that general policies may be superseded by more specific policies for each sub-area, we are concerned that some of the more specific policies appear to be making prescriptions for outcomes that are not based on analysis (e.g., allowed armoring). It is not appropriate, in our view, to have policies state conclusions that have not yet been supported by analysis, and it may be that the overarching policies are required to take precedence in that regard unless and until conclusions can be drawn in that manner.
 The policies appear to be looking to the 2040 horizon as ‘longer term’, and this seems an appropriate framework. We would encourage a close review to ensure that policies referring to other time frames (e.g., 20-year approvals) are understood in terms of this horizon, including to ensure that development years out also times to the same horizon.  It appears that some critical policy language is missing from some of the draft policies.

Please ensure that the following are addressed:
o Please provide design standards for the construction of shoreline protection devices (e.g., they must: blend with natural environment; avoid significant habitat areas; minimize footprint; protect, and where feasible, provide public access; control erosion from surface and groundwater flows; etc.).
o Please identify specific details regarding how proportional mitigation for all unavoidable impacts of shoreline protection devices to coastal resources (e.g., shoreline sand supply, recreation, public views, and water quality) is to be measured and applied. o Please ensure that the policies require removal of shoreline protection devices when they are no longer required to protect existing structures in danger from erosion, including when structures are demolished and then rebuilt, or redeveloped. o Please define what constitutes “substantial improvements” to ensure that current development is brought into compliance with the policies as it is renovated and redeveloped. We have previously identified appropriate standards for such a definition, and would be happy to provide that again.
 Certain themes, concepts, and terms used throughout the draft policies need to be better defined, including as follows:
o Please better describe how the triggers would be implemented (e.g., trigger for when armoring/nourishment etc. would be implemented when the bluff offset reaches the

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Packet Pg. 1467 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 4 specified distance, or whether the specified distance triggers a different approach). In addition, please explain how the years and amounts of sea level rise pertain to the offset values and describe how beach width and bluff offsets will be measured. o Please explain how the hazard areas referenced in the policies will be defined, including the coastal hazard zones, coastal hazard maps, flood hazard zones, and tsunami run-up zones. In addition, for particular hazard areas that will be mapped, we recommend that the City add timeframes for how often these maps must be updated and include contingencies in the event that they are not updated by the prescribed deadline. o Please discuss how height limitations will be accounted for if/when structures need to be elevated to meet FEMA base flood levels in some areas.
o Please further expound upon what constitutes current “best available science” and whether there is a different standard for what amount of sea level rise should be evaluated in geotechnical studies versus what amount of sea level rise new development must be sited/designed to be safe from. For example, consider specifying that all new development must evaluate, at a minimum, the medium-high projection scenario (from the 2018 OPC Sea-Level Rise Guidance and in line with the Draft 2018 Science Update to the CCC SLR Policy Guidance) over its anticipated lifetime, but that if new development cannot be sited to avoid impacts over that time period certain minimum standards must be met (similar to the policies related to takings). We would be happy to work with the City on this topic.
o References to hazard policies are made without those specific policies’ reference numbers included. Please update the references accordingly.

Again, we appreciate and commend the City on developing these draft policies and the related policy framework, and look forward to helping to refine the policies and approach through our ongoing collaboration on the City’s LCP update. It is clear from these policies that the City is taking the issues and problems associated with coastal hazards seriously, and in a way that advances the City’s approach to sea level rise and LCP planning. We hope these comments help move us forward in that regard. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me or Patrick Foster of my staff. Again, we greatly appreciate the ability to be a part of this important planning process and look forward to continued coordination and discussion of this important effort.

Sincerely,

Jeannine Manna
North Central Coast District Manager
California Coastal Commission
cc: Bonny O’Connor, City of Pacifica Planner

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Packet Pg. 1468 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G BROWN JR , GOVERNOR

CALIFORNIA COASTAL COMMISSION NORTH CENTRAL COAST DISTRICT OFFICE 45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
October 19, 2018
Tina Wehrmeister
Planning Director
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Draft Land Use Plan (LUP) Hazard Policies Dear Ms. Wehrmeister:

This letter is in response to the City of Pacifica’s request for comments on the “Proposed Updated Land Use Plan Coastal Hazards Policies” provided to us in a memo from ESA to the City (entitled “Sea-Level Rise Policy Options for Pacifica LCP Update” and dated August 24, 2018). As you know, we previously provided comments on a memo from ESA to the City with the same title and date (see attachment 1 for that memo, and see attachment 2 for our comments on it in a letter to the City dated August 31, 2018). We were surprised to see that the second memo (see attachment 3) was substantially different than the first memo and did not respond to the majority of our suggestions. Regardless of why the City may have chosen this approach, with respect to the second memo, many of our previous comments still stand, and are repeated below as appropriate. We have also suggested specific modifications to the policies and text within the new memo, including indicating where we believe that language from the first memo we reviewed should be re-inserted (see attachment 3). It is our understanding that the City Council will be considering these draft hazard policies by themselves now, but it is ultimately the City’s intention to incorporate them into an overall draft LCP update for consideration sometime in 2019. As such, although we provide some preliminary comments and suggestions here, it appears that there will also be future junctures when further refinement and comment is possible. Toward that end, we look forward to continued dialogue on the proposed policies, and to working with City staff to further develop this policy language in conjunction with the rest of the LCP update as the draft moves forward, including as it is modified in light of public and City Council input.

When we commented on the first memo we noted that we believed that the proposed policies began to provide a solid foundation and framework for advancing the City’s sea level rise adaptation efforts. As the Coastal Commission has routinely stated, clear, proactive policies for addressing sea level rise are critically important. This is undoubtedly true in Pacifica where, as is identified in the City’s Sea Level Rise Vulnerability Assessment (June 2018), the City is already vulnerable to storm and wave impacts. Such impacts are evidenced by the loss of blufftop residential structures in recent years, and by the fact that efforts to protect against such impacts have resulted in narrowed or completely inundated beaches backed by armoring where beach

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Packet Pg. 1469 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 2 access can be largely unavailable at higher tides. These hazards are only expected to increase as sea levels rise, resulting in a significant loss of public recreational beach resources and shorelinearea habitats, as well as damage to and loss of residential and commercial structures, and transportation, stormwater, and wastewater infrastructure. In particular, given its beaches are a fundamental backbone and significant part of the City’s social fabric and economic engine, it is critically important for the policies to reflect the importance of the City’s beaches, and to be transparent (and provide appropriate mitigations) where the policies might lead to increased impacts to same.

To this end, we are concerned that both the removal of some proposed policies from the first memo and the addition of new language in the second memo will result in policies that do not clearly state the need to ensure that new development and redevelopment be sited and designed to be safe from coastal hazards and to avoid the need for armoring. We also continue to have the same concerns that we have previously relayed to the City regarding how existing development will be addressed going forward in a manner that ensures beaches, habitat, public access, and recreation will be preserved for current and future generations, as required by the Coastal Act. In addition, we previously identified concerns associated with policy preparation based on a lack of technical and feasibility information as the City worked through its Adaptation Plan (including through meeting with you and your staff throughout this year as well as letters dated June 12, 2018 and August 29, 2018). One of our primary concerns was, and remains, ensuring that policies which prescribe specific adaptation measures (like armoring and beach nourishment with the use of sand retention structures) are based on a clear and detailed assessment of the environmental, technical, and economic feasibility of such alternatives. It is not clear that such information has been fully developed.

We do continue to recognize that addressing new and existing development in a place like Pacifica is a complex challenge given the scope of current and future hazards combined with existing patterns of development and shoreline armoring and uncertainties about future sea level rise and future conditions on the ground. As we have previously explained in meetings with and letters to City staff, there are policy approaches that would allow for continued reliance on armoring for certain development over a specified time horizon, including as identified in the City’s current sub-area policies. However, such policy approaches still need to ensure that impacts to other coastal resources would be mitigated, and need to build in an understanding that other adaptation options may be necessary if and when armoring (and/or beach nourishment) can no longer provide adequate protection for both development and coastal resources. Part of the challenge before us is to refine the policies and strike an appropriate balance in order to protect the range of coastal resources and development, while ensuring that short and long term policies interact and seamlessly move towards similar objectives.

In any case, we want to commend the City for tackling difficult sea level rise issues and for starting to identify practical and substantive measures to address such issues moving forward. To be sure, the proposed policies provide many key mechanisms for future steps to take over time as sea level rise advances, including interim protection measures, beach nourishment, monitoring of changing conditions, and periodic updates to the City’s Adaptation Plan to respond to such changes. Although many important coastal hazard planning provisions are addressed in the proposed policies and they provide a good foundation for the LCP update, we also believe that

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Packet Pg. 1470 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 3 many important details will require refinement moving forward, including to ensure that the proposed policies are logical, feasible, realistic, and consistent with the Coastal Act. We continue to look forward to working together with the City to refine this work so that it achieves Coastal Act and City objectives related to minimizing hazards and protecting coastal resources, even as sea level rises.

In terms of some more specific comments on the draft policies in the second memo, here are some preliminary observations:
• The previous memo included a summary with details of how the City has dealt with the impacts of shoreline erosion and coastal flooding for decades. We recommend including a similar setting description in the LUP itself to speak to the broad purpose of the proposed coastal hazard policies and to provide context for their future implementation. • The proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously with City staff, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support it as a primary adaptation strategy through the proposed policies. In short, we think policies that rely so heavily on nourishment, particularly in the shorter term, need to be supported by more thorough data. Similarly, the use of sand retention structures can alter ocean waves, currents and sand movement, potentially exacerbating erosion on one side or the other of the structure (e.g., depending on currents, littoral drift, etc.). These potential impacts should be evaluated accordingly if sand retention structures are planned to be used in conjunction with beach nourishment.
• The proposed policies refer to developing a “Shoreline Mitigation Program” in the future to address impacts associated with hazard response. The policies need be structured to address such impacts now, and many policies seem to imply that is their intent. It may be appropriate to identify development of a future mitigation program as a refinement and a next step, but it needs to be clear that this does not negate the need for mitigation in the interim. Accordingly, given the Shoreline Mitigation Program is not yet complete, we recommend removing reference to implementation of the Program in the policies, instead of referencing only that it will be developed in the future. Until the Program is fully developed, mitigation should be implemented consistent with the type of requirements found in proposed Hazard Policy 60. • It may be appropriate to reformat and reorganize the policies. For example, the “Standard Policies” sections from pages 12-16 account for the overarching approach for new development in all areas throughout the City, and in both the short- and long-term. It may make better logical, and document-flow sense to move these, along with the definitions section, to the beginning of the document. Additionally, although we understand the policy construct that suggests that general policies may be superseded by more specific policies for each sub-area, we are concerned that some of the more specific policies appear to be making prescriptions for outcomes that are not based on analysis (e.g., allowed armoring). It is not

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Packet Pg. 1471 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 4 appropriate, in our view, to have policies state conclusions that have not yet been supported by analysis, and it may be that the overarching policies are required to take precedence in that regard unless and until more definitive conclusions can be drawn. • It appears that some critical policy language is missing from some of the proposed draft policies. Please ensure that the following are addressed:
o Please provide design standards for the construction of allowable shoreline protection devices (e.g., they must: blend with natural environment; avoid significant habitat areas; minimize footprint; protect, and where feasible, provide public access; control erosion from surface and groundwater flows; etc.).
o Please identify specific details regarding how proportional mitigation for all unavoidable impacts of shoreline protection devices to coastal resources (e.g., shoreline sand supply, beaches, public recreational access areas and amenities, public views, water quality, etc.) is to be measured and applied. Please ensure that the policies require removal of shoreline protection devices when they are no longer required to protect existing structures in danger from erosion (including when structures are demolished and then rebuilt, or redeveloped) when such removal and restoration can be accomplished without endangering existing principal structures or existing public facilities on adjacent sites. o Please discuss how height limitations will be accounted for if/when structures need to be elevated to meet FEMA base flood levels in some areas.
o The siting and design policies for hazard areas no longer address substantial improvements to existing development (or ‘redevelopment’) in the second memo. We recommend the City develop specific language for how the siting and design of structures will be addressed when they are redeveloped in situations where there is existing, legally authorized shoreline protection and in cases where there is a natural bluff or shoreline fronting the proposed development. In addition, we recommend including separate policies to address new development on vacant lots that are fronted by existing, legally authorized shoreline armoring and in places where there is a natural bluff or shoreline. In cases where new development/redevelopment cannot be located safe from hazards without reliance on existing and/or new armoring or cannot meet the required setbacks, any approval for such development should include triggers for eventual removal in response to coastal hazards (e.g., when declared unsafe for occupancy and/or use; when the development encroaches onto current or future public trust land and the State Lands Commission denies a grant, lease, or other legal mechanism to allow the development to remain in place; when access and utilities are no longer available to serve the development and cannot be restored; when the blufftop edge erodes to the minimum setback line; when removal is required by subsequent adaptation planning; etc.), as well as propose ways in which the new and redeveloped structures will mitigate for that armoring’s impacts to coastal resources.
o Please provide a policy that outlines how the City will address development that becomes unsafe for occupancy and a public nuisance due to coastal hazards.

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Packet Pg. 1472 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 5 • Certain themes, concepts, and terms used throughout the draft policies need to be better defined or explained in order for us to better evaluate the intent and application of the proposed policies, including as follows:
o Please define “existing structure,” as it is used often in the policies in relation to shoreline armoring. We recommend that it be defined as a structure legally authorized prior to the effective date of the Coastal Act on January 1, 1977, including as is identified in the Commission’s Sea Level Rise Policy Guidance.
o Instead of only a reliance on “new development”, please also define “redevelopment” to ensure that current development is brought into compliance with the policies as it is substantially changed over time. Please establish clear thresholds for when repair, maintenance, improvement, or other work is conducted to the extent that a structure needs to be reviewed against all current standards, including for coastal hazards.

Typically, such thresholds would at the least include alteration (including demolition, renovation or replacement) of 50% or more of major structural components. o Please further describe what constitutes current “best available science” and whether there is a different standard for what amount of sea level rise should be evaluated in geotechnical studies versus what amount of sea level rise new development must be sited/designed to be safe from. For example, consider specifying that all new development must evaluate, at a minimum, the medium-high projection scenario (from the 2018 OPC Sea-Level Rise Guidance and in line with the Draft 2018 Science Update to the Commission’s Sea Level Rise Policy Guidance) over its anticipated lifetime, but that if new development cannot be sited to avoid impacts over that time period certain minimum standards must be met (similar to the policies related to takings). We would be happy to work with the City on this topic.
o Please explain how the hazard areas referenced in the policies will be defined, including the coastal hazard zones, coastal hazard maps, flood hazard zones, and tsunami run-up zones. The current definition of hazard zone refers to the City’s current maps, but it is not clear to what maps that refers. Any maps referred to in the policies should be included as part of the LCP. In addition, for particular hazard areas that will be mapped, we recommend that the City add timeframes for how often these maps must be updated and include contingencies in the event that they are not updated by the prescribed deadline. o Proposed Hazard Policy 5 states that the City will implement a monitoring program for sea level rise to establish thresholds for reassessing the City’s Adaptation Plan. Please describe the type of thresholds that will be identified. Additionally, the current sub-area policies refer to triggers, but do not explain how the triggers would be implemented. For example, clarify whether armoring/nourishment etc. would be implemented when the bluff offset reaches the specified distance, or whether the specified distance triggers a new approach. Please also explain how beach width and bluff offsets will be measured. o Proposed Hazard Policy 7 states that the Shoreline Mitigation Program will identify priority improvements for maintaining and enhancing coastal shoreline resources, particularly public access and recreation. Please further describe what types of

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Packet Pg. 1473 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 6 improvements the City is contemplating in this regard and provide relevant examples. o Proposed Hazard Policy 8 refers to funding for “adaptation strategies”. Please outline what kind of strategies this refers to, and specify if this will include voluntary removal or relocation of development.
o Proposed Hazard Policy 9 calls for identifying areas where densities and heights may be increased using TDR credits, including to facilitate affordable housing. Please describe how such determinations will be made, including which specific criteria will be evaluated.
o Proposed Hazard Policy 11 states that the City will preserve, protect, or relocate hazard prone infrastructure to maintain critical services and the environment. Given that these two goals will often conflict, please specify what criteria will be evaluated in determining the preferred option for infrastructure projects. Also, given similarities and overlap, please consider combining with proposed Hazard Policy 10. o Please clarify the intent of proposed Hazard Policy 50. Presumably redevelopment of existing development will require the entire structure to conform to applicable LCP standards, but the policy is not clear on this point.
o Proposed Hazard Policy 52 requires sea level rise buffer areas be added to new development if necessary to allow for the migration of wetlands and other shoreline habitats. Please describe how such buffer areas will be delineated, applied, and protected as same.
o The definition of shoreline within the hazard policies appears to exclude shoreline properties adjacent to rivers, streams and creeks, as well as properties that will be impacted by erosion and/or flooding by large storm events or over longer time periods due to rising sea levels. We recommend that the policies instead refer to coastal hazard areas so that properties that are potentially subject to coastal flood and erosion hazards both now and in the future will be reviewed for consistency with the hazard policies.

Again, we appreciate and commend the City on developing these draft coastal hazard policies and the related policy framework, and look forward to helping to refine the policies and approach through our ongoing collaboration on the City’s LCP update. It is clear from these policies that the City is taking the issues and problems associated with coastal hazards seriously, and in a way that advances the City’s approach to sea level rise and LCP planning. We hope these comments help move us forward in that regard. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me or Patrick Foster of my staff. Again, we greatly appreciate the ability to be a part of this important planning process and look forward to continued coordination and discussion of this important effort.

Sincerely,

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Packet Pg. 1474 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 7 Jeannine Manna
North Central Coast District Manager
California Coastal Commission
cc: Bonny O’Connor, City of Pacifica Planner
Attachments:

Attachment 1 – ESA memo to the City dated August 24, 2018 (memo 1) Attachment 2 – CCC comments on memo 1 dated August 31, 2018 Attachment 3 – ESA memo to the City also dated August 24, 2018 (memo 2)

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Packet Pg. 1475 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 550 Kearny Street
Suite 800
San Francisco, CA 94108
415.896.5900 phone
415.896.0332 fax
www.esassoc.com
memorandum
date August 24, 2018
to Bonny O’Connor, AICP
cc Tina Wehrmeister
from James Jackson, PE; Charles Lester, PhD, JD; Bob Battalio PE subject Sea-Level Rise Policy Options for Pacifica LCP Update Summary
This memo presents a recommended LCP policy update to address projected sea-level rise and its impacts on coastal development and resources within the City of Pacifica. The City has grappled with the impacts of shoreline erosion and coastal flooding for decades, especially in north Pacifica, generally north of Mori Point, but also Rockaway, Linda Mar and Pedro Point. Most of the city’s shoreline development pre-dates Proposition 20 and the Coastal Act, making it eligible for shoreline protection under state law. Since the early 1970s many of the properties north of the Pacifica pier have been armored with rock revetments and seawalls. At the same time, the high, sandy bluffs of Pacifica present difficult engineering challenges. Since the late 1990s a dozen homes and three apartment buildings along Esplanade Ave could not be saved and have been removed. Several reinforced concrete seawalls and rock revetments have failed and been repaired to varying degrees. Coastal storms are also already extremely hazardous along Beach Boulevard; and homes in the Sharp Park and Linda Mar neighborhoods are subject to flooding from the sea, stream and storm runoff, and rising groundwater. Coastal access is limited north of the pier where shore erosion has met the armoring, causing ephemerally narrow to non-existent beaches.

While Rockaway Beach is also mostly armored, the main beach at Linda Mar continues to be an important recreational resource. The recent damages and loss of coastal resources indicates an existing problem that will become progressively worse regardless of the amount of sea-level rise.

Sea-level rise promises to make all of Pacifica’s coastal hazards even more challenging. The City’s vulnerability assessment concluded that residential and commercial properties and significant public infrastructure are endangered by future sea-level rise. The recently completed Sea-level Rise Adaptation Plan analyzed various strategies for addressing sea-level rise in each of eight sub-areas of the City. The plan concludes that maintaining and expanding armoring for existing development is the best near-term strategy while the City pursues beach nourishment and sand retention options that might rebuild and better maintain Pacifica’s beaches. However, the plan also concludes that over the longer run, managed retreat of existing development and infrastructure may be required. While the economic analysis indicates managed retreat may be a more cost-effective and superior Attachment 1

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Packet Pg. 1476 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
2 investment for the City, including the benefit of maintaining its natural shoreline resources, there is concern in the community that it is premature to adopt this strategy and many coastal property owners and associated service industries have rejected the concept out-right.

The LCP update policies proposed here would implement a phased adaptation strategy that relies on continued armoring over the next several decades in most sub-areas in conjunction with a comprehensive mitigation program for the resource impacts of armoring, particularly the anticipated loss of Pacifica’s beaches. The program will direct mitigation fees mostly to the Linda Mar and Rockaway sub-areas where they would be most effective in offsetting the loss of beach resources. The LCP would also require the simultaneous pursuit of alternative softer strategies for protecting shoreline resources over the longer run, such as beach replenishment. In particular, sand placement to widen the beach in Rockaway will be pursued owing to its relatively favorable economics ranking and smaller scale. The effectiveness of the shorter-term armoring strategy in protecting development and coastal resources may be contingent on the success of these alternative strategies. Finally, the LCP update would establish programs for implementing voluntary managed retreat over the shorter run and potential acceleration of City-sponsored (and funded) managed retreat over the longer-run (2050-2100) as the impacts of sea-level rise accelerate. This includes using transfer of development rights to relocate development in hazard zones to safer areas of the City, and taking advantage of potential state and federal funding for the planned removal of endangered structures and infrastructure.

The intent of the LCP update is to continue to protect existing, private development and the City’s infrastructure while recognizing and anticipating what may be an inevitable need to move back from the shoreline. And while the policies support new efforts for community-level funding of continued armoring, beach replenishment, and planned retreat, including establishing new geological hazard abatement districts or securing federal hazard mitigation funds, they also make clear that private landowners in hazard zones are responsible for and must assume the risks of continued armoring and reinvestment in their properties. This includes assuring that adequate mitigation in the form of in-lieu fees is provided to the City to support beach recreation and other coastal resources impacted by armoring; and making sure that existing or future shoreline development doesn’t encroach on public tidelands. Consistent with the City’s current LCP and state Coastal Commission guidance, the updated LCP would allow for significant improvements to properties in hazard zones, but substantial redevelopment would trigger conformance with the City’s hazard policies and zoning rules, much like the rules for other nonconforming development in the City.

Attachment 1

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Packet Pg. 1477 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
3 LCP Background
Pacifica’s Local Coastal Program (LCP) guides development and protects coastal resources within the Coastal Zone. LCPs must be consistent with the California Coastal Act of 1976, as amended. Pacifica’s LCP is made up of two parts: the Land Use Plan (a compilation of goals, policies, and recommended programs) and Implementation Plan (regulations and zoning district maps that implement the provisions of the Land Use Plan) (City of Pacifica, 1980; 1994). The Implementation Plan has been codified into Pacifica’s municipal code as individual sections (Chapter 4, Articles 43 and 44) in Title 9 Planning and Zoning (City of Pacifica, 2017) [CITY TO CONFIRM, IP IS NOT AVAILABLE ON THE WEBSITE].

The California Coastal Act aims to ensure that public access to and along the shoreline is maintained; that water quality, marine life, and environmentally sensitive habitat areas are protected; and that coastal visual resources and special communities are preserved. The Coastal Act calls for certain land uses within the Coastal Zone to have priority over other uses: recreation and visitor-serving uses, fishing, boating, and other coastal-dependent uses, and public works and industrial facilities needed to support priority uses.

Pacifica’s current Land Use Plan was certified in 1980. The Land Use Plan includes the following main sections:
• The California Coastal Act policies in effect at the time the Land Use Plan was adopted • Land use designation maps organized by neighborhood, and land use designation definitions • Neighborhood map of six coastal neighborhoods
• A detailed description of existing conditions, development criteria, and coastal access policies for each coastal neighborhood
• A detailed description of each existing or proposed beach access point • Policies addressing a range of topics, including habitat protection, geotechnical hazards, coastal views and viewsheds, housing, etc.

Pacifica’s current Implementation Plan was certified in 1994 [CITY TO CONFIRM] and establishes regulations that address permit requirements and procedures, creation of a Coastal Zone Combining District that serves as an overlay to the underlying zoning districts, protection of sensitive coastal resources or to ensure public shoreline access, protection of environmentally sensitive habitats, geotechnical suitability, grading and drainage, shoreline protection, public shoreline access, coastal view corridors, and neighborhood commercial districts.

In 2009, the City of Pacifica initiated a comprehensive update to its General Plan and LCP. A draft LCP Land Use Plan was prepared that includes background information and policies for the following themes: land use and development, public access and recreation, environmental and scenic resources, and natural hazards (City of Pacifica, 2014). The draft LCP has not been adopted by the City of Pacifica nor certified by the California Coastal Commission, and is not in effect at this time.

Attachment 1

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Packet Pg. 1478 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
4 PROPOSED UPDATED LAND USE PLAN COASTAL

HAZARDS POLICIES
General Policies
Hazard Policy 1 (Key Coastal Act Policies).

The City of Pacifica adopts the key policies of the Coastal Act to address coastal hazards:

PRC 30253. New development shall: (1) minimize risks to life and property in areas of high geologic, flood, and fire hazard; and (2) 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; and, PRC 30235. Revetments, breakwaters, groins, harbor channels, seawalls, cliff retaining walls, and other such construction that alters natural shoreline processes shall be permitted when required to serve coastal-dependent uses or to protect existing structures or public beaches in danger from erosion, and when designed to eliminate or mitigate adverse impacts on local shoreline sand supply.

The updated LCP and sub-area adaptation policies adopted herein are intended to achieve and are consistent with these key policies, subject to periodic updating as resource and development monitoring and program implementation may dictate.

Hazard Policy 2 (Sea-level Rise and Best Available Science).

Planning and development reviews in the City of Pacifica shall use, as applicable, the best available science about projected sea-level rise and other climate-change related environmental changes when addressing coastal erosion, bluff failure, flooding and other coastal hazards.

Hazard Policy 3 (Hazard Identification and Mapping).

The City’s coastal hazard zones shall be mapped based on the best available science about projected sea-level rise, erosion, flooding, and other coastal hazards. Mapping shall be updated as necessary to guide implementation of the LCP’s hazard policies. Notwithstanding the coastal hazard zone maps, site-specific hazard mapping and assessment may be required as part of the individual development review process.

Attachment 1

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Packet Pg. 1479 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
5 Coastal Hazards and Sub-area Adaptation Policies
Hazard Policy 4 (Shoreline Adaptation Plan and Override).

The City shall implement its Sea-level Rise Adaptation Plan (Appendix xx) as expressed in the LUP’s general and sub-area coastal hazard adaptation policies. The City shall monitor implementation and, from time to time, update the Sea-level Rise Adaptation Plan to strengthen public safety, preserve existing neighborhoods, assure local economic vitality, respond to climate change, promote environmental justice, implement the Coastal Act and protect the public trust.

Development in coastal hazard zones may be approved consistent with the sub-area policies (xx – xx) if the following findings can be made:
a. The proposed development is sited and designed to minimize coastal hazards and impacts to coastal resources to the extent feasible, consistent with the Adaptation Plan; b. The approval is limited in duration, consistent with sub-area policies. c. All project impacts are mitigated to the maximum extent feasible through the City’s shoreline mitigation program (Hazard Policy xxx) or consistent with Hazard Policy xx. d. The project does not pose unacceptable risks to life or property or otherwise create a nuisance; and
e. The project will not encroach on public trust lands.

Hazard Policy 5 (Monitoring Shoreline Change).

The City shall implement a monitoring program for sea-level rise, beach width, bluff offset, flooding and storm damage, and other potential measures or triggers for guiding implementation of the LCP’s shoreline adaptation policies.

Hazard Policy 6 (Shoreline Mitigation Program).

Within three years of certification of the LUP update, the City shall incorporate into the LCP a Shoreline Mitigation Program to address the coastal resource impacts of existing and future shoreline protection projects in the City. Special emphasis shall be placed on maintaining beaches and public access to and along the shoreline. The program will update the public access inventory of the LUP as necessary, include a coastal resource inventory and identify priority improvements for maintaining and enhancing coastal shoreline resources, particularly public access and recreation. The program will include enforceable measures to achieve proportional mitigation of resource impacts identified in shoreline protection projects, including consideration of beach widths, sediment management plan actions, and monitoring. The program will identify potential funding sources for implementation of identified improvements, such as new hazard abatement districts or city fees or taxes. The program will include provisions for monitoring implementation and program updates as necessary.

Hazard Policy 7 (Adaptation Funding).

The City will seek and establish as feasible new funding mechanisms, such as the formation of Geologic Hazard Abatement Districts (GHADs), participating in County Service Areas, or securing FEMA and other federal or state adaptation and hazard mitigation funds, to finance Attachment 1

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Packet Pg. 1480 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
6 shoreline protection projects, beach replenishment, the Shoreline Mitigation Program and voluntary managed retreat projects. The City will encourage and assist in the acquisition of grants for multi-objective, nature-based solutions for adaptation and the voluntary purchase or relocation of property and structures in high hazard areas to mitigate against damage to vulnerable structures and infrastructure.

Hazard Policy 8 (Managed Retreat).

The City shall establish and pursue funding of a Managed Retreat Program for voluntary removal, modification or relocation of development when necessary to protect private property interests and provide for the migrating shoreline and associated coastal resources, such as sandy beach area. The Managed Retreat Program will include identification of priority areas and timing for implementing managed retreat, based on sub-area planning, monitoring, and beach management planning pursuant to the LCP; provisions for voluntary participation of property owners in the program; strategies for funding the purchase of easements or development rights from participating property owners; and provisions to allow phased implementation to maintain occupancy of properties for as long as possible, including through acquisition and lease-back arrangements.

Hazard Policy 9 (Transfer of Development Rights).

Use the City’s transfer of development rights (TDR) ordinance to relocate development from coastal hazard zones (sending sites) to receiving sites outside of hazard zones. Identify areas where densities and heights may be increased using TDR credits, including to facilitate affordable housing.

Hazard Policy 10 (LHMP Alignment).

Coordinate City departments and programs to align the Local Hazard Mitigation Plan (LHMP) with the LCP to ensure proactive, coordinated and streamlined adaptation efforts and response to future coastal hazards. Leverage FEMA funding opportunities for hazard mitigation and other related funding mechanisms to implement the Shoreline Adaptation Plan.

Hazard Policy 11 (Critical Transportation Infrastructure).

The City will pursue opportunities to preserve and protect critical transportation infrastructure to mitigate against isolation, economic loss and ensure public safety.

Hazard Policy 12 (Hazard Prone Infrastructure).

The City will preserve, protect, or relocate hazard prone infrastructure to maintain critical services and maintain the environment.

Hazard Policy 13 (Business Outreach).

The City will develop and deliver business outreach programs to mitigate against the functional loss of community businesses and promote business resiliency.

Hazard Policy 14 (High Water Program).

Where feasible, the City will implement a program to record high water marks following highwater events.

Attachment 1

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Packet Pg. 1481 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
7 Hazard Policy 15 (Flood Ordinance Consistency).

Review and amend as necessary the City’s flood damage prevention ordinance to assure consistency with the updated policies and ordinances of the LCP.

Sub-Area Policies and Programs
The following policies and programs implement the near-term sea-level rise adaptation priorities for each subarea in Pacifica, and identify mid- and longer-term measures, subject to feasibility and monitoring concerns.

These priorities were developed based on existing conditions and existing/near term vulnerabilities for each subarea, as well as the City’s adopted goals for the project that include protecting existing development as well as preserving and enhancing coastal access along Pacifica. While the cost-benefit analysis conducted for the City’s Sea-level Rise Adaptation Plan indicates that managed retreat/realignment may be a long-term cost-effective option in many sub-areas, the immediate costs and impacts to the City’s adopted goals would be severe compared to the benefits speculated in the long-term future, which makes this option difficult to support and implement in the near-term. The adaptation priorities discussed below can buy time for the City by protecting at risk assets in the near term and leaving options open for the long term.

The recommended time frames for action are based on the medium-high risk aversion SLR projection of 6 feet by 2100. As required in other policies, the City shall monitor erosion, flooding, and sea-level rise amount into the future to identify triggers for adaptation measures. Many initial actions are required regardless of future SLR due to existing conditions. Where applicable, specific triggers are clarified in the policies.

Generally, for all lands within the 2050 Pacific Institute erosion hazard zone, utilities, roadways and other public infrastructure should be floodproofed unless other adaptation alternatives are implemented and performing well.

The City should incentivize risk reduction (floodproofing etc.) that property owners can invest in, with funding or code updates. In addition, the City should consider realigning infrastructure (utilities, roadways) that may be exposed to coastal erosion and flooding to reduce the consequences of under-performance of protection measures (construction and maintenance of armoring structures).

Fairmont West
The roadway and utilities in Fairmont West are at risk after one to two feet of sea-level rise. Some beach width may exist for access and other coastal resources, but given the high bluffs here, there is not adequate vertical access to the beach. Due to the undeveloped conditions of the bluffs in this sub-area, armoring is not required immediately. Beach nourishment, while a lower priority for this sub-area compared to other more developed subareas in city, could take place at a later date with a larger volume of sand. Coarse sand and/or gravel sources are also preferable and would be more cost effective than finer sands due to sediment transport regimes in this subarea. By constructing sand retention structures along north Pacifica, the efficacy of beach nourishments can be increased.

Hazard Policy 16 (Shoreline Structures: 2020-2050, 0-1 foot SLR or 260-foot offset from bluff toe to infrastructure).

Shoreline structures shall be avoided except that the Dollar Radio property may maintain and expand shoreline structures to protect existing development in danger from erosion if found to be the least environmentally-damaging alternative, impacts are fully mitigated consistent with Attachment 1

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Packet Pg. 1482 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
8 Hazard Policy xx, and any prior permit conditions or legal obligations pursuant to the California Coastal Act are addressed. Approvals shall be limited to twenty years, and may be reauthorized if no other less environmentally damaging alternatives are feasible. After 2040, allow shoreline protection for the public road and sewer line if necessary. Any new blufftop development shall comply will all LCP setback policies.

Hazard Policy 17 (Beach Nourishment: 2050-2060, 2 feet SLR or 260-foot offset from bluff toe to infrastructure)
Evaluate the feasibility of using beach nourishment, in conjunction with sand retention structures (see artificial headlands concept in the Adaptation Plan), to reduce shoreline structure maintenance requirements and maintain beaches of at least 100 feet in width on average. If feasible and approved through a coastal development permit, secure funding and implement as soon as possible. Repeat as necessary. Mitigate all adverse impacts and monitor effectiveness over time.

Hazard Policy 18 (Transfer of Development Credits: 2020-2100, ongoing).

Provide an option to private landowners to voluntarily transfer development potential and/or remove existing development through a public buyout as feasible.

Hazard Policy 19 (Realignment of Public Infrastructure: 2050-2070, 2-4 feet SLR or 260-foot offset from bluff toe to infrastructure).

Initiate transportation study to identify alternative access options for Fairmont West. Realign Palmetto Avenue and wastewater pipeline or implement other adaption plans that may be identified through future study if shoreline protection or beach nourishment are not feasible and effective in maintaining existing conditions.

West Edgemar and Pacific Manor
Hazard Policy 20 (Shoreline Structures: 2020-2040, 0-1 foot SLR or 220-foot offset from bluff toe to infrastructure or development).

Maintain and expand shoreline structures to protect existing public infrastructure, including between Bill Drake Way and Manor Drive. Allow private property owners to maintain existing or construct new shoreline structures, consistent with prior permit conditions or legal obligations pursuant to the California Coastal Act. Limit authorization of all new structures to twenty years or 2040, whichever is sooner, and require mitigation of beach, public access and recreation and other resource impacts, consistent with Hazard Policy xx. Consider reauthorization subject to beach monitoring and implementation of beach nourishment and other strategies to maintain beaches.

Hazard Policy 21 (Beach Nourishment: 2020-2050, 0-1 foot SLR or 220-foot offset from bluff toe to infrastructure or development)
Evaluate the feasibility of using beach nourishment, in conjunction with sand retention structures (artificial headlands concept), to reduce shoreline structure maintenance requirements and maintain beaches of at least 100 feet in width on average. If feasible and approved through a coastal development permit, secure funding and implement as soon as possible. Mitigate all adverse impacts and monitor effectiveness over time.

Attachment 1

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Packet Pg. 1483 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
9 Hazard Policy 22 (Managed Retreat: 2020-2100, 0-1 foot SLR or 220-foot offset from bluff toe to infrastructure or development).

Provide option to private landowners to voluntarily remove existing armoring and receive a buyout of property as feasible. After 2040, if the beach nourishment strategy planned under Hazard Policy xx is ineffective at maintaining beaches, fund and implement a voluntary relocation, buyout or transfer of development rights of private property. Evaluate and implement relocation of public infrastructure as necessary. Assure protection of public access to and along the shoreline, consistent with the Public Access Plan required under Hazard Policy xx.

Northwest Sharp Park
The backshore of Northwest Sharp Park is armored but may be overwhelmed by waves with as little as one foot of sea-level rise, due to scour and structure sloughing, increased wave loads and overtopping of the structure.

Beaches tend to exist ephemerally in pockets, with armoring impeding lateral access from the degraded vertical access ways. Existing property and infrastructure are at risk from coastal erosion so actions should be taken soon.

A public access improvement plan should be provided, consistent with the City’s beach mitigation program. Due the potential lead time of establishing a sand source, beach nourishment planning should begin immediately.

Coarse sand and/or gravel sources are also preferable and would be more cost effective than finer sands due to sediment transport regimes in this sub-area. By constructing sand retention structures along north Pacifica, the efficacy of beach nourishments can be increased. In absence of any beach nourishment, managed relocation of private property by private property owners (optional) and realignment of public infrastructure will be needed before 2050 even if coastal armoring structures are maintained in their current elevations (up to the edge of bluff).

Hazard Policy 23 (Shoreline Structures: 2020-2040, 0-1 feet SLR or 70-foot offset from bluff toe to development or infrastructure).

Private land owners may maintain and expand shoreline structures to protect existing development in danger from erosion, consistent with Hazard Policy xx and any prior permit conditions or legal obligations pursuant to the California Coastal Act. Approvals shall be limited to twenty years, and may be reauthorized if no other less environmentally damaging alternatives are feasible.

Hazard Policy 24 (Beach Nourishment: 2020-2050, 0-2 feet SLR or 70-foot offset from bluff toe to development or infrastructure)
Evaluate the feasibility of using beach nourishment, in conjunction with sand retention structures (artificial headlands concept), to reduce shoreline structure maintenance requirements and maintain beaches of at least 100 feet in width on average. If feasible and approved through a coastal development permit, secure funding and implement as soon as possible. Repeat as necessary. Mitigate all adverse impacts and monitor effectiveness over time.

Hazard Policy 25 (Flood Protection: 2030-2040, 1 feet SLR).

Enable property owners to modify structures to manage impacts of wave run-up and overtopping of bluff face.

Attachment 1

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Packet Pg. 1484 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
10 Hazard Policy 26 (Managed Retreat/Realignment of Public Infrastructure: 2030-2050, 1 foot SLR or 70-foot offset from bluff toe to development or infrastructure).

Provide option to private landowners to voluntarily remove existing armoring and receive a buyout of property as feasible. Evaluate and implement relocation of public infrastructure as necessary. Assure protection of public access to and along the shoreline, consistent with the Public Access Plan required under Hazard Policy xx.

Sharp Park, West Fairway Park and Mori Point
Most of this area is armored. The northern section between the pier and Paloma is subject to frequent wave overtopping and damage to homes has occurred. Beaches are narrow and ephemeral, with armoring impeding lateral access from the degraded vertical access ways. South of the pier, the beach tends to be more persistent and wider, and there is usually an accessible beach in the vicinity of the end of Clarendon, with reliable vertical and lateral beach access. South of Clarendon to Mori Point, the beach persists although wave run-up can reach the levee and there is some armoring. This sub-area is exposed to flooding due to rainfall runoff which cannot flow directly to the ocean. The Clarendon area is exposed to flooding now, and the West Fairway development may be exposed to flooding if sea-level and ground water levels rise over 3 feet. Due to the potential lead time of establishing a sand source, beach nourishment planning should begin immediately. Coarse sand and/or gravel sources are also preferable and would be more cost effective than finer sands due to sediment transport regimes in this sub-area. By constructing sand retention structures along north Pacifica, the efficacy of beach nourishments can be increased.

Flood protection is already needed for homes and businesses along Clarendon Avenue during rain events and will need to be improved around the SPGC to manage flooding of Laguna Salada regardless of the condition of the SPGC berm. San Francisco is expected to maintain the SPGC berm which protects the Sharp Park neighborhood from the coastal flooding source, but existing pumping facilities in SPGC are not designed to mitigate flooding in and around the course during significant rainfall events (i.e., a portable pump station is currently used to manage rainfall-runoff flooding along Clarendon Avenue). The priority recommendations for flood protection surrounding SPGC are therefore based on the rainfall (fluvial) flood source, but would also be effective during a major coastal storm if the SPGC berm is overtopped or breached. Flooding due to wave run-up landward of Beach Boulevard seawalls is already an issue. If the seawalls are not properly maintained and upgraded in the future to accommodate higher sea-levels, private landowners will need other mechanisms to adapt to flood risks such as raising homes.

In absence of any armoring or beach nourishment, managed relocation of private property by private property owners (optional) and realignment of public infrastructure will be needed by 2050. Timing is dependent on presence and condition of coastal armoring structures, location of built assets relative to the bluff edge and or flood hazard zone, willingness of property owners to engage in managed retreat, and availability of public funding for relocation of public infrastructure.

Hazard Policy 27 (Sharp Park Golf Course).

Coordinate with the City of San Francisco to maintain the Sharp Park Golf Course berm and armoring, consistent with coastal development permit 2-17-0702; support adaptation planning for the course, and protect public access.

Attachment 1

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Packet Pg. 1485 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
11 Hazard Policy 28 (Shoreline Protection: 2020-2030, 0 feet SLR).

Maintain and expand shoreline structure to protect public infrastructure. Extend the Beach Boulevard seawall to the Sharp Park Golf Course berm. Mitigation shall be provided consistent with the City’s Shoreline Mitigation Plan.

Hazard Policy 29 (Shoreline Protection/Structure Elevation: 2030-2050, 0-2 feet SLR).

Upgrade existing shoreline structures to limit wave overtopping unless beach nourishment strategies are effective in reducing wave run-up on the backshore. Elevate structures as necessary to mitigate flood damage, consistent with existing height limitations.

Hazard Policy 30 (Monitoring, Utilities and Public Safety: 2050-2100, 2 feet SLR).

Monitor public safety and wave hazards. Relocate or abandon utilities as necessary and consider closing Beach Boulevard as necessary to protect public health.

Hazard Policy 31 (Beach Nourishment: 2020-2050, 0-1 feet SLR).

Pursue beach nourishment and sand retention structures to reduce shoreline protection maintenance requirements and provide beach resources. Encourage the City of San Francisco to nourish the beach fronting the Sharp Park Golf Course berm to maintain beach widths.

Hazard Policy 32 (Flood Protection: 2020-2030, 0 foot SLR).

Construct a Clarendon Avenue stormwater basin, pump station, and interior SPGC levee to protect homes and businesses from existing fluvial storm flood hazard zone.

Hazard Policy 33 (Flood Protection: 2060-2070, 3 feet SLR).

Construct a West Fairway Park stormwater basin, pump station, and interior SPGC levee to protect western homes from future coastal/fluvial flood hazard zone.

Hazard Policy 34 (Managed Retreat/Realignment of Public Infrastructure: 2050).

Provide option to private landowners to voluntarily remove existing armoring and receive a buyout of property as feasible. Evaluate and implement relocation of public infrastructure as necessary. Assure protection of public access to and along the shoreline, consistent with the Public Access Plan required under Hazard Policy xx.

Rockaway Beach, Quarry and Headlands
The armoring near the end of Rockaway Blvd is overtopped by waves under present conditions, with occasional damages. Hence, this area has very little capacity and will have a noticeably degraded condition with as little as one foot of sea-level rise. There is no beach in this area, with waves crashing directly into the armor structures.

The shore becomes more accessible with distance northward but will also be more limited with as little as 1 foot of sea-level rise. The south end of rockaway is unarmored, has a persistent beach and the backshore is estimated to will be impacted with about 2 feet of sea-level rise.

Due to the cove configuration of Rockaway Beach, it is a great candidate for beach nourishment. Policies recommend that Rockaway be used as a pilot project for beach nourishment in Pacifica. In the pilot project, the City will go through the overall process for beach nourishment and identify available sources in the region and Attachment 1

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Packet Pg. 1486 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
12 corresponding sediment characteristics and costs, evaluate the performance of the nourishment and enable the City to reevaluate nourishment along northern Pacifica and perform a more thorough assessment for a larger scale nourishment project.

Hazard Policy 35 (Shoreline Protection: 2020-2030, 0 feet SLR).

Existing public shoreline structures along the north cove shall be upgraded for public safety and hazard reduction.

Hazard Policy 36 (Shoreline Protection: 2050-2060, 2-3 feet SLR, or when backshore is 100 feet of Highway 1).

Coordinate with Caltrans to plan and install a revetment or other appropriate shoreline protection for the Highway 1 embankment if necessary.

Hazard Policy 37 (Public Access: 2020-2050).

Plan and provide for enhanced public access, consistent with the City’s shoreline mitigation plan.

Hazard Policy 38 (Beach Nourishment/Public Access: 2020-2030, 0 feet SLR).

Plan and implement beach nourishment for Rockaway Beach. Monitor and measure performance and any reduction of shoreline structure maintenance needs. Establish mechanisms through the shoreline mitigation plan to receive beach impact mitigation monies from other sub-areas of the City.

Hazard Policy 39 (Development Setbacks: 2020-2030, ongoing).

Implement new development shoreline setbacks consistent with Hazard Policy xx.

Hazard Policy 40 (Transfer of Development: 2020-2100, ongoing).

Evaluate and implement as feasible a transfer of development credit program for private property at the Quarry and Headlands.

Hazard Policy 41 (Managed Retreat/Realignment: 2060-2100, 2-3 feet SLR).

Provide option to private landowners to voluntarily remove existing armoring and receive a buyout of property as feasible. Evaluate and implement relocation of public infrastructure as necessary. Assure protection of public access to and along the shoreline, consistent with the Public Access Plan required under Hazard Policy xx.

Pacifica State Beach & West Linda Mar
Adaptation policies for Pacifica State Beach and West Linda Mar are presented together because actions taken at Pacifica State Beach influence coastal hazard exposure to West Linda Mar. Much of the Pacifica State Beach subarea has a persistent, relatively wide beach with bulkheads in the south transitioning to dune fields in the north.

Hence, this shore and roadway can withstand at least 2 feet of sea-level rise. However, the West Linda Mar subarea east of Highway 1 has a low elevation and is subject to flooding from high creek flows and rising groundwater associated with sea-level rise. Due to the existing beach widths in Pacifica State Beach and existing coastal armoring, armoring actions are not a near term priority. However, conditions of existing armoring at the Attachment 1

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Packet Pg. 1487 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
13 Anza pump station should be monitored to ensure protection in the near term. Nourishment of Pacifica State Beach should be initiated using the shoreline-backshore offset for the main parking lot. Beach nourishment projects should include dune restoration to maintain ecology, protect the sewer force main that is buried in existing dune field north of the main parking lot/Anza pump station as well as provide flooding protection of Highway 1 and West Linda Mar. Pump stations at Pacifica State Beach are vulnerable to wave run-up and require floodproofing in place. West Linda Mar neighborhood is also vulnerable to flooding from San Pedro Creek based on existing FEMA hazard maps and will become more vulnerable as SLR increases the flood levels in the creek via its ocean boundary condition. West Linda Mar neighborhood was constructed in a former lagoon and experiences groundwater issues in the lowest areas, which is evident by existing wetlands around the skate park and homes furthest west. Groundwater in low areas near the ocean are directly influenced by the sea-level, and thus groundwater issues will increase with SLR.

Hazard Policy 42 (Shoreline Protection: 2050-2060, 2 ft SLR or 100 foot offset from shoreline to infrastructure).

Evaluate beach conditions and consider shoreline protection to protect parking and the Linda Mar pump station as necessary.

Hazard Policy 43 (Highway One Protection: 2050).

Coordinate with Caltrans to evaluate options for protecting Highway 1, if necessary.

Hazard Policy 44 (Beach Nourishment: 2050-2060, 2 ft SLR or 100 foot offset from shoreline to infrastructure).

Evaluate beach conditions and implement beach nourishment as necessary to maintain 100-foot buffer seaward of the sewer force main and/or Highway 1. Repeat nourishments as needed.

Hazard Policy 45 (Flood Protection: 2020-2030, 0 feet SLR).

Analyze need for floodwall along commercial property to manage flooding from San Pedro Creek under existing conditions with SLR allowance. Future flood studies that include climatedriven changes in precipitation should inform any floodwall design. Floodproof Anza pump station (stormwater) to mitigate existing coastal storm flooding vulnerabilities to wave run-up.

Hazard Policy 46 (Flood Protection: 2050-2060, 2 feet SLR or 100-foot offset from shoreline to infrastructure).

Floodproof the Linda Mar pump stations (sewer and stormwater) to mitigate future coastal storm flooding vulnerabilities to wave run-up as necessary.

Hazard Policy 47 (Groundwater Management: 2030-2050, 0-2 feet SLR).

Begin groundwater monitoring to determine needs for dewatering wells in the lowest portions of the West Linda Mar neighborhood.

Hazard Policy 48 (Managed Retreat/Realignment: 2050, 2 feet SLR).

Provide option to private landowners to voluntarily remove existing armoring and receive a buyout of property as feasible. Evaluate and implement relocation of public infrastructure as necessary. Assure protection of public access to and along the shoreline, consistent with the LCP and Shoreline Mitigation Plan required under Hazard Policy xx.

Attachment 1

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Packet Pg. 1488 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
14 Pedro Point and Shelter Cove
Potential bluff erosion may reach the most seaward bluff top homes at Pedro Point by about 2050 with 1 to 2 feet of sea-level rise. Private property is mostly armored along the water (boat docks/homes) but require upgrades by property owners, while bluff top properties have limited ability to prevent bluff toe erosion due to parcel limits.

Private property is vulnerable to bluff erosion, but implementing bluff toe armoring would be complicated due to land ownership
Hazard Policy 49 (Shoreline Structure Upgrades).

Allow replacement and upgrades of existing shoreline structures to reduce hazards and resource impacts. Mitigate impacts consistent with the City’s shoreline mitigation program.

Hazard Policy 50 (Managed Retreat/Realignment: 2050-2100, 100 feet offset from bluff edge to development or infrastructure).

Provide option to private landowners to voluntarily remove existing armoring and receive a buyout of property as feasible. Evaluate and implement relocation of public infrastructure as necessary. Assure protection of public access to and along the shoreline, consistent with the LCP and Shoreline Mitigation Plan required under Hazard Policy xx.

Hazard Policy 51 (Flood Protection: 2030-2040, 0-1 feet SLR).

Allow private property owners to raise homes and other structures above wave run-up hazard, consistent with height limitations.

Standard Policies for New Shoreline Development
Hazard Policy 52 (Coastal Hazard Report).

Development proposed in coastal hazard zones shall include coastal engineering, geomorphology and other relevant technical reports unless on-site hazards already identified in a recent hazard map or assessment are adequate for evaluating and ensuring compliance with the LCP, including through use of permit conditions to address any uncertainty. Reports shall be prepared by a licensed civil engineer other suitably qualified professional; use the best available science; consider the impacts from the high projection of sea-level rise for the anticipated duration of the proposed development; demonstrate that the development will avoid or minimize impacts from coastal hazards; and evaluate the foreseeable effects that the development will have on coastal resources over time. Reports may be waived for temporary events, structures or other minor, short-term development where it is clear there will be no hazard risks over the project’s life.

Hazard Policy 53 (Land Divisions).

Land divisions that create new development potential in hazard zones, including lot splits, lot line adjustments and conditional certificates of compliance, are prohibited.

Hazard Policy 54 (Siting and Design).

New development in shoreline coastal hazard zones, including substantial improvements of existing structures, shall be sited and designed to be safe from erosion, bluff failure, wave runup, flooding and other coastal hazards for at least 100 years without existing or new shoreline Attachment 1

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Packet Pg. 1489 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
15 protection, considering projected sea-level rise and other climate change effects. Permit approvals shall prohibit shoreline protection for the authorized development, require the property owner to record an acknowledgement that the development does not qualify as a structure entitled to shoreline protection under Coastal Act Section 30235, and a waiver of any rights to such protection, and where necessary require a removal and restoration plan, including bonding for large projects, to avoid future shoreline protection or project failure.

Hazard Policy 55 (Assumption of Risk by Private Landowners).

Permit approvals of development in coastal hazard zones shall require the applicant to record a deed restriction acknowledging and agreeing: 1) that the development is located in a hazardous area, or an area that may become hazardous in the future; 2) to assume the risks of injury and damage from such hazards in connection with the permitted development; 3) to unconditionally waive any claim of damage or liability against the City of Pacifica, its officers, agents, and employees for injury or damage from such hazards; 4) to indemnify and hold harmless the City of Pacifica, its officers, agents, and employees with respect to approval of the project against any and all liability, claims, demands, damages, costs (including costs and fees incurred in defense of such claims), expenses, and amounts paid in settlement arising from any injury or damage due to such hazards; 5) that sea-level rise could render it difficult or impossible to provide services to the site (e.g., maintenance of roadways, utilities, sewage or water systems), thereby constraining allowed uses of the site or rendering it uninhabitable; 6) that the boundary between public tidelands and private land may move inland causing the structure to be located on public land and thus subject to removal unless otherwise authorized by the Coastal Commission and State Lands Commission; and 7) that the structure may need to be removed or relocated if it becomes unsafe or substantially damaged.

Hazard Policy 56 (MHTL and Avoidance of Public Trust Lands).

Applications for low-lying development adjacent to coastal waters shall include a Mean High Tide Line (MHTL) survey of the development site prepared by a licensed professional land surveyor based on field data collected within 12 months of the date submitted. The survey shall be conducted in consultation with and approved by the California State Lands Commission (CSLC) staff. Development shall be sited to avoid public trust lands for the its approved duration, unless otherwise authorized by the California State Lands Commission and Coastal Commission.

New MHTL surveys shall be submitted every ten years or within one year of a new tidal datum epoch, seismic event in the project area greater than 5.5, or significant relative rise in annual local mean sea-level records.

Hazard Policy 57 (Bluff Face Development).

Structures, grading, and landform alteration on bluff faces are prohibited, except for the following: public access structures where no feasible alternative means of public access exists, and shoreline protective devices if otherwise allowed by the LCP and the public access and recreation policies of the Coastal Act. Such structures shall be designed and constructed to be visually compatible with the surrounding area to the maximum extent feasible and to minimize effects on erosion of the bluff face.

Hazard Policy 58 (Minor Development in Hazardous Areas).

Minor and/or ancillary development, including public trails, benches, gazebos, patios, etc., may be located seaward of a bluff or shoreline setback line provided that development is otherwise consistent with the LCP, does not create a hazard, and does not use a foundation that can serve as a bluff retaining device, such as caissons, or that requires landform alteration, and that the Attachment 1

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Packet Pg. 1490 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
16 development is removed or relocated by the landowner when threatened or in the event that portions of the development fall to the bluffs, beach or ocean.

Hazard Policy 59 (Non-conforming Structures in Hazardous Areas).

When proposed development would involve substantial improvement of an existing structure that is legally non-conforming with an LCP standard, including bluff setbacks or other hazard criteria, the entire structure must be made to conform with the LCPs and, if applicable, the Coastal Act. Non-exempt improvements to existing non-conforming structures, regardless if the proposed improvements meet the thresholds for redevelopment, shall not increase the degree of non-conformity of the existing structure by, for example, increasing the hazardous condition, developing seaward, or increasing the size of the structure in a non-conforming location.

Hazard Policy 60 (Protection of Private Property in Hazardous Areas).

Where full adherence with all LCP policies, including for setbacks and other hazard avoidance measures, would preclude a reasonable economic use of the property as a whole, the City may allow the minimum economic use and/or development of the property necessary to avoid an unconstitutional taking of private property without just compensation. There is no taking that needs to be avoided if the proposed development constitutes a nuisance or is otherwise prohibited pursuant to other background principles of property law (e.g., public trust doctrine).

Continued use of an existing structure, including with any permissible repair and maintenance (which may be exempt from permitting requirements), may provide a reasonable economic use. If development is allowed pursuant to this policy, it must be consistent with all LCP policies to the maximum extent feasible.

Hazard Policy 61 (Habitat Sea-level Rise Migration Buffers).

A sea-level rise buffer area shall be added to required new development habitat buffers if necessary to allow for the migration of wetlands and other shoreline habitats caused by sea-level rise over the anticipated duration of the development. Except for temporary uses, as described below, uses and development within sea-level rise buffer areas shall be limited to minor passive recreational uses, with fencing, de-siltation or erosion control facilities, or other improvements deemed necessary to protect the habitat, to be located in the upper (upland) half of the buffer area. Water quality features such as drainage swales required to support new development shall not be constructed in wetland buffers. Temporary uses may also be placed in the sea-level rise buffer area until such time as sea-level rise causes the wetlands or other shoreline habitat to migrate to within 100 feet of the temporary uses, at which time, they shall be removed. All habitat and buffers identified shall be permanently conserved or protected through a deed restriction, open space easement or other suitable device.

Hazard Policy 62 (Stormwater and Dry Weather Flows).

New development shall provide adequate drainage and erosion control facilities that convey site drainage in a non-erosive manner to minimize hazards resulting from increased runoff and erosion. Runoff shall be directed inland to the storm drain system or to an existing outfall, when feasible. If no storm drain system or existing outfall is present, blufftop runoff shall not be channelized or directed to the beach or the ocean.

Attachment 1

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Packet Pg. 1491 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
17 Hazard Policy 63 (Reduction of Greenhouse Gases).

New development shall include solar panels and, as appropriate, other energy reducing techniques to minimize greenhouse gas emissions, consistent with community character, coastal views and protection of biological resources.

Standard Policies for Shoreline Structures
Hazard Policy 64 (Soft Shoreline Protection).

Encourage the use of soft or natural shoreline protection methods, such as dune restoration and beach/sand nourishment as alternatives to hard shoreline protective devices. Soft shoreline protection devices shall be fully evaluated for coastal resource impacts, and shall only be approved if found consistent with the LCP policies related to shoreline protection. Consider combining beach replenishment with groin construction to maintain beaches and protect development (see subarea policies).

Hazard Policy 65 (Beach Nourishment).

In coordination with the Coastal Commission and other permitting agencies (e.g., State Lands Commission, U.S. Army Corps of Engineers), the City shall develop and implement a beach nourishment program in conjunction with sand retention structures to assist in maintaining beach width and elevations, consistent with subarea policies. The beach nourishment program will include measures to protect water quality and to minimize and mitigate potential adverse biological resource impacts from deposition of material, including measures such as sand compatibility specifications, restrictions on volume of deposition, timing or seasonal restrictions, and identification of environmentally preferred locations for deposits. The City will also consider developing an opportunistic sand program and evaluate how replenishment options may need to change over time with sea-level rise.

Hazard Policy 66 (Existing Shoreline Structures).

Except as may be otherwise provided in the LUP subarea policies, legally permitted shoreline protection structures may be repaired and maintained until the development they are protecting is removed or substantially improved, at which time the shoreline protection shall be reevaluated for consistency with LCP. Repair and maintenance activities shall not result in any enlargement or extension of the structure, or any seaward encroachment or impairment of public trust resources, and shall provide mitigation for any new coastal resource impacts not previously or otherwise mitigated through the City’s Shoreline Mitigation Program. Expansion, augmentation or replacement of 50 percent or more of the protective structure (by volume, linear (height or length) or areal extent) constitutes a new shoreline structure and shall comply with all policies of the LCP.

Hazard Policy 67 (New Shoreline Structures).

Unless a waiver of rights to shoreline protection applies on the property, shoreline protection structures, including revetments, breakwaters, groins, seawalls, cliff retaining walls, and other such construction that alters natural shoreline processes shall be permitted consistent with the LUP’s sub-area policies when required to serve coastal-dependent uses or protect existing principal structures or public beaches in danger from erosion, when designed to eliminate or mitigate adverse impacts on local shoreline sand supply, and when there is no less environmentally damaging feasible alternative such as relocation of the threatened development, beach nourishment, non-structural drainage and native landscape improvements, or other similar non-structural options. For purposes of this policy “existing principal structures” means Attachment 1

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Packet Pg. 1492 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
18 principal structures that were legally authorized prior to January 1, 1977 [or March 24, 1980; or date of LUP Update Certification] that have not since undergone redevelopment.

Hazard Policy 68 (Authorization Limits of New Shoreline Structures, 30235; Coastal Act).

Unless otherwise directed in a subarea policy, shoreline protection structures shall only be authorized until the time when the existing principal structure or adjacent structure that is protected by such a device: 1) is no longer present; 2) no longer requires armoring; or 3) is substantially improved.

Hazard Policy 69 (Mitigating Impacts of New Shoreline Structures).

Necessary shoreline structures shall be sited and designed to avoid sensitive resources to the maximum extent feasible. Adverse coastal resource impacts shall be fully mitigated, including impacts on sand supply, beach area, public access (vertical access to the shore and horizontal access along the shore and blufftop) and recreational use (surfing, fishing, hiking, etc.), public trust lands and values, ecological function, water quality, shoreline aesthetics, and cultural resources. Mitigation options shall include consideration of providing equivalent new public access, recreation, habitat or other coastal resource in the vicinity of the project, or if such options are not feasible, proportional in-lieu fees that consider and reflect, to the maximum extent practicable, the full value of lost resources for the approved lifetime of the project. Any fees shall be deposited in an interest-bearing account held by the City of Pacifica for use within the city limits for mitigation of the specific impact identified in the project approval. If unused after ten years, such fees may be used, including in combination with other similar fees, in San Francisco or San Mateo Counties to mitigate the impacts of shoreline structures generally. This policy may be met through compliance with the City’s Shoreline Mitigation Program pursuant to Hazard Policy xx.

Hazard Policy 70 (Monitoring Plan for New Shoreline Structures).

Proposals for new, replacement or repaired shoreline protection structures shall include a monitoring plan that evaluates the condition of the structure, conditions at the site and surrounding area, and whether the shoreline protection structure is still needed for protection.

The plan shall require an inspection at least every five years to identify: any structural damage and need for repair; environmental impacts, including excessive scour, impacts to shoreline processes and beach width (at the project site and the broader area and/or littoral cell as feasible), and impacts to public access and the availability of public trust lands for public use; and the status of the structure being protected. At least every 15 years the landowner shall submit a new Mean High Tide Line (MHTL) survey of the Subject property based on field data collected within 12 months of the date submitted. Surveys shall comply with Hazard Policy xx.

Standard Policies for Coastal Flooding and other
Hazards
Hazard Policy 71 (Flooding).

New development in flood hazard zones shall be avoided. If relocation of existing development in hazard zones is infeasible, substantial improvements shall be sited and designed to be safe from flooding, and without adverse offsite effects, for at least 100 years, considering projected sealevel rise and future flooding, including at least the 1% probability event. Design requirements shall include raising finished floor elevations of habitable space above projected flood Attachment 1

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Packet Pg. 1493 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
19 elevations; storing hazardous materials out flood areas; elevating mechanical and utility installations; prohibiting basements; and using flood vents and anchoring structures where appropriate. Structure elevations shall be limited to ensure consistency with LCP visual and community character policies and assure access to utilities over the duration of the development.

Hazard Policy 72 (Flood Risk Reduction).

The City shall evaluate and pursue floodproofing of infrastructure and other development in danger from projected flooding in 2050. Allow and facilitate private owners to floodproof structures, consistent with other LCP policies.

Hazard Policy 73 (Repetitive Loss).

The City shall monitor repetitive flooding loss and FEMA claims to assist in identification of priorities for adaptation measures, including acquisition of high-risk properties.

Hazard Policy 74 (Steep Slopes and Landslides).

New development shall minimize siting on steep slopes and in areas prone to land sliding.

Development on slopes over 35% is prohibited.

Hazard Policy 75 (Seismic Hazards).

New development shall be sited and designed to minimize risks from seismic events. Buildings for human occupancy shall avoid surface traces of active faults, consistent with the Alquist-Priolo Act and other relevant state law.

Hazard Policy 76 (Tsunami Hazards).

New development shall consider and minimize risks from in identified tsunami run-up zones.

Measures may include signage and education, evacuation plans, warning systems and other mitigations of tsunami risks.

Hazard Policy 77 (Bluff Drainage and Erosion).

The City shall 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.

Attachment 1

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Packet Pg. 1494 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Sea-Level Rise Policy Options for Pacifica LCP Update
20 REFERENCES
California Coastal Commission (CCC) 2015. Sea-level Rise Policy Guidance Interpretive Guidelines for Addressing Sea-level Rise in Local Coastal Programs and Coastal Development Permits. Unanimously Adopted August 12, 2015.

California Coastal Commission (CCC) 2018. Residential Adaptation Policy Guidance: Interpretive Guidelines for Addressing Sea-level Rise in Local Coastal Programs. March 2018, Revised.

California Natural Resources Agency (CalNRA) and California Ocean Protection Council (OPC), 2018. State of California Sea-Level Rise Guidance: 2018 Update. Adopted March 2018.

City of Pacifica. 2014. City of Pacifica Local Coastal Land Use Plan. Prepared for City of Pacifica. Prepared by Dyett and Bhatia, DKS Associates, Economic and Planning Systems (EPS) and ESA. Available at:
http://www.cityofpacifica.org/depts/planning/general_plan_update/default.asp. Accessed on January 11, 2018.

City of Pacifica. 1980. City of Pacifica Local Coastal Land Use Plan. March 24, 1980. Available at:
http://www.cityofpacifica.org/depts/planning/. Accessed on January 11, 2018.

City of Pacifica. 1994. City of Pacifica Implementation Plan codified in Articles 43 and 44, Chapter 4, Title 9 Planning and Zoning. Amended November 8, 2017. Available at:
https://library.municode.com/ca/pacifica/codes/code_of_ordinances?nodeId=16544. Accessed on January 11, 2018.

Environmental Science Associates (ESA), 2017. Future Conditions Scenarios for Pacifica LCP Update, Memorandum. Prepared for the City of Pacifica, December 18, 2017.

Environmental Science Associates (ESA), 2018a. Sea-Level Rise Vulnerability Assessment. Prepared for the City of Pacifica January 2018, Revised June 2018.

Environmental Science Associates (ESA) 2018b. Final Draft Sea-level Rise Adaptation Plan. Prepared for the City of Pacifica. July 2018.

Attachment 1

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Packet Pg. 1495 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G BROWN JR , GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
August 31, 2018
Tina Wehrmeister
Planning Director
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Draft Land Use Plan (LUP) Hazard Policies Dear Ms. Wehrmeister:

This letter is in response to the City of Pacifica’s request for comments on the “Proposed Updated Draft LUP Hazard Policies” provided to us in a memo from ESA to the City (entitled “Sea-Level Rise Policy Options for Pacifica LCP Update” and dated August 24, 2018). We note that we received this document just this week, and you have requested comments by today. As discussed with you, due to that abbreviated timeline of just a few days, we won’t be able to provide final or comprehensive comments, but we are happy to provide some preliminary thoughts and some broader observations regarding the current proposed policies. We look forward to continued dialogue on the policies, including with respect to refinements identified herein.

Overall, the proposed policies appear to provide a solid framework for advancing the City’s sea level rise adaptation efforts, which will be critically important in the coming decades. As is identified in its Sea Level Rise Vulnerability Assessment (June 2018), the City of Pacifica is already vulnerable to storm and wave impacts, including as evidenced by the loss of residential structures in recent years, and efforts to protect against such impacts have resulted in narrowed or completely inundated beaches backed by armoring where access can be largely unavailable at higher tides. These hazards are only expected to increase as sea levels rise, resulting in significant loss of public recreational beach resources and shoreline-area habitats, as well as damage to and loss of residential and commercial structures, and transportation, stormwater, and wastewater infrastructure. In particular, given its beaches are a fundamental backbone and significant part of the City’s social fabric and economic engine, it is critically important for the policies to reflect the importance of the City’s beaches, and to be transparent (and provided appropriate mitigations) where the policies might lead to increased impacts to same.

To this end, the proposed policies address the need to ensure that new development is sited and designed to be safe from coastal hazards and to avoid the need for armoring, and the policies provide many key mechanisms for future steps to take as sea level rise advances over time, including interim protection measures, beach nourishment, and eventual managed retreat in Attachment 2

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Packet Pg. 1496 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 2 certain locations. We want to commend the City for tackling such difficult issues head-on, and for starting to identify practical and substantive measures to address such issues moving forward.

At the same time, although many important sea level rise planning provisions are addressed in the proposed policies, and they provide a good foundation for the LCP update, we also believe that many important details will require refinement moving forward, including to ensure that the proposed policies are logical, feasible, realistic, and consistent with the Coastal Act. We look forward to working together with the City to refine this work so that it achieves Coastal Act and City objectives related to minimizing hazards and protecting coastal resources, even as sea level rises.

In the interim, and in drilling down a bit into the proposed policies, the current draft includes effective and important policies that address planning and accounting for coastal hazards longer term, but appear to require some focus on the shorter term horizon. For example, the “Standard Policies for New Development,” “Shoreline Structures,” and “Coastal Flooding and Other Hazards” sections provide policies for long-term planning throughout the City that should help ensure new development will be safe from current and future vulnerabilities and protective of coastal resources. However, we continue to have the same concerns that we have previously relayed to the City regarding how existing development will be addressed going forward in a manner that ensures beaches, habitat, public access, and recreation will be preserved for current and future generations, as required by the Coastal Act. Part of the challenge before us in refining the policies will be to make sure that the shorter term and longer term policies interact and seamlessly move towards similar objectives, and aren’t somehow at cross-purposes.

In addition, as you know we have previously identified issues associated with potential policy preparation as the City has worked through its Draft Adaptation Plan (including through meeting with you and your staff throughout this year as well as letters dated June 12, 2018 and August 29, 2018). One of our primary concerns was ensuring that such policy preparation was based on a detailed assessment of the feasibility and costs/benefits of different adaptation alternatives, and it is not clear that this sort of information has been fully developed. No matter what policies are ultimately proposed, it will be critical for decision-makers, both at the City and Commission level, to have the benefit of that sort of information as they weigh potential policy approaches.

We would be happy to work with you and your staff as this effort proceeds locally to ensure that such background is clearly provided.

In terms of more specific comments on the draft policies, here are some preliminary observations:
 The proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support it as a primary adaptation strategy through the proposed policies. In short, we think that policies that rely so heavily on nourishment, particularly in the shorter term, need to be Attachment 2

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Packet Pg. 1497 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 3 supported by more thorough data.
 The proposed policies refer to developing a “Shoreline Mitigation Program” in the future to address impacts associated with hazard response. The policies are going to need to be able to be structured to address such impacts now, and many policies seem to imply that is their intent. It may be appropriate to identify development of a future mitigation program as a refinement and a next step, but it needs to be clear that this does not negate the need for mitigation in the interim.
 It may be appropriate to reformat and reorganize the policies. For example, the “Standard Policies” sections from pages 14-19 account for the overarching approach for new development and substantial improvements to existing development, in all areas throughout the City, and in both the short- and long-term. It may make better sense to move these to the beginning. Additionally, although we understand the policy construct that suggests that general policies may be superseded by more specific policies for each sub-area, we are concerned that some of the more specific policies appear to be making prescriptions for outcomes that are not based on analysis (e.g., allowed armoring). It is not appropriate, in our view, to have policies state conclusions that have not yet been supported by analysis, and it may be that the overarching policies are required to take precedence in that regard unless and until conclusions can be drawn in that manner.
 The policies appear to be looking to the 2040 horizon as ‘longer term’, and this seems an appropriate framework. We would encourage a close review to ensure that policies referring to other time frames (e.g., 20-year approvals) are understood in terms of this horizon, including to ensure that development years out also times to the same horizon.  It appears that some critical policy language is missing from some of the draft policies.

Please ensure that the following are addressed:
o Please provide design standards for the construction of shoreline protection devices (e.g., they must: blend with natural environment; avoid significant habitat areas; minimize footprint; protect, and where feasible, provide public access; control erosion from surface and groundwater flows; etc.).
o Please identify specific details regarding how proportional mitigation for all unavoidable impacts of shoreline protection devices to coastal resources (e.g., shoreline sand supply, recreation, public views, and water quality) is to be measured and applied. o Please ensure that the policies require removal of shoreline protection devices when they are no longer required to protect existing structures in danger from erosion, including when structures are demolished and then rebuilt, or redeveloped. o Please define what constitutes “substantial improvements” to ensure that current development is brought into compliance with the policies as it is renovated and redeveloped. We have previously identified appropriate standards for such a definition, and would be happy to provide that again.
 Certain themes, concepts, and terms used throughout the draft policies need to be better defined, including as follows:
o Please better describe how the triggers would be implemented (e.g., trigger for when armoring/nourishment etc. would be implemented when the bluff offset reaches the Attachment 2

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Packet Pg. 1498 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 4 specified distance, or whether the specified distance triggers a different approach). In addition, please explain how the years and amounts of sea level rise pertain to the offset values and describe how beach width and bluff offsets will be measured. o Please explain how the hazard areas referenced in the policies will be defined, including the coastal hazard zones, coastal hazard maps, flood hazard zones, and tsunami run-up zones. In addition, for particular hazard areas that will be mapped, we recommend that the City add timeframes for how often these maps must be updated and include contingencies in the event that they are not updated by the prescribed deadline. o Please discuss how height limitations will be accounted for if/when structures need to be elevated to meet FEMA base flood levels in some areas.
o Please further expound upon what constitutes current “best available science” and whether there is a different standard for what amount of sea level rise should be evaluated in geotechnical studies versus what amount of sea level rise new development must be sited/designed to be safe from. For example, consider specifying that all new development must evaluate, at a minimum, the medium-high projection scenario (from the 2018 OPC Sea-Level Rise Guidance and in line with the Draft 2018 Science Update to the CCC SLR Policy Guidance) over its anticipated lifetime, but that if new development cannot be sited to avoid impacts over that time period certain minimum standards must be met (similar to the policies related to takings). We would be happy to work with the City on this topic.
o References to hazard policies are made without those specific policies’ reference numbers included. Please update the references accordingly.

Again, we appreciate and commend the City on developing these draft policies and the related policy framework, and look forward to helping to refine the policies and approach through our ongoing collaboration on the City’s LCP update. It is clear from these policies that the City is taking the issues and problems associated with coastal hazards seriously, and in a way that advances the City’s approach to sea level rise and LCP planning. We hope these comments help move us forward in that regard. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me or Patrick Foster of my staff. Again, we greatly appreciate the ability to be a part of this important planning process and look forward to continued coordination and discussion of this important effort.

Sincerely,

Jeannine Manna
North Central Coast District Manager
California Coastal Commission
cc: Bonny O’Connor, City of Pacifica Planner
Attachment 2

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Packet Pg. 1499 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G BROWN JR , GOVERNOR

CALIFORNIA COASTAL COMMISSION NORTH CENTRAL COAST DISTRICT OFFICE 45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
October 19, 2018
Tina Wehrmeister
Planning Director
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Draft Land Use Plan (LUP) Hazard Policies Dear Ms. Wehrmeister:

This letter is in response to the City of Pacifica’s request for comments on the “Proposed Updated Land Use Plan Coastal Hazards Policies” provided to us in a memo from ESA to the City (entitled “Sea-Level Rise Policy Options for Pacifica LCP Update” and dated August 24, 2018). As you know, we previously provided comments on a memo from ESA to the City with the same title and date (see attachment 1 for that memo, and see attachment 2 for our comments on it in a letter to the City dated August 31, 2018). We were surprised to see that the second memo (see attachment 3) was substantially different than the first memo and did not respond to the majority of our suggestions. Regardless of why the City may have chosen this approach, with respect to the second memo, many of our previous comments still stand, and are repeated below as appropriate. We have also suggested specific modifications to the policies and text within the new memo, including indicating where we believe that language from the first memo we reviewed should be re-inserted (see attachment 3). It is our understanding that the City Council will be considering these draft hazard policies by themselves now, but it is ultimately the City’s intention to incorporate them into an overall draft LCP update for consideration sometime in 2019. As such, although we provide some preliminary comments and suggestions here, it appears that there will also be future junctures when further refinement and comment is possible. Toward that end, we look forward to continued dialogue on the proposed policies, and to working with City staff to further develop this policy language in conjunction with the rest of the LCP update as the draft moves forward, including as it is modified in light of public and City Council input.

When we commented on the first memo we noted that we believed that the proposed policies began to provide a solid foundation and framework for advancing the City’s sea level rise adaptation efforts. As the Coastal Commission has routinely stated, clear, proactive policies for addressing sea level rise are critically important. This is undoubtedly true in Pacifica where, as is identified in the City’s Sea Level Rise Vulnerability Assessment (June 2018), the City is already vulnerable to storm and wave impacts. Such impacts are evidenced by the loss of blufftop residential structures in recent years, and by the fact that efforts to protect against such impacts have resulted in narrowed or completely inundated beaches backed by armoring where beach

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Packet Pg. 1500 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 2 access can be largely unavailable at higher tides. These hazards are only expected to increase as sea levels rise, resulting in a significant loss of public recreational beach resources and shorelinearea habitats, as well as damage to and loss of residential and commercial structures, and transportation, stormwater, and wastewater infrastructure. In particular, given its beaches are a fundamental backbone and significant part of the City’s social fabric and economic engine, it is critically important for the policies to reflect the importance of the City’s beaches, and to be transparent (and provide appropriate mitigations) where the policies might lead to increased impacts to same.

To this end, we are concerned that both the removal of some proposed policies from the first memo and the addition of new language in the second memo will result in policies that do not clearly state the need to ensure that new development and redevelopment be sited and designed to be safe from coastal hazards and to avoid the need for armoring. We also continue to have the same concerns that we have previously relayed to the City regarding how existing development will be addressed going forward in a manner that ensures beaches, habitat, public access, and recreation will be preserved for current and future generations, as required by the Coastal Act. In addition, we previously identified concerns associated with policy preparation based on a lack of technical and feasibility information as the City worked through its Adaptation Plan (including through meeting with you and your staff throughout this year as well as letters dated June 12, 2018 and August 29, 2018). One of our primary concerns was, and remains, ensuring that policies which prescribe specific adaptation measures (like armoring and beach nourishment with the use of sand retention structures) are based on a clear and detailed assessment of the environmental, technical, and economic feasibility of such alternatives. It is not clear that such information has been fully developed.

We do continue to recognize that addressing new and existing development in a place like Pacifica is a complex challenge given the scope of current and future hazards combined with existing patterns of development and shoreline armoring and uncertainties about future sea level rise and future conditions on the ground. As we have previously explained in meetings with and letters to City staff, there are policy approaches that would allow for continued reliance on armoring for certain development over a specified time horizon, including as identified in the City’s current sub-area policies. However, such policy approaches still need to ensure that impacts to other coastal resources would be mitigated, and need to build in an understanding that other adaptation options may be necessary if and when armoring (and/or beach nourishment) can no longer provide adequate protection for both development and coastal resources. Part of the challenge before us is to refine the policies and strike an appropriate balance in order to protect the range of coastal resources and development, while ensuring that short and long term policies interact and seamlessly move towards similar objectives.

In any case, we want to commend the City for tackling difficult sea level rise issues and for starting to identify practical and substantive measures to address such issues moving forward. To be sure, the proposed policies provide many key mechanisms for future steps to take over time as sea level rise advances, including interim protection measures, beach nourishment, monitoring of changing conditions, and periodic updates to the City’s Adaptation Plan to respond to such changes. Although many important coastal hazard planning provisions are addressed in the proposed policies and they provide a good foundation for the LCP update, we also believe that

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Packet Pg. 1501 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 3 many important details will require refinement moving forward, including to ensure that the proposed policies are logical, feasible, realistic, and consistent with the Coastal Act. We continue to look forward to working together with the City to refine this work so that it achieves Coastal Act and City objectives related to minimizing hazards and protecting coastal resources, even as sea level rises.

In terms of some more specific comments on the draft policies in the second memo, here are some preliminary observations:
• The previous memo included a summary with details of how the City has dealt with the impacts of shoreline erosion and coastal flooding for decades. We recommend including a similar setting description in the LUP itself to speak to the broad purpose of the proposed coastal hazard policies and to provide context for their future implementation. • The proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously with City staff, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support it as a primary adaptation strategy through the proposed policies. In short, we think policies that rely so heavily on nourishment, particularly in the shorter term, need to be supported by more thorough data. Similarly, the use of sand retention structures can alter ocean waves, currents and sand movement, potentially exacerbating erosion on one side or the other of the structure (e.g., depending on currents, littoral drift, etc.). These potential impacts should be evaluated accordingly if sand retention structures are planned to be used in conjunction with beach nourishment.
• The proposed policies refer to developing a “Shoreline Mitigation Program” in the future to address impacts associated with hazard response. The policies need be structured to address such impacts now, and many policies seem to imply that is their intent. It may be appropriate to identify development of a future mitigation program as a refinement and a next step, but it needs to be clear that this does not negate the need for mitigation in the interim. Accordingly, given the Shoreline Mitigation Program is not yet complete, we recommend removing reference to implementation of the Program in the policies, instead of referencing only that it will be developed in the future. Until the Program is fully developed, mitigation should be implemented consistent with the type of requirements found in proposed Hazard Policy 60. • It may be appropriate to reformat and reorganize the policies. For example, the “Standard Policies” sections from pages 12-16 account for the overarching approach for new development in all areas throughout the City, and in both the short- and long-term. It may make better logical, and document-flow sense to move these, along with the definitions section, to the beginning of the document. Additionally, although we understand the policy construct that suggests that general policies may be superseded by more specific policies for each sub-area, we are concerned that some of the more specific policies appear to be making prescriptions for outcomes that are not based on analysis (e.g., allowed armoring). It is not

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Packet Pg. 1502 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 4 appropriate, in our view, to have policies state conclusions that have not yet been supported by analysis, and it may be that the overarching policies are required to take precedence in that regard unless and until more definitive conclusions can be drawn. • It appears that some critical policy language is missing from some of the proposed draft policies. Please ensure that the following are addressed:
o Please provide design standards for the construction of allowable shoreline protection devices (e.g., they must: blend with natural environment; avoid significant habitat areas; minimize footprint; protect, and where feasible, provide public access; control erosion from surface and groundwater flows; etc.).
o Please identify specific details regarding how proportional mitigation for all unavoidable impacts of shoreline protection devices to coastal resources (e.g., shoreline sand supply, beaches, public recreational access areas and amenities, public views, water quality, etc.) is to be measured and applied. Please ensure that the policies require removal of shoreline protection devices when they are no longer required to protect existing structures in danger from erosion (including when structures are demolished and then rebuilt, or redeveloped) when such removal and restoration can be accomplished without endangering existing principal structures or existing public facilities on adjacent sites. o Please discuss how height limitations will be accounted for if/when structures need to be elevated to meet FEMA base flood levels in some areas.
o The siting and design policies for hazard areas no longer address substantial improvements to existing development (or ‘redevelopment’) in the second memo. We recommend the City develop specific language for how the siting and design of structures will be addressed when they are redeveloped in situations where there is existing, legally authorized shoreline protection and in cases where there is a natural bluff or shoreline fronting the proposed development. In addition, we recommend including separate policies to address new development on vacant lots that are fronted by existing, legally authorized shoreline armoring and in places where there is a natural bluff or shoreline. In cases where new development/redevelopment cannot be located safe from hazards without reliance on existing and/or new armoring or cannot meet the required setbacks, any approval for such development should include triggers for eventual removal in response to coastal hazards (e.g., when declared unsafe for occupancy and/or use; when the development encroaches onto current or future public trust land and the State Lands Commission denies a grant, lease, or other legal mechanism to allow the development to remain in place; when access and utilities are no longer available to serve the development and cannot be restored; when the blufftop edge erodes to the minimum setback line; when removal is required by subsequent adaptation planning; etc.), as well as propose ways in which the new and redeveloped structures will mitigate for that armoring’s impacts to coastal resources.
o Please provide a policy that outlines how the City will address development that becomes unsafe for occupancy and a public nuisance due to coastal hazards.

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Packet Pg. 1503 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 5 • Certain themes, concepts, and terms used throughout the draft policies need to be better defined or explained in order for us to better evaluate the intent and application of the proposed policies, including as follows:
o Please define “existing structure,” as it is used often in the policies in relation to shoreline armoring. We recommend that it be defined as a structure legally authorized prior to the effective date of the Coastal Act on January 1, 1977, including as is identified in the Commission’s Sea Level Rise Policy Guidance.
o Instead of only a reliance on “new development”, please also define “redevelopment” to ensure that current development is brought into compliance with the policies as it is substantially changed over time. Please establish clear thresholds for when repair, maintenance, improvement, or other work is conducted to the extent that a structure needs to be reviewed against all current standards, including for coastal hazards.

Typically, such thresholds would at the least include alteration (including demolition, renovation or replacement) of 50% or more of major structural components. o Please further describe what constitutes current “best available science” and whether there is a different standard for what amount of sea level rise should be evaluated in geotechnical studies versus what amount of sea level rise new development must be sited/designed to be safe from. For example, consider specifying that all new development must evaluate, at a minimum, the medium-high projection scenario (from the 2018 OPC Sea-Level Rise Guidance and in line with the Draft 2018 Science Update to the Commission’s Sea Level Rise Policy Guidance) over its anticipated lifetime, but that if new development cannot be sited to avoid impacts over that time period certain minimum standards must be met (similar to the policies related to takings). We would be happy to work with the City on this topic.
o Please explain how the hazard areas referenced in the policies will be defined, including the coastal hazard zones, coastal hazard maps, flood hazard zones, and tsunami run-up zones. The current definition of hazard zone refers to the City’s current maps, but it is not clear to what maps that refers. Any maps referred to in the policies should be included as part of the LCP. In addition, for particular hazard areas that will be mapped, we recommend that the City add timeframes for how often these maps must be updated and include contingencies in the event that they are not updated by the prescribed deadline. o Proposed Hazard Policy 5 states that the City will implement a monitoring program for sea level rise to establish thresholds for reassessing the City’s Adaptation Plan. Please describe the type of thresholds that will be identified. Additionally, the current sub-area policies refer to triggers, but do not explain how the triggers would be implemented. For example, clarify whether armoring/nourishment etc. would be implemented when the bluff offset reaches the specified distance, or whether the specified distance triggers a new approach. Please also explain how beach width and bluff offsets will be measured. o Proposed Hazard Policy 7 states that the Shoreline Mitigation Program will identify priority improvements for maintaining and enhancing coastal shoreline resources, particularly public access and recreation. Please further describe what types of

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Packet Pg. 1504 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 6 improvements the City is contemplating in this regard and provide relevant examples. o Proposed Hazard Policy 8 refers to funding for “adaptation strategies”. Please outline what kind of strategies this refers to, and specify if this will include voluntary removal or relocation of development.
o Proposed Hazard Policy 9 calls for identifying areas where densities and heights may be increased using TDR credits, including to facilitate affordable housing. Please describe how such determinations will be made, including which specific criteria will be evaluated.
o Proposed Hazard Policy 11 states that the City will preserve, protect, or relocate hazard prone infrastructure to maintain critical services and the environment. Given that these two goals will often conflict, please specify what criteria will be evaluated in determining the preferred option for infrastructure projects. Also, given similarities and overlap, please consider combining with proposed Hazard Policy 10. o Please clarify the intent of proposed Hazard Policy 50. Presumably redevelopment of existing development will require the entire structure to conform to applicable LCP standards, but the policy is not clear on this point.
o Proposed Hazard Policy 52 requires sea level rise buffer areas be added to new development if necessary to allow for the migration of wetlands and other shoreline habitats. Please describe how such buffer areas will be delineated, applied, and protected as same.
o The definition of shoreline within the hazard policies appears to exclude shoreline properties adjacent to rivers, streams and creeks, as well as properties that will be impacted by erosion and/or flooding by large storm events or over longer time periods due to rising sea levels. We recommend that the policies instead refer to coastal hazard areas so that properties that are potentially subject to coastal flood and erosion hazards both now and in the future will be reviewed for consistency with the hazard policies.

Again, we appreciate and commend the City on developing these draft coastal hazard policies and the related policy framework, and look forward to helping to refine the policies and approach through our ongoing collaboration on the City’s LCP update. It is clear from these policies that the City is taking the issues and problems associated with coastal hazards seriously, and in a way that advances the City’s approach to sea level rise and LCP planning. We hope these comments help move us forward in that regard. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me or Patrick Foster of my staff. Again, we greatly appreciate the ability to be a part of this important planning process and look forward to continued coordination and discussion of this important effort.

Sincerely,

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Packet Pg. 1505 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 7 Jeannine Manna
North Central Coast District Manager
California Coastal Commission
cc: Bonny O’Connor, City of Pacifica Planner
Attachments:

Attachment 1 – ESA memo to the City dated August 24, 2018 (memo 1) Attachment 2 – CCC comments on memo 1 dated August 31, 2018 Attachment 3 – ESA memo to the City also dated August 24, 2018 (memo 2)

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Packet Pg. 1506 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW COASTAL CA GOV
November 22, 2019
City of Pacifica Planning Department
Attn: Tina Wehrmeister
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Consultation Draft Local Coastal Program Land Use Plan Update Dear Ms. Wehrmeister:

Thank you for the opportunity to review and comment on the City’s proposed draft update to the Local Coastal Program (LCP) Land Use Plan (LUP). As you know, the LUP is a key regulatory tool that implements the statewide goals and policies specified in the California Coastal Act to protect, restore, and enhance coastal resources at the local level, including by specifying the kinds, locations, and intensities of allowed development and applicable coastal resource protection requirements. Once the LUP and an accompanying Implementation Plan (IP) are certified by the Coastal Commission,1thus certifying an updated LCP overall, the updated LCP forms the basis and standard of review for future development within the City’s Coastal Zone.

Accordingly, the City’s current LCP update process offers an exciting opportunity to holistically and comprehensively envision Pacifica’s future and craft the process for how to achieve that vision. Given that importance, Commission staff has been actively and directly engaged with you and your staff to identify issues early and provide recommendations on how to approach the many complicated coastal resource policy decisions facing the City. We acknowledge the substantial time and energy the City has invested in developing this draft document and we greatly appreciate the efforts to coordinate and discuss with Commission staff.

In that vein, we are hopeful that these comments are understood in the manner in which intendednamely to provide as much helpful guidance from our perspective as possible at this juncture. As such, this letter provides a summary of some of the key issues we’ve identified thus far in our review of the draft document, as well as some broad recommendations for how to address these issues. Some of these issues we have discussed with you to-date, while others will be introduced for the first time in this letter.

Specific comments, as well as some line-edits, have been provided on each of the draft LUP chapters in the attached documents. However, given our limited review time, these comments and edits should not be considered final or comprehensive. Lastly, this letter is intended to respond to the City’s letter dated October 31, 2019 to clarify Commission staff’s general perspective regarding the consultation process thus far.

1 The standard of review for an LUP is Chapter 3 of the Coastal Act, and for an IP is the certified LUP.

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Packet Pg. 1507 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
2 Consultation Process
With regard to the letter sent to Commission staff regarding the LCLUP consultation process, we note that the City of Pacifica originally initiated the LCLUP Update process by developing a Consultation Draft in 2014. While this draft document was transmitted to Commission staff for initial review, the City halted the LCLUP process due to time and budgetary constraints. As a result, Commission staff did not conduct a thorough review nor provide written comments to the City at that time. The City began to reengage in the LCLUP update process again in 2018 through the development of an administrative draft of the LUP Coastal Hazards Chapter in conjunction with the development of a vulnerability assessment and adaptation plan. Throughout the multiple rounds of review prior to City action, Commission staff sent three comment letters (dated August 29, 2018, August 31, 2018, and October 19, 2018) on the Hazard Policy Update, all within the abbreviated timeframes requested by City staff, as well as attended a number of public meetings. Through all of these communications, Commission staff noted a willingness to work with the City to identify alternative, context-specific approaches to resolve significant concerns with the hazard policies as drafted (see included attachments). Other than a few coordination calls, Commission staff did not receive specific requests from the City to meet staff-to-staff to further engage at that juncture. Following action by the City Council approving the draft hazard policies for incorporation into the full LCLUP update, no further progress was made on the LCP update, as reflected in LCP grant progress reports received from the City during early 2019.

In summer and early fall of 2019, the City began to recirculate a new LCLUP Consultation Draft, starting with the version originally developed in 2014, incorporating the latest draft Hazards Policy Chapter approved by the City Council. While the City initially emailed Commission staff in August regarding their plans for revising the draft LCLUP recirculation schedule, there was no further discussion with Commission staff regarding the revised timeline to ensure it would be workable and provide for adequate review and staff to staff coordination prior to the draft going before the City Council and Planning Commission for feedback. In an effort to improve coordination on the LUP update process to ensure adequate and meaningful consultation could occur, Commission staff reached out to the City about the anticipated schedule and how to accommodate essential timeframes for both agencies.

At that time, the City relayed that they were sticking to an accelerated timeline to meet grant requirements, but did agree to modify the deadline for comments so as to provide Commission staff with 30-working days to review the draft document as opposed to 30-calendar days. During this review period City and Commission staff have met various times, both in-person and over the phone, and agreed the meetings have been productive. Commission staff continues to commend City staff for the hard work and coordination to-date, and it is our hope this cooperative process can continue. In our experience, this type of early coordination helps to ensure a smoother LCP certification process, including streamlining review and resolution of issues upon ultimate submittal to the Coastal Commission. As such, we will continue to honor our commitments to provide feedback to the City as requested, as we have previously done, regardless of existing workload constraints and staff turnover.

Draft LCLUP Update Feedback and Recommendations
First, in general, the proposed LUP update provides a good starting point by which the City can evaluate development in the coastal zone through assessing up-to-date information and revised policies that address current issues facing the City and reflect the City’s present day vision. However, at a broad level, the document requires numerous clarifications and details added to the policy language to make

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Packet Pg. 1508 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
3 the LUP as user-friendly as possible, manage development expectations in certain areas of the City with known constraints, and ensure consistency with the resource protection policies of the Coastal Act.

Additionally, there is significant overlap between policies in different chapters that creates redundancy, most notably between the Natural Hazards and Coastal Resilience Chapters. In our view, with added refinements and focus, the LUP will offer more clarity and ease of use, ensure adequate protections for sensitive habitats and public access to the beach, and minimize hazard risks to new development. We strongly recommend that the document be reviewed to add detail and clarify language where needed, eliminate policy redundancies, both within and among chapters, and to group related policies accordingly, as discussed in meetings and addressed in this letter and in the attached document edits.

Additionally, in 2019, the Coastal Commission unanimously adopted its first environmental justice policy to provide guidance for Commissioners, staff, and the public on how the Commission will implement its environmental justice authority and integrate the principles of environmental justice, equality, and social equity into all aspects of the Commission’s program and operations. While the current draft LUP mentions environmental justice in terms of the City Council’s Goals and in policy CR-I-2, we recommend the City consider adding additional policies that will more fully address environmental justice issues that pertain to coastal resources as well as participation in the decision making process to help to reduce disparate impacts on vulnerable communities resulting from new development.

In terms of the Land Use and Development chapter, we recommend: 1) ensuring that all figures, numerical references, and maps regarding existing and proposed land use patterns are accurate and upto-date; 2) adding language regarding maps/diagrams to indicate that they are illustrative and for planning purposes only; 3) adding directive policies requiring new development to demonstrate that there are adequate public services to serve such development, examples of which were previously provided to the City; 4) adding up-to-date neighborhood-specific traffic, hazard, visual character, and coastal planning constraints as outlined in the 1980 version of the LUP; 5) including further detail about sites with known development constraints (i.e. the Quarry and Pedro Point field); 6) prohibiting increases in density of land use in hazard and sensitive resource areas; 7) redesignating areas with severe development constraints to the Conservation land use designation, including lots adjacent to the bluff edge where homes and apartments were recently removed; and 8) providing a figure that indicates all proposed changes to existing certified land use designations. With regard to the Public Access Chapter, we recommend: 1) adding more policies that specifically bolster and speak to coastal access, as opposed to public access more generally; 2) ensuring that coastal access will be able to adapt in response to coastal hazards including in areas with and without shoreline protection; and 3) including all existing coastal access points throughout the City including lateral and vertical trails required as CDP requirements, and public parking lots.

Within the Environmental and Scenic Resources Chapter, in general, more recent sources and information should be referenced, and internal references should only be made to maps and documents that are part of the LUP rather than to other City documents. More specifically, the relationship between wetlands and environmentally sensitive habitat areas (ESHA) warrants further discussion. For example, while not all wetlands are ESHA, wetland policies are applied to all wetland areas, which should be stated explicitly. Further, the draft LUP should cite and recognize Coastal Commission regulations that

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Packet Pg. 1509 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
4 more clearly articulate the requirement for a one-parameter criteria for wetland delineations which is applied in the coastal zone, contrasting this with the USACE three-parameter approach. It should also be noted that because the National Wetlands Inventory (and similarly, any map provided or prepared by the City) are not all comprehensive, on-the-ground conditions will prevail. Discussions on ESHA should also: 1) include policies on ‘especially valuable habitat’ as defined by the Coastal Act, which captures natural resources not considered rare but that have some other particular value (e.g. unusually pristine conditions, vegetation supporting other sensitive species, wildlife corridors, etc.); 2) remove references to degrees of habitat value without definition, as an area can be severely degraded and still constitute ESHA if it can be restored and/or is supporting sensitive resources; 3) categorically designate dune habitats as ESHA; 4) reorganize and bolster the ‘Plant Communities and Wildlife Habitats’ section for consistency in terms of vegetation types and levels of specificity and relevance; 5) consider habitat not defined by vegetation communities including bluff faces, offshore rocks and islets, and dunes; 6) articulate why seasonal wetlands are included under ESHA; and 7) explain that all riparian habitat should be treated as ESHA, while clearly articulating the differences between streams, creeks, riparian vegetation, and riparian corridors.

In addition, minimum buffer requirements should be established for sensitive habitat areas including wetlands and ESHA, including streams, and any uses allowed within such buffers should be specified.

Moreover, a defined limit should be established for any exceptions to such minimum buffer requirements resulting in a buffer reduction. 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 wetland and/or ESHA and will be compatible with the continuance of the wetland and/or 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 wetland and/or ESHA. For both perennial and intermittent streams, buffers should be measured from the outer edge of riparian vegetation where it exists; if it does not, the buffer should be measured from the edge of the bank; and if there is no bank, the buffer should be measured from the mid-line of the watercourse. With respect to impacts and mitigation, impacts to coastal resources must always first be avoided to the maximum extent feasible, then minimized, then mitigated for. As such, compensatory mitigation requirements for impacts to sensitive habitats that cannot be avoided should be addressed in this document. Further, the City should consider defining temporary versus permanent impacts- where temporary impacts are those that would be resolved within 12 months, and do not include earthwork or other significant disturbance, with impacted vegetation restored to equal or better including that similar age/size structure of the community is restored.

The Environmental and Scenic Resources Chapter should also reference both perennial and nonperennial resources in any discussion on creeks and other waterways, should further develop the discussion and policies on marine resources (including beaches, rocky intertidal and reef habitats, softbottom habitats, and offshore rocks), and should avoid referencing “restoring” beaches unless it is intended to include ecological, as well as mineral and physical, resources. Additionally, instead of referencing restrictions on invasive plant species, we recommend prohibiting the use of any California Invasive Plant Council (Cal-IPC)-listed species with a status of high or moderate, or identified as locally-threatening under the limited alert or watch status, and to establish requirements for their

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Packet Pg. 1510 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
5 abatement from sites on a project-by-project basis as well as through broader restoration efforts. Lastly, there is the potential to frame some of the issues in the chapter under a theme of ‘water security,’ including concepts such as groundwater recharge, use of recycled water, etc.

As mentioned above, there are numerous redundancies between the “natural shorelines” section in the Environmental and Scenic Resources chapter and the content of the Natural Hazards and Coastal Resilience chapters. We recommend instead framing the protection of natural shorelines as “preservation of natural shore dynamics.” In addition to these redundancies, feedback on adaptation and hazard policies expressed in the aforementioned comment letters in 2018 (enclosed) was not incorporated into the draft policies, and as such the main themes are reiterated here. Specific details on policy language that should be incorporated can be found in the enclosed letters, including topics such as design, mitigation, and removal of shoreline protection structures, as well as triggers for removal of threatened development.

In general, the hazard and coastal resilience policies seem to recommend an approach for protecting development throughout the City with hard armoring, supplemented by potential beach nourishment, with no policies that would allow the City to prepare to relocate structures out of hazardous areas. The emphasis on armoring would likely result in the loss of beaches and their associated public access, recreation, economic, and habitat benefits as sea levels rise, and would leave the City unprepared for sea level rise in the long term. While armoring may protect existing development in the short- to mediumterm, such an approach may not be technically or economically feasible in all areas and/or over longer timeframes, and would not, by itself, be consistent with Coastal Act requirements to ensure protection of coastal resources. Policies should be framed to better balance the dual Coastal Act goals of ensuring safe development and protecting coastal resources such as beaches, habitat, and public access and recreation, as sea level rises over time. As discussed in our previous comment letters and in recent coordination calls, Commission staff would be happy to work with City staff in developing a more appropriate balance of short- and long-term approaches, including those that would consider the use of shoreline armoring.

Additionally, the proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue if technically feasible, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support such an approach as a primary adaptation strategy in this proposed LCP update. In short, we think that policies that rely so heavily on nourishment, particularly in the shorter term, need to be supported by more thorough quantitative data.

In addition, we have previously identified appropriate definitions of “redevelopment” and “existing structures” or “existing development” that should be incorporated into the draft. “Existing development” should be defined as a structure legally authorized prior to the effective date of the Coastal Act, i.e.- January 1, 1977, including as it is identified in the Commission’s Sea Level Rise Policy Guidance.

Instead of defining redevelopment, the draft defines ‘new development’ as development on a previously

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Packet Pg. 1511 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
6 vacant parcel, which would mean no current structures would ever have to be brought into compliance with policies if substantially redeveloped and as such does not align with the Coastal Act or the Commission’s guidance on sea level rise planning.

Finally, as discussed above, we have reviewed each of the draft LUP chapters and provided City staff with our suggestions and recommendations via in person meetings and phone calls on each chapter. In closing, we again thank you and your staff for the thoughtful and collaborative work done to date, and appreciate and commend the City for moving forward with the sometimes difficult, but important, task of updating the LCP’s LUP. We also very much look forward to continued collaboration, and helping the City to refine the draft LUP, and a future draft IP, including in the ways identified in this letter. We hope these comments help move us forward to this end. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me.

Sincerely,
Julia Koppman Norton
Coastal Planner
North Central Coast District Office
California Coastal Commission
cc: Kevin Woodhouse, City of Pacifica City Manager
Encl.: CCC Letter to City, dated August 29, 2018
CCC Letter to City, dated August 31, 2018
CCC Letter to City, dated October 19, 2018
LCP Draft Update, Ch. 1-6 & Appendices, with edits

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Packet Pg. 1512 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) From: Pat Kremer [
Sent: Friday, February 18, 2022 8:21 AM
To: Public Comment [
CC: PHS Info [
Subject: Comments from Pacifica Historical Society
Attachments: CommentsPHSBoard .pdf
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These Comments refer to the Draft General Plan only.

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Packet Pg. 1513 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) To: [email protected]
From: The Pacifica Historical Society Board of Directors, Judy Heldberg – President
Address:

Box. 752
Pacifica, CA 94044
Date: February 18, 2022
These comments regarding the Draft Pacifica General Plan have been approved by the Board of Directors of The Pacifica Historical Society on February 8, 2022. In order to be clear with what changes we propose, we have included here the entire section of the 2022 Draft Pacifica General Plan Chapter 7 (Conservation) section 7.6 “CULTURAL RESOURCES AND HISTORIC PRESERVATION”. We have crossed out parts we think should not be included, and made changes in yellow highlight, with additional notes in red to clarify the changes. Fig.

4. could not be copied, but comments about it are included after comments on Table 5.

For clarity, a second copy that incorporates the changes is included here after the one with notations .

7.6 CULTURAL RESOURCES AND HISTORIC

PRESERVATION
One objective of the General Plan is to protect community assets, including sites with historical and cultural significance. Cultural resources include prehistoric or archaeological sites, properties of cultural or historic significance, or paleontological sites. Pacifica has a rich history with regional and statewide significance, as it was home to several Native American villages as well as the site of the discovery the first sighting of the San Francisco Bay by non-indigenous people. The Sanchez Adobe Historical Site along San Pedro Creek, which features physical evidence of several significant periods in California history.

Historic Context
Native Americans had an extensive presence in the Planning Area. When Europeans arrived, the area was home to persons speaking the Costanoan/Ohlone language, and living in and around two villages: Pruristac, in San Pedro Valley, and Timiigtac Timigtac, in Calera Valley. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering both Baja and Alta California, camped in San Pedro Valley and discovered first sighted San Francisco Bay

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Packet Pg. 1514 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) from a point on Pacifica’s Sweeney Ridge. Not long after, Mission San Francisco de Asis (Mission Dolores in present-day San Francisco) was established, and in 1786 the Mission developed an outpost in San Pedro Valley, alongside Pruristac. The Costanoan Ohlone village was wiped out by disease in 1791.21
Mexican independence from Spain was followed by a “secularization” program, and in 1839 the San Pedro mission outpost and its rancho, covering the majority of the Planning Area, was granted to Francisco Sanchez, who built the adobe house that stands today as the oldest structure in San Mateo County. Following his death, the land was divided and the area developed slowly.

In 1905 construction began on the Ocean Shore Railway, which was to connect San Francisco with Santa Cruz. The line was never completed, but operated as far south as Half Moon Bay until 1921, supporting a string of stops in present-day Pacifica including Edgemar, Salada Beach, Brighton Beach, Vallemar, Rockaway Beach, and Tobin (San Pedro Terrance-by-theSea). Salada Beach, and Rockaway Beach. The The communities surrounding the railway stops, including Edgemar, Sharp Park, Pacific Manor, Vallemar, Rockaway Beach, and San Pedro Terrace-by-the- Sea, grew slowly until the building boom following World War II.

Pacifica incorporated as a City in 1957, as the union of these unincorporated communities neighborhoods.

Native American Cultural Resources
Five Native American archaeological resources have been found and recorded in Pacifica, all classified as habitation sites. Two additional resources contain both Native American and historic-era archaeological value. The Sanchez Adobe’s, operated by the San Mateo County Historical Association as an historical site, is listed as a State Historical Landmark and Point of Historical Interest is listed on the National Register of Historic Places. and operated by the San Mateo County Historical Association as an historical site. The Sanchez Adobe Park, site of the Pruristac village and the San Pedro mission outpost or asistencia San Pedro y San Pablo of the Mission San Francisco de Asis (Mission Dolores), also is listed in the National Register of Historic Places and the California Register of Historical Resources. The San Mateo County Historical Association recently dedicated (summer 2021) a new building in Sanchez Adobe Park featuring the history and lifeways of the local Aramai-Ohlone who lived in the village of Pruristac. The facility is specifically designed to accommodate tours of school groups.

The Planning Area is rich with the types of environments where Native American cultural resources have been found: permanent and intermittent streams, productive coastal environments, and sheltered locations for permanent habitations, as well as ridgelines, terraces, spurs and saddles. The Planning Area also includes a significant amount of alluvial soil, which in some cases is overlaid by artificial fill, increasing the probability for buried archaeological deposits. There is considered to be a high likelihood that unrecorded Native American cultural resources are present.

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Packet Pg. 1515 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Contemporary Native American Resources
As part of the General Plan update process, the Native American Heritage Commission (NAHC) conducted a record search of the sacred lands file in 2009. The search did not indicate the presence of additional Native American cultural resources within the Planning Area. The NAHC response listed six tribes that may have historic ties to the Planning Area, and letters of inquiry were sent to the six tribal representatives; however, no responses were received.

In 1769, an expedition led by Gaspar de Portola discovered sighted San Francisco Bay from a point on Pacifica’s Sweeney Ridge (top upper). The Sanchez Adobe, built in 1842, is the oldest surviving structure in San Mateo County. The site was once the Costanoan Ohlone village of Pruristac (middle lower).

Historic Resources
The Portola Expedition Camp at San Pedro Creek, the Discovery Site, and the Sanchez Adobe are State Historical Landmarks. Tobin Station, one of two remaining structures from the Ocean Shore Railroad, is a State Point of Historical Interest.

A Master Plan for the Sanchez Adobe Historical Site, completed in 2007 aims to increase visitation and improve visitors’ educational experience while ensuring that the site is preserved for future generations.

The City has identified nine local historical landmarks: Sanchez Adobe; the Little Brown Church; the former San Pedro Schoolhouse (now City Hall); the 1907 Anderson’s Store building on Paloma Avenue; the Sharp Park Golf Course club house, from 1932; Vallemar Station; the former Dollaradio Station; and two private residences (see Table 7-5).

In 2005, the Pacifica Historical Society began restoration of the Little Brown Church to establish it as into the Pacifica Coastside Museum, which opened in 2015. The Historical Society also owns the last remaining car from the Ocean Shore Railroad, and has stated its interest in moving the railcar along- side to be close to the Little Brown Church, preferably in the parking lot at Salada Avenue and Francisco Blvd. The City is consideringed this as the potential location of the railcar in the City-owned Salada Avenue parking lot as part of a Civic Center master plan discussed by the City Council in 2021. All of the Nine different types of local historic resources landmarks in Pacifica are specifically designated in the Historic Preservation Ordinance of 1985. They in are listed below in Table 7-5 and also shown in Figure 7-4. [revisions to Table 7-5 and Fig. 7-4 are listed on next page]

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Packet Pg. 1516 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) A)…
B)
C)…
D)…
Revisions to Table 7-5 with correct headings & listings:

A) National Historic Landmark – change 1st heading,
this applies only to one site:

San Francisco Bay Discovery Site
B) National Register of Historic Places –new heading for 2 items San Francisco Bay Discovery Site Remove Little Brown Church as it is Sanchez Adobe not in B) National Register
C) California Historical Landmarks – all O.K.

Discovery Site
Sanchez Adobe
Portola Expedition Camp
D) Local Landmarks Identified in Historic Preservation Ordinance (1985) – all 9 listings O.K.

Age of buildings: Vallemar Station 1906; 165 Winona 1908; 185 Carmel Avenue: 1910 ******************************
Revision to Figure 7-4:
• Little Brown Church is not listed on National Register. • The line points to the Portola Camp Historic marker, not the actual campsite (which was on San Pedro Creek).

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Packet Pg. 1517 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) • Discovery Site should add “National Historic Landmark, National Register, and California Historic Landmark”.
• We think the format of the map is good overall, but the size of the notations of the sites themselves is VERY small, so the colors do not show well.

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

POLICIES
Policies included in both the General Plan and Local Coastal Land Use Plan are indicated Guiding Policies
CO-G-17
CO-G-18
Historic and Cultural Sites. Conserve designated historic and cultural sites and structures that help define Pacifica’s identity and character and increase public awareness and appreciation of them.

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

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

Integration of Historic and Cultural Resources with City Identity. Incorporate historic and cultural resources into the City’s marketing and branding efforts. Specific initiatives might include:

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Packet Pg. 1518 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) • Identifying historic sites in the City’s wayfinding scheme; • Giving priority to streetscape and public realm improvements around historic structures that are visitor destinations;
• Hosting/supporting events and educational programs that feature Pacifica’s history and promote its relevance; and
• Linking related historical sites through the City’s open space and trail system.

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

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

CO-I-68
Resource Impact Mitigation.

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

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

CO-I-69 CO-I-70

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Packet Pg. 1519 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Adaptive Reuse. Promote adaptive reuse of historic structures—preserving their original design and character—as an option for preserving sites that are threatened with demolition or degradation.

Native American Sites. Work with local Native American tribes to protect recorded and unrecorded cultural and sacred sites, and educate developers and the community-at-large about the connections between Native American his- tory and the environmental features that characterize the local landscape.

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

1. (Section 7.6, p. 7-40, para. 1) The word “sites” is too limiting, as “historical significance” is not limited to buildings and specific locations. For example, the old trees (many planted more than 100 years ago) of both Sharp Park and Vallemar are an integral part of what defines these Districts and makes them both have “historical significance”.

2. (p. 7-40, para. 2) Many descendants of the original native people of this region object to the use of the words “discovered” or “Discovery”, as thousands of people living in the Bay Area already knew about The Bay when Portola’s Expedition arrived. This may be a semantic point to most people, but is a matter of some sensitivity and significance to present day Ohlone.

3. (p. 7-41, para. 1) Pacific Manor was built in 1948, long after the demise of the OSRR.

4. (p. 7-41, para. 3) Unfortunately “spurs and saddles” sounds like something found on a rancho. Are these common enough terms of geography to avoid confusion?

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Packet Pg. 1520 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) To: [email protected]
From: The Pacifica Historical Society Board of Directors, Judy Heldberg – President
Address:

Box. 752
Pacifica, CA 94044
Date: February 18, 2022
These comments regarding the Draft Pacifica General Plan have been approved by the Board of Directors of The Pacifica Historical Society on February 8, 2022. In order to be clear with what changes we propose, we have included here the entire section of the 2022 Draft Pacifica General Plan Chapter 7 (Conservation) section 7.6 “CULTURAL RESOURCES AND HISTORIC PRESERVATION”. Fig. 4. could not be copied, but comments are included after comments on Table 5.

For clarity, this second copy does not show the suggested changes and omissions.

7.6 CULTURAL RESOURCES AND HISTORIC

PRESERVATION
One objective of the General Plan is to protect community assets, including sites with historical and cultural significance. Cultural resources include prehistoric or archaeological sites, properties of cultural or historic significance, or paleontological sites. Pacifica has a rich history with regional and statewide significance, as it was home to Native American villages as well as the first sighting of the San Francisco Bay by non-indigenous people. The Sanchez Adobe Historical Site along San Pedro Creek, which features physical evidence of several significant periods in California history.

Historic Context
Native Americans had an extensive presence in the Planning Area. When Europeans arrived, the area was home to persons speaking the Costanoan/Ohlone language, and living in and around

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Packet Pg. 1521 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) two villages: Pruristac, in San Pedro Valley, and Timigtac, in Calera Valley. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering both Baja and Alta California, camped in San Pedro Valley and first sighted San Francisco Bay from a point on Pacifica’s Sweeney Ridge. Not long after, Mission San Francisco de Asis (Mission Dolores in present-day San Francisco) was established, and in 1786 the Mission developed an outpost in San Pedro Valley, alongside Pruristac. The Ohlone village was wiped out by disease in 1791.21 Mexican independence from Spain was followed by a “secularization” program, and in 1839 the San Pedro mission outpost and its rancho, covering the majority of the Planning Area, was granted to Francisco Sanchez, who built the adobe house that stands today as the oldest structure in San Mateo County. Following his death, the land was divided and the area developed slowly.

In 1905 construction began on the Ocean Shore Railway, which was to connect San Francisco with Santa Cruz. The line was never completed, but operated as far south as Half Moon Bay until 1921, supporting a string of stops in present-day Pacifica including Edgemar, Salada Beach, Brighton Beach, Vallemar, Rockaway Beach, and Tobin (San Pedro Terrance-by-theSea. The communities surrounding the railway stops grew slowly until the building boom following World War II. Pacifica incorporated as a City in 1957, as the union of these unincorporated neighborhoods.

Native American Cultural Resources
Five Native American archaeological resources have been found and recorded in Pacifica, all classified as habitation sites. Two additional resources contain both Native American and historic-era archaeological value. The Sanchez Adobe, operated by the San Mateo County Historical Association as an historical site, is listed as a State Historical Landmark and is listed on the National Register of Historic Places. The Sanchez Adobe Park, site of the Pruristac village and the outpost or asistencia San Pedro y San Pablo of the Mission San Francisco de Asis (Mission Dolores), also is listed in the National Register of Historic Places and the California Register of Historical Resources. The San Mateo County Historical Association recently dedicated (summer 2021) a new building in Sanchez Adobe Park featuring the history and lifeways of the local Aramai-Ohlone who lived in the village of Pruristac. The facility is specifically designed to accommodate tours of school groups.

The Planning Area is rich with the types of environments where Native American cultural resources have been found: permanent and intermittent streams, productive coastal environments, and sheltered locations for permanent habitations, as well as ridgelines, terraces, spurs and saddles. The Planning Area also includes a significant amount of alluvial soil, which in some cases is overlaid by artificial fill, increasing the probability for buried archaeological deposits. There is considered to be a high likelihood that unrecorded Native American cultural resources are present.

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Packet Pg. 1522 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Contemporary Native American Resources
As part of the General Plan update process, the Native American Heritage Commission (NAHC) conducted a record search of the sacred lands file in 2009. The search did not indicate the presence of additional Native American cultural resources within the Planning Area. The NAHC response listed six tribes that may have historic ties to the Planning Area, and letters of inquiry were sent to the six tribal representatives; however, no responses were received.

In 1769, an expedition led by Gaspar de Portola sighted San Francisco Bay from a point on Pacifica’s Sweeney Ridge (upper). The Sanchez Adobe, built in 1842, is the oldest surviving structure in San Mateo County. The site was once the Ohlone village of Pruristac (lower).

Historic Resources
The Portola Expedition Camp at San Pedro Creek, the Discovery Site, and the Sanchez Adobe are State Historical Landmarks. Tobin Station, one of two remaining structures from the Ocean Shore Railroad, is a State Point of Historical Interest.

A Master Plan for the Sanchez Adobe Historical Site, completed in 2007 aims to increase visitation and improve visitors’ educational experience while ensuring that the site is preserved for future generations.

The City has identified nine local historical landmarks: Sanchez Adobe; the Little Brown Church; the former San Pedro Schoolhouse (now City Hall); the 1907 Anderson’s Store building on Paloma Avenue; the Sharp Park Golf Course club house, from 1932; Vallemar Station; the former Dollaradio Station; and two private residences (see Table 7-5).

In 2005, the Pacifica Historical Society began restoration of the Little Brown Church to establish it as into the Pacifica Coastside Museum, which opened in 2015. The Historical Society also owns the last remaining car from the Ocean Shore Railroad, and has stated its interest in moving the railcar to be close to the Little Brown Church, preferably in the parking lot at Salada Avenue and Francisco Blvd. The City is considering this as the potential location of the railcar as part of a Civic Center master plan discussed by the City Council in 2021. Local historic landmarks in Pacifica are specifically designated in the Historic Preservation Ordinance of 1985. They are listed below in Table 7-5 and also shown in Figure 7-4 (not shown).

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Packet Pg. 1523 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) [revisions for Table 7-5 and Fig. 7-4 ]
A)…
B)
C)…
D)…
Revisions to Table 7-5 with correct headings & listings:

A) National Historic Landmark – change 1st heading,
this applies only to one site:

San Francisco Bay Discovery Site
B) National Register of Historic Places –new heading for 2 items San Francisco Bay Discovery Site Remove Little Brown Church as it is Sanchez Adobe not in B) National Register
C) California Historical Landmarks – all O.K.

Discovery Site
Sanchez Adobe
Portola Expedition Camp
D) Local Landmarks Identified in Historic Preservation Ordinance (1985) – all 9 listings O.K.

Age of buildings: Vallemar Station - 1906; 165 Winona - 1908; 185 Carmel Avenue - 1910

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Packet Pg. 1524 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Revision to Figure 7-4:
• Little Brown Church is not listed on National Register. • The line points to the Portola Camp Historic marker, not the actual campsite (which was on San Pedro Creek).
• Discovery Site should add “National Historic Landmark, National Register, and California Historic Landmark”.
• We think the format of the map is good overall, but the size of the notations of the sites themselves is VERY small, so the colors do not show well.

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

POLICIES
Policies included in both the General Plan and Local Coastal Land Use Plan are indicated Guiding Policies
CO-G-17 CO-G-18
Historic and Cultural Sites. Conserve designated historic and cultural sites and structures that help define Pacifica’s identity and character and increase public awareness and appreciation of them.

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

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

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Packet Pg. 1525 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Integration of Historic and Cultural Resources with City Identity. Incorporate historic and cultural resources into the City’s marketing and branding efforts. Specific initiatives might include:
• Identifying historic sites in the City’s wayfinding scheme; • Giving priority to streetscape and public realm improvements around historic structures that are visitor destinations;
• Hosting/supporting events and educational programs that feature Pacifica’s history and promote its relevance; and
• Linking related historical sites through the City’s open space and trail system.

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

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

CO-I-68
Resource Impact Mitigation.

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

In the event that historical, archaeological, or paleontological resources are accidentally discovered during construction, grading activity in the immediate area shall cease and materials and their surroundings shall not be altered or collected. A qualified archaeologist or paleontologist must make an immediate evaluation and avoidance measures or appropriate mitigation should be completed, according to CEQA Guidelines. The State Office of Historic

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Packet Pg. 1526 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) Preservation has issued recommendations for the preparation of Archaeological Resource Management Reports that may be used as guidelines.

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

Native American Sites. Work with local Native American tribes to protect recorded and unrecorded cultural and sacred sites, and educate developers and the community-at-large about the connections between Native American his- tory and the environmental features that characterize the local landscape.

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

1. (Section 7.6, p. 7-40, para. 1) The word “sites” is too limiting, as “historical significance” is not limited to buildings and specific locations. For example, the old trees (many planted more than 100 years ago) of both Sharp Park and Vallemar are an integral part of what defines these Districts and makes them both have “historical significance”.

2. (p. 7-40, para. 2) Many descendants of the original native people of this region object to the use of the words “discovered” or “Discovery”, as thousands of people living in the Bay Area already knew about The Bay when Portola’s Expedition arrived. This may be a semantic point to most people, but is a matter of some sensitivity and significance to present day Ohlone.

3. (p. 7-41, para. 1) Pacific Manor was built in 1948, long after the demise of the OSRR.

4. (p. 7-41, para. 3) Unfortunately “spurs and saddles” sounds like something found on a rancho. Are these common enough terms of geography to avoid confusion?

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Packet Pg. 1527 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update) From: Stan Zeavin [
Sent: Monday, March 7, 2022 5:50 PM
To: Public Comment [ _City Council Group
[[email protected]]; Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]; Murdock, Christian [[email protected]]; Nibbelin, John [[email protected]]; Berman, Lauren [[email protected]]; Domurat, George [[email protected]]; Ferguson, Alex [[email protected]]; Godwin, James [[email protected]]; Hauser, Samantha [[email protected]]; Leal, David [[email protected]]
Subject: Varied topics from Margaret Goodale
Attachments: Misc topics – mg.docx
[CAUTION: External Email]
Dear Council and Staff,
Please see my comments below and attached:

Wildfire danger
>>Please include the informative Figure 8-5 Fire Hazards and Public Safety Services document from the 2014 draft. The 2014 mapping is much more realistic and useful than simply showing fire danger stopping at the city boundary. Pacificans’ safety depends on accurate information.

Plan Pacifica DEIR - Public Review Draft - Interactive TOC - 2022-01-

07.pdf