Pacifica City Council
June 25, 2022

Sincerely,
Brian Gaffney
cc: Pedro Point Community Association
I. The 2022 Draft EIR’s Project Description is Inadequate. "[A]n accurate, stable and finite project description is the sine qua non of an informative and legally sufficient EIR." (San Joaquin Raptor Rescue Center v. County of Merced (2007) 149 Cal.App.4th 645, 655 quoting County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 199.) The project description must include a general description of the project’s technical, economic and environmental characteristics, considering principal engineering proposals and supporting facilities. (CEQA Guideline 15124, subd. (c).) The EIR must include detail sufficient for evaluation and review of environmental impacts. (CEQA Guideline 15124.) Even where an EIR is adequate in all other respects, a “truncated project concept” violates CEQA. (San Joaquin Raptor/Wildlife Rescue Ctr. v. Cnty. of Stanislaus (1994) 27 Cal. App. 4th 713,730; County of Inyo, supra, 71 Cal.App.3d at 200.)
An EIR project description should include all project components. All phases of a project must be considered in the EIR as the “whole of the action,” so that “environmental considerations do not become submerged by chopping a large project into many little ones, each with a potential impact on the environment, which cumulatively may have disastrous consequences.” (Bozung v. Local Agency Formation Commission of Ventura County (1975) 13 Cal.3d 263, 283–284; Burbank-GlendalePasadena Airport Authority v. Hensler (1991) 233 Cal.App.3d 577; CEQA Guideline 15126.)
The 2022 Draft EIR’s Project Description is flawed in the following ways:
1) The 2022 Draft EIR at p. 2-14 states that “Figure 2.3-1 shows the General Plan Land Use Diagram.” However, the 2022 Draft EIR does not contain a Figure 2.3-1.

Given that the 2022 Draft EIR provides that the Land Use Diagram will be used “to review and approve, modify or deny proposed development projects” (DEIR, p. 2-14), the absence of a Land Use Diagram at Figure 2.3-1 makes the 2022 Draft EIR’s project description uncertain and thus invalid under CEQA.
2) There is an underlying uncertainty regarding how many new units will be allowed to be developed under the proposed 2022 GP Update. The 2022 Draft EIR defines “buildout” as development resulting from application of land use designations and assumed densities under the General Plan.1 DEIR, p. 2-20. “Buildout is calculated based on assumptions about new residential and non-residential development that could be built under the Plan’s land use designations and their respective densities and intensities, adjusted to match expected demand. Id. The 2022 Draft EIR provides that “implementation of the Proposed Project is projected to result in an additional 990 units.” DEIR p. 2-21.

Yet the 2022 GP Update provides that only a few months from now, by January 31, 2023, the City will update the General Plan Housing Element to accommodate 1,892 housing units in compliance with the 6th Cycle Regional Housing Needs Allocation (RHNA 6). 2022 GP Update, p. 1-6. Nor does the DEIR project description consider ADUs, ministerial development allowed by SB 9, or lot splits. The 2022 Draft EIR does not acknowledge these additional housing units, nor attempt to harmonize or explain these widely variant housing unit assumptions. Given these discrepancies, the Project description is not finite and stable.

Further, as discussed below, this uncertainty in the number of housing units under Project buildout results in a flawed analysis of Project impacts. 3) The City of Pacifica appears to be impermissibly segmenting the Project and its analysis of Project impacts by separating the General Plan Housing Element from the

1 Elsewhere, Buildout is defined as the level of urban development characterized by full occupancy of all developable sites in accordance with the General Plan; the maximum probable level of development envisioned by the General Plan under specified assumptions about densities and intensities. DEIR, p. 9-2.

General Plan Update released to the public in January 2022.

The City’s August 5, 2020 Notice of Preparation of a Program Environmental Impact Report for the General Plan Update stated that “the State-mandated Housing Element will be updated as part of a separate process as part of the next Housing Element cycle (2023).” The January 5, 2022 Notice of Availability of a 2022 Draft EIR and Draft 2040 General Plan states that “While a part of the General Plan, the Housing Element will be updated separately in compliance with state law and is not a part of the Plan Pacifica Project.” The 2022 Draft EIR states that “the current Housing Element was adopted on May 11, 2015 as a separate volume,” and that “SB 375 requires regional housing elements and transportation plans to be synchronized on 8-year schedules.” DEIR, pp. 2-1 & 3-22.

Not evaluating any GP Housing Element as part of the 2022 Draft EIR impedes understanding of the proposed Project, and therefore Project impacts. Review of past Pacifica Housing Elements shows that issues discussed include population, population growth trends and housing units, information that is germane and crucial to understanding buildout under the 2022 General Plan and its long term environmental impacts. Given that the City has not updated its General Plan in over 40 years, and that the Housing Element must be produced in nine months - by January 31, 2023 – both the public and Pacifica decision makers would benefit from an analysis that includes the Housing Element. By segmenting the 2022 GP Update from the General Plan Housing Element, the City is impermissibly segmenting the Project. Further, the 2022 Draft EIR does not analyze the consistency of the Housing Element with the rest of the General Plan.
4) The 2022 Draft EIR omits any narrative explanation or graphic representation which parts of the City of Pacifica are proposed to be changed under the Project.

Further, reference to Figure 2.1-2 is insufficient as the size of the map and the similarity of colors prevent the public from determining whether sites are Coastal Residential Mixed Use, or Office Commercial, or Service Commercial, or Low Intensity

Visitor-Serving Commercial. While the March 2014 Pacifica General Plan Draft Environmental Impact Report (“2014 DEIR”) showed the area around the undeveloped San Pedro Avenue site in pink as bounded generally by Danmann Ave and San Pedro Ave, the 2022 Draft EIR does not even include this general information about the area in pink at the south west portion of Figure 2.1-2.2
Without this specific information of what areas will be re-designated or changed under the proposed Project, public disclosure is impeded as it is impossible to assess the conclusion that Coastal Residential Mixed Use will result in 70 new units. 2022 Draft EIR Table 2.4-2. Further, the 2022 Draft EIR does not disclose if all of these 70 units will be at the undeveloped San Pedro Avenue site, or how many new units could be permitted at this particular site. It is not the public’s role to connect the dots; this is the City’s duty under law in preparing an adequate environmental impact report. Thus, the 2022 Draft EIR falls short of CEQA’s requirement for a finite project description. 5) The 2022 Draft EIR project description fails to provide a list of related environmental review and consultation requirements, including but not limited to compliance with the Coastal Act.

II. The 2022 Draft EIR’s Environmental Setting is Inadequate.

An EIR must present an accurate and complete description of the environmental setting in the vicinity of the project as it existed before commencement of the project. (San Joaquin Raptor I, supra, 27 Cal.App.4th at 722.) A city “should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published.” (CEQA Guideline 15126.2.) The environment consists of the “physical conditions which exist within an area which will be affected” by a project. (Pub. Res. Code § 21060.5.) A complete description of the “preexisting environment” (San Joaquin Raptor I, supra, 27 Cal.App.4th at 723) is critical to

2 The California State Clearinghouse has two SCH numbers associated with EIRs for this project:

SCH#2012022046 and SCH#2020089010. The 2022 Draft EIR states that “between 2014 and 2018, the update work paused,” but does not provide any explanation to the public for changes between the DEIR released in 2014 and the instant draft EIR.

establish a baseline for analyzing whether the project’s impacts are significant. (County of Amador v. El Dorado County Water Agency (1999) 76 Cal.App.4th 931, 952; CEQA Guidelines 15125 & 15126.2(a).) The environmental setting must be sufficiently comprehensive to allow the impacts “to be considered in the full environmental context.” (CEQA Guideline 15125, subd (c).) As the County of Amador court stated, “ the question is whether the EIR contains a sufficient description of the baseline environment to make further analysis possible.” (Id. at 954.)
The 2022 Draft EIR’s Environmental Setting is flawed in the following ways:
1) In analyzing potential Project impacts, the 2022 Draft EIR frequently does not compare the Project to existing environmental conditions. In many instances, the 2022 Draft EIR compares the 2022 GP Update to development permissible under the 40-year old Pacifica General Plan. Repeatedly the 2022 Draft EIR fails to justify its decision to use a baseline consisting of environmental conditions projected to exist in the future.

Further, the 2022 Draft EIR has failed to demonstrate that an existing conditions baseline would be misleading or without informational value – as CEQA requires. 2) Simply identifying the undeveloped San Pedro Avenue site at Figure 3.1-1 as “vacant/undeveloped” utterly fails to adequately describe the site such that the 2022 Draft EIR can evaluate the direct, indirect and secondary effects of the proposed Project. The absence of a more detailed description of the undeveloped San Pedro Avenue site at Figure 3.1-1 could be excused if the 2022 Draft EIR elsewhere described the rich biological and recreational resources of this site, but the 2022 Draft EIR makes no attempt to provide this baseline.
3) The EIR’s description of the environmental setting is insufficient to provide adequate analysis of flooding and tsunami impacts. There is no mention of baseline conditions in the undeveloped San Pedro Avenue site.

Also, Figure 3.5-1 is flawed; while it shows the San Pedro Avenue site as a Tsunami Evacuation Area, it fails to show the site as subject to flooding. This affects the EIR’s analysis of impacts including, inter alia, whether reasonably foreseeable

development pursuant to the 2022 GP Update will substantially alter the existing drainage pattern of the San Pedro Avenue site resulting in substantial erosion and/or flooding, or place future housing within a 100-year flood hazard area and/or redirect flood flows. 4) Average household size is used by the 2022 Draft EIR to determine population at “buildout” under the proposed General Plan update. Table 3.1-3 of the 2022 Draft EIR shows that average household size is 2.86 persons per household. However the 2014 DEIR stated an average household size of 2.6 persons or 2.7 persons. (Compare 2014 DEIR pp. 3.1-6 & 3.13-13.) The 2022 Draft EIR does not acknowledge or explain these differences.
5) The 2022 Draft EIR’s conclusions about the increase in population is inconsistent, and it is unclear if this is a flaw in the description of the existing environmental setting or inconsistency in the Project impact analysis.

The Executive Summary of the 2022 Draft EIR states the Project will result in a population of 41,280 at buildout, referencing Table ES-1. See 2022 Draft EIR at p. E5.

However, Table ES-1, Table 2.4-1 and Section 5.1 of the 2022 Draft EIR state a population of 41,050. If the Executive Summary is correct, it is unclear if the higher population number in other parts of the 2022 Draft EIR is due to the Project causing a further increase in population or if the existing population setting is inaccurate. 6) CEQA requires the lead agency to use a baseline that represents real conditions on the ground at the time of CEQA review. The DEIR relies on traffic data from 2010, 2011 and in the case of potential VMT thresholds of significance, 2015. (DEIR, pp. 3-28, 3-40).
7) Certainly more was possible from this EIR’s description of existing conditions.

The 2022 Draft EIR at p. 1-3 references the Existing Conditions and Key Issues Report (July 2010) (hereinafter GP Existing Conditions). Review of this other document reveals discussion of neighborhood character, including Pedro Point (GP Existing Conditions p. 2-160), discussion of historical development (GP Existing Conditions p. 2-5), housing density by neighborhood (GP Existing Conditions p. 2-26), existing zoning and zoning

maps (GP Existing Conditions pp. 2-48 to -53), and sites available for potential housing development of 405 units (GP Existing Conditions p. 3-12). In contrast, the 2022 Draft EIR omits this critical background information, despite that the information is readily available. The environmental baseline information must be in the EIR not solely in some other referenced document.

III. The 2022 Draft EIR’s Analysis of Impacts Is Flawed.

An EIR must evaluate all significant environmental effects of a proposed project. (Pub. Res. Code §§ 21100(b) (1), 21061; CEQA Guidelines 15126(a), 15143.) Both direct and indirect impacts must be analyzed, in the short term and the long term. (CEQA Guideline 15126.2.) “Significant effects should be discussed with emphasis in proportion to their severity and probability of occurrence.” (CEQA Guideline 15143.) EIRs “should be prepared with a sufficient degree of analysis to provide decision-makers with information which enables them to make a decision which intelligently takes account of environmental consequences.” (Galante, supra, 60 Cal.App.4th at 1123; CEQA Guideline 15151.)
Bare conclusions without explanation of the factual and analytical basis is not sufficient analysis of an environmental impacts. (Laurel Heights I, supra, 47 Cal.3d at 404; City of Maywood v. Los Angeles Unified (2012) 208 Cal.App.4th 362, 393.) Further, failure to adequately explain the reasons why an impact is insignificant violates CEQA. (Protect The Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099, 1111-12.)
The EIR must include analysis of how adverse the Project’s adverse impacts will be. (Galante Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal.App.4th 1109, 1123.) Without this analysis, the EIR does not provide decisionmakers with information to make a decision which “intelligently takes account of environmental consequences.” (Ibid.)
Designating an EIR as a program EIR does not by itself decrease the level of analysis required in the EIR. (Friends of Mammoth v. Town of Mammoth Lakes

Redevelopment Agency (2000) 82 Cal.App.4th 511.) A program EIR must evaluate the broad policy direction of a general plan, even though an EIR on a specific construction project will necessarily be more detailed. The sufficiency of the information contained in an EIR is reviewed in light of what is reasonably feasible. (CEQA Guideline 15151; Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 733.) At minimum, an EIR “must include detail sufficient to enable those who did not participate in its preparation to understand and to consider meaningfully the issues raised by the proposed project.” (Laurel Heights, supra, 47 Cal.3d at p. 405.) Tiering does not excuse the City from adequately analyzing reasonably foreseeable significant environmental effects of the Project, and does not justify deferring such analysis to a later tier EIR or negative declaration. (CEQA Guideline 15152(b).)
The 2022 Draft EIR’s discussion of Project environmental impacts is flawed in the following ways:
1) The City has long known that analysis of impacts from redesignating the San Pedro Avenue property was important to the public. The 2014 DEIR included scoping comments raising issues which are still relevant in 2022: viable land use designations for the San Pedro Avenue (Calson) site; incorporation of most recent Coastal Commission guidance; the relationship between preserved open space and biological resources, and barriers to wildlife movement. (2014 Draft EIR, p. E-5 & E-6) Despite these public concerns raised eight years ago, the 2022 Draft EIR does not mention these 2014 concerns in this DEIR. See DEIR, p. E-8 & E-9. Nor does the 2022 Draft EIR discuss viable land use designations for the San Pedro Avenue (Calson) site, incorporation of most recent Coastal Commission guidance, hydrology and flooding at the San Pedro Avenue site, or interference with California red-legged frog movement from reasonably foreseeable Project development at the San Pedro Avenue site. 2) The 2022 Draft EIR does not analyze the impacts of changing land use classifications. For example, while the Coastal Residential Mixed Use (“CRMU”) designation is noted in the 2022 Draft EIR’s Project Description (p. 2-16) and included in

Figure 2.1-2, the 2022 Draft EIR includes no discussion of impacts from this CRMU land use designation, modifications to the proposed Project which would lessen impacts, or assess alternatives in comparison.
3) The 2022 Draft EIR’s project description includes “guiding policies” for each of the proposed Pacifica General Plan elements. See Section 2.5 Key Plan Guiding Policies at DEIR, p. 2-24 et seq. Yet, these guiding policies themselves are not analyzed in the DEIR for their potential impacts.

For example, one guiding principle is SA-I-104 (Areas that Lack Emergency Access) which purports to develop a plan to widen critical rights-of-way that do not provide adequate clearance for emergency vehicles. This initiative would include a plan to “open access to or otherwise serve” the Pedro Point neighborhood. DEIR, p. 3-47.

There is no analysis of the direct, indirect or secondary traffic, stormwater, air quality or any other impact of this guiding policy in the Pedro Point neighborhood.

Guiding principles most similar to the CRMU designation proposed for the San Pedro Avenue field would appear to be “Compact Mixed Use Development” (LU-G-6) and “Coastal Development.” DEIR, pp. E-13 & 2-26. “Compact Mixed Use Development” (LU-G-6) is claimed to be a General Plan policy that would reduce various land use and air quality impacts, but there is no explanation of how or why this would reduce impacts.

The 2022 Draft EIR’s project description states that the policy regarding Coastal Development (LU-G-1) is to “Ensure that development maximizes beach and coastal open space access and is oriented as much as possible to each particular coastal environment in use, design, and intensity.” DEIR, p. 2-26. This proposed Coastal Development policy is not mentioned except as a purported “mitigation” to visual impacts, but without explanation of how or why coastal development will reduce visual impacts. DEIR, p. 3.9-28.
4) The 2022 Draft EIR identifies Pedro Point as “vulnerable to increased coastal flooding.” DEIR, p. 3.5-11. It also acknowledges that undefined “sections of the City are

susceptible to flooding during heavy storm events. The Proposed Project allows for development in areas that may be located within 100-year flood zone areas. Siting structures in flood zones can result in direct impacts …; the frequency of flooding events may increase, and there may be an increase in the amount of area that is considered prone to a 100-year flood event.” DEIR, p. 3.5-38.

Yet, the 2022 Draft EIR under Impact 3.5-3 (New development alter existing drainage patterns, through stream alteration or addition of impervious surfaces, increases stormwater runoff or redirects flood flows) concludes – without adequate explanation - that this impact is less than significant. DEIR, p. 3.5-29. It asserts that compliance with the Project general policies would ensure the impact to water quality is less than significant. DEIR, p. 3.5-32. No mitigations are discussed. DEIR, p. 3.5-37. Again, the 2022 Draft EIR is flawed by not explaining the analytic route it followed to reach its conclusion, by not explaining how general policies would “ensure” the impacts is insignificant, by combining the analysis of impacts with mitigations, and by not discussing mitigations at all.
5) While the 2022 Draft EIR acknowledges the need for analysis of indirect and secondary impacts which are caused by the Project and occur later in time or farther removed in distance (DEIR, p. 1-8), the EIR’s discussion of such indirect Project impacts is troublingly scant. The 2022 Draft EIR fails to properly focus on the indirect and secondary effects that can be expected to follow from the adoption of the General Plan amendment. (CEQA Guideline 15146, subd. (b).) Given the specific land uses proposed in the General Plan Update (see 2022 General Plan Figure 4-3), CEQA requires that the 2022 Draft EIR provide correspondingly detailed analysis of reasonably foreseeable potential impacts. “The degree of specificity required in an EIR will correspond to the degree of specificity involved in the underlying activity which is described in the EIR.” (CEQA Guideline 15146.)
Under Impact 3.7-4 (implementation of the proposed General Plan would not interfere substantially with the movement of species or wildlife corridors), the 2022 Draft

EIR states only that development at the undeveloped San Pedro Avenue site could potentially result in indirect impacts to the wildlife utilizing nearby creek habitat, including from fuel spills and/or leaks which could make their way into the riparian corridor of San Pedro Creek. DEIR, p. 3.7-62. This is insufficient for three independent reasons:
(A) there is no discussion of the interference with California red-legged frog movement from reasonably foreseeable Project development; (B) there is no disclosure of whether the noted indirect impacts to wildlife utilizing nearby creek habitat is adverse or significant; and
(C) there is no discussion of how this impact will be mitigated. 6) The analysis of land use impacts at Section 3 of the 2022 Draft EIR is fatally flawed as it “compared the Land Use Diagram to existing land use conditions to determine whether implementation of the Proposed Project would trigger any impacts.” 2022 Draft EIR, p. 3.1-18. “Figure 2.3-1 shows the General Plan Land Use Diagram.” 2022 Draft EIR at p. 2-14. However, the 2022 Draft EIR does not have a Figure 2.3-1.

Thus, there is no way the public could know what the 2022 Draft EIR compared the existing land uses to in order to determine potential impacts. 7) The 2022 Draft EIR’s analysis of Project impacts is flawed as it relates to “buildout” resulting from the 2022 GP Update. The Executive Summary (at p. E5) states the Project will result in a population of 41,280 at buildout, referencing Table ES-1. Yet, that Table ES-1, as well as Table 2.4-1 and Section 5.1 of the 2022 Draft EIR state a population of 41,050. The 2022 Draft EIR fails to acknowledge or evaluate this discrepancy in its analysis of land use, traffic, air quality, or GHG impacts. 8) The 2022 GP Update provides that only a few months from now, by January 31, 2023, the City will update the General Plan Housing Element to accommodate 1,892 housing units in compliance with the 6th Cycle Regional Housing Needs Allocation (RHNA 6). 2022 GP Update, p. 1-6. Further, ADUs, ministerial development allowed by SB 9, and lot splits are reasonably foreseeable.The 2022 Draft EIR fails to acknowledge

or evaluate these factors in its analysis of land use, traffic, air quality, or GHG impacts. 9) The 2022 Draft EIR references that population growth is necessary in order to meet Pacifica’s Regional Housing Needs Assessment (RHNA) (pursuant to California Government Code Section 65584(a)), as well as in accordance with the regional policies of Plan Bay Area 2040. Yet, the 2022 Draft EIR fails to consider the Plan Bay Area 2040’s regional policies in evaluating Project impacts. 10) This uncertainty as to buildout – instability of the Project Description – thwarts the 2022 Draft EIR’s analysis of impacts. For example, “for purposes of the cumulative impacts analysis, the City utilized the ‘summary of projections’ method by considering the buildout scenario of the Proposed Project within the relevant cumulative impacts context for each potential impact.” DEIR, p. 5-6. Thus, the 2022 Draft EIR did not evaluate cumulative impacts in the context of the RNHA, ADUs, ministerial development allowed by SB 9, or lot splits.
11) The 2022 Draft EIR “groups” land use designations before analyzing impacts, without explaining why this approach was utilized. DEIR, p. 3.1-18 & Table 3.1-4. 12) The 2022 Draft EIR fails to adequately analyze impacts to sensitive species.

The DEIR concludes that “there are several specific areas where proposed buildout could adversely affect [steelhead] and its habitat.” DEIR p. 3.7-50. Having acknowledged the adverse effect of the Project buildout to steelhead, the 2022 Draft EIR fails to disclose where this potential impact may occur, whether it will be significant and why, and how the adverse impact to steelhead could be mitigated.
13) While the 2022 Draft EIR states the proposed General Plan includes numerous trail improvements which could adversely affect wildlife movement corridors, it does not disclose whether this impact will be adverse or significant, and does not discuss how this impact will be mitigated. DEIR, p. 3.7-61.
14) The 2022 Draft EIR fails to first analyze impact significance and then analyze mitigation measures. The first step in an EIR’s analysis of a proposed project’s environmental effects is to evaluate significant project impacts, followed then by analysis

of mitigations. (1 Kostka & Zischke, Practice Under the Cal. Environmental Quality Act (Cont.Ed.Bar 2014, §13.2).) This DEIR skips that first step. The 2022 Draft EIR lists proposed General Project policies as if the Project will mitigate itself, and then little or no mitigation measures are included in the 2022 Draft EIR for each impact. The 2022 Draft EIR is flawed as it only discusses the significance of impacts after applying mitigation measures. An EIR “must determine whether any of the possible significant environmental impacts of the project will, in fact, be significant.” (Protect Historic Amador, supra, 116 Cal.App.4th at 1109; CEQA Guideline 15126.)
In Lotus v. Department of Transportation (2014) 223 Cal.App.4th 645, the court considered an EIR which likewise incorporated proposed mitigation measures into its description of the project and then concluded that any potential impacts from the project will be less than significant. The court held that “avoidance, minimization and/or mitigation measures” characterized in the EIR, are not “part of the project.” “By compressing the analysis of impacts and mitigation measures into a single issue, the EIR disregards the requirements
of CEQA.” (Id. at 655-56.)
“Absent a determination regarding the significance of the impacts ...it is impossible to determine whether mitigation measures are required or to evaluate whether other more effective measures than those proposed should be considered.” (Id. at 656.) This flaw affects the EIR’s other procedural requirements, including (1) consideration of a range of specifically targeted mitigation measures, including analysis of whether the project itself could be modified to lessen the impact, (2) the discussion of potentially feasible alternatives that, if adopted, would avoid or substantially lessen the otherwise significant environmental effects of the proposed project, and (3) what should be included a mitigation and monitoring plan. (Ibid.)
The failure of the EIR to separately identify and analyze the significance of the impacts ...before proposing mitigation measures is not merely a harmless procedural failing. Contrary to the trial court's conclusion, this short-cutting of CEQA requirements subverts the purposes of CEQA by omitting material necessary to informed decision-making and informed public participation. It precludes both identification of potential environmental consequences arising from

the project and also thoughtful analysis of the sufficiency of measures to mitigate those consequences.
(Id. at 658.)
Review of Table ES-3 shows that the 2022 Draft EIR repeats this error - determining significance of impacts only after applying mitigation - for almost every impact it analyzes. Table ES-3 lists each impact with no discussion of its significance.

Likewise, the impact discussions in the body of the 2022 Draft EIR largely fail to analyze impact “significance” separate from and before applying mitigation measures.

For example, for Impact 3.7-1 (substantial adverse effect on sensitive species), the 2022 Draft EIR never describes if impacts will be potentially significant or why, and instead jumps to the conclusion that “implementation of the following Proposed Project policies would reduce potential impacts to special-status species to a less than significant level.” DEIR, p. 3.7-51. Given that San Francisco garter snake, California red-legged frog and steelhead are threatened/endangered species, and that CEQA requires a finding of significance if a project is likely to substantially
impact threatened or endangered species, the 2022 Draft EIR was required to properly analyze Project impacts for their potential significance and then discuss potential mitigations.

This same approach of impermissibly avoiding explanation of potential impacts, based on the unexplained conclusion that “implementation of the following Proposed Project policies would reduce potential impacts to special-status species to a less than significant level,” is used by the 2022 Draft EIR also in regards to biological impacts:
• Impact 3.7-2 (substantial adverse effect on riparian habitat or other sensitive natural communities) (DEIR, p. 3.7-57);
• Impact 3.7-3 (substantial adverse effect on protected wetlands) (DEIR, p. 3.7-60); • Impact 3.7-4 (substantially interfere with fish or wildlife movement or with wildlife corridors, or impede use of wildlife nursery sites) ((DEIR, p. 3.7-62); Perhaps the most glaring flaw regarding biological impacts in this regard comes under the heading “Cumulative Impacts to Biological Resources.” DEIR, p. 5-5-7. There

it states
Pacifica’s population is expected to increase in coming years, which could result in a decrease in habitat for native flora and fauna, increased indirect effects such as noise disturbance, increased night lighting, harassment from pets, increased mortality from automobiles, and increased fragmentation of habitat. Pacifica contains habitat for several special-status plants, insects, CRLF, and SFGS.

Implementation of the Proposed Project may result in a considerable incremental contribution to cumulative impacts, because the majority of undeveloped areas in Pacifica (about 50 percent of the Planning Area) have habitat types known to support special-status species.

The DEIR concludes that the Project may result in a considerable contribution to cumulative impacts. Yet, the 2022 Draft EIR reverses itself by following up with “due to the policies proposed in the Proposed Project and Local Coastal Land Use Plan, the Proposed Project’s contribution to this potentially significant cumulative impact is not cumulatively considerable.” DEIR, p. 5-5-7. Thus, there is no analysis of whether this impact is significant without mitigation measures, and instead only a conclusion of insignificance by reference to completely undefined Project policies.

The public is left wondering what policies could possibly decrease this impact and the analytic route the 2022 Draft EIR travelled in getting from facts to a conclusion of insignificant cumulative biological resource impacts.
3 By circulating the 2022 Draft EIR
for public review that did not disclose if impacts before mitigation measures are significant or not, the 2022 Draft EIR thwarts informed public participation and does not serve CEQA’s information disclosure purpose.
15) Under Impact 3.5-1 (New Development Would Not Degrade Surface Water Quality) the 2022 Draft EIR acknowledges that
new construction, redevelopment, and infrastructure upgrades that would require earthwork. Earthwork activities such as excavation, soil stockpiling, boring, pile

3 The 2022 Draft EIR repeats this error of relying on policies to reduce impacts without evaluating impact significance or adequately explaining why the policies will reduce impacts in regards to, inter alia, cumulative air quality, cumulative stormwater, cumulative transportation, cumulative wildfire, cumulative noise, and cumulative energy and GHG impacts.

driving, and grading could generate loose, erodible soils that, if not properly managed, could be washed into surface water by rain or by water used during grading operations. Soil erosion could cause excess sediment loads in storm drains and affect the water quality of receiving waters. Construction could also involve use of fuel and other chemicals that, if not managed properly, could be washed off into the stormwater. Although construction of specific projects would be relatively short-term, the impact on water quality could be significant if not managed appropriately.”
DEIR, p. 3.5-20. Yet, the 2022 Draft EIR title heading for Impact 3.5-1 states “Less than Significant.” Ibid. The 2022 Draft EIR asserts that compliance with the Project general policies would ensure the impact to water quality is less than significant. DEIR, p. 3.5-22.

No mitigations are discussed. DEIR, p. 3.5-27.

The 2022 Draft EIR’s analysis of water quality impacts is flawed (1) by not explaining the analytic route to reach its conclusion, (2) by not explaining how general policies would “ensure” the impacts is insignificant, (3) by combining the analysis of impacts with mitigations, and (4) by not discussing mitigations at all. 16) Coastal development is not discussed at all in the EIR except in regards to Alternative 2, where the 2022 Draft EIR vaguely states that “coastal development, depending on site specifics, could result in coastal flooding and coastal erosion” and that “Depending on location, coastal development locations could be susceptible to coastal erosion hazards.” DEIR, pp. 4-18 & 4-19. These statements do not constitute adequate disclosure of potential Project impacts as
(A) the site specifics of coastal development reasonably foreseeable from the proposed Project are known and thus must be analyzed in this document, (B) the 2022 Draft EIR does not state if coastal flooding and coastal erosion impacts will be adverse or significant,4 and
(C) there is no discussion of mitigation measures including changes in the proposed

4 There is a vague reference to “the overall impact under this alternative is not significant,” but “overall” impact is an unexplained term and one not recognized under CEQA. “Overall impact” appears to be short-hand for the same impermissible approach of blending impacts and mitigations and assuming, without explanation, that the Project will mitigate itself.

Project to avoid or minimize such impacts.
17) The 2022 Draft EIR does not properly analyze growth inducing impacts of the Project. An “EIR must discuss growth-inducing impacts even though those impacts are not themselves a part of the project under consideration, and even though the extent of the growth is difficult to calculate.” (Napa Citizens for Honest Government v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 368.) This includes consideration of a project’s potential to foster economic or population growth, future development, or construction of additional housing. (Pub. Res. Code § 21100, subd. (b)(5); CEQA Guidelines 15126, subd. (d), 15126.2, subd. (d).)
The 2022 Draft EIR is confusing and contradictory as to whether the Project will foster or induce population growth or construction of additional housing. It states in the same paragraph that “the Proposed Project allows for increased housing development and resulting population growth,” but reverses itself by continuing that “[r]ather than inducing growth, the Proposed Project intensifies development in target areas… .” DEIR, p. 5-2. The DEIR also states that “[t]he Planning Area will accommodate a population of approximately 41,050 people at buildout in 2040,” and that this is an increase (p. 5-2), but does not analyze whether the proposed Project will “foster” or facilitate this growth.

Instead, the 2022 Draft EIR pretends that this growth is something that the planning area will accommodate, and the General Plan update and the City of Pacifica are hapless bystanders to this growth and have no role in inducing or fostering such growth.

IV. The 2022 Draft EIR Fails to Adequately Analyze Mitigation Measures.

In addition to assessing a project’s significant and cumulative impacts, an EIR is also required to set forth and analyze feasible mitigation measures to eliminate or substantially minimize each significant impact. (Pub. Res. Code §§ 21002, 21002.1(a) & (b); CEQA Guidelines 15126(e), 15126.4.) Mitigations must be designed to minimize, reduce, rectify or compensate for the project’s impacts. (CEQA Guideline 15370.) Analyzing “the manner in which [the] significant effects can be mitigated or avoided" is one of the main functions of an EIR. (Pub. Res. Code § 21002.1(a).) As with

all aspects of an EIR, the discussion of mitigation measures must be "prepared with a sufficient degree of analysis to provide decisionmakers with information which enables them to intelligently take account of environmental consequences. . . . The courts have looked. . . for adequacy, completeness and a good faith effort at full disclosure." (CEQA Guideline 15151.)
An EIR is inadequate where mitigation efforts largely depend upon management plans that have not yet been formulated, and have not been subject to analysis and review within the EIR. (Communities for a Better Environment v. City of Richmond (2010) 184 Cal.App.4th 70, 92, citing San Joaquin Raptor II, supra, 149 Cal.App.4th at 670.) “[A]n agency violates CEQA by deferring the formulation of mitigation measures without committing to specific performance criteria for judging the efficacy of the future mitigation measures.” (POET, LLC v. California Air Resources Board (2013) 218 Cal.App.4th 681, 698-99; see also CEQA Guideline 15126.4(a)(1)(B.) Simply stating a generalized goal for mitigating an impact is not adoption of a specific performance criteria. (POET at p. 740.)
In Communities for a Better Environment (2010) 184 Cal.App.4th 70, the Court struck down an EIR which merely proposed a generalized goal of “no net increase” in greenhouse gas emissions and then set out a handful of cursorily described mitigation measures for future consideration. Similarly, an agency goes too far when it simply requires a project applicant to obtain a biological report and then comply with any recommendations that may be made in the report. (Save Panoche Valley v. San Benito Cty. (2013) 217 Cal. App. 4th 503 citing Defend the Bay v. City of Irvine (2004) 119 Cal.App.4th 1261, 1275.)
The 2022 Draft EIR’s Mitigation Measures are flawed in the following ways:
1) The 2022 Draft EIR repeatedly lists General Plan policies (by number and often cyptic explanation), without explaining the manner in which the impacts can be mitigated or avoided by each of the listed policies." The 2022 Draft EIR only provides the glaringly conclusory statement that “Implementation of the following Proposed Project policies

would reduce potential impacts to…to a less than significant level.” Such policies include, but are not limited to, General Plan policies LU-G-7, LU-I-12, CO-G-10, CO-I27, CO-I-33, and CO-I-42.

This failure to explain the manner in which policies will reduce impacts to a level of insignificance is particularly troublesome regarding traffic Impact 3.2-2 where the 2022 Draft EIR concludes that the Vehicles Miles Traveled impact is both significant and unavoidable. The 2022 Draft EIR concludes that certain Circulation Element policies will “Reduce the Impact,” but doesn’t explain how these reductions will occur or how much the impact will be reduced.

Even where the City has the highest level of duty to protect endangered and sensitive species, the 2022 Draft EIR fails to offer any discussion of how the City believes each policy will reduce impacts. It provides only a list of policies with no explanation of the manner in which the measure will reduce impacts. See e.g. DEIR, p.

3.7-51: “Implementation of the following Proposed Project policies would reduce potential impacts to special-status species to a less than significant level.” This is the sum total of any discussion offered by this fatally flawed draft EIR.

After listing these policies, without explanation of the manner in which each will reduce impacts, the 2022 Draft EIR frequently fails to propose any further mitigation measure. It simply states: “Mitigation Measures. None required.” As discussed above, this DEIR’s approach of compressing the analysis of impacts and mitigation measures into a single issue, disregards the requirements of CEQA.” (Lotus v. Department of Transportation (2014) 223 Cal.App.4th 645, 655-56.) The court held that “avoidance, minimization and/or mitigation measures” characterized in the EIR are not “part of the project.” This flaw affects the EIR’s other procedural requirements, including (1) consideration of a range of specifically targeted mitigation measures, including analysis of whether the project itself could be modified to lessen the impact, (2) the discussion of potentially feasible alternatives to avoid or substantially lessen otherwise significant project effects, and (3) what should be included in a mitigation and

monitoring plan. (Id. at 656.)
2) The 2022 Draft EIR improperly defers mitigation measure formulation in many of the General Plan policies the City claims will reduce Project impacts. Many of the plan policies listed in the 2022 Draft EIR are conditioned by terms such as “to the extent feasible”, “strive to”, “study”, “consult with”, ‘coordinate with” and similarly vague, non-committal language that fail to assure that the proposed mitigation measures will be implemented or, if implemented, will be successful in reducing project impacts to a lessthan-significant level. There are no performance standards. There is no discussion of feasibility of each such policy.

In utilizing this approach the City of Pacifica has not committed itself to specific performance standards. The measures in the 2022 Draft EIR are similar to those the Court critiqued in Communities for a Better Env't v. City of Richmond (2010) 184 Cal. App. 4th 70, as “nonexclusive, undefined, untested and of unknown efficacy. The only criteria for ‘success’ of the ultimate mitigation plan adopted is the subjective judgment of the City Council, which presumably will make its decision outside of any public process a year after the Project has been approved.” (Id. at 93.)
CEQA prohibits loose or open-ended performance criteria. Where as here, the measures are loose or open-ended, such that they afford a means of avoiding mitigation during project implementation, it is unreasonable to conclude that implementing the measures will reduce impacts to less than significant levels. (Rialto Citizens for Responsible Growth v. City of Rialto (2012) 208 Cal.App.4th 899, 945.) Even where the 2022 Draft EIR proposes specific mitigation measures, these measures fail to meet CEQA standards as they lack performance standards. Mitigation Measures MM-TRA-1 and MM-TRA-2 are proposed to reduce traffic impacts, air quality impacts, and energy and GHG impacts. See 2022 Draft EIR pp. 3-42, 3-43, 3.3-25, 3.3- 28, 3.4-33. Mitigation Measure MM-TRA-1 proposes to implement an employee commute trip reduction (CTR) program, but there is no performance standard. “The project applicant or designee shall implement at least one of the following incentives for

commuters as part of the CTR program, or another equally effective incentive. DEIR, p. 3-42. There is no performance standard, the applicant gets to choose the measures or an undefined “equally effective” incentive. Likewise, MM-TRA-2, a voluntary measure that would simply “encourage,” has no performance standard. The 2022 Draft EIR admits that it has not even attempted to quantify the reduction potential of these mitigation measures.

DEIR, p. 3-43.

So too, the mitigation measures to reduce significant GHG emission impacts are flawed. MM-GHG-1 proposes to “expand” vehicle recharging network with no performance standard, and uses the loose goal that it will “promote” zero-emission VMT.

Likewise, MM-GHG-2 and MM-GHG-3 only consist of loose goals of promoting and encouraging, without performance standards.
3) The 2022 Draft EIR has not proposed or adequately analyzed mitigations that would reduce significant unavoidable impacts. Where the 2022 Draft EIR concludes that impacts are significant and unavoidable (Impact 3.2-2 [General Plan Update Increases the Vehicle Miles Traveled (VMT) Per Person]), it has not adequately analyzed mitigations that would reduce impacts to less than significant, including changes in the proposed Project. Only two mitigations for this significant “unavoidable” impact are proposed:

MM-TRA-1 and MM-TRA-2. “MM-TRA-1 applies only to new non-residential development of a certain size and MM-TRA-2 is a voluntary measure.” DEIR, p. 3-43.

The 2022 Draft EIR is flawed as CEQA requires a more robust proposals to reduce and avoid significant project impacts.
4) The 2022 Draft EIR impermissibly relies on mitigations it assumes that California and federal agencies will impose. This approach contravenes CEQA which requires “each” public agency to comply with CEQA and “meet its responsibilities, including evaluating mitigation measures and project alternatives. (CEQA Guideline 15020; Citizens for Quality Growth v. City of Mt. Shasta (1988) 198 Cal.App.3d 433, 442, fn. 8.)

V. The 2022 Draft EIR Fails To Integrate Other Required Environmental Analysis With This CEQA Process.

To the fullest extent possible, the City of Pacifica must integrate its CEQA review of the proposed Project with related environmental review and consultation requirements. (CEQA Guidelines 15124, subd. (d)(1)(C), 15006, subd. (i).) Toward that end, agencies are encouraged to “[c]onsult[] with state and local responsible agencies before and during preparation of an environmental impact report so that the document will meet the needs of all the agencies which will use it.” (CEQA Guideline 15006, subd. (g).) Lead agencies must take a comprehensive view in an EIR. CEQA requires that the City integrate the requirements of CEQA with planning and environmental review procedures required by other law “so that all those procedures, to the maximum feasible extent, run concurrently, rather than consecutively.” (Pub. Res. Code § 21003, subd. (a).) 1) The City of Pacifica has ignored its obligation to integrate CEQA review with the requirements of the Coastal Act. The City is impermissibly segmenting the Project and its environmental analysis of the whole of the Project. The 2022 Draft EIR acknowledges that the proposed Project “includes an update to the Local Coastal Land Use Plan, but expressly excludes this part of the Project from any analysis in this EIR.

DEIR, p. 1.1.
2) LCP amendments, including the City’s LCLUP Update, are not exempt from CEQA, as the 2022 Draft EIR erroneously claims. The Coastal Act does not exempt the City of Pacifica from evaluating the environmental impacts of the whole of its Project, including its proposed LCP amendment. The City is required to conduct its own environmental review of the discretionary approval of an LCLUP, and is not exempt from CEQA review based on a subsequent Coastal Commission staff report.5

The 2022 Draft EIR must include discussion of the Local Coastal Land Use Plan

5 Even the Coastal Commission must thoroughly comply with CEQA, but the certification staff report is the functional equivalent of an EIR for the Coastal Commission’s purposes in conducting the LCP certification process. (Pub. Res. Code §§ 21080.5 and 21080.9; CEQA Guidelines 15250, 15251(f) and 15265).)

or LCLUP, the first and primary element of the City’s LCP. The Local Coastal Program consists of a coastal land use plan, zoning ordinances, zoning district maps, and other actions which taken together implement the Coastal Act provisions. The Local Coastal Land Use Plan “serves as the basis for the City to update its zoning code and any other implementing tools needed in the Coastal Zone, and apply to the Coastal Commission for recertification of the LCP.” DEIR, p. 2.7. The City is the lead agency for this Project under CEQA, while the Coastal Commission is a responsible agency. (CEQA Guideline 15050, subds. (b)(1), (c).) “CEQA mandates a lead agency to conduct a thorough review of the project in question even though additional review might later be undertaken by other agencies with jurisdiction over specific resources.” (Save San Francisco Bay Assn. v. San Francisco Bay Conservation etc. Com. (1992) 10 Cal.App.4th 908, 921.) 3) The 2022 Draft EIR fails to include any analysis of the impacts of reasonable foreseeable development resulting from the 2022 GP Update on ESHAs under the Coastal Act. Instead, ESHAs are mentioned only as part of policies that will reduce impacts. Nor are ESHAs identified on the Figures in the 2022 Draft EIR. The DEIR’s approach is similar to that rejected by the California Supreme Court in Banning Ranch Conservancy v. City of Newport Beach (2017) 2 Cal. 5th 918. There the court found that the city “did not use its best efforts to investigate and disclose what it discovered about ESHA” and held that the City’s approach of delaying consideration of ESHA until the project permitting phase was “inconsistent with CEQA's policy of integrated review. (Id. at 939 citing Pub. Res. Code § 21003, subd. (a).)
4) The 2022 Draft EIR does not identify or discuss which LCLUP policies and relevant narratives are included in the General Plan Update. 5) The City has ignored or refused to comply with the Coastal Commission’s demands for more information regarding the City’s proposed LCLUP Update. The September 9, 2020 comment of the CCC stated any General Plan policies will need to be consistent with the LCP. Despite this, the 2022 Draft EIR does not analyze the Project for consistency with the LCP. Instead, the DEIR impermissibly defers this consistency

analysis to a subsequent LCP Amendment. (DEIR, p. 2-7.) Further, CCC correspondence to the City demanded that the City provide (1) a map highlighting all properties that will result in a land use designation change as a result of the LCLUP amendment, (2) discussion of the City’s reasoning behind the proposed land use designation changes, and (3) a description of how the proposed land use designation changes are consistent with the Coastal Act. The City refused to provide the CCC with this information.

In addition, the City’s October 11, 2021 response to the Coastal Commission indicates that the City intends not to comply with the CCC’s demand for additional explanation and evaluation in regards to its proposed LCLUP. Further, the figure at Appendix A to the City’s October 11, 2021 response appears to designate by color code the San Pedro Avenue field as “Commercial,” further obfuscating the land use designation for this parcel.

VI. The Draft EIR Will Need to Be Recirculated for Additional Responsible Agency and PublicComment.

Because significant new information will need to be is added to the DEIR before certification to address each of the issues identified above and in other public comments. the City of Pacifica will be required to recirculate the 2022 Draft EIR. (CEQA Guideline 15088.5.) Recirculation is also required because this draft EIR is so fundamentally and basically inadequate that meaningful public review and comment is precluded. (Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043).

VII. The 2022 GP Update Fails to Comply With California General Plan Law Every city must adopt a ‘comprehensive, long-term general plan for the physical development of the city, and of any land outside its boundaries which in the planning agency’s judgment bears relation to its planning. (Citizens of Goleta Valley v. Bd. of Sups. (1990) 52 Cal.3d 553, 570.) The Supreme Court has described the general plan as “the constitution for all future developments within the city or county.” Id.

A city’s general plan is “atop the hierarchy of local government law regulating

land use.” (Neighborhood Action Group v. Cty. of Calaveras (1984) 156 Cal. App. 3d 1176, 1183.) “Zoning ordinances are regulations governed by the superior enactments in the hierarchy of planning laws.” (Id. at 1184.) The “propriety of virtually any local decision affecting land use and development depends upon consistency with the applicable general plan and its elements.” (DeVita v. Napa (1995) 9 Cal.4th 763, 803.) To be legally adequate, the general plan must show “substantial compliance with the statutory requirements” for general plans. (Camp v. Bd. of Sups. (1981) 123 Cal.App.3d 334, 348.) A general plan must be internally consistent, both among the elements and within each element. (Govt. Code § 65300.5; Concerned Citizens of Calaveras Co (1985) 166 Cal.App.3d 90, 97-98.) This requirement applies to maps and drawings as well as text. (Citizens Assoc. v. Inyo, 172 Cal.App.3d 151 (1985); Environ.

Council v. Bd. of Sups. (1982) 135 Cal.App.3d 428.) Each of the general plan elements must be carefully correlated with one another to “comprise an integrated, internally consistent and compatible statement of policies for the adopting agency.” (DeVita , 9 Cal. 4th at 803.)
The 2022 GP Update is flawed in the following ways:
1) It is impossible to assess the General Plan’s claim that the Housing Element is consistent with the General Plan (GP, p. 1-6) without access to this Element. 2) The 2022 GP Update is inconsistent regarding the amount of new housing which will be allowed. The General Plan states that “only a small amount of new housing—about 990 units—is expected to be developed during the planning period.” (2022 GP Update, pp. 1-13 & 4-29.) Yet, the 2022 GP Update also provides that by January 31, 2023, the City will update the GP Housing Element to accommodate 1,892 housing units in compliance with the 6th Cycle Regional Housing Needs Allocation (RHNA 6). (2022 GP Update, p. 1-6.) Further, while the 2022 GP Update acknowledges that “Accessory dwelling units may be built in areas zoned to allow residential uses pursuant to State law” (at p. 4-16), and includes Policy CD-I-6 to “Facilitate the creation of second units” (at p. 3-9), the 2022 GP Update does not consider these ADUs in its

calculation of housing units or density. Nor does the 2022 GP Update consider ministerial development allowed by SB 9 or lot splits.
3) The 2022 GP Update improperly defers standards development to future zoning ordinances, standards and regulation updates.
4) The circulation element of the 2022 GP Update is not correlated with the land use element or the other elements of the General Plan.
5) Land use designations in the 2022 GP Update conflict with policies, particularly at the San Pedro Avenue site.
6) There are vertical and horizontal internal inconsistences in and between the General Plan and the LCP updates.
7) The 2022 GP Update, in its current form, is inconsistent and does not provide guidance as to what uses, intensities or densities are allowable for specific parcels where policies regarding wetlands, ESHAs, steep slopes, and flood-prone areas conflict with land use designations. This is true, for example, with the proposed CRMU designation at the San Pedro Avenue (Calson) site.

Thank you for your careful attention to these issues.

From: Christine Boles [
Sent: Friday, February 11, 2022 4:52 PM
To: Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Woodhouse, Kevin [[email protected]]; Public Comment [[email protected]]; Myers, Ron [NCC Fire] [ Bier, Mary [[email protected]]; _City Council Group
[[email protected]]; Clements, Christopher [ Cumming, Thomas [ Erbacher, Frank [
Hladky, Doug [
Subject: Pacifica DEIR and General Plan Comment Letter #3 Attachments: Christine Boles Comment Letter #3.pdf
[CAUTION: External Email]
Dear Mr. Murdock, Honorable Mayor Bier, Council and Staff, Please see attached letter noting potential fatal flaws in the DEIR and General Plan regarding CEQA required conclusions that cannot be verified, including miscellaneous comments on Traffic, Emergency Evacuation, Fire and Safety.

I have copied officials from police and fire as well as the Emergency Preparedness Committee as I hope that you all are carefully reviewing the General Plan documents for these types of life safety issues as well.

Please feel free to reach out to me with any questions.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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.
478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com DATE: February 11, 2022
TO: Christian Murdock, AICP
Deputy Director of Planning
City of Pacifica Planning Department
540 Crespi Drive, Pacifica, CA 94044

RE: City of Pacifica General Plan and DEIR Comments, letter #3, CEQA Required Conclusions Cannot be Verified, including miscellaneous comments on Traffic, Emergency Evacuation, Fire and Safety Dear Mr. Murdock,
As I read the DEIR, I am very puzzled as to how some of the CEQA required conclusions in Chapter 5 were reached.

This is why I have asked you, Planning Director Wehrmeister and City Manager Woodhouse a number of questions via email over the past few weeks about dates of source documents, the lack of a current bibliography beyond 2014, and whether these draft documents were reviewed recently by agencies such as North County Fire before they were released. The lack of transparency and answers to these basic questions is directly affecting my ability to review the DEIR and I want to again raise my objections to both the short review time and the poor quality of the documents which makes a thorough review impossible.

I have filed several official Public Document Requests to try to obtain some of this information, and the city has responded by declaring the need for time extensions. Isn’t that ironic given that the city won’t answer our requests for an extension until next Monday, only a week before the self-imposed deadline, which is the minimum period allowed by state law?
The following is a list of my outstanding PRA requests related to the General Plan. • 22-24 Filed 1/24/22 Dyett & Bhatia communications
• 22-26 Filed 1/25/22 North County Fire Communications
• 22-30 Filed 1/27/22 Fish and Wildlife Communication. This PRA request was inappropriately closed, indicating that the city is not complying FOIA regulations. I was only given the voicemail message from Will Kanz at Fish and Wildlife to Christian Murdock. I know for a fact that Will spoke to someone at the city and that he asked for an extension to the DEIR review period deadline, and that the request was denied. Where are the records of that conversation? And was the denial of an extension approved by the Council or was it simply a staff decision? It is my understanding that only the Council can make the determination to extend the deadline. Please reopen the PRA request and provide the required records. • 22-48 Filed 2/9/22 Communications with the city’s other technical consultants DKS Associates, Environmental Science Associates, and Charles Salter and Associates. 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com As an example, of the impossibility of making CEQA required findings, let’s talk about traffic. We all know that traffic is bad in Pacifica, especially on the southern end of town. The fact that traffic has gotten worse since the tunnel was opened in 2013 is clear (please see supporting social media answers from many residents, attached at the end of this letter) and yet apparently the traffic data used in the DEIR analysis dates from 2010, pre-tunnel.

Much more recent traffic data is available free online from Cal Trans and other sources, see correspondence sent to you directly from Vicki Sundstrom, who is licensed Civil Engineer and who works professionally as a traffic engineer. To imply that the city cannot afford a new traffic study and is therefore relying on “best available data” from 2010 is ludicrous and a fatal flaw in this DEIR and draft General Plan.

Chapter 5.1 on Growth Inducing Impacts says that per CEQA Guidelines Section 15126.2(d) that “this analysis must also include the removal of obstacles to population growth, such as improvements in the regional transportation system.” Please clarify what obstacles were studied and removed and how projected cumulative traffic impacts was calculated and mitigated under full buildout.

Please also clarify how projected hazards, like flooding and sea level rise are addressed and mitigated in relation to major transportation corridors and emergency evacuation routes, like Highway One, and how this information has informed project buildout and specific zoning changes that increase density.

478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com The fire risk with the highly flammable eucalyptus forest at the approach to the tunnel is also a major issue that I have not seen addressed anywhere. The fire map in the DEIR, figure 3.14-1 does not include mapping of Very High Fire Hazard Severity Zones, but the one in the old 2014 draft GP does, see below. Please confirm why this critical information is missing in the DEIR, and where it can be obtained so I can start a proper review of the Fire Hazards chapter. Note that this map shows several areas of Very High Fire Hazard Severity Zones are within City Limits, despite the DEIR saying multiple times that these areas are only outside city limits. 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com And please clarify why the DEIR is quoting the Multi-Jurisdictional Local Hazard Mitigation Plan for fire risk analysis when staff and council members clearly stated in the 11/21/21 Council hearing that it was not important for this document to be accurately updated despite the obvious errors I and others pointed out; that we only needed to file it in time to be eligible for FEMA disaster funding.

Chapter 5.1 continues under Growth Management that “Rather than inducing growth, the Proposed Project identifies developments in target areas.” But the basis of the “Project” is an additional 990 units, most in Sharp Park, but also in other parts of town such as the Pedro Point Avenue site/wetlands where housing density is proposed to be increased, as well as in shopping centers scattered throughout town, including at the far back of Linda Mar/Park Pacifica at the Park Mall and at Manor Plaza. All of these projects would increase traffic in already highly congested areas with minimal evacuation options based on exiting roadway infrastructure and in areas identified with very low grades (E and F) of traffic levels of service.

The DEIR also speaks in favor of annexing land on San Pedro Mountain and in Shamrock Ranch to build housing. Please clarify in detail how the consultants and/or planning staff determined that all of these proposed project and zoning changes are determined to not be “growth inducing” under the full buildout per this plan, and under the much greater buildout that will need to be identified with the upcoming update to the Housing Element later this year for a total of almost 1900 new units.

And please clarify how the DEIR will still be applicable in January of 2023 when we are forced to plan for our full RHNA allocation, with almost double the environmental impacts analyzed in the current DEIR.

One sentence in this section on page 5-2 seems to be missing words:
“The Planning Area is located in an area that is partially and urban and lacks opportunities for greenfield development.” Please clarify the missing word(s) and also please define “greenfield development” as it is missing from the glossary.
478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com Further down, section 5.3 Significant and Unavoidable Impacts identifies transportation/traffic as a major issue that cannot be mitigated. It says, “Impacts to transportation would be cumulatively considerable”.

Further down on page 5-7 under Cumulative Impacts of Transportation So somehow with these vague undefined policies that are deferred for future analysis the “Project” has been determined to have less than significant cumulative impacts on traffic? 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com It is my understanding that this poor work and analysis will not hold up very well to a CEQA challenge especially if the lack of analysis has the potential to cause harm. For example, traffic issues need to be understood as part of Greenhouse gas emissions in Chapter 3.4. What source of traffic data did Dyett & Bhatia use for this new analysis required by BAAQMD in their response to the NOP? Current traffic demand also needs to be understood so that North County Fire can verify that they can provide the right level of service. Today I was given access to the 2010 Existing Conditions Report that informed the 2014 draft General Plan. The screenshot below shows that even with 2010 traffic and road conditions, they were having difficulty meeting the level of service standards that they were comfortable with. 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com And North County Fire was already in discussions with the city in 2009 about the potential need to build a third fire station. I have not seen any planning for this future fire station in the Land Use Element. Please confirm.

Will a new station be needed for 990 new units? For 1892? For the buildings over three stories that are proposed for Sharp Park that are too tall for our traditional fire trucks? Has land been designated for a new station? Are these needs included in the capital improvements program for North County Fire in the near future? The more I read, the more questions I have and the less certain I am that this process and the General Plan documents have really addressed even our basic safety.

Again, it is in all our interests to complete a proper General Plan update as soon as possible. I maintain that these draft documents need to be revised, the major errors and omissions fixed, current source data provided (much of which is available online at no cost to the city) and then recirculated so that the public and other reviewing agencies can start a proper review of the plans for Pacifica’s future.

Sincerely,
Christine Boles, Architect
Principal
Cc: Honorable Mayor Mary Bier
Tina Wehrmeister, Planning Director
Kevin Woodhouse, City Manager
[email protected]
1 2
3 4
5 6
7 From: Nancy Tierney [
Sent: Monday, March 7, 2022 3:52 PM
To: Public Comment [[email protected]]
Subject: Pacifica DEIR comments
[CAUTION: External Email]
March 7, 2022
To: City of Pacifica Mayor and City Council Members and Planning Staff Subject: Draft Environmental Impact Report
Dear Mayor, Council Members and Planning Staff:

I write to you as a Pacifica resident with a strong interest in the direction of our community. I am a retired campus and facility planner with over 35 years of experience in higher education at 5 universities across the country, as well as a certified planner. I have worked on many campus master plans, involving interactions with local jurisdictions, e.g., the General Use Permit update in Santa Clara County while at Stanford University. So I am familiar with the requirements of the relevant jurisdictions and the planning processes of the institutions.

My brief comments today focus on the DEIR, recognizing the pending comment deadline, while referencing the related General Plan update and Sharp Park Specific Plan as well as the Local Coastal Plan. I also reviewed the 2014 General Plan update which provided good context for the process and pressing concerns at that time. In fact, the Aims laid out in the document are worth noting here:
• to guide development and conservation decisions;
• to allow the City and others to design projects that enhance the character of the community, promote public health, preserve environmental resources, and minimize hazards; • to provide a basis for zoning, specific area plans, and Capital Improvement Plan.

DEIR comments
• Regarding the Proposed Project, it’s not clear what this is, or for that matter how the alternatives compare (including No Project).
• Section 1.2 Planning Process, covering the period of 2009 – 2019. Why the 10-year period and why wasn’t the 2014 update adopted?
• I note two different project population figures: 41,280 (established buildout on page 6) and 41,050 in table 2.4-1 (page 181). While not materially different, accuracy and consistency are important.
• The Land Use Framework identifies the objectives of concentrated development, higher density housing, compact mixed used development, along with conserving open space and protecting habitat—all worthwhile. Further the Conservation section addresses the importance of insuring good water and air quality and protecting biological resources. Yet it’s not clear how these objectives are met with the Proposed Project and in light of the apparent focus on expanded development in the City of Pacifica through approved projects and the SPSP. • Plan Bay Area 2040 is referenced (page 298). Note that the current document that Pacifica should adhere to, adopted in October 2021, is Plan Bay Area 2050. • In section 3.3-5 addressing BAAQMD 2017 Clean Air Plan, where are the recommended actions? Further, there are statements (CO-I-60) about monitoring the effectiveness of the CA Green Building Code and (CO-1-62) to promote use of solar. I think the current climate crisis calls for more aggressive steps. [This also warrants updating the City’s Climate Action Plan.] • CO-1-54 on Climate Action Plan and GHG emissions reduction. What is the status of a baseline GHG inventory? That will inform how we can reduce emissions. • In the Land Use Element (LU-1-16) regarding density bonuses “up to 50% over maximum allowed by zoning,” it makes sense to identify specific sites that meet the criteria, e.g., accounting for a city center or neighborhood.
• In Section 3.4 on Energy and GHG, a reference to 2011 data is made. A source for current data, is the IPCC Sixth Assessment Report.

Thank you for considering my comments. I look forward to hearing more about the City’s plans through public outreach and discussion of these critical documents.

Nancy Tierney
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From: Lawrence Bothen [
Sent: Monday, March 7, 2022 9:56 PM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]
CC: Wehrmeister, Tina [[email protected]]; _City Council Group [ Woodhouse, Kevin [[email protected]]
Subject: Pacifica Draft General Plan
Attachments: Pacifica draft GP March 7 22.docx
[CAUTION: External Email]
Please find attached above, for the record, a word document of my comments re Pacifica General Plan and EIR Update Draft Jan. 2022. Please include this in the General Plan and EIR record, and acknowledge receipt. Also please distribute to Planning Commission members.

Thank you.

Larry Bothen
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March 7, 2022
By e-mail [email protected]
[email protected]
Pacifica Planning Department
Attn: Christian Murdock, Deputy Director
540 Crespi Dr. Pacifica, CA. 94044
Re: 2022 Draft General Plan, and Environmental Impact Report Public Comment Due to the sprawling mass of the General Plan, I will confine my remarks to the areas that directly affect me as a resident of Pacifica and the Rockaway Beach neighborhood, and that I had time to read. That said, I also support and concur with the remarks submitted by Richard Harris of the San Francisco Public Golf Alliance, which notes that the Sharp Park Golf Course is not included with its clubhouse as a Pacifica Historical Site, despite its inclusion as such in the 1980 general plan. Obviously, the golf course must be included with its clubhouse as a significant historical site in Pacifica.

There aren’t many golf courses that can trace their origin to the legendary golf course architect, Alister MacKenzie. Augusta National, home of the Masters Tournament, Pasatiempo in Santa Cruz, and St.

Andrews in Scotland are towering examples of how he integrated man’s plan into the natural environment and enhanced both. His collaboration in the late 1920’s with John McLaren on Sharp Park Golf Course, and its clubhouse, is a testament to that ethos. The fact that we are blessed with this resource within our city limits is something that should be identified with signage directing visitors to it.

There should be a concomitant upgrade to restore the Sharp Park Restaurant to a status worthy of a visitor’s time, or a local’s for that matter.

Fig. 3-3, Visual Resources, are Pacifica’s greatest asset. Coastal View Corridors, refers to the views of Sharp Park Golf Course from Rt. 1 and from Sharp Park Rd. and how they establish the visual character of Pacifica. You cannot exclude the golf course from its proper designation as a Pacifica Historical Site when it is so representative of that visual character, and you have referred to it in this document.

What kind of visual experience are you offering to visitors when you have already enabled lining these corridors with derelict RV’s that park along Esplanade, with its spectacular view of the pier and Pedro Pt., Francisco Blvd. from the offramp to the golf course, Fairway and Ridgeview drives next to the golf course, Rockaway Beach parking area, and Roberts Rd? Not to mention the other significant view corridor of San Pedro Mountain from eastbound Linda Mar Blvd. That is also slated to be a parking area for homeless RV’s from Adobe Drive to Oddstad Blvd., in front of existing single family homes.

CD-G-5 and CD-I-II, hillsides & ridgelines, states development should “minimize grading and conform with natural landforms.” Well, that ship has sailed. The new condo project on Fassler doesn’t even attempt to conform to that standard, or this one; “design structures so that they follow contours and limit their downslope exposure.” The new proposed developments off Coast Highway between the Lutheran Church and Reina del Mar completely ignore it. The proposed 8 story apartment tower next to the church might be OK on El Camino from SSF to Millbrae, but it’s a boiler plate flatland project with no attempt to integrate into the steep hillside it’s sited on. The adjacent single family home project, built on steep, hazardous hillsides pretends that’s a flatland project too. Neither one says how they’d dump all that traffic on Coast Highway at peak crush hours, but that’s our problem, not theirs, right? CD-I-17, Headlands Special Area for Rockaway Headlands. This section calls for hikers huts and kiosks, and maybe a “view restaurant” if it can be made accessible to hikers. Have you ever visited this area? It’s a 10 minute walk from Rockaway to Linda Mar. There’s 4 restaurants in Rockaway you can drive to and park, plus Taco Bell and several more restaurants at Pedro Pt. shopping center on the other side. This is pure detritus from an earlier draft of this plan.

CD-I-18, Rockaway Quarry Site, proposes to rename Mori Pt. special area for visitor serving development on portion of quarry site, two distinctly separate areas. Have you been here? What is the intent? The entry to Mori Pt. for GGNRA is near the Moose Lodge.
“Development on the Quarry flats should be connected to adjacent Rockaway Beach business district. If a hotel is built there it must be designed to blend with landscape and convey a high quality image.” No problem there. I’m thinking of something climbing inside the bowl of the excavated hillside with south facing ocean views. Prepare for pushback from dog owners who think the entire quarry is a free range kennel.

3.4 Scenic Routes, states Coast Highway and Sharp Park Rd. should be scenic highways. Well, if that isn’t self evident put up a couple signs saying that. I don’t think we need to waste taxpayer dollars on a study by a consultant to tell us what we already know. Spend half of that money for Public Works to pick up trash and cut down weeds on Sharp Park Rd and make CalTrans spend our tax dollars to do the same on Rt. 1 That would make both roads a lot more scenic.

Roadway “Enhancements.” This states “on Sharp Park Road completion of bicycle improvements will improve the character of this roadway and make its scenic quality available to cyclists,” while needlessly ruining the commute over the hill we all make so that maybe dozens of cyclists can include this in their weekend ride. This is the same stupid idea put forth by our Council in 2021 and roundly condemned by any regular or occasional commuter in and out of Pacifica because it would cut the roadway to one lane for vehicular traffic in either direction. Fig. 5-4 highlights Sharp Park Rd as a Class IV road, by definition a road with a separated bike lane. This may be practical when we are crashing into each other in the airspace above with our flying electric cars. But it won’t be before 2040.

All of the above criticisms seem to point up the fact none of the public’s concerns about them were incorporated into this supposedly revised draft document. If I had taken the time to read the entire document I’m sure I could write another 20 pages poking holes in its assumptions, but I’m sure they would get no more attention than they did the first time around. Nevertheless, those are my takes on the plan and an indication of how I will vote when they come before me again.

Sincerely,
Larry Bothen
Rockaway Beach
Citizen
From: Richard Harris Jr. [
Sent: Wednesday, March 9, 2022 8:32 AM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]
CC: Wehrmeister, Tina [[email protected]]; Coffey, Sarah [[email protected]]; _City Council Group [ Woodhouse, Kevin
[[email protected]]; 'Potter, Spencer (REC)' [
'Lisa Villasenor' [ 'HELEN DUFFY'
[ 'Leslie Davis' [ 'Bob Downing'
[ 'Bo Links'
[ 'Kathleen Manning' [
Subject: Pacifica General Plan and EIR Update Drafts, Jan. 2022/ San Francisco Public Golf Alliance Comment re: Visual Resources
Attachments: Ltr.SFPGA.Pac.Plng.Comt.2.Gen.Pl.EIR.3.8.22.pdf [CAUTION: External Email]
Pacifica General Plan and EIR Update Drafts, Jan. 2022/ San Francisco Public Golf Alliance Comment, Mar. 8, 2022 re: Visual Resources
Please find attached above, for the record, a pdf of an additional San Francisco Public Golf Alliance comment, dated March 8, 2022 re Pacifica General Plan and EIR Update Draft Jan. 2022. Please include this in the General Plan and EIR record, and acknowledge receipt. Also please distribute to Planning Commission members.

Thank you.
• Richard Harris
• San Francisco Public Golf Alliance
•
•
•
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1 1370 Masonic Ave., San Francisco, CA 94117 • •
View to the east from the California Coastal Trail across Sharp Park Golf Course Photo by Bill Fields March 8, 2022
By e-mail

[email protected]
Pacifica Planning Department
Attn: Christian Murdock, Deputy Director
540 Crespi Dr.

Pacifica, CA. 94044
2022 Draft General Plan, and Environmental Impact Report Public Comment of San Francisco Public Golf Alliance
Re: Sharp Park Golf Course as a Pacifica Visual Resource 2 The Environmental Impact Report text should identify Sharp Park Golf Course as a Pacifica Visual Resource, and the Coastal View Corridors on the Visual Resources maps in both the General Plan and the Environmental Impact Report should identify as “Coastal View Corridor” the unique open Coastal view to the east from the California Coastal Trail across the golf course into the surrounding hills.

Dear Pacifica Planning Department,
This comment is in addition to the March 7, 2022 comment of the San Francisco Public Golf Alliance.

1. The identical “Visual Resources” map in the Public Comment Draft ‘General Plan (January 2022) 1 and its Supporting Environmental Impact Report2 designates as Pacifica “visual resources” Sharp Park Road (identified as both a scenic “gateway” to Pacifica and as a “Scenic Route”), and the view from Sharp Park Road to the west across Sharp Park Golf Course as a “Coastal View Corridor”.

Segment of “Visual Resources” maps

1 Public Comment Draft – [Pacifica ] General Plan Update – 2022-01-07, Figure 3-3, “Visual Resources,” at the page following 3-10 (56/299 https://cityofpacifica.egnyte.com/dl/vtH8my01NW

2 Pacifica General Plan 2022 Update Draft EIR, Figure 3.9-1, “Visual Resources,” at the page following 3.9-2 (588/1001) https://cityofpacifica.egnyte.com/dl/VMaTQXxRdS 3 2. Scenic views of the ocean and along the beach are not the only “Coastal” views protected by the Coastal Act, but also views from the shore inland across Coastal Zone lands and waters. The unique open scenic view to the east from the California Coastal Trail, across Sharp Park Golf Course into the surrounding hills is such a view and should also be designated a “Coastal View Corridor” on the Visual Resources maps in the General Plan and EIR.

The Draft EIR notes, at page 3.9-10, that “Section 30251 of the California Coastal Act requires that scenic and visual qualities of coastal areas be considered and protected as a resource of public importance.” The Coastal Act defines, at Section 30103(a) the term “Coastal zone” to include not just the shore, but also “. . that land and water . . . extending inland generally 1000 yards from the mean high tide land. . . ”3 And at Section 30116, the Coastal Act provides that “highly scenic areas” constitute “sensitive coastal resource areas”.4 So views inland from the shore across Coastal Zone lands and waters are to be protected under the Coastal Act. The only “Coastal View Corridors” identified on the Visual Resources maps (Draft General Plan Figure 3.3, at page 56/299, and Draft EIR Figure 3.9-1, at page 588/1001 – see footnotes 1 and 2 at page 2, above) are views from roads. As if views from a vehicle were the only protectable Coastal views. This is not so. The California Coastal Trail in the section that runs atop the Sharp Park berm between the Pacifica Pier and Mori Point (which section of trail atop the berm was recently improved by the City of San Francisco with viewing platforms, beach access stairways, and interpretive signage, under an order from the Coastal Commission) has a magnificent view inland from the shore across the golf course into the hills (pictured on page 1 of this letter), which merits the “Coastal View Corridor” designation.

This open view of the hills from the shore – without streets, houses, or buildings of any kind (other than the historic Sharp Park Clubhouse sometimes glimpsed across the fairways and through the Cypress) – is unique in Pacifica and should be identified as “Coastal View Corridor” on the Visual Resources maps of both the General Plan (Figure 3-3, at 56/299) and the EIR (Figures

3.9-1). See Footnotes 1 and 2 at page 1, above.

3. Notwithstanding that the Draft EIR’s “Visual Resources” map identifies Sharp Park Golf Course as a Pacifica Visual Resource, the Draft EIR omits mention of the golf course in a key section of text and in Figure 3.9-2, “Pacifica Visual Resources”.

These omissions should be cured.
(i) The textual omission occurs in a sentence listing “dramatic coastal features” under the heading “Regional Scenic Features,” at EIR Page 3.9-2 (587/1001). The omission should be cured by adding “Sharp Park Golf Course” to the final sentence of text as follows:
3 California Coastal Act, Public Resources Code Section 30103(a) https://leginfo.legislature.ca.gov/faces/codes displaySection.xhtml?sectionNum=30001.&lawCode=PRC 4 California Coastal Act, Public Resources Code Section 30116(c) https://leginfo.legislature.ca.gov/faces/codes displaySection.xhtml?sectionNum=30116.&lawCode=PRC 4 “Mori Point, Rockaway Headlands, and Pedro Point Headlands, as well as Pacifica State Beach, Rockaway Beach, Sharp Park Beach, [ADD: Sharp Park Golf Course,] and the Northern Coastal Bluffs, are dramatic coastal features.” (i) Figure 3.9-2, “Pacifica Visual Resources” (which appears at page 3.9.8 (593/1001) of the Draft EIR (See Footnote 2, at page 2, above) should be augmented with a photo of the view to the east from the Coastal Trail across the golf course into the hills. (This letter contains such a photo at page 1, above, and the San Francisco Public Golf Alliance will be pleased to make that photo available to the Planning Department for this purpose.)

2. CONCLUSION
The dramatic coastal scenery of the Sharp Park Golf Course should be expressly recognized and designated by both the General Plan and the EIR as a significant Pacifica coastal scenic resource, as requested above.

Respectfully submitted,
San Francisco Public Golf Alliance
Richard Harris
Richard Harris, President
cc:

Pacifica City Council Members
Pacifica Planning Commission Members
Pacifica Planning Director Tina Wehrmeister
Pacifica City Manager Kevin Woodhouse
Spencer Potter, SF Recreation and Park Department
Leslie Davis, Helen Duffy, Lisa Villasenor, Sharp Park Business Women’s Golf Club Bob Downing, Sharp Park Golf Club
Pacifica Historical Society
From: Richard Harris Jr. [
Sent: Monday, March 7, 2022 11:44 AM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]
CC: Wehrmeister, Tina [[email protected]]; Coffey, Sarah [[email protected]]; _City Council Group [ Woodhouse, Kevin
[[email protected]]; 'Potter, Spencer (REC)' [
Lisa Villasenor [ 'HELEN DUFFY'
[ 'Leslie Davis' [ Bob Downing
[ Bo Links
[ Kathleen Manning [
Subject: Pacifica General Plan and EIR Update Drafts, Jan. 2022/ San Francisco Public Golf Alliance Comment
Attachments: Ltr.SFPGA.Pacif.Plng.Comnt.Gen.Pln.EIR.Update.3.7.22.pdf [CAUTION: External Email]
Please find attached above, for the record, a pdf of San Francisco Public Golf Alliance comment re Pacifica General Plan and EIR Update Draft Jan. 2022. Please include this in the General Plan and EIR record, and acknowledge receipt. Also please distribute to Planning Commission members.

Thank you.
• Richard Harris
• San Francisco Public Golf Alliance
•
•
•
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1 • •
March 7, 2022
By e-mail
[email protected]
[email protected]
Pacifica Planning Department
Attn: Christian Murdock, Deputy Director
540 Crespi Dr.

Pacifica, CA. 94044
Re: 2022 Draft General Plan, and Environmental Impact Report Public Comment San Francisco Public Golf Alliance Requests Revisions to the 2022 Draft General Plan and Environmental Impact Report, to Identify Sharp Park Golf Course as Pacifica Historic Site and Historic Resource Dear Pacifica Planning Department,
Herewith the comment of San Francisco Public Golf Alliance, whose 7,000-plus members are mostly public course golfers in San Francisco and the Peninsula, including substantial numbers of Pacifica resident men and women.

I. The Public Comment Draft Pacifica General Plan (January 2022) 1 and its Supporting Environmental Impact Report2
both fail to identify Sharp Park Golf
Course as a Pacifica Historical Site. This is error. It is inconsistent with the existing 1980 General Plan, and inconsistent with unanimous resolutions of the Pacifica Historical Society, Pacifica City Council, San Mateo County Board of Supervisors, an historic resource property determination under CEQA by the San Francisco Planning Department, and inconsistent with the April 2015 Response to Comments on the Draft General Plan Prepared by Pacifica Planning Department and Dyett & Bhatia. 1 Public Comment Draft – [Pacifica ] General Plan Update – 2022-01-07, at: (1) p. 7-42 (213/299) “The city has nine local historical landmarks: . . . Sharp Park Golf Course club house from 1932” . . . All of the different types of historic resources in Pacifica are shown in Figure 4 and listed in Table 7-5; Table 5: Historic Sites in Pacifica, [listing] “Sharp Park Golf Course Clubhouse”; (2) Page 7-43 (214/299) “Figure 7-4 Historic and Cultural Resources” [identifies] Sharp Park Golf Course Clubhouse” [but not Sharp Park Golf Course]. https://cityofpacifica.egnyte.com/dl/vtH8my01NW

2 Pacifica General Plan 2022 Update Draft EIR, at: (1) Page 3.8-4 (568/1001): “All of the different types of historic resources in Pacifica are listed in Table 3.8-1 and shown in Figure 3.8-1.”; (2) Figure 3.8-1 “Historic and Cultural Resources,”(identifying “Sharp Park Golf Course Clubhouse” – but not Sharp Park Golf Course, at pg. 3.8-6 (569/1001); and (3) Page 3.8-7 (570/1001), Table 3.8-1, “Historic Resources in the Planning Area,” and listing “Sharp Park Golf Curse Clubhouse,’ but not Sharp Park Golf Course. https://cityofpacifica.egnyte.com/dl/VMaTQXxRdS 2 A. The existing (1980) Pacifica General Plan at page 95a identifies both the Sharp Park Golf Course and Clubhouse on the list and map of “Pacifica Historic Sites”.3 List and map of “Pacifica Historic Sites,” 1980 General Plan B. Sharp Park Golf Course and Clubhouse are both designated “historically significant facilities” by unanimous resolutions of the Pacifica City Council4 and the San Mateo County Board of Supervisors.5
3 See 1980 Pacifica General Plan, “Historic Sites” Map, at pages 95 and 95a (125-126/248), listing “Sharp Park Golf Course & Clubhouse” on the map: http://www.cityofpacifica.org/civica/filebank/blobdload.asp?BlobID=3443 4 Pacifica City Council, Resolution No. 63-2007, Dec. 10, 2007, at page 1 https://drive.google.com/file/d/1EC6KmukbSSxSdIFvX9aDahcmfz46B1f4/view?usp=sharing 5 San Mateo County Board of Supervisors, Resolution No.069145, Dec. 18, 2007, at page 1 https://drive.google.com/file/d/12287bypq7f1cFy3c8fNZYjAMVnVvbEk6/view?usp=sharing 3 C. The Pacifica Historical Society by unanimous resolution of its Board of Directors, has determined and declared Sharp Park Golf Course to be a “significant historic and cultural resource.6
D. The Planning Department of the City and County of San Francisco – the owner of the property – has determined Sharp Park Golf Course to be “historic resource property” pursuant to provisions of the California Environmental Quality Act (CEQA).7 E. San Francisco Public Golf Alliance, by letter dated July 9, 2014, submitted to Pacifica Planning Department in the course of public comment on the Draft Revised General Plan, commented with extensive documentation, on the architectural history of Sharp Park Golf Course and the fame and preeminence of its architect, Alister MacKenzie.8 This July 9, 2014 San Francisco Public Golf Alliance letter was resubmitted to the Planning Department when Pacifica reopened in 2020 reopened public comment on the Draft General Plan.9

F. The April 15, 2015 Response to Comments on the Draft Pacifica General Plan,10 prepared by City [of Pacifica Planning] Staff and Dyett and Bhatia, recommend that Sharp Park Golf Course be identified as a historic resource, and that the text, table, and map in the Historic Resources sections of the EIR and Revised General Plan be corrected to show both Sharp Park Golf Course and Clubhouse as historic resources. • Chapter 2, Responses to Plan-Related Comments

”SHARP PARK GOLF COURSE AS A HISTORIC RESOURCE
Multiple commenters stated that Sharp Park Golf Course itself – and not only the Clubhouse—should be identified in the General Plan and EIR as a historic resource.

The Golf Course and Clubhouse are identified as a historic site in the 1980 General Plan, and were identified by Resolution No. 63-2007 as “historically significant facilities” by the Pacifica City Council. The fact that the golf course is not identified in the Proposed General Plan or Draft EIR as an historic resource reflects the language in the

6 Pacifica Historical Society letter and Resolution, June 14, 2011 https://drive.google.com/file/d/1XSesOhmwrjOP9yIlopuKzWECJbFRfgrd/view?usp=sharing 7 San Francisco Planning Department, Historic Resource Evaluation Response, Feb. 11, 2011, at page 2, with supporting Historic Resource Evaluation Report, January 2011 (at pp.5-32/40) and California Department of Parks and Recreation Form DPR 523A (at pp. 33-40/40):
https://drive.google.com/file/d/1cOKm3g1TcOzfx2Q5gxZV9vVSfH6gvIzt/view?usp=sharing 8 SF Public Golf Alliance Comment Letter re Pacifica Draft General Plan and Environmental Impact Report, Jy. 9, 2014 https://drive.google.com/file/d/1JHtusyzIS4xo12EFIAdpy7fbDiPZEYlx/view?usp=sharing 9 E-mail exchange dated August 6 and September 24, 2020, between Richard Harris and Pacifica Planning Department: https://drive.google.com/file/d/1P8LIUmmkWBFACu1R4FWFo wqRrwqeaQy/view 10 Responses to Comments on the Draft Pacifica General Plan, April 2015, Prepared by City Staff (Dyett and Bhatia stamp appears at page 120/120). https://www.cityofpacifica.org/civicax/filebank/blobdload.aspx?blobid=7443 4 zoning code, which only recognizes the Sharp Park Golf Course Clubhouse. However, given other formal recognition of the Golf Course by the City, and the Draft EIR and is corrected here. . . .

Recommendation: Identify Sharp Park Golf Course as a historic resource.

Sharp Park Golf Course is identified as a historic resource in the text, table and map on pages 7-44 and 7-45 of the Draft General Plan. Please see Chapter 3: Recommended Plan Modifications.”11
• Chapter 3: Recommended Plan Modifications
“Page 7-44
The City has 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 and Club-house, from 1932; Vallemar Station; the former Dollaradio Station; and two private residences (see Table 7-5).

Table 7-5: Historic Sites in Pacifica
. . . .

Sharp Park Golf Course and Clubhouse”

Figure 7-6: Historic and Cultural Resources
Map will be revised to show Sharp Park Golf Course and Clubhouse as a historic resource.” 12
The failure of the 2022 Draft Revised General Plan/EIR to incorporate the Planning Department’s April 2015 Responses to Comments regarding the historical status of Sharp Park Golf Course is inconsistent with the Department’s assurance of its “intent to rely on any environmental analysis which was completed in the earlier EIR process.” 13

11 Responses to Comments on the Draft Pacifica General Plan, April 2015, Prepared by City Staff, at pg. 2-50 (58/120) https://www.cityofpacifica.org/civicax/filebank/blobdload.aspx?blobid=7443 12 Responses to Comments on the Draft Pacifica General Plan, April 2015, Prepared by City Staff, at pp. 3-15 to 3-16 (85-86/120): https://www.cityofpacifica.org/civicax/filebank/blobdload.aspx?blobid=7443 13 E-mail, Aug. 6, 2020 from Pacifica Deputy Planning Director Murdock, in response to Aug. 6, 2020 e-mail from Richard Harris: https://drive.google.com/file/d/1P8LIUmmkWBFACu1R4FWFo wqRrwqeaQy/view 5 II. CONCLUSION: Sharp Park Golf Course is the eponym of Pacifica’s Sharp Park District. The golf course is the work of world-renowned master architect Alister MacKenzie, and is recognized as architecturally and historically significant by unanimous resolutions of the Pacifica City Council, Pacifica Historical Society, San Mateo County Board of Supervisors, and an Historic Resource Property determination under CEQA by the San Francisco Planning Department. The General Plan and EIR should be revised – as provided in the April 2015 Responses to Comments on the Draft General Plan – to show and determine Sharp Park Golf Course to be a Pacifica Historic Site and Resource.

Respectfully submitted,
San Francisco Public Golf Alliance
Richard Harris
Richard Harris, President
cc:

Pacifica City Council Members
Pacifica Planning Commission Members
Pacifica Planning Director Tina Wehrmeister
Pacifica City Manager Kevin Woodhouse
Spencer Potter, SF Recreation and Park Department
Leslie Davis, Helen Duffy, Lisa Villasenor, Sharp Park Business Women’s Golf Club Bob Downing, Sharp Park Golf Club
Pacifica Historical Society
From: Jake Scussel [
Sent: Sunday, February 20, 2022 5:56 PM
To: Murdock, Christian [[email protected]]
Subject: Pacifica General Plan Public Comment
[CAUTION: External Email]
Hello Christian,
First of all, thank you for all that you do! I know that putting together the General Plan must be arduous and mostly thankless, but I truly appreciate all the exhaustive detail you and the team have included here - lots to be excited about!
I have a couple concerns/questions:

1. Development encroachment on virgin land
o We should strive to limit or halt urban expansion and avoid exceeding development on 50% of Pacifica's land mass.
o Particularly concerning is the proposed Higgins Way development located in the "Urban Reserve" that is currently in planning stages. It's on an HPD, the land is critical habitat for endangered species and is labeled Very High fire risk...
o Development should be limited to only areas adjacent to existing roadways throughout Pacifica.

The wooded hillsides between San Pedro Valley Park and Pedro Point Headlands should be protected land, and efforts should be made to ensure that if/when Shamrock Ranch is sold, development is limited strictly to alongside Peralta and Shamrock Ranch Rd. o We need to focus on utilizing under-developed and under-utilized existing spaces first and foremost, then building up - not out - once those options have been exhausted. I would be more than willing to map out potential locations for renovation/development if it would be helpful o Population growth is slowing, and may very well be declining in 40 years:
https://www.ppic.org/publication/californias-population/

2. Sustainability
o Small-scale wind farms should be strongly considered in/near the old quarry and Nike missile site. o Fog collection systems should also be considered. Fresh water could be harvested directly from the air during summer months and stored in the tanks under the skate park, sold, and/or pumped to San Andreas Lake.
o Strong incentives should be implemented to move residents away from heating their homes with wood-burning fireplaces to reduce air pollution.

3. Disaster Planning
o Does the city have a plan if something like a tsunami/earthquake were to make HWY 1 impassable for days/weeks on end leaving many residents in Linda Mar and Rockaway stranded with no way for people/goods to easily move in/out or out of the city? I would love for Pacifica to be a model for ethical, sustainable development, and I'm looking forward to seeing a lot of the plans laid out in the GP come to fruition!
All the best,
Jake
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From: Laura Sloan [
Sent: Friday, January 14, 2022 1:58 PM
To: Public Comment [[email protected]]
Subject: Pacifica General Plan update comment RE:Transitional Open Space for old San Pedro Mountain road
[CAUTION: External Email]
Hello,
Thank you for the opportunity to provide feedback on Pacifica's general plan draft.

I'm writing to comment that I am in support of the land around Old San Pedro Mtn road at the end of Higgins to become Transitional Open Space/Residential with up to 0.1 units/acre). My home today is on Perez Dr. and I use this area regularly for hiking and occasional bicycling. I think the more this hillside land is preserved for future outdoor enjoyment and use by everyone, the better. I am not in favor of the development property proposed there. I think making Old San Pedro Road Higgins entrance an official trailhead to connect to McNee Ranch state park trails would be a welcome addition as well.

Thank you
Laura Sloan
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From: Danny Estrella [
Sent: Saturday, February 26, 2022 6:57 AM
To: Public Comment [[email protected]]
Subject: Pacifica GPU Comment
Attachments: 23 Feb 2022 letter re GPU 2022.docx
[CAUTION: External Email]
25 February 2022
Christian Murdock, AICP
Deputy Director of Planning City of Pacifica Planning Department 540 Crespi Drive
Pacifica, CA 94044
Re: Pacifica General Plan Update comments
Dear Mr. Murdock,
As a resident of the Pedro Point Community, I’m writing to express my concern for the sections of the Pacifica General Plan Update (GPU) pertaining to the area referred to as the Undeveloped San Pedro Avenue Site. I will emphasize the history of this property as stated in the summary below.

Imagine a five-acre, outdoor, visitor-serving destination nestled between the Bay Area's most accessible surf break, a commercial kitchen, four restaurants, and a historic community center with a community-built playground. This is the Pedro Point Basin, the heart of our Community.

The Pedro Point Community Association (PPCA) welcomes commercial recreational opportunities such as kayak and bike rentals, for-profit community spaces and outdoor events consistent with the current land use designation and conditions on the ground.

The Proposed General Plan Update would change the land-use designation from very low density visitor-serving commercially-viable recreational uses to the development of high-density (at least 70 homes, pre-ADUs) housing on this property, despite strong opposition from the Pedro Point Community and state regulatory agencies.

Existing Allowed Uses:

The City of Pacifica's current Local Coastal Land Use Plan, Certified by the California Coastal Commission on March 24, 1980, describes the appropriate uses of this property, which is designed Commercial Recreation. The Basin has since been designated a likely Environmentally-Sensitive Habitat by the California Coastal Commission.
“The designated land use for this area is Commercial with emphasis on coastal related and/or visitor-serving uses... this small, oceanside commercial center could be rejuvenated and expanded to become an attractive visitor destination, as well as provide for neighborhood retail needs ""Small scale, rustic design and ample landscaping throughout the commercial development would complement the existing attractive design elements in the Pedro Point area. Adequate public access through the development to the shoreline and a general orientation to coastal related/visitor-serving uses within the project would be appropriate in ·this location.

Given these criteria, commercial use of this portion of the neighborhood is consistent with the following policies of the Coastal Act: 30212 (Provision of Public Access in New Developments), 30222 (Priority of Recreational/Visitor-Serving Uses), 30250 (Concentration of Development)." The current field has a floor area ratio (FAR) of 0.2, to promote non-intensive recreational use of the site, retaining most of the site in open space.

The PPCA has been, and remains committed to ensuring that any new developments, and in particular, large-scale land-use changes are sustainable and consistent with State Law. The following table summarizes some of the likely Coastal Act violations inherent to the City's proposed Land Use Designation change.

COMPARISON OF COASTAL ACT POLICY CONSISTENCY:

LAND USE FOR PEDRO POINT FIELD
Coastal Act Policy Commercial – Recreation [CR] (current) or Low-Intensity Visitor-serving Commercial
(LIVC); PPCA alternative)
Coastal Residential Mixed
Use [CRMU]
proposed LU Update
Section 30212 New development
projects – (a) Public access from the
nearest public roadway to the
shorelineand along the coast shall be
provided in new development
projects except where:
(1) [conflict] public safety, military
security..protection of fragile coastal
resources,
Fully consistent; Recreational land
use: physically compatible with public
access from public road to shore.

CONSTRAINT OR CONFLICT: Mixed
residential land use at 10-15 units/acre:
constraint on access from public road
to shore
(2) [redundant shore access]
(3) [conflict] agriculture
Section 30221 Oceanfront land;
protection for recreational use and
Development
Oceanfront land suitable for
recreational use shall be protected
for recreational use and
development unless present and
foreseeable future demand for public or
commercial recreational activities that
could be accommodated on the
property is already adequately provided
for in the area.

Fully consistent; directly furthers
purpose of section 30221.

Pedro Point Field is adjacent to Pacific
Ocean, separated by historic railroad
berm segment; thus “oceanfront”; fully
suitable for recreational use (Outdoor
beer garden or socially-distant eating
opportunities, food trucks, mini-golf,
Easter egg hunts, Firehouse children’s
park spillover, dog walking; ball
games)
CONFLICT: Residential development
precludes recreational use and
development.

Recreational opportunities in the
neighborhood on alternate sites are
precluded: steep hillslopes, saturated
residential development.

Section 30222 Private lands; priority
of development purposes
The use of private lands suitable
for visitor-serving commercial
recreational facilities designed to
enhance public opportunities for
coastal recreation shall have
priority over private residential,
general industrial, or general
commercial development, but not
over agriculture or coastaldependent industry.

Fully consistent: visitor-serving
commercial recreational
facilities designed to enhance public
opportunities for coastal recreation
CONFLICT:

Private residential development and
general commercial development
allowed to have priority over and
exclude visitor-serving commercial
recreational development.

Section 30240 Environmentally
sensitive habitat areas (ESHA);
adjacent developments
(a) Environmentally sensitive habitat
areas shall be protected against any
significant disruption of habitat values,
and only uses dependent on those
resources shall be allowed within those
areas.
(b) Development in areas adjacent to
environmentally sensitive habitat areas
and parks and recreation areas shall be
sited and designed to prevent impacts
which would significantly degrade those
areas, and shall be compatible with the
continuance of those habitat and
recreation areas.

Compatible: Low-intensity recreational
uses may be compatible with seasonal
wetlands (no fill or drainage required for
dry season use) and adjacent perennial
wetland swale tributary to San Pedro
Creek (documented California redlegged frog habitat)
CONFLICT: Residential development
at proposed density range would
require fill and drainage of seasonal
wetlands and degrade ESHA
wetlands.

Section 30242. Lands suitable for
agricultural use; conversion
All other lands suitable for
agricultural use shall not be converted
to nonagricultural uses
Compatible: historical artichoke field
soils may be kept intact or converted
back to coastal agriculture (U-pick berry
farm model)
CONFLICT: Residential development
would require placement of pad fill
(flood protection; 100-year floodplain)
and drainage) precluding agriculture
physically and by land use conflict
Section 30251 Scenic and visual
qualities
Compatible. Low-intensity or open
space recreational development
protects scenic ocean views.

CONFLICT: Residential development
would infill the last open space in
The scenic and visual qualities of
coastal areas shall be considered
and protected as a resource of
public importance. Permitted
development shall be sited and
designed to protect views to and along
the ocean and scenic coastal areas,
to minimize the alteration of natural
land forms, to be visually compatible
with the character of surrounding
areas…
coastal lowlands from Linda Mar to
Pedro Point.

Section 30253 Minimization of
adverse impacts
New development shall do all of the
following:
(a) Minimize risks to life and
property in areas of high geologic,
flood, and fire hazard.
(b) Assure stability and structural
integrity, and neither create nor
contribute significantly to erosion,
geologic instability, or destruction of
the site or surrounding area or in any
way require the construction of
protective devices that would
substantially alter natural landforms
along bluffs and cliffs. […]
Compatible. CONFLICT.

Most of field lies approximately 15-17
feet in elevation above Mean Sea Level
(MSL), only about 3-5 feet above the
marsh and high tide beach at the mouth
of San Pedro Creek. Residential
development requires flood protection
and drainage.

Wave runup to the field depends on the
non-engineered privately owned berm
which is not maintained by Pacifica.

Residential development would require
armored flood protection structures as
sea level rises.

Alluvial soils (historical wetland) of the
field have the same relative liquefaction
(earthquake shaking) potential as diked
bay muds and marshes in San
Francisco Bay
Section 30255 Priority of coastaldependent developments Coastal-dependent developments
shall have priority over other
developmentson or near the shoreline.

Except as provided elsewhere in this
division, coastal-dependent
developments shall not be sited in a
wetland. When appropriate, coastalrelated developments should be accommodated within reasonable
proximity to the coastal-dependent
uses they support.

Fully consistent.

Coastal visitor-serving recreational
uses do not require fill or drainage of
wetlands in field directly landward of
the ocean shoreline.

FULL CONFLICT. Residential
development is not coastal-dependent,
and would infill the seasonal wetlands
in the lowland floodplain of the field.

The Pedro Point Community has a vision, compatible with existing land uses, for this critical parcel as a bridge between Pacifica State Beach, the Bay Area's only accessible beginner's surf break, the Pedro Point Headlands, and the Coastal Trail. The Pedro Point basin can be a vibrant community corridor connecting emerging recreational commercial tourism and job opportunities that make use of existing environmental assets, and do not require extensive non-permeable paved areas and roofed buildings. Examples of existing opportunities which align with Pacifica's economic and the region's commercial and recreational commercial needs and the environment include SparkSocialSF, Half Moon Bay Kayak Company, an outdoor family-friendly party destination, a bicycle rental and repair shop, and Beach Break Entertainment. Any changes to land-use designations must take into account the present geologic and biological realities of this parcel.

A History of Neighborhood Comments Pertaining to Zoning Changes and Development in the Pedro Point Field
Historically, the Pedro Point Field has been a wetlands owned by the Archdiocese of San Francisco, which was leased out for recreational uses such as a golf driving range. These uses are compatible with the seasonal flooding inherent in a coastal wetlands.

In 1996 and 1997 this property was acquired in three private transactions by "Calson Ronald W", "Calson Ronald W & Sheryl W", and "Calson Ronald W & Sheryl W Trs." for $550,000, total. (Ron Calson of RC & Associates in Millbrae has represented the Archdiocese of San Francisco in past real estate transactions.) The designated land use at the time of the acquisition was--and remains--Commercial Recreation.

Subsequent, persistent unauthorized diking, dumping, and infill events have eroded the native plant species and habitat in this designated Environmentally Sensitive Habitat Area, but opportunities for restoration abound, consistent with State law, which requires cities to identify natural infrastructure that may be used for adaptation projects including the restoration of wetlands and coastal floodplains "Upzoning" this key parcel without adequate environmental review will severely impact the quality of life and coastal access rights of Pacifica's citizens and visitors to the Coast, while endangering future homeowners who are unwittingly purchasing new homes built on a FEMA-Designated flood plain and historical wetlands temporary protected by coastal armament built for the short-lived Ocean Shore Railroad.

Excerpt of U.S. Coast Survey map of San Francisco Peninsula, 1869, based on 1850s topography: San Pedro Creek Valley and beach, now Linda Mar. Approximate location of Field in red.

Parallel horizontal hatched lines indicate freshwater marsh. Stippled shoreline area indicates sandy beach, dune, washover. Fine horizontal hatching is open freshwater (Lake Mathilda; historical Pedro Creek Lagoon, drained for agriculture 19th century).

Irregular circles/dots within marsh = wooded freshwater swamp (alder, willow). 1995 Community Plan "…Pedro Point residents have registered strong support for preserving a major portion of the Archdiocese property in some form of open space.

It would be a major setback to the entire Pedro Point community if any development calling for intensive coverage of the land with buildings and pavement were to take place without a generous reservation of land for open space use. The community would look with favor on an adequate provision for open space and a compatible mix of visitor-serving uses appropriate to the Point’s oceanside setting." 2011 Letter in Opposition to the Proposed Land Use Designation Change The Pedro Point Community Association rejected the Draft GPU's proposed Land Use Designation change, and recommended that it adopt "Commercial-Recreational," the designation most similar to the existing land use. The PPCA also supported a change in the land use designation to Open Space.
2012 Letter in Support of Commercial-Recreational Uses: In 2012, the PPCA again, after extensive discussions which included inviting the current-land owners to the PPCA board, voted for the field remain in its current zoning of CommercialRecreational. The proposed Commercial Recreation designation in the current Draft General Plan is intended for land use that would remain in a primarily undeveloped state but would allow for limited commercial establishments supporting recreational uses in keeping with the enjoyment of the beach and community character. 2014 DOCUMENTS: In 2014, the PPCA unanimously voted to pool their resources to hire experts and an attorney citing deficiencies in City's General Plan Update and draft Environmental Impact Report (DEIR). The Proposed Land Use change did not pass, and the approved Land Use Designation remained Commercial Recreation. The following documents have been submitted to the City and are part of the comments on the GPU.
• PPCA Comment Letter Summarizes the PPCA's official position • Brian Gaffney The DEIR fails to comply with the California Environmental Quality Act. Errors found by the PPCA's witnesses are materially tied to the legal adequacy of the plan.
• Grassetti Environmental Consulting (GECO) The general plan land use designations are the heart of the plan; once a site is designated, applicants have certain development rights. Therefore, it is essential that the City fully consider site values and constraints prior to re-designating sites, not after the site is re-designated. This GPU fails to do that,

25 February 2022
Christian Murdock, AICP
Deputy Director of Planning City of Pacifica Planning Department 540 Crespi Drive
Pacifica, CA 94044
Re: Pacifica General Plan Update comments
Dear Mr. Murdock,
I’m writing to express my concern for the sections of the Pacifica General Plan Update (GPU) pertaining to the area referred to as the Undeveloped San Pedro Avenue Site. I will emphasize the history of this property as stated in the summary below.

Imagine a five-acre, outdoor, visitor-serving destination nestled between the Bay Area's most accessible surf break, a commercial kitchen, four restaurants, and a historic community center with a community-built playground. This is the Pedro Point Basin, the heart of our Community.

The Pedro Point Community Association (PPCA) welcomes commercial recreational opportunities such as kayak and bike rentals, for-profit community spaces and outdoor events consistent with the current land use designation and conditions on the ground.

The Proposed General Plan Update would change the land-use designation from very low density visitor-serving commercially-viable recreational uses to the development of highdensity (at least 70 homes, pre-ADUs) housing on this property, despite strong opposition from the Pedro Point Community and state regulatory agencies.

Existing Allowed Uses:

The City of Pacifica's current Local Coastal Land Use Plan, Certified by the California Coastal Commission on March 24, 1980, describes the appropriate uses of this property, which is designed Commercial Recreation. The Basin has since been designated a likely Environmentally-Sensitive Habitat by the California Coastal Commission. “The designated land use for this area is Commercial with emphasis on coastal related and/or visitor-serving uses... this small, oceanside commercial center could be rejuvenated and expanded to become an attractive visitor destination, as well as provide for neighborhood retail needs ""Small scale, rustic design and ample landscaping throughout the commercial development would complement the existing attractive design elements in the Pedro Point area. Adequate public access through the development to the shoreline and a general orientation to coastal related/visitor-serving uses within the project would be appropriate in ·this location. Given these criteria, commercial use of this portion of the neighborhood is consistent with the following policies of the Coastal Act: 30212 (Provision of Public Access in New Developments), 30222 (Priority of Recreational/Visitor-Serving Uses), 30250 (Concentration of Development)." The current field has a floor area ratio (FAR) of 0.2, to promote non-intensive recreational use of the site, retaining most of the site in open space.

The PPCA has been, and remains committed to ensuring that any new developments, and in particular, large-scale land-use changes are sustainable and consistent with State Law. The following table summarizes some of the likely Coastal Act violations inherent to the City's proposed Land Use Designation change.

COMPARISON OF COASTAL ACT POLICY CONSISTENCY:

LAND USE FOR PEDRO POINT FIELD
Coastal Act Policy Commercial – Recreation [C-R]
(current) or Low-Intensity
Visitor-serving Commercial
(LIVC); PPCA alternative)
Coastal Residential Mixed Use
[CRMU]
proposed LU Update
Section 30212 New development
projects – (a) Public access from the
nearest public roadway to the
shoreline and along the coast shall be
provided in new development projects
except where:
(1) [conflict] public safety, military
security..protection of fragile coastal
resources,
(2) [redundant shore access]
(3) [conflict] agriculture
Fully consistent; Recreational land
use: physically compatible with public
access from public road to shore.

CONSTRAINT OR CONFLICT: Mixed
residential land use at 10-15 units/acre:
constraint on access from public road to
shore
Section 30221 Oceanfront land;
protection for recreational use and
Development
Oceanfront land suitable for
recreational use shall be protected
for recreational use and
development unless present and
foreseeable future demand for public or
commercial recreational activities that
could be accommodated on the
property is already adequately provided
for in the area.

Fully consistent; directly furthers
purpose of section 30221.

Pedro Point Field is adjacent to Pacific
Ocean, separated by historic railroad
berm segment; thus “oceanfront”; fully
suitable for recreational use (Outdoor
beer garden or socially-distant eating
opportunities, food trucks, mini-golf,
Easter egg hunts, Firehouse children’s
park spillover, dog walking; ball games)
CONFLICT: Residential development
precludes recreational use and
development.

Recreational opportunities in the
neighborhood on alternate sites are
precluded: steep hillslopes, saturated
residential development.

Section 30222 Private lands; priority
of development purposes
The use of private lands suitable for
visitor-serving commercial
recreational facilities designed to
enhance public opportunities for
coastal recreation shall have priority
over private residential, general
industrial, or general commercial
development, but not over
Fully consistent: visitor-serving
commercial recreational facilities
designed to enhance public
opportunities for coastal recreation
CONFLICT:

Private residential development and
general commercial development
allowed to have priority over and
exclude visitor-serving commercial
recreational development.
agriculture or coastal-dependent
industry.

Section 30240 Environmentally
sensitive habitat areas (ESHA);
adjacent developments
(a) Environmentally sensitive habitat
areas shall be protected against any
significant disruption of habitat values,
and only uses dependent on those
resources shall be allowed within those
areas.
(b) Development in areas adjacent to
environmentally sensitive habitat areas
and parks and recreation areas shall be
sited and designed to prevent impacts
which would significantly degrade those
areas, and shall be compatible with the
continuance of those habitat and
recreation areas.

Compatible: Low-intensity recreational
uses may be compatible with seasonal
wetlands (no fill or drainage required for
dry season use) and adjacent perennial
wetland swale tributary to San Pedro
Creek (documented California redlegged frog habitat)
CONFLICT: Residential development at
proposed density range would require
fill and drainage of seasonal wetlands
and degrade ESHA wetlands.

Section 30242. Lands suitable for
agricultural use; conversion
All other lands suitable for
agricultural use shall not be converted
to nonagricultural uses
Compatible: historical artichoke field
soils may be kept intact or converted
back to coastal agriculture (U-pick berry
farm model)
CONFLICT: Residential development
would require placement of pad fill
(flood protection; 100-year floodplain)
and drainage) precluding agriculture
physically and by land use conflict
Section 30251 Scenic and visual
qualities
The scenic and visual qualities of
coastal areas shall be considered
and protected as a resource of
public importance. Permitted
development shall be sited and
designed to protect views to and along
the ocean and scenic coastal areas, to
minimize the alteration of natural land
forms, to be visually compatible with the
character of surrounding areas…
Compatible. Low-intensity or open
space recreational development
protects scenic ocean views.

CONFLICT: Residential development
would infill the last open space in
coastal lowlands from Linda Mar to
Pedro Point.

Section 30253 Minimization of
adverse impacts
New development shall do all of the
following:
(a) Minimize risks to life and property
in areas of high geologic, flood, and
fire hazard.
(b) Assure stability and structural
integrity, and neither create nor
contribute significantly to erosion,
geologic instability, or destruction of
the site or surrounding area or in any
way require the construction of
protective devices that would
substantially alter natural landforms
along bluffs and cliffs. […]
Compatible. CONFLICT.

Most of field lies approximately 15-17
feet in elevation above Mean Sea Level
(MSL), only about 3-5 feet above the
marsh and high tide beach at the mouth
of San Pedro Creek. Residential
development requires flood protection
and drainage.

Wave runup to the field depends on the
non-engineered privately owned berm
which is not maintained by Pacifica.

Residential development would require
armored flood protection structures as
sea level rises.

Alluvial soils (historical wetland) of the
field have the same relative liquefaction
(earthquake shaking) potential as diked
bay muds and marshes in San
Francisco Bay
Section 30255 Priority of coastaldependent developments Coastal-dependent developments
shall have priority over other
developments on or near the
shoreline. Except as provided
elsewhere in this division, coastaldependent developments shall not be sited in a wetland. When
appropriate, coastal-related
developments should be
accommodated within reasonable
proximity to the coastal-dependent uses
they support.

Fully consistent.

Coastal visitor-serving recreational
uses do not require fill or drainage of
wetlands in field directly landward of the
ocean shoreline.

FULL CONFLICT. Residential
development is not coastal-dependent,
and would infill the seasonal wetlands
in the lowland floodplain of the field.

The Pedro Point Community has a vision, compatible with existing land uses, for this critical parcel as a bridge between Pacifica State Beach, the Bay Area's only accessible beginner's surf break, the Pedro Point Headlands, and the Coastal Trail. The Pedro Point basin can be a vibrant community corridor connecting emerging recreational commercial tourism and job opportunities that make use of existing environmental assets, and do not require extensive non-permeable paved areas and roofed buildings. Examples of existing opportunities which align with Pacifica's economic and the region's commercial and recreational commercial needs and the environment include SparkSocialSF, Half Moon Bay Kayak Company, an outdoor familyfriendly party destination, a bicycle rental and repair shop, and Beach Break Entertainment. Any changes to land-use designations must take into account the present geologic and biological realities of this parcel.

A History of Neighborhood Comments Pertaining to Zoning Changes and Development in the Pedro Point Field
Historically, the Pedro Point Field has been a wetlands owned by the Archdiocese of San Francisco, which was leased out for recreational uses such as a golf driving range. These uses are compatible with the seasonal flooding inherent in a coastal wetlands.

In 1996 and 1997 this property was acquired in three private transactions by "Calson Ronald W", "Calson Ronald W & Sheryl W", and "Calson Ronald W & Sheryl W Trs." for $550,000, total. (Ron Calson of RC & Associates in Millbrae has represented the Archdiocese of San Francisco in past real estate transactions.) The designated land use at the time of the acquisition was--and remains--Commercial Recreation.

Subsequent, persistent unauthorized diking, dumping, and infill events have eroded the native plant species and habitat in this designated Environmentally Sensitive Habitat Area, but opportunities for restoration abound, consistent with State law, which requires cities to identify natural infrastructure that may be used for adaptation projects including the restoration of wetlands and coastal floodplains
"Upzoning" this key parcel without adequate environmental review will severely impact the quality of life and coastal access rights of Pacifica's citizens and visitors to the Coast, while endangering future homeowners who are unwittingly purchasing new homes built on a FEMADesignated flood plain and historical wetlands temporary protected by coastal armament built for the short-lived Ocean Shore Railroad.

Excerpt of U.S. Coast Survey map of San Francisco Peninsula, 1869, based on 1850s topography: San Pedro Creek Valley and beach, now Linda Mar. Approximate location of Field in red.

Parallel horizontal hatched lines indicate freshwater marsh. Stippled shoreline area indicates sandy beach, dune, washover. Fine horizontal hatching is open freshwater (Lake Mathilda; historical Pedro Creek Lagoon, drained for agriculture 19th century).

Irregular circles/dots within marsh = wooded freshwater swamp (alder, willow). 1995 Community Plan "…Pedro Point residents have registered strong support for preserving a major portion of the Archdiocese property in some form of open space. It would be a major setback to the entire Pedro Point community if any development calling for intensive coverage of the land with buildings and pavement were to take place without a generous reservation of land for open space use. The community would look with favor on an adequate provision for open space and a compatible mix of visitor-serving uses appropriate to the Point’s oceanside setting."
2011 Letter in Opposition to the Proposed Land Use Designation Change The Pedro Point Community Association rejected the Draft GPU's proposed Land Use Designation change, and recommended that it adopt "Commercial-Recreational," the designation most similar to the existing land use. The PPCA also supported a change in the land use designation to Open Space.
2012 Letter in Support of Commercial-Recreational Uses: In 2012, the PPCA again, after extensive discussions which included inviting the current-land owners to the PPCA board, voted for the field remain in its current zoning of Commercial-Recreational. The proposed Commercial Recreation designation in the current Draft General Plan is intended for land use that would remain in a primarily undeveloped state but would allow for limited commercial establishments supporting recreational uses in keeping with the enjoyment of the beach and community character.
2014 DOCUMENTS: In 2014, the PPCA unanimously voted to pool their resources to hire experts and an attorney citing deficiencies in City's General Plan Update and draft Environmental Impact Report (DEIR). The Proposed Land Use change did not pass, and the approved Land Use Designation remained Commercial Recreation. The following documents have been submitted to the City and are part of the comments on the GPU. • PPCA Comment Letter Summarizes the PPCA's official position • Brian Gaffney The DEIR fails to comply with the California Environmental Quality Act. Errors found by the PPCA's witnesses are materially tied to the legal adequacy of the plan.
• Grassetti Environmental Consulting (GECO) The general plan land use designations are the heart of the plan; once a site is designated, applicants have certain development rights. Therefore, it is essential that the City fully consider site values and constraints prior to re-designating sites, not after the site is re-designated. This GPU fails to do that, and the EIR fails to adequately or accurately assess impacts of the proposed re‐ designation of the Pedro Point Field site.
• Peter R. Baye, Ph.D., Coastal Ecologist, Botanist: The Draft Environmental Impact Report fails to recognize the parcels as an Environmentally Sensitive habitat for Endangered Species.

In 2019, the PPCA formally requested a Neighborhood-Specific Study to consider the robust community input and evidence presented thus-far. This request was denied.

The proposed GPU disregards the facts of the history and community concern for this land. For the sake of completing the GPU so the City of Pacifica can move forward with intelligent development the GPU should be revised to reflect the comments presented here.

Regards,
Daniel Estrella
From: Kathy [
Sent: Wednesday, March 9, 2022 6:44 PM
To: Public Comment [[email protected]]
Subject: Pedro Point Field Proposed Use Designation Change [CAUTION: External Email]
Dear Mr. Murdock:

My name is Kathy Castor and I have lived at
since May 1995.

I am writing to you to express my distress, dismay, disgust and whole-heart objection to the general plan update that would change the Pedro Point field from commercial
recreation to COASTAL RESIDENTIAL MIXED USE???!!!
What in the world? Must we completely destroy Pedro
Point?
As I mentioned earlier, I have lived on Pedro Point for 27 years. Not once in these 27 years, has the building of
homes ceased on Pedro Point. The single family
residences just march up the hill. And recently, numerous multi-family and mixed-use projects have been approved
and are being built. Every tiny piece of land - even
designated PAPER STREETS are being approved for
construction. Pedro Point used to be a nice SINGLE
FAMILY RESIDENTIAL NEIGHBORHOOD.

I understand the City needs to generate income, but for crying out loud...must it all come from never ending
building permits?
You state that the proposed land use change would "not
create significant visual impact"....REALLY? I live far enough up the hill to have full view of this parcel of land and enjoy that sight. The thought of another black, 2-story mixed use building box with limited parking (which is
another HUGE issue on PP) makes me physically ill. Not
to mention the amount of traffic this will generate. Have you visited Pedro Point on the weekends? If not, come
have a look at the weekend parking issues.

The kids have an Easter egg hunt every year in the field.

Numerous dogs love to frolic in the field. Gobs of us
residents walk the field. Most of the residents I walk this field with moved to Pacifica, like me, for the "small town" feel. There are a number of birds and wildlife that occupy the field that will be greatly impacted.

What about the strain on San Pedro Avenue? What about
the strain on sewer and water issues? What about all their lights, glare, etc. affecting the evening darkness we all now enjoy?
I firmly believe this project (changing the land use
designation) is going to negatively affect the entire Point.

For all of these reasons and a million more that I will not get into right now, changing the land use to residential mixed use for this parcel, is the worst decision the city could make. It needs to stay low intensity commercial - high density residential.

Thank you.

Kathy Castor
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.

From: John Keener [
Sent: Monday, March 7, 2022 8:55 AM
To: Public Comment [[email protected]]; Murdock, Christian [[email protected]]
Subject: Personal comments on GPU
[CAUTION: External Email]
Hi Christian and others,
Here are my comments on the General Plan Update.

Proposed addition: Pacifica Gardens, located behind the Linda Mar School, donates over 3,000 pounds of the produce it raises to the Pacifica Resource Center for distribution to needy families.

Proposed change: A tributary to San Pedro Creek is incorrectly labeled as Brooks Creek. This tributary is Sanchez Fork. Brooks Creek is the small tributary to the South Fork San Pedro Creek, and the location of Brooks Creek Falls in San Pedro Valley Park. This error originated with Google maps and they have so far been unwilling to fix it. Please don't compound their error!

boundaries. These tributaries include the South Fork, Middle Fork, North Fork, and Brooks/Sanchez Creek.

Proposed change: San Pedro Creek has several tributaries, some of which extend past the City boundaries. The tributaries include the South Fork, Middle Fork, North Fork, Sanchez Fork, and Brooks Creek.

Proposed inserted sentence after "Wetlands along San Pedro Creek provide habitat for the threatened California red-legged frog.": Recently, the northern tidewater goby, a small federally-listed endangered fish, was detected near the mouth of of San Pedro Creek. [[Reference: Michael Sutter & Andrew P. Kinziger, Rangewide tidewater goby occupancy survey using environmental DNA. Conservation Genetics (2019) 20:597-613. see page 608]] Alterations from urban development have resulted in a deep channel with steep banks.

Proposed change: Alterations from historical agriculture and more recent urban development have resulted in a deep channel with steep banks.
7-6 Stormwater
This drainage system acts to convey drainage to area creeks or the ocean. Two areas in the City, Linda Mar and lower Sharp Park, are too low to allow drainage to a creek or the ocean, and are served by pump stations to prevent street flooding.

Proposed changes: This drainage system acts to convey stormwater and other drainage via storm drain pipes to area creeks or the ocean. San Pedro Creek acts as a conduit for stormwater from storm drains to the ocean. Two areas in the City, lower Linda Mar and lower Sharp Park, are too low to allow drainage to a creek or the ocean, and are served by pump stations to prevent street flooding.
7-11 CO-I-3 Funding for Creek Maintenance.

Establish funding mechanism to require property owners with land adjacent to creeks to pay proportionate share of creek improvement maintenance.

Comment: Given that stormwater from all of the San Pedro Creek watershed washes through the creek, it seems inappropriate to require creekside residents to pay for the creek's maintenance. At present, maintenance of the creek by the city primarily consists of a yearly trek up the creek for removal of trunks and large branches.

Thanks for the opportunity to comment, and I hope that you find some of my comments useful! Best regards,
John Keener
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From: Breck Hitz [
Sent: Sunday, March 6, 2022 1:04 PM
To: Public Comment [[email protected]]
Subject: Please see attached document regarding the Pedro Point field.

Attachments: Christian Murdock ltr.pdf
[CAUTION: External Email]
Please see attached document regarding the Pedro Point
field.

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March 6, 2022
Christian Murdock
Deputy Director of Planning
City of Pacifica Planning Department
540 Crespi Drive
Pacifica, CA 94044
Dear Mr Murdock:

My wife and I have lived on Pedro Point for more than 30 years. We’ve raised two kids here, and made many good and lasting friendships with our neighbors. I am writing you today to state my objection to the General Plan Update (GPU) and Draft Environmental Impact Report (DEIR)’s proposed land use designation change of the undeveloped San Pedro Avenue site in Pedro Point (i.e., the Pedro Point field) from “Commercial Recreation” (CR) to a new “Coastal Residential Mixed Use” (CRMU) designation.

Such a designation change would have a detrimental effect on the congestion and safety on the Point, especially on lower San Pedro Avenue. I’m sure you’re aware of the congestion that occurs now on a sunny weekend day: there are surfers, kids, dogs, skateboards, baby carriages, and cars wandering around looking for a parking place.

Everybody is intent on whatever he’s doing, and it’s not at all unusual for surfers, kids, dogs, baby carriages, etc, to suddenly wander into the street despite approaching traffic.

The addition of dozens and dozens of housing units in the Pedro Point field would elevate this problem a sunny-weekend-day issue to an everyday problem, and exacerbate the sunny-weekend issue even further. I emphasize that this is an issue of public safety – perhaps life-or-death safety – and I hope it will be taken into account in any decision regarding the future of the Pedro Point field.

Sincerely,
s/ Breck Hitz
Breck Hitz
From: Christine Boles [
Sent: Monday, January 10, 2022 3:29 PM
To: Public Comment [[email protected]]; Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]; Murdock, Christian [[email protected]]; Michelle Kenyon [BWS Law] [ _City Council Group [[email protected]]
Subject: Public Comment letter for tonight's council meeting regarding General Plan Attachments: Boles Letter to City Council Public Comments Safety Element 1.10.21.pdf [CAUTION: External Email]
Please see attached, thank you.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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DATE: January 10, 2022
TO: Mary Bier, Mayor
Tygarjas Bigstyck, Mayor Pro-Tempore
Sue Beckmeyer,, City Council Member
Michael O’Neill, City Councilmember
Sue Vaterlaus, City Council Member
Kevin Woodhouse, City Manager
Christian Murdock, Deputy Director of Planning
Tina Wehrmeister, Planning Director
Michelle Kenyon, City Attorney
RE: 2021 Draft General Plan Safety Element Comments for 1.10.21 City Council Meeting Dear Mayor Bier, Mayor Pro-Tem Bigstyck, City Council Members and city staff, I appreciate the release of the draft General Plan documents last Friday (at 10:30 pm, such dedication Mr.

Murdock!) and I wanted to reaffirm my commitment to a cooperative process of giving informed comments based on my training and over 30 years of professional experience with entitlement processes, environmental analysis, development, and construction.

I acknowledge that I have been hard on planning staff in the last year and a half, and I want to assure each of you, that it is not my intention to personally malign staff. My interests are in improving our practices and policies to better serve the entire City of Pacifica. As I have said in the past, clear regulations also work in the favor of developers and design professionals. I can tell you that as an architect, San Francisco is the worst local city to work in as the rules change depending on who you talk to! I have spent a LOT of time over the past year researching the subject of safety in Pacifica, both in the hills with landslides and fires, and on the coast with coastal erosion and sea level rise. I spent days reviewing and commenting on Pacifica’s Local Hazard Mitigation Plan this year, only to be told after the fact that that this work was not needed, and that Pacifica’s hazards will be properly addressed very soon with the release of the updated General Plan Safety Element.

I spent the majority of this weekend reviewing the Safety Element, and honestly, I am appalled. Besides the landslide and coastal erosion errors I have already brought to your attention, the fire map only considers risks to property in the county (State Responsibility Area); there is no data at all for the entire area in City of Pacifica in the city limits.

The Introduction section of the General Plan talks about the importance of Horizontal Consistency within General Plan documents on page 1-5. I’ve copied the text below.

Horizontal Consistency between General Plan documents is a legal term and a basic requirement, along Vertical Consistency with other city documents like our zoning ordinances. I’m copying the City Attorney here because I am afraid that this poorly written document could actually put the City in legal jeopardy if adopted as written.

To be specific, here is one glaring example of horizontal inconsistency. Page 8-9 of the Safety Element talks about coastal bluff erosion and discusses the apartment buildings on the 300 block of Palmetto that were lost and had to be demolished in 2016. The Map of Slope Failure and Coastal in Figure 8-3, which was definitely updated since the 2014 version as it now includes riprap locations, still shows these bluffs as “Not Landslide Prone”.

There are no other maps in the Safety Element for coastal erosion or sea level rise, which obviously are an immediate and long-term issue of our city.

SB 379 also requires cities to update their Safety Elements by January 2022 for climate change adaptation. “This bill would, upon the next revision of a local hazard mitigation plan on or after January 1, 2017, or, if the local jurisdiction has not adopted a local hazard mitigation plan, beginning on or before January 1, 2022, require the safety element to be reviewed and updated as necessary to address climate adaptation and resiliency strategies applicable to that city or county. The bill would require the update to include a set of goals, policies, and objectives based on a vulnerability assessment, identifying the risks that climate change poses to the local jurisdiction and the geographic areas at risk from climate change impacts, and specified information from federal, state, regional, and local agencies.” There is very vague information about coastal vulnerabilities in section 8-3 which I will comment on in detail later, but I want to point out that the requirements of SB379 are for the entire city, not just the coastal zone.

So much is missing from this draft document.

I am disappointed, because I have reached out to planning staff and the City Manager on numerous occasions over the past 16 months offering my assistance with the General Plan update and other planning issues. Were any public meetings ever held related to the Safety Element? Even if they were held in 2009, with climate change, these factors are now completely different. We have the resources here with coastal and geotechnical engineers, scientists and other professionals like me who would gladly donate time to improve this document.

There is a wealth of knowledge and experience on the Planning Commission. Were they asked to review this document before its release?
By the City Manager choosing to save staff time and not involve the public in this update, I fear we are now on a much more expensive, confrontational, and lengthy path. I hope that is not the case and that you will be willing to reconsider the process to allow real dialogue. I and many others are ready and willing to volunteer our time to work with you all for a proper General Plan update that will be able to safely guide Pacifica through the next 20 years.

Sincerely,
Christine Boles, Architect
From: Nick Lusson [
Sent: Tuesday, March 8, 2022 5:07 PM
To: Public Comment [[email protected]]
CC: Sydney Sulak [ Cassie Leonardi [
Xavier Macy [
Subject: public comment on DEIR
Attachments: DEIR feedback from PSPM.docx
[CAUTION: External Email]
Please see the attached for our public comment. Thank you! Nick Lusson
Sydney Sulak
Cassie Leonardi
Xavier Macy
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PROTECT SAN PEDRO MOUNTAIN
Preserving Pacifica’s Hillsides
www.ProtectSanPedroMountain.org
To the Pacifica City Council and Planning Staff, March 8, 2022 We want to begin by thanking you for the tremendous amount of work that has gone into this first draft of our city's General Plan. Stepping back and looking at it as a whole, we applaud the overall vision you're taking and your recognition of how vital a document this is for our community's health, safety, and prosperity for decades to come. Pacificans will not all agree on all details and all decisions contained within, but we hope that we can all find compromise and understanding as we chart our future together.

As you well know, our organization's primary efforts center on the protection of our environmental health and community safety as we work towards the preservation of the cherished undeveloped lands along our southern border of San Pedro Mountain. The outcome of this General Plan will clearly play a significant role in those efforts, but we also understand that our work extends beyond it. We're a small operations team of passionate Pacifican residents, but with a very large following both here and from neighboring communities and regions. Our ability to properly and professionally review the Draft General Plan and the Draft Environmental Impact Report are limited. We acknowledge our limitations and are still in the process of engaging with all resources at our disposal to best ascertain our position on the plan and respond accordingly.

One area that does stand out to us for concern is the inclusion of sufficient hazard information for areas that are deemed in the highest tiers of fire risk by state agencies. This leaves ambiguities as to what and how much development is allowed. In this era of severe climate change, California has had to learn some tragic lessons about the risks of building & development into these areas. From what we've seen so far, this plan could use more work and detail to fill in the gaps of areas on the map that are known to be severe fire risk zones. We would hope that this type of additional hazard overlay would also further prohibit development of these vulnerable areas.

To summarize, we're writing to inform you that we will be turning in more detailed comments on the Draft General Plan and EIR in a timely manner, but they will be late from the deadline of March 8 as we work towards ensuring that this feedback is constructive and effective.

We also would like to review the feedback provided by other regional and state agencies that we believe may be providing official comment on the drafts, as our preference is to be wellresearched via objective sources before offering further feedback or opinion.

We thank you again for all the work you've done and look forward to working together as a community to plan a bright future together. Thank you for your time and consideration, Cassie Leonardi
Nick Lusson
Xavier Macy
Sydney Sulak
Protect San Pedro Mountain Operations Team & Pacifica Residents President
Nick
Lusson
Secretary
Mark
Rosales
Treasurer
Rob Kirby
From: Clif Lawrence [
Sent: Tuesday, March 8, 2022 11:51 AM
To: Public Comment [[email protected]]
CC: _City Council Group [ Ferguson, Alex
[ Leal, David [ Domurat, George
[ Godwin, James [ Nibbelin, John
[ Berman, Lauren [ Hauser, Samantha
[ Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Woodhouse, Kevin [[email protected]]; Jane Northrop [
Subject: Public Comment on Pacifica's DEIR 2022
[CAUTION: External Email]

1. Where is the analysis?
a. What happens when Sea Level Rise accelerates?
i. Where is the analysis of what happens
when the seawall infrastructure fails before it is
relocated?
ii. Where is the analysis of the flood
potential on Sharp Park area and Linda Mar?
b. What happens when cliff erosion accelerates?
i. How will it be “managed”?
ii. What will happen at 400 Esplanade?
iii. What will happen at 200-240 Palmetto
Ave?
iv. What happens when erosion at the
Palmetto South Canyon severs Palmetto Ave?

1. Where is the analysis for the impact on West
Fairmont residents if there is no Palmetto
access to Manor District?

2. What will be the impact on emergency
services to that area?
c. What happens if it is discovered the Mussel Rock
Landfill has leached into West Fairmont?
d. What happens if retreat is unmanaged?
e. Where is the analysis for a full buildout in Pacifica? f. Where is the analysis of what is actually “affordable” in Pacifica?
g. Where is the analysis of economic sustainability in
Pacifica?

2. Where are the contingencies?
a. What is the plan …
i. If the water treatment plant is
compromised?
ii. If public utilities are hijacked by
internet hackers?
iii. What is the plan for the inevitable
quake on Pacifica’s San Andreas Fault?
iv. If Pacifica cannot meet its RHNA
quotas?
b. What are the options …
i. To evacuate residents of Vallemar area if
needed?
c. What is the plan if developers continue to bring highend residential proposals?

3. Where is the commitment?
a. To Open Space?
i. Where is the commitment of 1980
Pacifica to promote alliances with non-profit
conservancies such as Peninsula Open Space Trust,
Golden Gate National Recreation Area?
ii. Where is the commitment
b. To Pacifica’s iconic Hillsides and Ridgelines?
c. To housing that Pacificans can afford?
i. Pacifica teachers, police, fire, store
clerks, restaurant workers?
d. Where is the commitment to the homeless?
e. Where is the commitment to preparing for elevated fire risk in Climate Change?
f. Where is the commitment to emergency preparedness?
g. Where is the commitment to full cooperation with the California Coastal Commission?
h. Where is the commitment to historical preservation?
i. Native communities
ii. Ocean Shore Railroad
iii. Early highways into and through today’s
Pacifica
i. Where is the commitment to preservation of wetlands? j. Where is the commitment to wildlife preservation?
k. Where is the commitment to public engagement?
l. Where is the commitment to cleaning up our beaches
and water?
Thank you.

Respectfully submitted by: Clifford (Clif) Lawrence
March 8, 2022
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From: House [
Sent: Monday, February 21, 2022 11:55 AM
To: Public Comment [[email protected]]
Subject: Public Comment Submission on Draft General Plan Attachments: Andrew - General Plan Public Comment.pdf
[CAUTION: External Email]
Dear General Plan Authors and Reviewers,
Please see PDF file attached with my feedback. Please confirm receipt. Please reply if there are any issues with opening the file so I can assist. I request an adjustment to the Pacifica General Plan to better serve its stated Guiding Policy. This small adjustment to the plan will positively impact the development of land use and will protect our community’s character and natural coastal appeal for years to come.

Thank you for your support and leadership,
Andrew
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2/21/22
Dear General Plan Authors and Reviewers,
I am writing you as a homeowner in the Ebken Street Neighborhood of Rockaway Beach. I request an adjustment to the Pacifica General Plan to better serve its stated Guiding Policy.

Request: Update the Plan to show Cattle Hill classified as “Prominent Ridgeline” fully to the HPD boundary. This area is currently shown as Hillside Preservation District with a partial prominent ridgeline. Small revision to Figure 4-4, Figure 3-3, and see excerpts below.

Figure 4-4 Revision (Extend Prominent Ridgeline to HPD Boundary) Figure 3-3 Revision (Update Prominent Ridgelines per above) Schematic Photograph
Designating prominent ridgeline to the HPD boundary better aligns with the General Plan:

1. “The General Plan envisions the Rockaway Beach district growing into a more distinct and highprofile visitor destination, with strong links to the natural setting of beaches, headlands, and ridges.” [page 4-22, emphasis added]

2. “Coastal views from Highway 1 toward Mori Point, Cattle Hill, and the Rockaway Headlands are important in establishing the identity of this area and Pacifica as a whole.” [page 4-22, emphasis added]

3. Guiding Policy
a. “CD-G-3 Neighborhood Conservation. Preserve the unique qualities of each of Pacifica’s residential neighborhoods.”
b. “CD-G-5 Hillsides and Prominent Ridge-lines. Maintain development standards that ensure that new development does not detract from the visual qualities of Pacifica’s hillsides and visually prominent ridgelines.”
c. “CD-G-6 Scenic and Visual Amenities of the Coastal Zone. Protect the City’s irreplaceable scenic and visual amenities in the Coastal Zone by protecting landforms, vegetation, special communities, and important viewsheds.”
d. “CD-I-12 Protection of Ridgelines. Protect visually prominent ridgelines from residential land commercial development.”
e. “CD-I-15 Minimize Impacts of Coastal Development on Landforms. Ensure that negative visual impacts resulting from new development in the Coastal Zone are minimized. In areas characterized by bluffs and landforms. Strategies to implement this policy include:

Prohibiting development on slopes in excess of 35 percent and highly visible tops of prominent landforms;” [emphasis added]

4. “This dramatic terrain [Hillsides and Ridges] is a defining feature of the city” [page 3-2]

5. “The General Plan supports continued investment in existing neighborhoods and development of a greater variety of housing types, while ensuring that new development is compatible in scale and density and respectful of neighbors.” [page 3-6]

6. “The key issues for hillside development are slope stability, grading, and visual impact.

Prominent ridgelines are identified based on their visual importance or scenic quality.” [page 3- 10]

7. “Ensure that development of highly sensitive slopes does not endanger the public” [page 4-13] ;

8. “Ensure that development of highly sensitive slopes does not … harm the environmental or scenic values of the site” [page 4-13];
This steep sloped area encompasses defining ridgelines for the signature topography of this coastal area.

This hill is a gateway to recreation for both visitors and residents, including daily regular trail use by bicycles and pedestrians. From personal observation, this ridgeline is home to wild bobcat, hawks (and other birds of prey) riding coastal thermals to “hover” and hunt, and other wildlife.

This small adjustment to the plan will positively impact the development of land use and will protect our community’s character and natural coastal appeal for years to come. Thank you for your support and leadership, Andrew, Ebken Street, Rockaway Beach, Pacifica, From: Christine Boles [
Sent: Friday, December 17, 2021 11:39 AM
To: Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]; Murdock, Christian [[email protected]] CC: _City Council Group [[email protected]]; Public Comment [[email protected]]; Berman, Lauren [[email protected]]; Hauser, Samantha [[email protected]]; Leal, David [[email protected]]; Godwin, James [[email protected]]; Nibbelin, John [[email protected]]; Ferguson, Alex [[email protected]]; Domurat, George [[email protected]] Subject: Questions about General Plan Process
[CAUTION: External Email]
Dear Mr. Woodhouse, Mayor Bier and City Council members, Planning Commissioners and Planning Staff,
While I appreciate that the General Plan document release has been delayed until January, I was hoping for some more clarification from staff about the process that the city will undertake to allow for the most input from the public. I have the following questions:
•
•
• How will the general public be notified? Will mailers also be sent to people not on social media/signed up for
• city updates?
•
•
•
• Will there be a launch meeting to explain the purpose, the documents, the process and how the public can best
• give input where we can ask questions?
•
•
•
• For people without computer access will there be copies provided at a library or at the community center?
•
•
•
• Will there be any community meetings where we can discuss certain elements of the GP? •
•
•
• Will someone on staff be available to answer questions during the 45 day period? Can we expect timely responses
• given the short time frame? Who do we complain to if we’re not getting responses? •
•
•
• To understand the timing and what is expected of the community, can you tell us approximately how many pages are
• in the EIR? And the General Plan ?
•
•
•
• Which General Plan elements are being updated now versus later - ie. we know the Housing Element will follow after
• the main GP update. What about the Sharp Park Specific Plan and Local Coastal Plan since the LCLUP is still nowhere near being approved by the Coastal Commission? •
•
•
•
• It was my understanding that public meetings were to have been scheduled to review and discuss the Sharp Park
• Specific Plan. The last meeting I recall was with the council where they gave direction to allow 5 story development, but there were a lot of questions left unanswered., and as Mayor Bier pointed out, the consultant's renderings didn't even show the context • of the existing neighborhood homes.
•
•
•
• Should we not review and approve the EIR first in case changes to the EIR need to be incorporated into the various
• GP elements?
•
•
•
• Does the public get to see the comments from the state agencies such as Fish and Wildlife and USGS after their
• 45 day review while the city is preparing responses?
•
•
•
• Will we have enough time to review the changes made to the GP and EIR before the public hearings? A staff report
• issued a few before the hearing is not enough for these enormous documents. •
•
•
•
• Will changes be tracked to enable easy scanning of updated documents without having to reread the whole of the
• documents?
•
•
•
• Processes such as Hazard Mitigation Plan where the public commented and staff responded to questions globally
• is not enough. Many comments were ignored or mis-interpreted. How will this process be different?
•
•
•
• How will the Planning Commission and City Council hearings be divided up? Do we only get 3 minutes to comment
• on the entire EIR and GP, or will there be separate hearings for each element? I could talk for 1/2 hour on just the Safety Element asIv'e spent a lot of time researching it this past year!
•
•
Thank you and I'll leave you all with the quote I read at the 12/13 Council hearing from the League of California Cities about the importance of General Plans and robust Public Engagement. “Experts advise local government officials to examine their General Plan at least every 10 years.” They go on to explain that ”a General Plan is more likely to withstand pressure to change it when it has been updated in a comprehensive way with public input and all the necessary environmental documents have been completed. Such a plan can work well for residents and community activists because they know what they want and have agreed to in terms of their collective vision for the future. When the public is engaged in the planning process and the updated General Plan reflects that, a win-win situation ensues.

Not only does the community have a clear picture of its priorities, but developers also benefit from the certainty that community members are essentially on the same page.” As an architect who regularly works with developers, I can attest that the last sentence is so important. I hope to work with you all in the near future to also help improve our planning review processes to engage the public earlier to reduce contentious hearings so that we can actually get more good projects built!
Happy holidays to everyone and I look forward to working with you all soon on this important process to define our city's future.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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From: Virgilio Jr L Yap [
Sent: Wednesday, January 19, 2022 7:00 PM
To: Public Comment [[email protected]]
Subject: Questions
[CAUTION: External Email]
Christian, Question, regarding the plans can be directed to you.

Send to my iPhone 11 Pro
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From: Remi Tan [
Sent: Saturday, February 26, 2022 4:22 PM
To: Murdock, Christian [[email protected]]; _City Council Group [ Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]; Public Comment [[email protected]]; Berman, Lauren [ Hauser, Samantha [ Nibbelin,
John [ Leal, David [ Godwin, James
[ Domurat, George [ Ferguson, Alex
[ O'Connor, Bonny [[email protected]]
Subject: Re: 2022-01 Pacifica General Plan - Public Comment Draft - Comments - Rockaway Headlands
[CAUTION: External Email]
City Council and City Planning:

Pacifica's proposed General Plan update has zoned the Rockaway Headlands for development for visitor serving commercial use. That is a prominent scenic headland ridge and should not be built on. Because the headland's edges are all steep - any access would require significant grading. Visitor serving should be on the parking lot next to the left and right of the Linda Mar BeachTaco Bell on the first row of parking, so there are more waterfront eating places by the beach like in HMB. Also at Rockaway, they should add more restaurants on the parking lots fronting the beach on the right side of the hotel and to the left of Nicks...

This headlands should be zoned park or open space in the General Plan. To avoid legal taking issues since this is private land, the city should allow TDR's where the headlands parcel owners can sell TDRs to other landowners who have parcels near transit and not on hillsides to develop denser housing or commercial projects that will help meet Pacifica's RHNA requirements and economic development needs.

Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment Pacifica, CA
Virus-free. www.avast.com
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From: Woodhouse, Kevin [[email protected]]
Sent: Friday, January 21, 2022 9:11 AM
To: City Manager [[email protected]]; Carter, Yulia [[email protected]]; Murdock, Christian [[email protected]]
CC: Wehrmeister, Tina [[email protected]]
Subject: RE: Beach Parking
Also cc’ing Christian here in case this is considered a General Plan comment too.

Thx,
Kevin
From: City Manager <[email protected]>
Sent: Thursday, January 20, 2022 3:12 PM
To: Carter, Yulia <[email protected]>
Cc: Wehrmeister, Tina <[email protected]>; Woodhouse, Kevin <[email protected]> Subject: FW: Beach Parking
Hi Yulia,
We received this email in the CM inbox from Chuck Gust, owner of Nick’s Seashore restaurant.

Kevin – I’m CC’ing you just in case Mary brings it up with you.

The email is below.

Thanks!
Shelby
From: Nick's Seashore Restaurant <
Sent: Thursday, January 20, 2022 2:57 PM
To: City Manager <[email protected]>; Economic Development <[email protected]>; Bier, Mary <[email protected]>; Pacificachamber Info <[email protected]> Subject: Beach Parking
[CAUTION: External Email]
I am sure you have lots to deal with these days as we all do. I have tried to follow progress of the EDC and the general plan. I have read a number of suggestions. I do not believe I have read anything that deals with parking. You can attract all the people you want but if there is no plan to park you just create a mess for businesses. My example is Rockaway Beach. It is a mess on nice summer days when surfers, beach goers and anyone visiting the coast stops by. There was a long term plan many years ago for parking in Rockaway, but it never materialized. Much of the problem was the city selling parking for in lieu of fees, putting more stress on parking that was existing.

Anyway, it’s a long story so my suggestion is that you consider putting parking on the top of the list. It’s not just Rockaway, its Pedro Point, Highway 1 Beach Parking and actually most areas on the coast side have fallen way behind concerning parking. I thought the coastal commission was formed to assist with coastal recreation; Hmmm, that is another story for another day.

Chuck Gust
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From: Sue Digre [
Sent: Monday, March 7, 2022 3:28 PM
To: Murdock, Christian [[email protected]]
Subject: Re: clarify please
Attachments: image001.png
[CAUTION: External Email]
Understood but the web does not indicate that info clearly.

Info on the DEIR says it is "due".

The info on the GP & SharpPk Specific Plan say they are " requested by 3 08" with no clarification.

If you don't look carefully at the fine print for each at the same time and on all related pages a reader may not assume that "requested" does give them some lee way.

Th General Plan is the focus, but wait
in statements about " plan pacifica" , (which include
Sharp Park Specific plan, etc ,etc ), then confusion rises.

The relationships to each other are not clear.

It seems reasonable a GP draft & DEIR would be essential before any of the others because the others must conform to a GP.

To add to the confusion: the operative GP is 1980.

Soooo what are the other specific plans conforming to? It can't be legal to be conforming to a Draft GP.

Hopefully not!
For those.of us who are not techy, all these
confusions are a nightmare.

For those of us who work full time and our work and life circumstances are severely impacted by COVIDimpacts keeping up is nearly impossible. I started months ago! We are in a pandemic.

Then there are other PACIFICANS who can not know that any of this is even going on .

I am very concerned and frustrated for them and all of us.

Please state who are the Stakeholders? My assumption is that Pacifica constituents, ( residents, voters )are the most important persons to get ample responses from.

Are we??
Or are "special interest" groups of higher importance? Esp are there " for profit agencies or lobbyists" that are considered "stakeholders".

What are the %ages of outreach towards all & the %age of input to the Drafts.

Sorry. I have tried to keep pace. But ,I am failing and getting exasperated.

I tried to avoid having to state these things but .

A Gen Plan is the vision of Pacificans about who they are and want to be.

As stated on the web , a Gen Plan is a constitution,
Of, by for the people .

Are we mistaken in our understanding?
These questions should be addressed in the process including in the DEIR & in the draft of the Gen Plan.

Best wishes.

Sue Digre
On Mon, Mar 7, 2022, 12:31 PM Murdock, Christian <[email protected]> wrote:

Hi Sue,
The deadline for written comments on the DEIR is 5 PM on 3/8. You may continue to comment on the draft General Plan and Sharp Park Specific Plan up to the day of adoption, although we strongly encourage comments to be submitted earlier so we can consider them and see if there is some way to incorporate them into the draft plans.

Regards,

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From: James Kremer [
Sent: Monday, January 17, 2022 6:40 PM
To: Murdock, Christian [[email protected]]
CC: Woodhouse, Kevin [[email protected]]
Subject: Re: DEIR PDF glitches-anyone else?
Attachments: PDF Selecting glitches in DEIR-480.mov
[CAUTION: External Email]
Christian,
Here is a strange issue with the PDF file provided for the DEIR. I think it is serious, and I wonder if you are aware of it?
I downloaded files for all the dropped docs from the Project Docs page on PlanPacifica.org. (I like to be able to save notes.). The problem seems to be also present online, though I’ve spent more time tracking it down with my downloaded files.
• There is a problem with SEARCH, online and with downloaded PDF files in 2 PDF reader laptop apps: Apple’s Preview, but also with Adobe Acrobat Pro XI. • The problem is ONLY with the DEIR. The GP works fine. (Perhaps it happened in the compression step?)
• Text words are NOT recognized as words everywhere; most places text seems to only be as block phrases, not searchable.
• I am painfully aware this may not be a problem for everyone, but I am sure you want to check if others have it.

A. Please try this:

1. Open the DEIR file online (Public Review Draft EIR (January 2022 Version) | Public Comments Due by 2/21/2022)

2. Use the FIND feature to search for “CEQA” &/or “(CEQA)”.

3. It MISSES the word in the first ¶.

4. Now Search for “Executive" or “Summary”. It finds them fine, in the first header.

If this happens for you, it is not just me!
B. Please view my short clip that shows the problem –
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C. One last example from the start of chapter INTRODUCTION shows what might be going on –
Again, search for “CEQA” which is right there in the 3rd line. It does NOT see the first hit (does not highlight the word) but it does find it in the heading. When I click-and-drag to select text (shown in green) it behaves inconsistently, sometimes missing the headings, and most importantly, selecting the text IN BLOCKS. You can see the small heavier green bands where the selected blocks overlap. The search DOES NOT SEE text in these blocks. (It really seems to be bad OCR coding for the main text ¶s, but it works for headings, and maybe some places in tables.)
----------------------------
All this seems especially unfortunate since the City has said you are most interested in comments on the EIR which is over 1000 pg and does not have an interactive Table of Contents. If the public (anyone using files from the website) can’t search for key words, it makes it even more intractable.

If you cannot repeat this behavior, it still might be worth checking with some others. I hope it is not just me! Again, i’ve seen it on 2 different Macs with 2 browsers online, and with downloaded files using two PDF readers.

Please let me know if you confirm or deny this. It has me dead in the water, essentially unable to work with the EIR, with only manual navigation.

Thanks for your attention to this.
-- Jim
From: Christine Boles
Sent: Wednesday, February 9, 2022 2:12 PM
To: Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Woodhouse, Kevin [[email protected]]; Bier, Mary [[email protected]]; Public Comment [[email protected]]; O'Neill, Mike [[email protected]]
Subject: Re: DEIR question abotu technical studies
[CAUTION: External Email]
And a few more specific questions about data related to greenhouse gasses - 1) I do see in Chapter 3.3 Air Quality that Dyett and Bhatia provided new emissions data in several tables. Can you confirm where they got their data for travel/trip information - was it from the 2010 traffic study or something more recent?
2) Dyett and Bhatia (D&B) also references Pacifica's Climate Action Plan on page 3.3-40 but doesn't list the source.The Bibliography refers to Pacifica's 2012 draft Climate Action Plan and I know there is one later that was adopted by council. What did they use? 3) I keep trying to look at the bibliography to find sources, but I don't think it was updated at all since 2014. It does not include BAAQMD's newer data sources referenced by D&B in Chapter 3.3.

Can you confirm? Do you have access to a more current bibliography that just did not make it into this published draft? That would be very helpful if you could share it.

I'm approaching my mental limit because this has given me another splitting headache...

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Wed, Feb 9, 2022 at 10:52 AM Christine Boles wrote:

Good morning Christian,
I understand from Vicki Sundstrom that no new technical studies were found in the public records to assess our traffic conditions as part of this DEIR update, but I wanted to confirm that with you.

It seems odd because DKS Associates is noted as a source in 2020 in the DEIR - see screenshot below. Please clarify.

Were any other technical studies required or prepared as part of the CEQA process to inform the DEIR? The NOP on page 14 says "The environmental assessment will utilize the most current CEQA Guidelines and for each issue area, including global warming and greenhouse gases/climate change."
A city planner friend tells me that you would normally find these technical studies in an appendix, but there is no appendix. I was pointed to Los Angeles County that had recently updated their general plan as a good example as they have a lot of the same issues we do with sensitive biology, steep hillsides, coastal erosion and sea level rise. Their website shows all these appendices and detailed technical documents. Am I missing something?
Thank you, my brain hurts trying to make sense of all this! Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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.

From: Murdock, Christian [[email protected]]
Sent: Monday, January 31, 2022 4:23 PM
To: Christine Boles [
CC: Woodhouse, Kevin [[email protected]]; Bier, Mary [[email protected]]; Wehrmeister, Tina [[email protected]]; Public Comment [[email protected]]
Subject: RE: Existing Conditions Reports/Traffic Studies for GP/EIR? Hi Christine,
It appears you have located the relevant SPSP existing conditions report. Make sure to review the December 2019 updated version, not the initial version from November 2019.

I do not know if we have a digital version of the General Plan existing conditions report. I seem to recall a hard copy of the document that may be in my former office at our old building on Francisco. If you submit a PRA, that will enable our team to search for that record.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]
From: Christine Boles <
Sent: Monday, January 31, 2022 3:59 PM
To: Murdock, Christian <[email protected]>; Wehrmeister, Tina <[email protected]>; Public Comment <[email protected]>
Cc: Woodhouse, Kevin <[email protected]>; Bier, Mary <[email protected]> Subject: Existing Conditions Reports/Traffic Studies for GP/EIR? [CAUTION: External Email]
Good afternoon Christian and Tina,
The DEIR references two Existing Conditions Reports, one done in 2010 and one done in 2019 for Sharp Park.

I think I found the one for Sharp Park here, please confirm this is current. https://www.planpacifica.org/spsp-ecr
I cannot find the one for the whole city that was discussed at a public hearing in September 2010. Can you forward that to me or should I file a PRA request?
And can you confirm if any updates were done for the city wide studies? I'm currently specifically looking for more recent traffic studies as 2010 was before the tunnel opened.

Thank you and I appreciate a quick response as our review time is so limited.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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.

From: Christine Boles [
Sent: Thursday, February 10, 2022 4:17 PM
To: Wehrmeister, Tina [[email protected]]; Murdock, Christian [[email protected]]; Bier, Mary [[email protected]]; Woodhouse, Kevin [[email protected]]
CC: Public Comment [[email protected]]
Subject: Re: General Plan Buildout Question
[CAUTION: External Email]
Tina,
Is it possible for you to answer this question since Christian appears to be out of the office for the next few days? I'll be coming to the city offices tomorrow at 12:30 to meet Sarah to view another document.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Thu, Feb 10, 2022 at 4:12 PM Christine Boles < wrote:

Hi again Christian,
I am trying to understand the calculation of Buildout per the draft General Plan. See screenshot below from Page 4-29. The whole DEIR is based on this maximum buildout number to assess environmental impacts for a project of 990 new units, so I wanted to clarify how these numbers were obtained.

I am assuming that you have in your files or in Dyett & Bhatia's the detailed calculations that informed these numbers that would list specific properties and their acreage that were included in each of these land use categories.

If I need to file another PRA request, please let me know specifically what to ask for so I can better guide poor Sarah.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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.

From: Christine Boles [
Sent: Saturday, January 15, 2022 1:18 PM
To: Woodhouse, Kevin [[email protected]]; Public Comment [[email protected]]
CC: Wehrmeister, Tina [[email protected]]; Murdock, Christian [[email protected]]; Myers, Ron [NCC Fire] [
Subject: Re: General Plan OPR distribution list and Fire Issues [CAUTION: External Email]
Thank you Mr. Woodhouse. Is it possible to also get an answer to my question of whether North County Fire and other stakeholder agencies were given the opportunity to review the drafts for factual accuracy before they were released?
And thank you also for copying Chief Myers of North County Fire. State and regional Cal Fire staff I contacted were not completely clear about who the responsible fire authority was for reviewing our General Plan and Safety Element.

It does concern me greatly that the Safety Element does not seem to have any information about fire risk in LRA (Local Responsibility Areas) and one of my goals in reaching out is to ascertain where I can find the current maps. This is my first time participating in a General Plan update and I am very confused as to the detailed process and how to be most helpful. How can I look at proposed land use changes for example without a thorough understanding of our hazards as a starting point? If I am confused as a professional, then I am sure I am not alone among the public.

And I know for a fact that fire risk is one of the top concerns of the residents on the south end of town near the proposed Linda Mar Woods project.

Thank you very much.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Fri, Jan 14, 2022 at 1:58 PM Woodhouse, Kevin <[email protected]> wrote:

Dear Ms. Boles, part of your question below falls into the “simple clarifying question” for staff response as part of the Plan Pacifica public comment period process, so a short response for your information is provided here to clarify your misunderstanding about the North County Fire Authority. Your comment in its entirety, of course, will be included in the DEIR public comments received.

The North County Fire Authority is not a “District” separate from the City of Pacifica. Thus, it is not an outside agency that the City would consult or refer a draft document to as part of the CEQA process. The NCFA is part of the City in a shared management Joint Powers Agreement between Pacifica, Daly City, and Brisbane. Chief Myers reports to the City Managers of each of those cities. Therefore, NCFA’s involvement in the Plan Pacifica process has been as an internal member of the City team just as that for any other City department such as Police, Public Works, and PB&R.

I understand you reached out directly to NCFA and spoke with one of the newer Deputy Chiefs, Sean Kavanaugh. He appropriately has forwarded your communication to the appropriate staff point of contact.

Sincerely,
Kevin Woodhouse
City Manager
City of Pacifica
www.cityofpacifica.org
From: Christine Boles <
Sent: Thursday, January 13, 2022 11:35 AM
To: Murdock, Christian <[email protected]>
Cc: Wehrmeister, Tina <[email protected]>; Woodhouse, Kevin <[email protected]>; Bier, Mary <[email protected]>; Public Comment <[email protected]>
Subject: Re: General Plan OPR distribution list
Good morning Christian and Tina,
I just noticed that the North County Fire District is not on this distribution list. Is that perhaps an oversight?
And section 7-8 of the DEIR, attached, notes them as a stakeholder agency, but says they were last contacted in 2009. Surely that must be a typo? Were the stakeholder agencies not all recontacted and interviewed in 2019? According to a city planner friend, 2009 is too long ago, the legal term is "stale". This document mentions Michael Crabtree and Van Campo as well who have obviously been gone from Pacifica for some time.

Are there copies of information collected from interviews with these agencies that I can request to view? I'm happy to file a document request, but Sarah is asking me to be as specific as possible to help her with her job.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Wed, Jan 12, 2022 at 2:41 PM Murdock, Christian <[email protected]> wrote:

Christine,
See attached. Additional state agencies are identified for routing on the CEQA Clearinghouse site.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) | [email protected]

Regards,
Christian
On Jan 11, 2022, at 11:31, Christine Boles <
wrote:
[CAUTION: External Email]
Good morning Christian and Tina,
Could you please forward a copy of the instructions to the State Clearinghouse, OPR along with the distribution list to responsible and optional agencies that will be reviewing the City's DEIR?
I can file an official document request if you prefer.

Thank you,
Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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.

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.

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.

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.

From: Christine Boles [
Sent: Thursday, January 13, 2022 11:47 AM
To: Murdock, Christian [[email protected]]
CC: Wehrmeister, Tina [[email protected]]; Woodhouse, Kevin [[email protected]]; Bier, Mary [[email protected]]; Public Comment [[email protected]]
Subject: Re: General Plan OPR distribution list
Attachments: 7_8_DEIR_OCR (1).pdf
[CAUTION: External Email]
Sorry, forgot the attachment.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Thu, Jan 13, 2022 at 11:35 AM Christine Boles < wrote:

Good morning Christian and Tina,
I just noticed that the North County Fire District is not on this distribution list. Is that perhaps an oversight?
And section 7-8 of the DEIR, attached, notes them as a stakeholder agency, but says they were last contacted in 2009. Surely that must be a typo? Were the stakeholder agencies not all recontacted and interviewed in 2019? According to a city planner friend, 2009 is too long ago, the legal term is "stale". This document mentions Michael Crabtree and Van Campo as well who have obviously been gone from Pacifica for some time.

Are there copies of information collected from interviews with these agencies that I can request to view? I'm happy to file a document request, but Sarah is asking me to be as specific as possible to help her with her job.

Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Wed, Jan 12, 2022 at 2:41 PM Murdock, Christian <[email protected]> wrote:

Christine,
See attached. Additional state agencies are identified for routing on the CEQA Clearinghouse site.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) | [email protected]
From: Christine Boles <
Sent: Tuesday, January 11, 2022 3:28 PM
To: Murdock, Christian <[email protected]>
Cc: Wehrmeister, Tina <[email protected]>
Subject: Re: General Plan OPR distribution list
[CAUTION: External Email]
I'm just looking for the Distribution list for the DEIR - the list of agencies who are required to, or invited to provide comments.

Thank you!
Christine Boles, Architect
Beausoleil Architects
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Tue, Jan 11, 2022 at 11:39 AM Murdock, Christian <[email protected]> wrote:

Christine,
I don’t understand what you mean by “ instructions to the State Clearinghouse, OPR.” Please clarify.

Regards,
Christian
On Jan 11, 2022, at 11:31, Christine Boles <
wrote:
[CAUTION: External Email]
Good morning Christian and Tina,
Could you please forward a copy of the instructions to the State Clearinghouse, OPR along with the distribution list to responsible and optional agencies that will be reviewing the City's DEIR?

From: Christine Boles [
Sent: Thursday, January 13, 2022 11:35 AM
To: Murdock, Christian [[email protected]]
CC: Wehrmeister, Tina [[email protected]]; Woodhouse, Kevin [[email protected]]; Bier, Mary [[email protected]]; Public Comment [[email protected]]
Subject: Re: General Plan OPR distribution list
[CAUTION: External Email]
Good morning Christian and Tina,
I just noticed that the North County Fire District is not on this distribution list. Is that perhaps an oversight?
And section 7-8 of the DEIR, attached, notes them as a stakeholder agency, but says they were last contacted in 2009. Surely that must be a typo? Were the stakeholder agencies not all recontacted and interviewed in 2019? According to a city planner friend, 2009 is too long ago, the legal term is "stale". This document mentions Michael Crabtree and Van Campo as well who have obviously been gone from Pacifica for some time.

Are there copies of information collected from interviews with these agencies that I can request to view? I'm happy to file a document request, but Sarah is asking me to be as specific as possible to help her with her job.

Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Wed, Jan 12, 2022 at 2:41 PM Murdock, Christian <[email protected]> wrote:

Christine,
See attached. Additional state agencies are identified for routing on the CEQA Clearinghouse site.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]
From: Christine Boles <
Sent: Tuesday, January 11, 2022 3:28 PM
To: Murdock, Christian <[email protected]>
Cc: Wehrmeister, Tina <[email protected]>
Subject: Re: General Plan OPR distribution list
[CAUTION: External Email]
I'm just looking for the Distribution list for the DEIR - the list of agencies who are required to, or invited to provide comments.

Thank you!
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Tue, Jan 11, 2022 at 11:39 AM Murdock, Christian <[email protected]> wrote:

Christine,
I don’t understand what you mean by “ instructions to the State Clearinghouse, OPR.” Please clarify.

Regards,
Christian
On Jan 11, 2022, at 11:31, Christine Boles <
wrote:
[CAUTION: External Email]
Good morning Christian and Tina,
Could you please forward a copy of the instructions to the State Clearinghouse, OPR along with the distribution list to responsible and optional agencies that will be reviewing the City's DEIR?
I can file an official document request if you prefer.

Thank you,
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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.

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.

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.

From:

Sent: Monday, March 7, 2022 9:44 AM
To: Murdock, Christian [[email protected]]
Subject: Re: GP and DEIR Comments
Attachments: Natesan_PGP_Comments_March_2022.pdf
[CAUTION: External Email]
Hi again Christian, I realized I forgot to put a date, so I added it. Please use this version with a date in it as my comment letter. Thank you. Ellen
On Mar 6, 2022, at 6:30 PM, ellen.natesan wrote:

Hello Christian, Here is my comment letter on the Pacifica General Plan and associated Draft Environmental Impact Report. Please let me know if you have any trouble with the attached file. I would be happy to talk to you or your consultants to answer questions or provide more information if that would be helpful. Thank you very much! Ellen <Natesan_PGP_Comments_March_2022.pdf>
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.

March 7, 2022
Christian Murdock, AICP
Deputy Director of Planning
Planning Department
540 Crespi Drive
Pacifica, CA 94044
Thank you for the opportunity to comment on Pacifica’s Draft General Plan and Draft Environmental Impact Report. These documents are a significant accomplishment for Pacifica. I appreciate and agree with the priority placed on protecting the beautiful open spaces and unique natural resources found in Pacifica. I know this is a shared value among Pacifica’s residents. It is why I moved here.

I am pleased to have this opportunity to offer my professional expertise to improve planning outcomes in my hometown of Pacifica. I have over 20 years of professional experience as an ecologist, and for the past 15 years I have been responsible for developing measures to protect natural resources during construction, as well as responsibility for many large and complex ecological restoration projects in the Bay Area. The comments I am providing below are derived from my experience and knowledge, but also benefit from expertise and input from many remarkable other professionals, including other residents of Pacifica.

In my comments below, I provide some specific suggestions in the form of suggested edits.

These are shown in red underline for suggested additions and red-strikethrough for suggested deletions. I have tried to provide an explanation and justification for each of these edits. If you have any questions about my recommendations, or would like additional resources or references, please let me know.

Thank you for your continued hard work on these important documents.

Sincerely,
Ellen Natesan, Ph.D.

General Comment - DEIR and GP Policy Discrepancies
The policies in the General Plan do not always match those in the DEIR. Not only are there textual differences, but the numbering seems to have changed. For example – CO-G-10 appears as a policy about “Other Environmentally Sensitive Areas” on page E-70 of the DEIR but also as a policy about “Trees” on page 3.3-34 of the DEIR. CO-I-26 in the DEIR is a “Sanitary Sewer Discharge” policy but CO-I-26 in the General Plan is about “Protection of Biological Resources with New Development.”
When I inquired about these discrepancies to the Pacifica Planning Department, I was instructed (in an email from Christian Murdoch dated January 29, 2022) to use the Policies in the General Plan as the basis for my comments. My comments below are therefore focused on the versions of the Policies found in the General Plan. Where possible I have attempted to refer to the corresponding policy in the DEIR. All of my comments should also be considered to be comments to the DEIR, except where I specify “General Plan Only.” Policy OC-G-5 – Open Space Preservation - DEIR and General Plan Recommended Edits:

Open Space Preservation. Preserve open space that protects natural resources, visual amenities, and public health and safety.

The top priority areas for conservation are beaches, oceanfront bluffs, ridgelines, hillsides areas adjacent to existing open space, and areas that support critical wildlife important habitat for special status and endangered species. See Figure 6-1.

Rationale:

The way this is written it is overly narrow. There are many special status plants, wildlife, and butterflies found in Pacifica with no designated critical habitat. Critical habitat has a specific and narrow legal meaning that would currently only apply to California red-legged frog within the planning area. The intent of this policy should be to protect important habitat for all special status species, whether or not the Fish and Wildlife Service has formally designated critical habitat. The word “critical” should not be used to avoid confusion. Please also see my comments on Policy CO-G-7 below.

Policy OC-I-28 - Highway 1 Over-Crossing at Mori Point - General Plan Only Recommended Edits:

Highway 1 Over-Crossing at Mori Point. Support the development of a new wildlife friendly over-crossing between Shelldance Nursery and Mori Point, in coordination with GGNRA and Caltrans to enhance visitor facilities in Pacifica. Pacifica should also encourage GGNRA and Caltrans to place wildlife barriers at strategic locations in this area to reduce roadkill and risk of wildlife collisions on Highway 1. Underpasses such as the Calera Creek underpass could potentially be modified to improve wildlife passage and connectivity between habitats. Pacifica should encourage Caltrans to improve these structures whenever these road segments are upgraded or replaced. As an interim alternative, strengthen signage and safe connections to the existing Sharp Park Golf Course undercrossing in the East Fairway Park neighborhood.

Rationale:

Highway 1 is a prominent feature running through Pacifica that has heavy traffic which is built at-grade with insufficient safety barriers and insufficient over- and under- passes. Currently, getting across Highway 1 presents dangers to both humans and wildlife. Safety improvements (for both people and wildlife) should be addressed whenever the opportunity presents itself, which is most likely to be when Caltrans is doing maintenance or upgrades. A safe crossing allowing people to safely cross Highway 1 and connect trails above Shelldance Nursery and Mori Point is urgently needed. It is likely that such a structure could be made in a way to be useable to at least some wildlife, particularly larger mammals. Pacifica should work with Caltrans and encourage them to identify the most dangerous areas (Mori Point being a good example of this) and install safe crossing structures for people and wildlife.

Policy CO-G-7 - Protect Habitat for Special Status Wildlife - DEIR and General Plan Recommended Edits:

CO-G-7 Protect Habitat for Special Status Wildlife and Critical Habitat. Conserve and protect indigenous threatened, endangered, and other special status species by preserving critical habitat that is important for the protection of these species.

Habitat can be protected by allowing very limited or no development, by identifying habitat areas as top priorities for permanent conservation, and by managing public land to ensure species protection.

Rationale:

The term “critical habitat” has a specific regulatory meaning, namely, habitat that has been designated as critical habitat by the United States Fish and Wildlife Service. Many special status wildlife species, including those listed as threatened or endangered by the Fish and Wildlife Service and California Department of Fish and Game, do not have designated critical habitat.

Currently, the only species with critical habitat designated in the project area is California redlegged frog. California red-legged frog is definitely not the only special status species in Pacifica with a need for habitat protection. The intent of this policy should be to protect important habitat for all special status species, and so the term “critical habitat” should not be used to avoid confusion.

Policy CO-G-10 – Trees – DEIR and General Plan (note also appears as Policy CO-G-9 in DEIR)
Recommended Edits:
*NOTE – this policy should be edited in both the DEIR and General Plan. The numbering seems to be incorrect in the DEIR and so the numbers should also be updated in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.

CO-I-10 Trees. Conserve trees and encourage native forestation and planting of appropriate trees and vegetation in areas identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan. In areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan, limit planting of trees to riparian areas or other areas known to have historically supported trees, to avoid impacts to special status plant and animal habitat, to non-tree dominated plant communities (such as prairie, chaparral, and wetlands), and to the invertebrates and wildlife that depend on these habitats.

Rationale:

In general, the trend on the San Francisco Peninsula has been towards increased afforestation rather than deforestation. Most of the region’s sensitive and special status species depend on grassland and shrubland communities, which are being lost through time to afforestation.

Planting trees (even native trees) should be considered an impact except in the narrow circumstances of urban planting or planting in areas known to historically support trees. For more background information on these ecological trends see the Peninsula Watershed Historical Ecology Study here:
https://www.sfei.org/documents/peninsula-watershed-historical-ecology-study Policy CO-I-1 - Creek Protection and Restoration - DEIR and General Plan Recommended Edits:
*NOTE – The edits below are to the version of Policy CO-I-1 in the General Plan which is different from the version of Policy CO-I-1 in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.

CO-I-1 Creek Protection and Restoration. Maintain, protect, and restore Pacifica’s creeks, including San Pedro, Calera, Sanchez, and Milagra creeks, as environmental and aesthetic resources. Actions will include, but are not limited to:
• Continuing restoration efforts along San Pedro Creek to improve conditions for steelhead by removing obstacles to fish passage, placing rock weirs to facilitate fish passage, and by monitoring the effectiveness of these projects;
• Partnering with local organizations, such as the San Pedro Creek Watershed Coalition, Go Native, the Pacifica Land Trust, and others, on restoration efforts; • Exploring opportunities to collaborate with other agencies and organizations on stream restoration and riparian habitat restoration along Sanchez and Calera creeks; • Enforcing restrictions on the planting of invasive species near creek areas; • Identifying and working with property owners to take advantage of unique opportunities where human active use (e.g., through trail development) would enhance creek appreciation without disrupting ecological function;
• Requiring a minimum of 100-foot set- backs from the top of creek banks, or from the outer edge of riparian vegetation, where it exists, for development proposed adjacent to creeks, in keeping with City regulations and Best Management Practices. Exceptions to such buffer requirements should be supported by a biological report demonstrating that the adjusted buffer, in combination with incorporated siting, design or other mitigation measures, shall prevent impacts that significantly degrade the creek. A Qualified Hydrologist with professional experience evaluating natural creek geomorphology shall evaluate the potential for impacts in coordination with a Qualified Biologist with professional experience evaluating the riparian and freshwater aquatic ecosystems found in the project area. This analysis shall be provided in writing and shall consider impacts to creek form and function, aquatic species, and to riparian habitat. Buffer adjustments should also be limited to where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the buffer would have a greater impact on the creek.

Rationale:

Analysis of potential for impacts of a development adjacent to a creek channel should be performed by someone with knowledge and experience analyzing creek hydrology and geomorphology. A biologist alone would not be able to predict the changes to creek form and function which will drive any biological impacts. A biologist however is needed to understand potential for impacts to special status species, riparian communities, and creek aquatic habitats.

The results of the analysis should be available in the form of a report or memo to staff, Planning Commission, and the public.

Policy CO-I-11 - Protect Water Quality through Best Management Practices - DEIR and General Plan
Recommended Edits:

CO-I-11 Protect Water Quality through Best Management Practices. Continue to require the use of best management practices to reduce water quality impacts from construction and development. Measures include:
• Site Design and Source Control. Ensure that all new development incorporates site design and source control BMPs into the project design in order to pre- serve the infiltration, purification, and retention functions of each site’s natural drainage systems, and to prevent or minimize the runoff of pollutants, sediments, waste, and pathogens from the site.
• Construction Pollution Control. Require all construction projects to adopt measures to avoid when possible, or minimize erosion and runoff of pollutants and sediments from construction-related activities, and to limit activities that result in the disturbance of land or natural vegetation.
• Construction projects will be required to use appropriate erosion prevention techniques, sediment control measures, and best management practices in accordance with City specifications and the San Mateo Countywide Water Pollution Prevention Program. • Treatment Control. Require that new development implement treatment control BMPs (or structural treatment BMPs) where the combination of site design and source control BMPs is not sufficient to protect water quality and comply with applicable water quality permits.
• Site Design and Source Control. Ensure that all new development incorporates site design and source control BMPs into the project design in order to preserve the infiltration, purification, and retention functions of each site’s natural drainage systems, and to prevent or minimize the runoff of pollutants, sediments, waste, and pathogens from the site.
• Runoff Capacity Management: Ensure that new developments do not cause flooding for communities downstream. Evaluate downstream drainage capacity for runoff that cannot be captured on-site during large storm events (100 year storms). If a development will increase peak runoff volumes during large storms (because of increased impervious surfaces or other factors), downstream capacity improvements should be part of the project, using a design standard of 100 year storm.

Stormwater treatment systems must meet the numeric sizing criteria established in the NPDES Permit, and must be operated and maintained in compliance with the NPDES Permit.

Rationale:

New developments should not cause downstream flooding. For example, new developments in the San Pedro Creek watershed should consider flooding at Adobe Drive, which is already prone to flooding during large storm events. The water conveyance capacity at Adobe Drive should be increased as a part of any new development project that would increase peak runoff to prevent the project from causing flooding in the neighborhood in the vicinity of Adobe Drive and San Pedro Creek. When undersized water conveyance structures like this are overtopped during storms, there is increased risk to the creeks of streambank failures, sedimentation, and a flush of contamination (such as from motor oil, tire wear particles, and litter) washing into the creeks.

Climate change is expected to increase the frequency of atmospheric rivers and high intensity precipitation events and so designing to a 100 year storm standard is a bare minimum. This measure might be more appropriate as a standalone new mitigation/policy.

Policy CO-I-26 – Protection of Biological Resources - General Plan and DEIR (see Policy CO-I-27 in DEIR)
Recommended Edits:
*NOTE –This Policy does not appear in the DEIR (and it should), however Policy CO-I-27 in the DIER may be an earlier version of this policy. This policy should be added to the DIER.

Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.

CO-I-26 Protection of Biological Resources with New Development or Other Earth Disturbing Projects. Protect sensitive habitat areas and special-status species through implementation of the following measures:

1. Discourage development and/or buildout in critical habitat of special status species habitat during the development review process in a manner consistent with Policy CO-G7.

2. Pre-construction pConduct plant and wildlife surveys prior to vegetation clearing or earth disturbing activities: Project applicants shall engage a qualified biologistQualified Botanist and Qualified Wildlife Biologist (as defined below) to conduct presence/absence biological surveys for sensitive plant and wildlife species prior to construction adjacent to or within identified special status communities and other sensitive areas identifiedcommencement of work in areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan. If special status species are identified, the qualified biologist shall consult with the California Department of Fish and Wildlife (CDFW) and establish no-disturbance buffers around avian nests, bat roosts, dusky footed woodrat nests, sensitive plant communities, special status plants, and sensitivespecial status butterfly host plants, wetlands, or other sensitive and special status natural resources to avoid disturbance and direct impacts to these resources during construction. If no special status species or plant communities are detected during surveys, then construction-related or earth disturbing activities may proceed. Nesting birds, in particular, are protected by two means; they receive protection under the Migratory Bird Treaty Act, and nesting raptors (in the order Falconiformes or Strigiformes) are protected under the State Fish and Game Code, §3503.5.

3. Incorporate bird, bat, and wildlife impact avoidance measures into vegetation removal activities. Prior to felling, prune trees to increase detectability of nesting birds, and disturb trees (eg. with axe or chainsaw) and then observe for 10-15 minutes. Near San Francisco garter snake or California red-legged frog habitat, tall vegetation can be cut to 1 foot in height to improve visibility for biologists and encourage wildlife to move out of the area, and then cleared to the ground.

4. Require biological resource assessments be conducted prior to approval for any development within 300 feet of creeks, wetlands, or other areas not identified as “Urban and Non Urban with Little or No Habitat Value” sensitive habitat areas shown on Figure 7-3 of the proposed General Plan.

5. Require on-site monitoring of biological resources by a qualified biologist throughout the duration of construction activity.

5.6.For projects taking place in areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan, require that equipment arrive on site for construction visibly clean of dirt and organic matter to minimize the risk of introducing new plant pathogens, pests, or invasive plants to the area.

Prior to approval and prior to any earth disturbance, grading, grubbing, vegetation clearing, staging or other temporary or permanent project-associated impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3, a Qualified Botanist will conduct pre-project botanical surveys to determine the potential for impacts to special status plants, plant communities, or special status butterfly (such as Mission blue butterfly) host plants.

The Qualified Botanist shall conduct botanical field surveys in a manner which maximizes the likelihood of locating special status plants and sensitive natural communities that may be present.

The botanical survey must take place during the appropriate season during which the target species can be readily detected and accurately identified. Botanical surveys should generally take place while target plants are in bloom. Multiple years of surveys may be required to accurately assess the location of or determine the absence of short-lived plant species or plants species with a persistent seed bank. Botanical field surveys should be floristic in nature, meaning that every plant taxon that occurs in the project area is identified to the taxonomic level necessary to determine rarity and listing status.

A Qualified Botanist must meet the following requirements:
• Knowledge of plant taxonomy and natural community ecology; • Familiarity with plants of the region, including the plants targeted for survey and any special status plants (or host plants of special status insects) that may occur in the survey area;
• Familiarity with natural communities of the region, including California Sensitive Natural Communities;
• Experience with the CNDDB, BIOS, and Survey of California Vegetation Classification and Mapping Standards;
• Experience conducting floristic botanical field surveys; • Familiarity with federal, state, and local statutes and regulations related to plants and plant collecting; and
• Experience analyzing the impacts of projects on native plant species and sensitive natural communities.

If a project will involve earth disturbance, grading, grubbing, staging or other temporary or permanent impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the General Plan, a Qualified Wildlife Biologist will survey for special status wildlife species and their habitat. A qualified wildlife biologist must be familiar with identification of essential physical and biological features for special status wildlife species, including space for individual and population growth and for normal behavior; cover or shelter; food, water, air, light, minerals, or other nutritional or physiological requirements; sites for breeding and rearing offspring; and habitats that are protected from disturbances or are representative of the historical geographical and ecological distributions of the species.

A Qualified Wildlife Biologist must meet the following requirements:
• Demonstrated professional experience identifying all of the target wildlife species at all life history stages;
• Experience and knowledge of the natural history, habitat affinities and wildlife species needs;
• Familiarity with federal, state, and local statutes and regulations; and • State and federal handling permits (as needed).

Rationale:

See explanation for CO-I-27 edits below.

Policy CO-I-27 - Page E-65 of DEIR and Page 7-26 of General Plan Recommended Edits:
*NOTE – The edits below are to the version of Policy CO-I-27 in the General Plan which is different from the version of Policy CO-I-27 in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.

CO-I-27 Verification of Environmentally Sensitive Habitat Areas (ESHA) within the Coastal Zone and identification of sensitive habitats or special status species that should be protected outside of the Coastal Zone. Prior to any proposed development or other earth disturbing project in an ESHA or potential ESHAin areas not identified as “Urban and Non Urban with Little or No Habitat Value” Figure 7-3 of the proposed General Plan, require that a habitat survey be conducted by a Qqualified Bbotanist or Qualified Wildlife Bbiologist. The habitat survey will verify whether the site is an ESHA or has special status under CEQA, and document the extent of the sensitive resources, document potential negative impacts to the habitat, and recommend appropriate mitigation measures. Verification of an ESHA or special status plant communities, plant or animal species, or habitat shall be based on the following considerations:
• Presence of natural communities identified as rare by the California Department of Fish and Wildlife (determined by a state rarity ranking of S1 to S3). • Recorded or potential presence of plant or animal species designated as rare, threatened or endangered under State or federal law.
• Recorded or potential presence of plant or animal species for which there is compelling evidence or rarity, such a designation of 1B (rare or endangered in California or elsewhere) or 2 (rare, threatened, or endangered in California, but more common elsewhere) by the California Native Plant Society.
• Presence of coastal waterways.
• Presence of drainages or wetlands.
• Integrity of the habitat and its connectivity to other natural areas.

Prior to approval and prior to any earth disturbance, grading, grubbing, vegetation clearing, staging or other temporary or permanent project-associated impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3, a Qualified Botanist will conduct pre-project botanical surveys to determine the potential for impacts to special status plants, plant communities, or special status butterfly (such as Mission blue butterfly) host plants.

The Qualified Botanist shall conduct botanical field surveys in a manner which maximizes the likelihood of locating special status plants and sensitive natural communities that may be present.

The botanical survey must take place during the appropriate season during which the target species can be readily detected and accurately identified. Botanical surveys should generally take place while target plants are in bloom. Multiple years of surveys may be required to accurately assess the location of or determine the absence of short-lived plant species or plants species with a persistent seed bank. Botanical field surveys should be floristic in nature, meaning that every plant taxon that occurs in the project area is identified to the taxonomic level necessary to determine rarity and listing status.

A Qualified Botanist must meet the following requirements:
• Knowledge of plant taxonomy and natural community ecology; • Familiarity with plants of the region, including the plants targeted for survey and any special status plants (or host plants of special status insects) that may occur in the survey area;
• Familiarity with natural communities of the region, including California Sensitive Natural Communities;
• Experience with the CNDDB, BIOS, and Survey of California Vegetation Classification and Mapping Standards;
• Experience conducting floristic botanical field surveys; • Familiarity with federal, state, and local statutes and regulations related to plants and plant collecting; and
• Experience analyzing the impacts of projects on native plant species and sensitive natural communities.

If a project will involve earth disturbance, grading, grubbing, staging or other temporary or permanent impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the General Plan, a Qualified Wildlife Biologist will survey for special status wildlife species and their habitat. A qualified wildlife biologist must be familiar with identification of essential physical and biological features for special status wildlife species, including space for individual and population growth and for normal behavior; cover or shelter; food, water, air, light, minerals, or other nutritional or physiological requirements; sites for breeding and rearing offspring; and habitats that are protected from disturbances or are representative of the historical geographical and ecological distributions of the species.

A Qualified Wildlife Biologist must meet the following requirements:
• Demonstrated professional experience identifying all of the target wildlife species at all life history stages;
• Experience and knowledge of the natural history, habitat affinities and wildlife species needs;
• Familiarity with federal, state, and local statutes and regulations; and • State and federal handling permits (as needed).

Rationale:

This policy is currently redundant to CO-I-31 and CO-I-26. It probably would make sense to combine these, however, if it is required to have a separate policy specific to ESHA under the Coastal Act, I have added the same recommended language to both CO-I-26 and CO-I-27. Preproject (and pre-approval) biological survey requirements should be the same inside and outside of the Coastal Zone in Pacifica since special status species and plant communities have high potential to occur in Pacifica both within and outside of the Coastal Zone. Figure 7-3 of the General Plan is an appropriate figure to use, and all of the areas not mapped as “Urban and NonUrban with Little or No Habitat Value” have sufficient potential for rare and special status species and their habitats to require a biological survey.

Any earth disturbing activity, and even off-road access in some cases, has the potential to damage or destroy sensitive habitat and species. For example, Mission blue butterfly is on or near its host plants in some life stage year-round, even when the host plant is dormant, low to the ground, and difficult to detect. “Take” of this endangered species could occur by any activity that would crush or destroy the host plants. Earth disturbing activities also have the potential to destroy the seed bank of special status plant species. Pacifica should consider any earth disturbing project-related activities to require biological surveys prior to authorization.

Planners and project applicants should be aware that biological surveys for special status plants and butterfly host plants often have a seasonally narrow window during which they can take place and plan accordingly. For example, Western leatherwood (Dirca occidentalis) a CRPR 1B.2 shrub found in Pacifica, is generally difficult to identify outside of January or February, while some grassland annual plants may not be identifiable until mid-summer. A project proposed in late-summer without biological surveys in hand may need to wait until the following summer so that surveys can be completed. Anticipating this need and performing surveys proactively will prevent project delays and reduce frustration on the part of applicants. A coordinated voluntary program for private landowners to pay into and participate in a coordinated larger-scale biological resource survey would be very valuable. Qualifications for a Qualified Botanist and Qualified Wildlife Biologist should be spelled out explicitly since the effectiveness of this Policy hinges on the professional qualifications of these individuals.

For additional supporting information see:
https://www.cnps.org/wp-content/uploads/2019/10/Bot-Cert_2018-CDFW-Plant-andVegetation-Survey-Protocols-LR.pdf CO-I-32 – Monitoring Requirements – General Plan and DEIR (not found in DEIR) Recommended Edits:
*NOTE – This policy is an extremely important component of impact reduction and it should be added as a mitigation requirement to the DEIR.

CO-I-32 - Restoration and Monitoring Requirements. Require a Restoration and Monitoring Proposal for any proposed habitat restoration or mitigation. The Proposal should describe the methods and practices to be employed, and include:
• A clear statement of the goals of the restoration or mitigation for all habitat types; • Sampling of reference habitat, with reporting of resultant data; • Designation of a qualified biologist as the Restoration or Mitigation Manager responsible for all phases of the restoration;
• A specific grading plan, if the topography must be altered; • A specific erosion control plan, if soil or other substrate will be disturbed during restoration, which should utilize erosion control materials free of invasive species (including invasive plant seeds), plastic microfibers and materials that are free of weed seeds, pests, pathogens, and other invasive species;
• An invasive species introduction avoidance plan to minimize introduction of new weeds, pests, or pathogens to the site. This should include
o a plan to clean equipment and vehicles before they arrive on site, and inspections to confirm that equipment and vehicles are free of soil, organic material, and vegetative debris prior to entering the work site,
o a plan to reject seed lots that contain invasive species that are not already present on the site or adjacent areas so they will not introduce new invasive species to the area, and
o a plan to require that all imported organic materials such as mulch, compost, and erosion control materials be free of new invasive species including invasive plants, animals, pests, or pathogens;
• A weed eradication plan designed to eradicate existing a specified list of target weeds (non-native invasive plant species expected to interfere with the restoration goals such as all CalIPC high and moderate species that form monocultures) and control future invasion by exotic species maintaining target invasive plant cover below 5% total absolute cover site-wide of target invasive plant species (unless restoration goals or reference sites justify a higher percent cover);
• A planting plan based on the natural habitat type using seeds wherever possible and using best management practices for avoiding introduction of plant pests and pathogens if container plants must be used;
• An irrigation plan that describes the method and timing of watering and ensures removal of watering infrastructure by two years prior to the end of the monitoring period; • An interim monitoring plan with annual reporting and a 5 year minimum reporting period with performance goals, assessment methods, and a schedule; and • A final monitoring planperformance criteria to determine whether the restoration has been successful.

Rationale:

Restoration is an extremely important component of impact mitigation and this measure should be robust (and in the DEIR!). Ecological restoration is complex and difficult and if done poorly, not only will fail, but can actually have significant impacts to surrounding natural areas.

Incorporating the specific added guidance I suggest above into the DEIR will help these restoration projects be successful.

Many erosion control materials contain plastics. The natural fibers in these materials degrade, while the plastic fibers do not. These bundles of loose plastic fibers pose wildlife entrapment hazards for special status and non-special status wildlife. For more information see:
https://documents.coastal.ca.gov/assets/water-quality/permits/WildlifeFriendly_Netting_in_Erosion_&_Sediment_Control-Factsheet_r5_Sept_2016.pdf Not all invasive species can be controlled, for example, some Cal-IPC high and moderate nonnative perennial grasses generally grow intermixed with native plant species in such a way that controlling them could be excessively destructive and undermine the success of a restoration project. Non-native invasive plant species should be selected for control depending on controllability, presence in San Mateo County (not just the site), and the restoration goals. Once selected, presence of these target species should be maintained so that the sum-total of the absolute cover by all target invasive plant species is less than 5% absolute cover. This is an achievable objective that keeps the seed bank, rhizomes, or other propagules of invasive plant species sufficiently under control so that the native plant species have room to become established.

To make sure the restoration plantings are self-sustaining, the irrigation should be stopped 2 years before the end of the performance monitoring period. Although I did not include this in the Policy as an edit, there should also be some restriction on replacement planting or re-seeding efforts during the final years of the performance monitoring period to ensure that the site is selfsustaining, however, you don’t want to disallow replanting completely since it can be a valuable site management strategy that improves outcomes.

Introducing a new invasive plant species, plant pest or pathogen to a restoration site has the potential to not only undermine the success of the restoration project but devastate surrounding natural areas. Planting should be done using direct seeding (not rooted plants) as much as possible to avoid unintentional introduction of invasive species. Imported materials should be free of invasive species to the degree possible as well and equipment and vehicles should be inspected as they arrive on site and only allowed to enter if they are free of organic matter. Also see my comments on CO-I-36 below.

Best management practices for avoiding spread of plant pathogens during restoration projects can be found here:
http://www.suddenoakdeath.org/welcome-to-calphytos-org-phytophthoras-in-nativehabitats/#WG More information about how restoration activities have introduced destructive plant pathogens into natural areas in California and the Bay Area can be seen here:
https://www.mdpi.com/1999-4907/11/12/1291
Policy CO-I-36 – Minimizing Introduction of Invasive Plant Species Through Plantings (see CO-I-38 of DEIR)
CO-I-36 Minimizing Introduction of Invasive Plant Species Through Plantings. Encourage planting of locally appropriate native plants directly from seed. If direct seeding is not possible, encourage sourcing of plants from nurseries which use techniques that minimize the risk of accidental introduction and spread of invasive species (such as, plant pests, plant pathogens, and invasive insects). Prohibit the use of invasive plant species (i.e., any California Invasive Plant Council (Cal- IPC)-listed species with a status of high or moderate, or identified such as locallythreatened under the limited, alert, or watch status).

Rationale:

Planting rooted plants grown in containers is a surprisingly risky activity. It is easy to accidentally introduce and spread invasive species. Invasive species that can move in plant containers include plant disease, plant pests, and other invasive invertebrate species. For example, Argentine ants thrive in plant nurseries and while they don’t attack plants, they do displace native ants where they are introduced.

Use of container plants in restoration has been documented as an introduction pathway for plant pathogens in California and the Bay Area. For more information see Phytophthora Introductions in Restoration Areas: Responding to Protect California Native Flora from Human-Assisted Pathogen Spread at the link below:
https://www.mdpi.com/1999-4907/11/12/1291
Best practices for avoiding spread of plant pathogens during restoration projects can be found here:
http://www.suddenoakdeath.org/welcome-to-calphytos-org-phytophthoras-in-nativehabitats/#WG Policy CO-I-37 – Beach Grooming – DIER and General Plan (See DEIR CO-I-39) Recommended Edits:

Note: The numbering seems to be incorrect in the DEIR, the numbering in the DEIR should be updated to reflect the numbering in the General Plan
Policy CO-I-37 – Beach Grooming. Work with the State of California, GGNRA, and other partners in the management of beaches in Pacifica to ensure biological resources are NOT adversely affected by beach grooming. Specifically, protect beach wrack (the piles of plant and animal debris that wash ashore), which plays an important role in the beach ecosystem.

Rationale: This appears to be a typo.

Policy SA-I-95 DEIR and General Plan
Recommended Edits:

Plan Review in Fire-Prone Areas. Continue to request the North County Fire Authority participation in plan review of new buildings in potentially fire-prone areas. New construction in fire prone areas shall be required to incorporate appropriate additional fire protections to minimize risk of fire and to minimize the need for fuel reduction, vegetation clearing, and destruction of habitat in adjacent wildland areas. Potentially fire prone areas are shown in Figure 8-7 of the General Plan.
*NOTE – Figure 8-7 of the General Plan must be updated to show the fire hazard throughout the study area (for more information see my comment on Figure 8-7 below).

Rationale:

It should be clear to planners when this measure should be implemented. A map would be the clearest way to show what areas are potentially fire prone and where Policy SA-I-95 would be applicable and required. Requiring new structures to be designed to be as fire resistant as possible would protect surrounding open space areas and reduce potential future cost to Pacifica (and society more broadly) in two ways: (1) by reducing the likelihood that structures are a source of ignition and cause of a-seasonal, overly frequent, or otherwise unnatural wildfire, and (2) by reducing the need to remove fuels (plants) from natural areas to protect structures. Fuel breaks are expensive to maintain, of limited efficacy in many situations, and can be destructive of natural habitats. It is better to build new structures to resist and withstand fire.

San Pedro Creek watershed – Page 3.5-4 of DEIR
Recommended Edits: Please add two more special status fish species to the list for San Pedro Creek
• Pacific lamprey (Entosphenus tridentatus) which is a CDFW Species of Special Concern and is mentioned in the General Plan as being present in San Pedro Creek; and • northern tidewater goby (Eucyclogobius newberryi) which has been detected in San Pedro Creek (Sutter and Kinziger, 2019) and is listed as Endangered under federal ESA by the Fish and Wildlife Service
Annual Grasslands - Page 3.7-2 of DEIR and Page 7-16 of General Plan Recommended Edits:

Annual Grasslands
Annual gGrasslands in Pacifica often occur most often in a mosaic pattern with coastal scrub and are dominated by non-native annual grass species and a variety of other non-native weeds. The presence of these grasslands in Pacifica is limited and generally occurs in highly disturbed areas.

Damage to grasslands is a result ofSome of Pacifica’s grasslands have been damaged by unauthorized vehicle activity, which resulting in off-road trails on hillsides. Many of Pacifica’s grasslands contain a mix of native and non-native grasses and forbs. Although some of the grasslands in Pacifica have been highly disturbed, other grasslands within Pacifica are known to support red fescue (Festuca rubra) prairie, and intact stands of California fescue (Festuca californica), needle grass (Stipa pulchra), Pacific reed grass (Calamagrostis nutkaensis), and blue wild rye (Elymus glaucus). The grasslands and prairies within Pacifica are also known to support a number of special status rare plant species. The grassland communities in Pacifica have not been surveyed extensively, however, grasslands in coastal California are known to support a high native component of native perennial grass species relative to inland California grasslands.

Grasslands provide essential basking, foraging, and sheltering habitat for reptiles and amphibians including the federally protected (Threatened) California red-legged frog, and state and federally protected (Endangered) San Francisco garter snake. Grassland communities with higher proportions of native species support more complex biological community of insects, over a wider range of seasonal conditions, and are therefore a better source of food for insectivorous wildlife such as adult California red-legged frog and Sierran tree frog, which are both important prey species for the San Francisco garter snake.

Rationale:

Referring to the grasslands within the study area as “annual” and “highly disturbed” presumes a low ecological value that is misleading and inaccurate. Pacifica’s grasslands and prairies, like almost all of California’s grasslands, do contain non-native annuals, however, many of these areas within Pacifica contain a significant component of native grassland and forb species. The grasslands and prairie in Pacifica provide essential refugia for native, rare, and special status grassland plant species in addition to habitat for special status wildlife.

For more information about the relative importance and rarity of grasslands in California, please also see the California Native Grassland Association (CNGA) website which points out, “To date, our state has already lost 99% of our native grasslands. With only 1% of our native grassland remaining statewide it is critical that we protect every remaining acre.” https://cnga.org/Conservation#:~:text=The%20California%20Native%20Grassland%20Associati on,UC%20Santa%20Cruz%20East%20Meadow.&text=To%20date%2C%20our%20state%20ha s,99%25%20of%20our%20native%20grasslands
In the absence of a complete survey of existing grasslands within the study area, this DEIR should not assume the absence of remnant patches of special status grasslands (CDFW designated California Sensitive Natural Communities) or special status native grassland and forb species.

Grasslands typically are complex and can contain within them mosaic patterns at a very fine scale that can only be detected through appropriately timed botanical surveys in the field.

Grassland communities with a native component should be prioritized for protection when possible over communities that are exclusively non-native.

The following species are ranked as California Rare Plants in CalFlora and are present or likely to be present in Pacifica. Although these species are mostly only documented in protected areas of Pacifica, the lack of observations in unprotected areas are likely due to lack of surveys rather than lack of actual presence on privately owned lands.

1. Centromadia parryi ssp. parryi, a dicot, is an annual herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 1B.2 (rare, threatened, or endangered in CA and elsewhere). Present Mori Point, Aramai Point

2. Chorizanthe cuspidata var. cuspidata, a dicot, is an annual herb that is native to California, and endemic (limited) to California.

California Rare Plant Rank: 1B.2 (rare, threatened, or endangered in CA and elsewhere).

3. Leptosiphon rosaceus, a dicot, is an annual herb that is native to California. California Rare Plant Rank: 1B.1 (rare, threatened, or endangered in CA and elsewhere).

4. Silene scouleri ssp. scouleri, a dicot, is a perennial herb that is native to California, and also found elsewhere in western North America. Present PPH
California Rare Plant Rank: 2B.2 (rare, threatened, or endangered in CA; common elsewhere)

5. Arabis blepharophylla, a dicot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.3 (limited distribution).

Present PPH* and Milagra Ridge

6. Erysimum franciscanum, a dicot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.2 (limited distribution) Present PPH* and Milagra Ridge

7. Piperia michaelii, a monocot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.2 (limited distribution).

Present PPH* and Aramai Point
See also Appendix below for a list of native grassland species that have been observed in Pacifica and documented in the iNaturalist database.

Vegetation Map - Figure 3.7-1 - Page 3.7-4 of DEIR & Figure 7-2 on Page 7-15 of General Plan
Recommended Edits:

Change the label on the legend and map from “Annual Grasslands” to “Grasslands/Prairie.” Update the landscape and vegetation map using recent GIS layers available for San Mateo County through the Fine Scale Vegetation Map and Landscape Database Project. See links and explanation below.

Rationale:

The term “Annual Grasslands” is an inaccurate and misleading title for the grasslands and prairie in the study area. Pacifica’s grasslands and prairie, like almost all of California’s grasslands do contain non-native annuals, however, many grasslands within Pacifica contain remnant patches of native grassland communities, as well as individual native grassland and forb species. These grasslands are essential refugia for native, rare, and special status grassland species. Re-labeling to “Grasslands/Prairie” would be a more accurate label for the grasslands in the study area that reflects our currently incomplete knowledge and the potential for important native biotic communities to occur within these areas.

For more information about the importance of using the correct terminology in CEQA documents for Grassland and Prairie see:

PRAIRIES AND GRASSLANDS: WHAT’S IN A NAME? by Glen Holstein):
https://cnps.org/wp-content/uploads/2018/03/FremontiaV39.2_39.3.pdf More accurate mapping data is available for Pacifica as a part of recent work to develop landform and fine scale vegetation maps for San Mateo County. Updating the map with this upto-date data would provide a more accurate and defensible basis for this General Plan and EIR.

For more information and access to this data, please see the websites below. https://www.nps.gov/articles/vegetation-mapping-projects-underway.htm https://www.nps.gov/articles/000/new-draft-lifeform-map-available-for-san-mateo-county.htm Comment on the Regulatory Setting (in General Plan and DEIR) Please cross check and update special status of species named in the conservation chapters and include all special status species found in Pacifica. Specific examples include:
• tricolored blackbird is listed as Threatened under California ESA and is mentioned in the General Plan as present in Pacifica but its special status is not mentioned • Pacific lamprey is a CDFW Species of Special Concern and is mentioned in the General Plan as present in San Pedro Creek but its special status is not mentioned • monarch butterfly was not mentioned but is a candidate for listing under federal ESA and is likely present in Pacifica
• mountain lion is not mentioned and is a candidate species under California ESA • northern tidewater goby (Eucyclogobius newberryi) has been detected in San Pedro Creek (Sutter and Kinziger, 2019) and is listed as Endangered under federal ESA by the Fish and Wildlife Service and should be mentioned (currently is not mentioned in the General Plan or DEIR)
Fire Hazards and Public Safety Services - Figure 6.11-3 on page 3.11-4 of DEIR and Figure 8-7 on Page 8-36 of General Plan
Recommended Edits:

Please expand the fire hazard mapping to include all undeveloped areas in the plan area. This figure currently has no information about fire hazard outside of the State Responsibility Area, which means there is no information shown for most of the plan area. This should be corrected.

The GIS layers available for San Mateo County through the Fine Scale Vegetation Map and Landscape Database Project include a 5 m fuels model as well as LiDAR slope data. These should be combined to generate a basic fire hazard map for the undeveloped portions of Pacifica.

Additional refinements could be added later. This fire hazard map should be calibrated to use similar criteria for hazard classifications used by CalFire so the mapping is consistent throughout the plan area. This map should be reviewed by the North County Fire Authority prior to finalization. For more information about the 5 m fuels and LiDAR data see links below. https://www.nps.gov/articles/vegetation-mapping-projects-underway.htm https://www.nps.gov/articles/000/new-draft-lifeform-map-available-for-san-mateo-county.htm Appendix
Additional native species below are confirmed in Pacifica’s grassland/prairie communities according to iNaturalist, Calflora, and as compiled by *Kramer Botanical, Vascular Plant Species within the Pedro Point Headlands Trail Improvement and Restoration Project Area, February 2016.
https://www.calflora.org//app/ipl?vrid=ce891&bloom=t
https://www.inaturalist.org/check_lists/3273-Mori-Point-Check- List?iconic_taxon=47126&without%5B%5D=page&without%5B%5D=q

https://www.inaturalist.org/check_lists/5529-Milagra-Ridge-Check- List?iconic_taxon=47126&without%5B%5D=page&without%5B%5D=q Native plants commonly present on grassland/prairie in Pacifica Alliaceae Allium dichlamydeum Coast Onion
Anacardiaceae Toxicodendron diversilobum Pacific Poison Oak Apiaceae Angelica hendersonii Henderson's Angelica
Daucus pusillus American Wild Carrot
Heracleum maximum Cowparsnip
Lomatium utriculatum Lomatium
Sanicula arctopoides Footsteps of Spring
Sanicula crassicaulis Pacific Sanicle
Agavaceae Chlorogalum pomeridianum Wavy-leafed Soap Plant Dipterostemon capitatus Blue Dicks
Triteleia laxa Ithuriel's Spear
Asteraceae Achillea millefolium Common Yarrow
Anaphalis margaritacea Pearly Everlasting
Centromadia parryi ssp. parryi Papoose Tarplant 1B.2
Cirsium occidentale Cobweb Thistle
Circium quercetorum Brownie Thistle
Grindelia stricta Pacific Gumplant
Lasthenia californica Goldfields
Lasthenia minor Coastal Goldfields
Layia platyglossa Tidytips
Madia sativa Coast Tarweed
Pseudognapthalium californicum California Cudweed
Pseudognaphalium ramosissimum Pink Everlasting
Solidago velutina ssp. californica Goldenrod
Symphyotrichum chilense Pacific Aster
Wyethia angustifolia Narrowleaf Mule-Ears
Boraginaceae Amsinckia menziesii Coast Fiddleneck
Phacelia californica California Phacelia
Phacelia malvifolia Stinging Phacelia
Brassicaceae Arabis blepharophylla Coast Rockcress 4.3
Erysimum franciscanum San Francisco Wallflower 4.2
Caryophyllaceae Silene scouleri ssp. scouleri Scouler Catchfly 2B.2 Convolvulaceae
Calystegia purpurata ssp
purpurata Smooth Westerng Morning glory
Calystegia subacaulis Hill Morning Glory
Curcurbitacea Marah fabacea California Manroot
Marah oregonus Coast Manroot
Fabaceae Astragalus nuttallii Bladder Pod
Lupinus nanus Sky Lupine
Lupinus variicolor Varied Lupine
Lupinus albifrons Silver Lupine
Lupinus bicolor Miniature Lupine
Vicia gigantea Giant Vetch
Iridaceae Iris douglasiana Douglas Iris
Iris longipetala Central Coast Iris
Sisyrinchium bellum Western Blue-eyed Grass
Lamiaceae
Clinopodium douglasii (Satureja
douglasii) Yerba Buena
Monardella villosa Coyote Mint
Stachys bullata Hedgenettle
Salvia spathacea Hummingbird Sage
Liliaceae Calochortus albus White Fairy-lantern
Fritillaria affinis Checker Lily
Toxicoscordion fremontii Fremont's Deathcamus
Malvaceae Sidalcea malviflora Checkerbloom
Onagraceae Clarkia rubicunda Ruby Chalice Clarkia
Taraxia ovata Sun Cup
Orchidaceae Piperia michaelii Michael's Rein orchid 4.2 Orobanchaceae
Castilleja densiflora ssp
densiflora Dense Flower Owl Clover
Castilleja exserta ssp exserta Purple Owl's Clover
Castilleja wightii Wight’s Paintbrush
Orobanche californica ssp
californica California Broomrape
Triphysaria pusilla Dwarf Owl's Clover
Papaveraceae Eschscholzia californica California Poppy
Plantaginaceae Plantago erecta Dotseed (Dwarf) Plantain Poaceae Agrostis pallens Leafy Bentgrass
Agrostis exarata Spike Bentgrass
Bromus carinatus California Brome
Bromus sitchensis var. maritimus Maritime Brome
Calamagrostis nutkaensis PacificReed Grass
Danthonia californica California Oatgrass
Deschampsia cespitosa Tufted Hair Grass
Elymus glaucus ssp. Glaucus Blue Wild Rye
Elymus triticoides Beardless Wild Rye
Festuca californica California Fescue
Festuca rubra Red Fescue
Hordeum brachyantherum Meadow Barley
Hordeum depressum Dwarf Barley
Koeleria macrantha Junegrass
Leymus triticoides Beardless Wildrye
Melica californica California Melicgrass
Melica torreyana Torrey's Melica
Stipa pulchra Purple Needlegrass
Stipa lepida Foothill Needlegrass
Poa unilateralis San Francisco Bluegrass
Polemoniaceae Navarretia squarrosa Skunkweed
Leptosiphon rosaaceus Rose Leptosiphon 1B.1
Polygonaceae Eriogonum latifolium Seaside Buckwheat
Chorizanthe cuspidata sp
cuspidata San Francisco Spineflower 1B.2
Portulacaceae Calendrinia ciliata Red Maids
Ranunculaceae Ranunculus californicus California Buttercup Rosaceae Acaena pinnatifida Biddy-biddy, Sheepburr
Horkelia californica California Horkelia
Rubus ursinus Califonria Blackberry
Themidaceae Triteleia laxa Ithuriel's spear
From: Christine Boles [
Sent: Sunday, January 9, 2022 10:01 AM
To: _City Council Group [[email protected]]; Woodhouse, Kevin [[email protected]]; Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Public Comment [[email protected]] CC: Berman, Lauren [[email protected]]; Hauser, Samantha [[email protected]]; Nibbelin, John [[email protected]]; Leal, David [[email protected]]; Godwin, James [[email protected]]; Domurat, George [[email protected]]; Ferguson, Alex [[email protected]] Subject: Re: GP landslide map has still not been properly updated [CAUTION: External Email]
Correction, I meant the upcoming January 18th Planning Commission hearing for the Talbot project, sorry about that.

And for the Planning Commissioners, here is a link to my Google folder with the documents I received from the city in regards to the HPD variance discussions for the adjacent property at 722 Talbot Avenue. I think these will be useful to you in looking at precedence. These are from the City Council hearing; I have still not been able to obtain any documentation from the Planning Commission hearing on 11/4/2004 or the previous Planning Commission Study Session despite my 8/16/21 PRA request. The city prematurely closed my request, but I am following up to try to obtain these documents and I will forward it to you if/when I get them. https://drive.google.com/drive/folders/1efu90KFgl-8ozcZr81k-uFPMrazgJVEt?usp=sharing Thank you,
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Sat, Jan 8, 2022 at 12:54 AM Christine Boles < wrote:

I was finally able to download the general plan documents after receiving several error messages about the city's lack of bandwidth. The first thing I wanted to do was look at the landslide/coastal erosion map.

I am copying the Council and Planning Commission as this relates to an article I wrote in the Tribune this week as well as private discussions I have had recently with two council members. It also relates to a project on the Planning Commission agenda for Monday the 10th on Talbot Avenue.

I have apparently been screaming into the void for over a year now...my letters, public comments, expert reports from scientists I sent you, mostly ignored. The Esplanade bluffs and Oddstad Boulevard where the kids died are still shown in white as not landslide/coastal erosion prone. I appreciate the new map of debris flow slides, but it does not reference the HDAI report that the city commissioned after the 475 landslides that winter of 1982 or consider all of these historic landslides. Even some of the 9 major slides studied, like the one between Moana and Talbot are not included on either map. The recent landslide on Highway One is missing, which is a blockage of a major evacuation route. You have these records in your files; I just saw them recently as part of a document request. And the new 2021 USGS maps, which I also shared with planning staff recently, shows most of Pacifica in landslide prone zones. Your document page 8-5 references USGS maps from 19888 (yes 3, 8s) by the way.

There is some discussion of bluff erosion in the written text, but again the map does not match.

And there have been many more properties that were forced to be removed in proximity to the shoreline than are mentioned, including at Linda Mar Beach, Rockaway and Manor that I know of.

I am so disappointed, and frankly, angry that the city after 40 years is apparently still not seriously considering our greatest environmental hazards. We must do better.

The Planning Commission is again reviewing the project on Talbot at their next meeting, which is asking for variances from HPD on up to 100% slope, near this historic landslide. How can Commissioners possibly do their jobs if we haven't given them accurate tools? Speaking of HPD, let me leave you with a couple of quotes I found recently in digging through newspapers from the 1970s when the HPD ordinance was being drafted and reviewed. There were 15 public hearings just for this one ordinance by the way, with a ton of community engagement and public comments. The ordinance was approved unanimously by both the Planning Commission and City Council.

11.17.71 Tribune
"Les Clark, Director of Community Development estimates that there are about 5400 acres of untouched land in Pacifica, 2800 of which are developable. The balance is on hillsides of 35% grade or more - too steep to develop....Preservation of steep land in excess of 35% grade is a top priority, said Clark. Such land should not be developed."

6.7.72 Tribune
At a Planning Commission hearing on June 1,1972, a developer complained about the proposed ordinance saying," 70 percent of the remaining land in Pacifica will have to remain undeveloped if this ordinance is approved."
Planning Commissioner Lee Forster replied,"You are finally getting the point. That is exactly what the citizens of Pacifica expect from this ordinance."
It begs the question as to whether the voices of Pacifica's citizens of today will be heard.

Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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.

From:

Sent: Saturday, January 8, 2022 9:59 AM
To: Murdock, Christian [[email protected]]
Subject: Re: Land Use Plan Updates
Attachments: OConnell Comments from Public Comment Draft - General Plan Update - Combined Version - 2022-01-07.pdf
[CAUTION: External Email]
Chrisitan
See attached comments on the GP. It doesn't look like the consultant picked up the changes on Rosita.

Thanks,
On Tue, Dec 7, 2021 at 7:31 PM Murdock, Christian <[email protected]> wrote:

Hi Mike,
I’ve placed the 900 Rosita property and the two adjacent properties on the final list of land use plan changes for our consultant to make before release of the draft GP for public comment in January. Because there are many moving parts to this process, please take another look once the document is released to make sure it’s in the final version.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]
From: Mike O'Connell >
Sent: Tuesday, August 3, 2021 8:57 PM
To: Murdock, Christian <[email protected]>
Subject: Re: Land Use Plan Updates
[CAUTION: External Email]
Chrisitan
Just wanted to follow up on this to see if these changes can be incorporated.

Thanks,
Mike O'Connell, PE
On Thu, Jun 24, 2021 at 7:38 PM Mike O'Connell < wrote:

Christian
Thanks for incorporating the updates for 535 and 195.

The other one I had noted was 900 Rosita Road, which I had changed the GP plan to low density residential in 2012 (Reso 870). It is noted as undeveloped on figure 4-1. Figure 4-8 shows it as public facilities. I think it has been mistakenly shown as part of Linda Mar School which is how it got the PF designation. There are 2 small lots behind 900 Rosita which are also shown as public facilities but have never been owned by the school district and so I believe those should also have a LDR designation (I do not own those lots).

Thanks,
Mike O'Connell, PE
DRE #02114316
On Thu, Jun 24, 2021 at 3:58 PM Murdock, Christian <[email protected]> wrote:

Hi Mike,
I look forward to receiving a list of suggested updates to the 2014 General Plan land use map. With respect to the Coastal Zone, I suggest basing your review off the Certification Draft LCLUP approved by City Council in 2020. We incorporated updates to the 535 San Pedro and 195 Carmel properties to reflect their existing mixed-use developments. We will be updating the next draft of the General Plan with the Certification Draft LCLUP land use maps for Coastal Zone areas.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
1800 Francisco Boulevard, Pacifica, CA 94044
Phone: (650) 738 – 7444 | [email protected]
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.

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.

PACIFICA GENERAL PLAN PUBLIC REVIEW DRAFT 4-23
21 22
23 24 25 26
27 Devil’s Slide Trail
San Pedro Creek
Old San Pedro MountianRd
Coastal Trail
Pedro Point Trail
Rosita Road Trail
DEVIL’S SLIDE TUNNEL

SAN PEDRO AVE
ROSITA
RD

ROBERTS
RD

GRAND AVE

FASSLER AVE

LINDA MAR BLVD
DESOLO
DR

PERALTA RD

ADOBE RD

LINDA MAR BLVD

ALICANTE DR

MANZANITA DR

SEVILLE DR

CRESPI DR

CRESPI DR
Fassler Ridge
Crespi Dr
Lower
San Pedro Ave Site
Undeveloped
Center
Shopping
Pedro Point
Center
Shopping
Linda Mar
Ranch
Shamrock
Hillsides
& Park Pacica
Linda Mar
Park
Skate
Center
Community
Pacica
E.S.

Cabrillo
Site
Park-and-Ride
Linda Mar
Pacic Bay
Christian
School
(GGNRA)
Headlands
Pedro Point
State Beach
Pacica
Adobe
Sanchez
School
Linda Mar
Art Center
Sanchez Park/
Pedro
Point
& Shelter
Cove
Pacica
State Beach
West Linda Mar
at up to 30 dwelling units per gross acre.
* Sites 0.5 acres or more may be developed
keyed to Table X-X
Coastal Access Points are
Planning Area
City Limits
Specic Sites
Subareas
Opportunity
Park Improvement
Park Opportunity Site
Proposed Trailhead
Existing Trailhead
On-street trail
Proposed Trail
Existing Trail
View Corridor
(Blu
top/View)
Coastal Access Points 8
(Beach)
Coastal Access Points 7
Transportation Corridor
Urban Reserve
Sandy Beach
Conservation
Park
Utilities
Beach/Commuter Parking
Public and Semi-Public
Serving Commercial
Low Intensity VisitorVisitor-Serving Commercial
Service Commercial
Retail Commercial
(up to 50 units/acre)
Mixed Use Center
(16 -26 units/acre)*
Mixed Use Neighborhood
Coastal Residential Mixed Use
(16 -21 units/acre)*
High Density Residential
(10 -15 units/acre)
Medium Density Residential
(3 -9 units/acre)
Low Density Residential
(0.2 -2.0 units/acre)
Very Low Density Residential
(up to 0.2 units/acre)
Open Space/Agriculture/Residential
(up to 0.1 units/acre)
Transitional Open Space/Residential
0 1/4 1/2
MILES
1 Pacica, Southwest
Figure 4-8:

Figure 4-8: Pacifica, Southwest
From: Mike O'Connell [
Sent: Tuesday, August 3, 2021 8:57 PM
To: Murdock, Christian [[email protected]]
Subject: Re: Land Use Plan Updates
[CAUTION: External Email]
Chrisitan
Just wanted to follow up on this to see if these changes can be incorporated.

Thanks,
Mike O'Connell, PE
DRE #02114316
On Thu, Jun 24, 2021 at 7:38 PM Mike O'Connell < wrote:

Christian
Thanks for incorporating the updates for 535 and 195.

The other one I had noted was 900 Rosita Road, which I had changed the GP plan to low density residential in 2012 (Reso 870). It is noted as undeveloped on figure 4-1. Figure 4-8 shows it as public facilities. I think it has been mistakenly shown as part of Linda Mar School which is how it got the PF designation. There are 2 small lots behind 900 Rosita which are also shown as public facilities but have never been owned by the school district and so I believe those should also have a LDR designation (I do not own those lots).

Thanks,
Mike O'Connell, PE
DRE #02114316
On Thu, Jun 24, 2021 at 3:58 PM Murdock, Christian <[email protected]> wrote:

Hi Mike,
I look forward to receiving a list of suggested updates to the 2014 General Plan land use map. With respect to the Coastal Zone, I suggest basing your review off the Certification Draft LCLUP approved by City Council in 2020. We incorporated updates to the 535 San Pedro and 195 Carmel properties to reflect their existing mixed-use developments. We will be updating the next draft of the General Plan with the Certification Draft LCLUP land use maps for Coastal Zone areas.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
1800 Francisco Boulevard, Pacifica, CA 94044
Phone: (650) 738 – 7444 | [email protected]
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.

From: Mike O'Connell [
Sent: Thursday, June 24, 2021 7:38 PM
To: Murdock, Christian [[email protected]]
Subject: Re: Land Use Plan Updates
[CAUTION: External Email]
Christian
Thanks for incorporating the updates for 535 and 195.

The other one I had noted was 900 Rosita Road, which I had changed the GP plan to low density residential in 2012 (Reso 870). It is noted as undeveloped on figure 4-1. Figure 4-8 shows it as public facilities. I think it has been mistakenly shown as part of Linda Mar School which is how it got the PF designation. There are 2 small lots behind 900 Rosita which are also shown as public facilities but have never been owned by the school district and so I believe those should also have a LDR designation (I do not own those lots).

Thanks,
Mike O'Connell, PE
DRE #02114316
On Thu, Jun 24, 2021 at 3:58 PM Murdock, Christian <[email protected]> wrote:

Hi Mike,
I look forward to receiving a list of suggested updates to the 2014 General Plan land use map. With respect to the Coastal Zone, I suggest basing your review off the Certification Draft LCLUP approved by City Council in 2020. We incorporated updates to the 535 San Pedro and 195 Carmel properties to reflect their existing mixed-use developments. We will be updating the next draft of the General Plan with the Certification Draft LCLUP land use maps for Coastal Zone areas.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
1800 Francisco Boulevard, Pacifica, CA 94044
Phone: (650) 738 – 7444 | [email protected]
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.

From: Brian Gaffney [
Sent: Tuesday, March 8, 2022 3:39 PM
To: Public Comment [[email protected]]
Subject: Re: Pacifica 2022 GP Update and 2022 Draft EIR Attachments: Housing Element 2015-2023 - General Plan Update GPA-90-15 - FINAL ADOPTED VERSION.pdf; All Pages - October 11, 2021 - Certification Draft Response to CCC (Third City Submittal) - 20211011.pdf; Rhodes CCC report F16a-3-2021-report (1).pdf; F16a-3- 2021-exhibits.pdf
[CAUTION: External Email]
Mr. Murdock,
Please add the attached 4 documents to the City's administrative record for the 2022 GP Update and the 2022 Draft EIR.

Brian Gaffney
On Tue, Mar 8, 2022 at 2:51 PM Brian Gaffney < wrote:

Mr. Murdock,
This office represents the Pedro Point Community Association in regards to the 2022 GP Update and the 2022 Draft EIR. Please see the attached comments.

Thank you
Brian Gaffney
--

LAW OFFICES OF BRIAN GAFFNEY APC
446 Old County Road, Suite 100-310
Pacifica, CA 94044
office
This e-mail is covered by the Electronic Communications Privacy Act, is intended only for the use of the entity named above, and may contain information privileged, confidential and exempt from disclosure under law. If you are not the intended recipient, do not disseminate or copy.
--

LAW OFFICES OF BRIAN GAFFNEY APC
446 Old County Road, Suite 100-310
Pacifica, CA 94044
office
This e-mail is covered by the Electronic Communications Privacy Act, is intended only for the use of the entity named above, and may contain information privileged, confidential and exempt from disclosure under law. If you are not the intended recipient, do not disseminate or copy.

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.

CITY OF PACIFICA

HOUSING ELEMENT
2015-2023
Planning Period: January 31, 2015 - January 31, 2023
Adopted with City Council Resolution No. 13-2015 on May 11, 2015 Prepared by: Planning Department
i

TABLE OF CONTENTS
I. COMMUNITY PROFILE

1. The Housing Element…………………………………………………...……………. 1
A. Public Participation Process…………………………………………………... 3 B. Housing Accomplishments: 2007 to 2014…………………………………... 4

2. The City……………………………………………………………………………..… 4

3. Population Characteristics…………………………………………………………… 7
A. Population…………………………………………………………………..… 7
B. Ethnicity………………………………………………………………………… 10
C. Persons with Disabilities………………………………………………………. 11

4. Housing Characteristics………………………………………………………….…… 13
A. Households and Housing Units……………………………………………... 13
B. Income……………………………………………………………………… 15
C. Housing Costs………………………………………………………………… 17
D. Household Characteristics…………………………………………………… 19
II. HOUSING NEEDS ASSESSMENT…………………………………………………………... 20

1. Purpose………………………………………………………………………………… 20

2. Population Trends and Projections…………………………………………...……… 20

3. Employment Trends and Projections…………………………………………...…… 21

4. Household and Housing Characteristics…………………………………………..… 25 A. Income………………………………………………………………………... 25
B. Housing Costs………………………………………………………………… 25
C. Rehabilitation………………………………………………………………… 28

5. Regional Housing Needs……………………………………………………………… 29

6. Special Housing Needs……………………………………………………………….. 30
A. Large Families………………………………………………………………… 30
B. Single Parent Households…………………………………………………….. 31
C. Seniors………………………………………………………………………… 32
D. Extremely Low Income………………………………………………………. 35
E. Families and Persons in Need of Emergency Shelters……………………….. 35 F. Transitional and Supportive Housing………………………………………... 39 G. Persons with Disabilities………………………………………………………. 39
H. Farm Workers………………………………………………………………… 42

7. Constraints upon Housing Maintenance, Improvement, and Development………. 43 A. Governmental Constraints…………………………………………………… 43
B. Nongovernmental Constraints……………………………………………….. 57
C. Other Constraints…………………………………………………………...… 59
D. Mitigation of Constraints…………………………………………………….. 61

8. Affordable Units at Risk……………………………………………………………… 66

9. Opportunities for Energy Conservation……………………………………………… 69 ii
III. LAND INVENTORY……………………………………………………………………….… 71

1. Purpose………………………………………………………………………………… 71

2. Sites Available Within the Eight-Year Planning Period……………………………… 71 A. Environmental and Physical Constraints……………………………………. 80 B. Zoning Appropriate to Accommodate Lower Income Housing………………… 81 IV. GOALS, QUANTIFIED OBJECTIVES, AND POLICIES TO MAINTAIN, PRESERVE, IMPROVE AND DEVELOP HOUSING……………………………………………………………... 87

1. Purpose………………………………………………………………………………… 87

2. Overall Goals………………………………………………………………………….. 87

3. Quantified Objectives………………………………………………………………… 87

4. Ongoing Policies………………………………………………………………………. 88

5. Housing Maintenance………………………………………………………………… 96
A. Policies, Programs and Objectives to Maintain Housing……………………. 96

6. Housing Preservation…………………………………………………………………. 99
A. Policies, Programs and Objectives to Maintain Housing……………………. 100

7. Housing Improvement……………………………………………………………….. 106
A. Policies, Programs and Objectives to Maintain Housing……………………. 106

8. Housing Development………………………………………………………………… 111
A. Policies, Programs and Objectives to Maintain Housing……………………. 111

9. Discontinued Programs……………………………………………………………….. 122
V. COASTAL ZONE HOUSING………………………………………………………………… 128

1. Purpose………………………………………………………………………………… 128

2. Housing Unit Construction, Demolitions and Replacement………………………… 128 VI. PUBLIC PARTICIPATION………………………………………………………………….. 130 VII. CONSISTENCY WITH GENERAL PLAN…………………………………………………... 130 VIII. SUMMARY AND CONCLUSION…………………………………………………………… 131 IX. CONTACT INFORMATION………………………………………………………………… 132

ATTACHMENTS
A. Administrative Policy No. 2: 2014-2015 Master Schedule of Fees…………………. A-1 City of Pacifica Housing Element: 2015-2023
1 I. COMMUNITY PROFILE

1. The Housing Element
Pacifica's General Plan, comprised of 12 elements, guides all City activities. The Housing Element is an integral part of the General Plan, focusing on analysis of future housing needs and methods to provide adequate housing for Pacificans from all walks of life. It contains goals and policies for housing and action programs which detail the steps the City can take to respond to the community’s evolving housing needs. One of the most important aspects of the Housing Element is its identification of sites for housing development that are sufficient to accommodate the City’s share of the regional housing need for the planning period (in this case, 2015-20231 ).

The Association of Bay Area Governments (ABAG) develops a regional housing needs allocation (RHNA) for all counties in the Bay Area2
. Based upon that allocation, the City/County Association of Governments of San Mateo (C/CAG) assigns specific allocations to incorporated and unincorporated areas within the County. The Bay Area overall received a housing unit allocation of 187,990 units for the period between 2014-2022. ABAG apportioned to San Mateo County 16,418 of those units. Pacifica’s share of the County total was 413 units, constituting 2.5 percent of the County’s allocation and .22 percent of the Bay Area’s allocation. Pacifica will play a small, yet critically important part in meeting regional housing needs.

Out of the total of 413 units allocated to Pacifica as part of the RHNA process for 2014 to 2022, the City has already approved eight units through April 30, 2015. The City can accommodate the balance of its RHNA through the identification of sites properly zoned for residential development that can occur during the planning period. The RHNA segments housing need by income level in the categories very low, low, moderate, and above moderate. The result is that the City must plan for a variety of housing types affordable to persons with varying incomes.

Past housing elements have helped the City of Pacifica work towards meeting its housing needs. The following is a summary of housing elements adopted along with and subsequent to Pacifica’s 1980 General Plan:
1980 Housing Element
- Identified the number of housing units needed over the 20-year period between 1980-2000. The Element called for an average of 79 affordable units per year between 1980-2000. From 1980- 1985, the projected need was 89 units per year; between 1985-2000, the figure was revised to 73-77 units per year;
- Identified seven vacant sites having the potential for meeting the housing needs indicated for low- and moderate-income groups over the 20-year period; - Summarized each housing program available;

1 ABAG’s coordinated Housing Element Planning Period is January 31, 2015 through January 31, 2023. 2 ABAG’s 5th RHNA Projection Period runs from January 1, 2014 through October 31, 2022 (8.8 years).

City of Pacifica Housing Element: 2015-2023
2 - Identified short- and long-term housing goals and programs; and - Discussed administration of housing programs.
1983 Housing Element Supplement
- Updated information in the 1980 Element. By 1983, the housing situation in the city had changed, due to infrastructure and land constraints, as well as approval of the Growth Control Ordinance in 1982;
- Estimated the amount of vacant land available for housing development; - Identified Pacifica's fair share housing need, based on Association of Bay Area Governments (ABAG) figures. The 1983 ABAG Housing Needs Determinations called for 81 units per year to meet growth needs. The number of low- and moderate-income units had been reduced to 45 units per year from the 73-77 units per year called for in the 1980 General Plan; and, - Identified current housing programs available.
1986 Housing Element
- Analyzed 1980 Census data, and included a more complete, city-wide vacant land survey; - Included 1983 ABAG Regional Fair Share Housing needs; and, - Described the most current housing programs available to maintain, improve, and develop housing.
1990 Housing Element
- Analyzed 1990 Census data; and,
- Added new Action Programs.
2007 Housing Element
- Analyzed 2000 Census data; and,
- Addressed SB 2 requirements related to site identification and zoning for emergency shelters as well as transitional and supportive housing.

The 2014 Housing Element seeks to continue the periodic refinement of the document to address projected housing needs. Notable changes include updated demographics based on the 2010 Census; realignment of the planning period to eight years (SB 375); identification of “beneficial impacts” from City of Pacifica Housing Element: 2015-2023
3 action programs (SB 375); assessment of needs of those with developmental disabilities (SB 812); and, adaptation of housing-related activities to the 2012 dissolution of the City’s Redevelopment Agency (ABx1 26 and AB 1484).

A. Public Participation Process
The City of Pacifica developed the 2015-2023 Housing Element with participation from members of the Pacifica community, as well as housing advocates and other interested parties. As part of the process to seek public input, staff sent notices to 50 nonprofit housing organizations and service providers servicing special needs populations, including Bay Area Legal Aid, Center for the Independence of the Disabled, Center on Homelessness, Community Legal Services, Golden Gate Regional Center, HIP Housing, InnVision/Shelter Network, Mental Health Association of San Mateo County, and the San Mateo County Commissions on Aging/Disabilities.

The City convened a study session with the Planning Commission to solicit input from the public on the City’s housings needs, and to provide the public with an opportunity to shape the City’s housing goals, policies, and objectives. The study session was publicized in the local print media, the “Coastal Connection” community event list, the City’s web site, and Nextdoor, Twitter, and Facebook social media platforms. In conducting outreach for the study session, care was taken to recruit potential participants that reflect the City’s full ethnic and economic diversity.

A study session is a public meeting for which the City provides public notice, but at which no action is taken by the Planning Commission. The informal format of a study session encourages planning commissioners, project proponents, and community members to engage in a vigorous dialogue with question-and-answer exchanges among all participants. A dozen community members attended the housing element study session, with nearly all attendees expressing ideas and communicating with the Commission and fellow community members. The public input focused on the need for more affordable housing in Pacifica; integrating affordable housing with improved access to public transportation; focusing future housing development into mixed use sites rather than the few remaining vacant parcels in the city; and, concerns with specific sites identified in the draft housing element’s “Potential Housing Development Sites” (Table III-1 in Section III.2).

In response to the public input received, staff revised the draft housing element to address community concerns where possible. Staff revised Table III-1 containing “Potential Housing Development Sites” to represent the community’s desire for higher density, mixed use housing near transit access. The result was the identification of numerous sites clustered primarily around the Pacific Manor Shopping Center in the northern portion of Pacifica. Existing transit routes within this neighborhood provide bus service to the area, including connections to the Bay Area Rapid Transit (BART) system in Colma and Daly City. Furthermore, the underlying commercial land use designation in the neighborhood allows high-density mixed use housing development. An additional result of incorporating the newly-identified sites was the ability to remove from Table III-1 the two sites discussed the most at the Study Session - the “Calson Property” and “Hacienda Court.” The public participation process continued after the study session phase with a public hearing before the Planning Commission on April 20, 2015. At the meeting, 13 members of the public provided comments on various aspects of the draft Housing Element, draft Negative Declaration, and other City of Pacifica Housing Element: 2015-2023
4 matters. A result of the public input was another revision of the housing site land inventories contained in Tables III-1 and Tables III-2 to remove all sites that were also listed within the City’s Open Space Task Force Report. Public input also resulted in continuation as ongoing policies two action programs that staff had proposed for discontinuance.

The final opportunity for public participation was during a public hearing before the City Council on May 11, 2015. Thirty-six members of the public spoke during the public hearing and several individuals submitted written comments prior to the meeting. In response to public comments, the City Council revised the draft Housing Element to add a note to Table IV-1 stating that the 93 units at Pacific Skies Estates mobile home park are subject to Article 2 of Chapter 1 of Title 9 of the Pacifica Municipal Code, also known as the Rent Stabilization Regulations, and to add a note in appropriate locations within the Housing Element Update that the operator of Pacific Skies Estates mobile home park will continue to replace older mobile homes.

The City provided public notice of all hearings and further encouraged community members and advocates to attend. After these public discussions and additional revisions based on the public input received, the City Council adopted the housing element with Resolution No. 13-2015 on May 11, 2015.

B. Housing Accomplishments: 2007 to 2014
Pacifica’s housing allocation for the 2007-2014 period was 275 units, of which 63 were needed for Very Low Income households, 45 for Low Income households, 53 for Moderate Income households, and 114 for Above Moderate Income households. Pacifica met 95 percent of its overall housing need during the period, approving, building, or constructing 262 housing units. Accomplishment by income category, however, reflects differing levels of success. The City met all of the need for Above Moderate Income units; 91 percent of the Moderate Income need; but less than 4 percent of combined Low and Very Low Income need.

Development of affordable housing was highly challenging during the 2007 to 2014 planning period.

Among other factors, the economic recession during the planning period slowed all types of development. This in turn limited opportunities to apply inclusionary zoning and housing in-lieu policies to larger developments in order to create new affordable units. The dissolution of redevelopment agencies during the planning period also presented new challenges to the financing of affordable housing projects in the City.

2. The City
Pacifica is located on the Pacific coast side of the San Francisco Peninsula, 13 miles south of downtown San Francisco, in San Mateo County. Two prominent features frame the city, with the ridges of the Coast Range to the east and the shoreline of the Pacific Ocean to the west. Pacifica possesses an attractive combination of secluded valleys and open hillsides set against a coastline of long beaches and rugged headlands.

City of Pacifica Housing Element: 2015-2023
5 Regional access is via State Highways 1 and 35 that, in turn, connect to Interstate Highway 280 and 80, and US-101. Through the northern half of the City, Highway 1 is a four-lane freeway. South of Sharp Park Road, the highway becomes a four-lane arterial with uncontrolled access, climbing south of the City and through the Lantos Tunnels (bypassing the infamous Devil's Slide) to the unincorporated villages of Montara and Moss Beach.

Originally visited by the Portola expedition in 1769, the area around what is now Pacifica remained primarily agricultural until after the San Francisco earthquake in 1906. Land speculators, stimulated by the construction of the Ocean Shore Railroad, subdivided and developed a series of small coast-side communities. Several of these communities incorporated in 1957 as the City of Pacifica. Despite incorporating nearly 60 years ago, neighborhood integrity retains special significance in the city.

Although recognizing their interdependence, each of the original communities desires to protect those characteristics which make them unique. The Neighborhood Map (Figure I-1) shows the various neighborhoods in the City.
(Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
6 FIGURE I-1

NEIGHBORHOOD MAP
City of Pacifica Housing Element: 2015-2023
7 3. Population Characteristics
A. Population
Rapid residential development occurred in Pacifica during the 1960s, with the 1960 population of 20,995 residents nearly doubling to 36,020 residents by 1970. From the 1970s onward, residential development tapered off and population increase became more moderate. Despite slowing residential development, Pacifica’s population peaked more three decades later in 2000 at 38,390 residents. Pacifica’s population, average household size, and median age from the last six decennial censuses are shown in Table I-1, below:

TABLE I-1
Population, Average Household Size, and Median Age – 1960 through 2010 1960 1970 1980 1990 2000 2010
Population 20,995 36,020 36,866 37,670 38,390 37,234
Household
Size (avg.)
* * 2.88 2.82 2.73 2.65
Median Age 22.5 23.6 29.2 33.5 37.6 41.5
Source: US Census Bureau.
*The U.S. Census from 1960 and 1970 calculated household size using a different methodology, making it incomparable to figures from 1980 onward.

Changes in average household size and the age of Pacifica’s residents in recent decades have contributed to a shift in housing needs. The table above demonstrates how average household size has steadily decreased since 1980, while median age has increased dramatically during the same period.

The characteristics of Pacifica’s housing stock have also changed in recent decades. In 1970, 87 percent of the City's housing stock was single-family residential; by 2010, this had declined to 77 percent. The majority of apartments and other multi-family housing units have been constructed in the West Sharp Park, West Edgemar, and Fairmont neighborhoods, although several senior housing developments have been constructed in other parts of the City. Despite multi-family development increasing in popularity after 1970, by 2000 all kinds of residential development had leveled-off. Table I-2 summarizes the rates of residential development in Pacifica since 1960. Between 1990 and 2010, 1,265 housing units were developed in Pacifica (with only 391 from 2000-2010). Compared to 1,146 units from 1980-1989 and more than 3,000 units in each of the three preceding decades, it is apparent that housing production has slowed tremendously in recent years. While it is difficult to pinpoint the cause of the dramatic reduction in housing unit production, the increasing scarcity of vacant, buildable sites in Pacifica is believed to be a significant factor.

City of Pacifica Housing Element: 2015-2023
8 TABLE I-2
Residential Units Constructed in Pacifica – 1960 through 2010 1960-
1970
1970-
1980
1980-
1990
1990-
2000
2000-
2010
Units Constructed >3,000 >3,000 1,146 874 391
Source: US Census Bureau.

To gain a better perspective of Pacifica’s population, it is helpful to compare its various aspects to those of the broader populations in San Mateo County and statewide. The next several tables and figures make comparisons across several dimensions.

In 2011, 37,361 people lived in Pacifica, down more than 1,000 residents from a decade earlier.

Pacifica's population was comprised of slightly fewer children and many more seniors than San Mateo County. Table I-3 summarizes population by age group.

TABLE I-3
Population by Age Group – 2000 vs. 2011
2000 2011
Pacifica Pacifica County State
Under 5 years 6% 5% 6% 7%
5 to 19 years 20% 17% 18% 21%
20 to 34 years 20% 18% 19% 22%
35 to 44 years 18% 15% 15% 14%
45 to 59 years 23% 26% 22% 20%
60 to 74 years 10% 15% 13% 11%
75 years and over 4% 5% 6% 5%
Median age 38 42 39 35
Total population 38,390 37,361 720,143 37,330,448
Source: 2000 US Census SF1, 2009-2011 American Community Survey (Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
9 FIGURE I-2
Population by Age Group – 2011
Pacifica's population decreased by 3.0 percent between 2000 and 2010, while San Mateo County’s population increased 1.6 percent over the same period. Pacifica’s population increased a modest 1.9 percent between 1990 and 2000. Within the last 30 years, the most rapid population increase occurred between 1980 and 1990 (2.2 percent). Table I-4 shows rate of population change in Pacifica for the period 1980-2010. Pacifica’s population growth rate has lagged behind that of San Mateo County since 1980, as shown in Figure I-3.

TABLE I-4
Pacifica Population Rate of Change,
1980-20103
Population % Change
1980-1990 37,670 2.2
1990-2000 38,390 1.9
2000-2010 37,234 -3.0
Base Year 1980 population was 36,866
Source: US Census Bureau

3 Decennial U.S. Census counts for 1980, 1990, 2000, and 2010. 0%
5%
10%
15%
20%
25%
30%
Under 5
years
5 to 19
years
20 to 34
years
35 to 44
years
45 to 59
years
60 to 74
years
75 years
and over
Pacifica
San Mateo County
City of Pacifica Housing Element: 2015-2023
10 FIGURE I-3
B. Ethnicity
Pacifica’s largest racial group was white persons, who comprised 68 percent of the population in 2011.

The largest minority group was Asian persons, at 19 percent of the population. Filipino and Chinese persons comprised two-thirds of the city’s Asian population. Black persons accounted for the smallest share of population of any single-race group at 3 percent. Persons of Hispanic or Latino ethnicity, while not counted by the U.S. Census as a separate racial group, comprised 18 percent of the population (most of these persons were counted within the “white” racial group). Non-Hispanic whites comprised 55 percent of the population. Table I-5 provides additional information on Pacifica’s racial composition.

TABLE I-5
Race and Ethnicity
Pacifica County State
White 68% 59% 62%
Black 3% 3% 6%
Asian 19% 25% 13%
Other 4% 8% 14%
More than one Race 6% 5% 4%
Hispanic 18% 25% 38%
Not Hispanic 82% 75% 62%
Total population 37,361 720,143 37,330,448
Source: 2009-2011 American Community Survey
-4.00
-2.00

0.00 2.00

4.00 6.00

8.00 10.00

12.00 1980-1990 1990-2000 2000-2010
Rate of Population Change (%) - 1980 to 2010
Pacifica
San Mateo County
City of Pacifica Housing Element: 2015-2023
11 FIGURE I-4
Race and Ethnicity
C. Persons with Disabilities
In 2011, 8 percent of Pacificans had one or more diagnosed disabilities, the same rate as San Mateo County (8 percent). Disabilities include physical and mental disabilities such as deafness, blindness, immobility, and cognitive challenges, as well as other conditions. As used throughout the housing element, the term “disability” includes, without limitation, developmental disability. Disabilities can affect the ability of affected persons to work, live independently, drive, and ride public transportation.

Limitations of this sort can affect the type of housing needed by persons with disabilities. Perhaps most impactful to housing needs is the ability of persons with disabilities to live independently and to travel outside the home to work and shop.

The prevalence of disabilities in Pacifica varied widely by age group. The population segment with the greatest rate of disabilities was persons age 65 years or older, at 28 percent. Among the working age population 18 to 64 years of age, the disability rate was 5.8 percent. San Mateo County’s respective rates were 31 percent and 5.0 percent. Information on persons with ambulatory (i.e. mobility), self-care, independent living, and other disabilities is summarized in Table I-6:
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
White Black Asian Other More than
one Race
Hispanic Not
Hispanic
Pacifica
San Mateo County
City of Pacifica Housing Element: 2015-2023
12 TABLE I-6
Age and Type of Disability of Residents
Number Percent
Pacifica County State Pacifica County State
Under 18 with Disability 173 3,270 280,649 2.3% 2.1% 3.0% Age 18-64 with Disability 1,481 23,231 1,843,497 5.8% 5.0% 7.9% Age 65 + with Disability 1,195 28,703 1,547,712 28% 31% 37% Any Age with Any Disability 2,849 55,204 3,671,858 8% 8% 10% Any Age With Hearing Disability 812 15,651 1,022,928 2.2% 2.2% 2.8% With Vision Disability 299 8,199 685,600 0.8% 1.1% 1.9% With Cognitive Disability 717 19,549 1,400,745 1.9% 2.7% 3.8% With Ambulatory Disability 1,474 29,757 1,960,853 4.0% 4.2% 5.3% With Self Care Disability 663 12,819 862,575 1.8% 1.8% 2.3% With Independent Living Disability 980 22,735 1,438,328 2.6% 3.2% 3.9% Source: 2009-2011 American Community Survey
Note: Some people may have multiple disabilities
A segment of the disabled population with particularly challenging housing needs is those with developmental disabilities. The California Welfare and Institutions Code describes a developmental disability to be one that originates prior to adulthood, that continues or can be expected to continue indefinitely, and that constitutes a substantial disability for that individual. Specific conditions include intellectual disability, cerebral palsy, epilepsy, and autism, but not disabilities that are solely physical in nature. Many developmentally disabled persons can live and work independently within a conventional housing environment; however, more severely disabled individuals require a supervised group living environment, often with medical care and physical therapy provided on-site. Given the pre-adulthood onset of developmental disabilities, a primary concern is transitioning a developmentally disabled person to an appropriate level of independence as an adult.

The U.S. Census does not track developmental disabilities specifically, meaning the City must estimate the population with a developmental disability in another way. The State Department of Developmental Services (DDS) is the lead agency in providing community-based services to approximately 243,000 developmentally disabled persons statewide through a system of 21 regional centers. The Golden Gate Regional Center provides services within San Mateo, San Francisco, and Marin counties. The information from the Golden Gate Regional Center in Table I-7 shows the number of Pacificans (ZIP Code 94044) who received services for a developmental disability in 2014:

TABLE I-7
Developmentally Disabled Residents, by Age, City of Pacifica (2014) 0-18 Years 19-34 Years 35-54 Years 55-64 Years 65+ Years Total 54 40 33 9 2 138
Source: Golden Gate Regional Center Service Data for January 2014 San Mateo County is fortunate to have access to a variety of resources to assist persons with developmental disabilities in addition to the Golden Gate Regional Center. Many of the organizations work in close partnership with the Regional Center on a referral basis to ensure continuity of care for developmentally disabled persons. Services of these groups include focusing on job skills to enhance City of Pacifica Housing Element: 2015-2023
13 economic stability, and thereby housing stability, as well as direct housing support through counseling, advocacy, search assistance, and direct placement into units. The organizations available to Pacifica residents include the following:
- Abilities United: Provides training, education, and support for persons with developmental and physical challenges.
- The Arc: Provides a range of services relevant to all areas of adult life, from independent living supports and skills building to employment training and creative expression. - Poplar ReCare: Provides therapeutic treatment, equipment loan, and other services for those with developmental disabilities, illness, or injury.
- Puente Clinic: Provides mental health services for developmentally disabled clients by bridging resources from San Mateo County Behavioral Health & Recovery Services (BHRS), Golden Gate Regional Center (GGRC) and Health Plan of San Mateo (HPSM). - West Bay Housing Corporation: Provides affordable, community-based supportive housing for individuals with developmental disabilities and other people with special housing needs.

4. Housing Characteristics
A. Households and Housing Units
In 2010, there were 13,967 households4 and 14,523 housing units5 in Pacifica. Compared to 2000, these figures decreased .2 percent and increased 2 percent, respectively. The annualized production of housing units from 2000 to 2010 was 27 units per year. In effect, Pacifica’s household creation and housing unit production have remained relatively static. Average household size reduced to 2.65 persons per household in 2010 from 2.73 in 2000, a decrease of 3 percent. This continues a trend of shrinking household size that started at least as early as 1980. Basic information on households, housing units, and average household size for Pacifica for 1990, 2000, and 2010 are summarized in Table I-8.

4 The U.S. Census Bureau defines “household” as “all the persons who occupy a housing unit as their usual place of residence.”
5 The U.S. Census Bureau defines “housing unit” as “a house, an apartment, a mobile home, a group of rooms, or a single room that is occupied (or if vacant, is intended for occupancy) as separate living quarters.” Separate living quarters are those in which the occupants live and eat separately from any other persons in the building and which have direct access from outside the building or through a common hall. The occupants may be a single family, one person living alone, two or more families living together, or any other group of related or unrelated persons who share living arrangements. People not living in households are classified as living in group quarters.

City of Pacifica Housing Element: 2015-2023
14 TABLE I-8
Households and Housing Units, City of Pacifica, 1990 through 2010
1990 2000 2010
Households 13,318 13,994 13,967
Housing Units 13,853 14,245 14,523
Household Size (avg.) 2.82 2.73 2.65
Source: US Census Bureau
Single-family detached housing dominates Pacifica’s housing stock. This housing type comprised 73 percent of housing units in 2011, with another 6.8 percent of units in the single-family attached category. Combined, approximately 80 percent of the housing stock is single-family. The share of the housing stock comprised by single-family-type units has increased since 2000, when attached and detached types were 72 percent and 5.4 percent of the housing stock, respectively. Compared to San Mateo County, Pacifica has a much greater share of detached single-family housing units. The County edges out Pacifica in all other housing categories, except that they both have similar shares of the mobile home housing type. Table I-9 summarizes Pacifica’s housing types.

TABLE I-9
Building Type of Housing Stock
Pacifica County State
Single Family Detached 73% 57% 58%
Single Family Attached 7% 9% 7%
2 units 1% 2% 3%
3 or 4 units 4% 5% 6%
5 to 9 units 4% 6% 6%
10 to 19 units 4% 6% 5%
20 or more units 7% 14% 11%
Mobile Home or Other 1% 1% 4%
Total 14,577 271,140 13,688,351
Source: 2009-2011 American Community Survey
Pacifica’s predominately single-family housing stock has contributed to high rates of home ownership. Owner-occupied housing units accounted for 69 percent of the housing stock in 2011, a rate that held steady since 2000 and which is 10 percent greater than in San Mateo County. Vacancy rates in Pacifica in 2011 were very low, with the homeowner vacancy rate at 1.5 percent and the rental vacancy rate at 2.4 percent6
. Vacancy rates in each category increased since 2000.

6 The U.S. Census Bureau considers a housing unit as vacant if no one is living in it at the time of the Census interview, unless its occupants are only temporarily absent. In addition, a vacant unit may be one which is entirely occupied by persons who have a usual residence elsewhere. New units not yet occupied are classified as vacant housing units if construction has reached a point where all exterior windows and doors are installed and final usable floors are in place.

Vacant sleeping rooms in lodging houses, transient accommodations, barracks, and other quarters not defined as housing City of Pacifica Housing Element: 2015-2023
15 Homeowner vacancy was comparable to San Mateo County, although rental vacancy was almosthalf of the County’s rate. It is generally accepted that an overall vacancy rate of 4 percent is needed to provide for normal turnover in housing units, which means Pacifica was experiencing an insufficient supply of housing. Table I-10 summarizes vacancy rates for Pacifica, San Mateo County, and the State of California.

TABLE I-10
Vacancy Rates of Owner and Rental Housing Units
Pacifica County State
2000 Owner 0.2% 0.5% 1.4%
Renter 1.9% 1.8% 3.7%
2011 Owner 1.5% 1.2% 2.2%
Renter 2.4% 4.0% 5.5%
Source: 2009-2011 American Community Survey, 2000 US Census B. Income

Pacifica’s residents enjoy greater household incomes than those in San Mateo County as a whole.

Median household income in Pacifica in 2011 was 4.7 percent higher than in the County as a whole.

Nearly half of all households earned $100,000 or more per year, and there were also fewer Pacifica households at the lowest income levels than in the County. Household income characteristics, summarized in Table I-11, contribute to the particular housing needs of the City’s population.

TABLE I-11
Household Income of Residents
Pacifica County State
Under $25,000 8% 12% 21%
$25,000 to $34,999 7% 6% 9%
$35,000 to $49,999 6% 10% 13%
$50,000 to $74,999 18% 16% 17%
$75,000 to $99,999 15% 12% 12%
$100,000+ 45% 44% 28%
Poverty Rate 4.0% 7.4% 16%
Total 14,061 256,305 12,433,049
Median Income 2000 $96,845 $95,606 $64,116
Median Income 2011 $96,289 $91,958 $63,816
Source: Association of Bay Area Governments
Note: Adjusted for inflation to 2013 dollars
Household income is only one part of determining housing needs, however. Family size also contributes to the amount of income needed to secure suitable housing and to provide for other needs.

Table I-12 depicts California Department of Housing and Community Development (HCD) 2014

units are not included in the statistics in this report.

City of Pacifica Housing Element: 2015-2023
16 income thresholds for San Mateo County based on family size, which are integral to obtaining adequate and affordable housing.

TABLE I-12
HCD Income Limits for 2014
Extremely
Low
Very
Low Low Median Moderate
Family
Size
30% of
Median
Income
50% of
Median
Income
80% of
Median
Income
100% of
Median
120% of
Median
1 $23,750 $39,600 $63,350 $72,100 $86,500
2 $27,150 $45,250 $72,400 $82,400 $98,900
3 $30,550 $50,900 $81,450 $92,700 $111,250
4 $33,950 $56,550 $90,500 $103,000 $123,600
5 $36,650 $61,050 $97,700 $111,250 $133,500
6 $39,400 $65,600 $104,950 $119,500 $143,400
7 $42,100 $70,100 $112,200 $127,700 $153,250
8 $44,800 $74,650 $119,450 $135,950 $163,150
Source: California Department of Housing and Community Development, February 28, 2014 — http://www.hcd.ca.gov/hpd/hrc/rep/state/inc2k14.pdf The poverty threshold income as defined by the U.S. Census Bureau is another measure commonly used to assess income levels of a given population. The Census Bureau establishes poverty-level income based on family size, and for 2011 the level ranged from $10,788 for an individual over 65 years of age with no dependent children to $43,487 for a family with eight or more children. Poverty threshold amounts are set nationally, and the Census Bureau does not adjust them for variations in cost of living throughout the country. The overall poverty rate for families in Pacifica in 2011 was 1.9 percent, less than half the rate for San Mateo County. The lowest observed rate among various family groups was for married couples at 0.2 percent. The highest rate was for families headed by a female with no husband present, at 7.7 percent. Across all family categories, the presence of children under 18 years of age dramatically increased family poverty rates.

The Census Bureau also calculates poverty rates for individuals by age. The overall individual poverty rate in Pacifica was 4 percent. The highest observed poverty rate was for working age individuals from 18 to 64 years old at 4.7 percent. The poverty rate for persons 65 years of age and older was 2.7 percent. All poverty rates for Pacifica were noticeably lower than corresponding rates for San Mateo County, as shown in Table I-13.

City of Pacifica Housing Element: 2015-2023
17 TABLE I-13
Poverty Rates of Families and Individuals
Pacifica County State
Families (All) 1.9% 4.8% 12%
Married Couples 0.2% 2.8% 7.0%
Female Householder
(no husband present)

7.7% 13% 26%
Individuals (All) 4.0% 7.4% 16%
Under 18 years 2.8% 9.1% 22%
18 to 64 years 4.7% 7.0% 14%
65 years and over 2.7% 6.2% 9.5%
Source: 2009-2011 American Community Survey
In January 2014, San Mateo County Housing Authority indicated that 4,416 households countywide received housing assistance either through vouchers or by direct placement into public housing units.

Within Pacifica, 208 residents received housing assistance, all of them through vouchers.

C. Housing Costs
Housing costs in Pacifica, as in much of the Bay Area, tend to be higher than California as a whole.

Pacifica is a costly place to live for homeowners and renters alike. Given the predominance of singlefamily housing among Pacifica’s housing stock and the high rates of homeownership, the prices of single-family homes have a significant effect on housing affordability. Table I-14 lists median home sale prices for detached and attached single-family units from 2005 through 2012.

TABLE I-14
Median Single-Family Home Sale Prices
Detached Units Attached Units
Pacifica County State Pacifica County State
2005 $916,387 $939,148 $576,436 $662,830 $586,432 $
$874,054 $961,170 $636,410 $592,250 $625,140 $
$841,860 $935,536 $594,272 $589,120 $600,432 $
$698,772 $865,512 $485,784 $494,640 $554,364 $
$614,535 $749,304 $365,580 $395,820 $465,696 $
$622,260 $762,910 $359,948 $385,200 $449,507 $
$527,638 $691,439 $330,527 $298,700 $390,576 $
$535,846 $660,944 $305,727 $314,363 $360,065 $271,185
Source: San Mateo County Association of Realtors, based on actual sales of each year; State based on Zillow/MLS
Note: Adjusted for inflation to 2013 dollars
The table shows that detached single-family housing in Pacifica tends to be 40 to 70 percent more expensive than elsewhere in the State but 10 to 20 percent less expensive than San Mateo County.

City of Pacifica Housing Element: 2015-2023
18 Attached single-family housing in Pacifica tends to be 15 to 20 percent more expensive than elsewhere in the State but 10 to 15 percent less expensive than elsewhere in the County.

The cost of rental housing is also an important factor in housing affordability in Pacifica. Lower “costs of entry” to rental housing as compared to ownership units makes it a vital source of housing for those with lower incomes, which can include single heads of household with children, young professionals, or senior citizens. Table I-15 shows average rents for a variety of unit types in Pacifica from 2005 through 2013, and Table I-16 compares average rents in Pacifica to those in San Mateo County.

TABLE I-15
Average Rents in Pacifica
Studio 1 Bed, 1 Bath 2 Bed, 1 Bath
Price
Percent
Increase Price
Percent
Increase Price
Percent
Increase
2005 $1,420 x $1,512 x $1,755 x
2006 $1,615 14% $1,577 4% $1,799 2%
2007 $1,560 -3% $1,617 3% $1,844 2%
2008 $1,619 4% $1,666 3% $1,893 3%
2009 $1,518 -6% $1,604 -4% $1,786 -6%
2010 $1,404 -8% $1,548 -3% $1,722 -4%
2011 $1,533 9% $1,594 3% $1,762 2%
2012 $1,541 1% $1,743 9% $2,047 16%
2013 $1,535 0% $1,778 2% $1,979 -3%
Source: RealFacts Annual Trends Report, based on reporting from large apartment complexes
Note: Adjusted for inflation to 2013 dollars
TABLE I-16
Summary of 2013 Rents
Pacifica County
Studio $1,535 $1,463
One Bedroom $1,778 $2,004
Two Bedroom $1,979 $2,285
Source: RealFacts Annual Trends Report, based on
reporting from large apartment complexes, Craigslist
Survey conducted in June and July 2013
The tables show that, with the exception of studio rental units, rental housing in Pacifica was less expensive than in San Mateo County. Rents for one- and two-bedroom units in Pacifica in 2013 were approximately 10% less expensive than those elsewhere in the County. However, with both ownership and rental units, affordability depends on income, and it is important to assess household housing costs from that perspective. Housing cost burden, or overpayment, will be discussed later in this document.

City of Pacifica Housing Element: 2015-2023
19 D. Household Characteristics
The make-up and size of households can have an important influence on the type of housing units needed and desired within a community. In 2011, Pacifica’s most common household type was the family with no children, which comprised 41 percent of households. The least common household type was multi-person, nonfamily, at 7 percent. Table I-17 summarizes Pacifica’s household types in relation to San Mateo County and State households.

TABLE I-17
Household Type
Pacifica County State
Single person 24% 25% 24%
Family (no children) 41% 37% 35%
Family (with children) 28% 31% 33%
Multi-person, nonfamily 7% 7% 7%
Total households 14,061 256,305 12,433,049
Source: 2009-2011 American Community Survey
The composition of Pacifica’s households has changed in recent years. In 2000, single-person households made up 16 percent of the City's households. Only 31 percent of households were families without children, and 32 percent of households had children. (Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
20 II. HOUSING NEEDS ASSESSMENT

1. Purpose
The housing needs assessment summarizes the specific types of housing needed by various populations within Pacifica. Data and housing issues are discussed and analyzed, and housing needs are quantified wherever possible. The Community Profile (Section I) provides background information for these housing needs.

State housing law, in Government Code Sections 65583(a)(1)-(9), requires that a housing element shall consist of “an identification and analysis of existing and projected housing needs," which includes:
 Analysis of population and employment trends and documentation of projections;  Analysis and documentation of household and housing characteristics;  Analysis of any special housing needs, such as those of the elderly, persons with disabilities, large families, farmworkers, families with female heads of household, and families and persons in need of emergency shelter;
 Identification of at least one zone where emergency shelters are allowed as a permitted use;  Analysis of potential and actual governmental and nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels and for persons with disabilities;
 Analysis of existing assisted housing developments that are eligible to change from lowincome housing uses during the next 10 years due to certain conditions.  Analysis of opportunities for energy conservation with respect to residential development; and,  Inventory of land suitable for residential development and an analysis of the relationship of zoning and public facilities and services to these sites; The following analysis satisfies the requirements outlined above.

2. Population Trends and Projections
The Association of Bay Area Governments (ABAG) has estimated Pacifica's future population growth in its publication "Projections 2009." ABAG expects the City's population to increase 6 percent from 2010 to 2020 and 1 percent from 2020 to 2030. Both growth rates are significantly lower than those projected for San Mateo County. Table II-1 demonstrates population growth from 1990 through 2030 (projected), and compares Pacifica to San Mateo County and the State of California.

City of Pacifica Housing Element: 2015-2023
21 TABLE II-1
Population Growth
Number Percent Change
Pacifica County State Pacifica County State
1990 37,670 649,623 29,760,021 x x x
2000 38,390 707,163 33,871,648 2% 9% 14%
2010 37,234 718,451 37,253,956 -3% 2% 10%
2020
(Projected) 39,300 801,300 x 6% 12% x
2030
(Projected) 39,600 862,800 x 1% 8% x
Source: Association of Bay Area Governments (ABAG), Projections 2009; US Census SF1 1990-2010 Note: ABAG does not prepare statewide projections
ABAG similarly projected household growth for Pacifica through 2030. Expected household growth in Pacifica will trail growth in San Mateo County by an even greater percentage than in population growth. Table II-2 shows these projected figures.

TABLE II-2
Household Growth
Number Percent Change
Pacifica County State Pacifica County State
1990 9,765 242,348 10,381,206 x x x
2000 13,994 254,104 11,502,870 30% 5% 10%
2010 14,320 264,400 12,577,498 2% 4% 9%
2020
(Projected) 14,410 287,350 x 1% 8% x
2030
(Projected) 14,550 310,970 x 1% 8% x
Source: Association of Bay Area Governments, Projections 2009; US Census SF1 1990-2010 Note: ABAG does not prepare statewide projections
Pacifica's projected low growth rate may be attributable to certain governmental and nongovernmental constraints, as this document will discuss later in this section.

3. Employment Trends and Projections
Pacifica is primarily a residential community, and contained nearly three-times more employed residents than jobs in 2010. Despite the existing imbalance, employment growth increased at a faster rate than population growth between 2000 and 2010. Job growth increased 14 percent with the addition of 780 jobs, while population growth was -3 percent with a loss of 1,156 residents over the same period.

Relative to San Mateo County, Pacifica’s job growth was positive compared to a 10 percent contraction countywide.

City of Pacifica Housing Element: 2015-2023
22 In 2011, there were 30,807 persons of working age (16 years and over) in Pacifica, 21,582 of which were in the labor force (70 percent). Of those in the labor force, the unemployment rate was 6.7 percent.7 Pacifica’s unemployment rate was slightly higher than San Mateo County’s (6.0 percent) but lower than California’s (7.7 percent). Table II-3 displays historical and 2025 projected figures for jobs and employment in Pacifica.8 The 2025 projection of a reduction in employed residents may be attributable to the aging of Pacifica’s population as many residents will leave the workforce during that timeframe. Still, it appears Pacifica will benefit from strong job growth through 2025, providing greater employment opportunities for residents.

TABLE II-3
Projections for Population, Households and Total Jobs (2000-2025) Geographical Area 2000 2010 2020 2025
2000-2025
Change
2000-2025
Percent
Change
Pacifica Planning Area (City Limits and Sphere of Influence) Jobs/Employed Residents 0.26 0.33 0.36 0.38 x x
Employed Residents 21,836 19,050 19,250 19,420 -2,416 -12% Jobs 5,580 6,360 7,020 7,290 1,710 23%
Percent of County
Population 5.4% 5.3% 4.9% 4.7% x x
Percent of County Jobs 1.4% 1.8% 1.7% 1.7% x x
San Mateo County
Jobs/Employed Residents 1.05 1.05 1.07 1.08 x x
Employed Residents 369,725 330,700 379,300 408,600 38,875 10% Jobs 386,590 346,320 404,400 439,850 53,260 12%
Percent of Bay Area
Population

10.4% 10.0% 10.0% 10.0% x x
Percent of Bay Area Jobs 10.3% 10.0% 10.0% 10.0% x x
Bay Area Regional Total
Jobs/Employed Residents 1.09 1.02 1.02 1.03 x x
Employed Residents 3,452,117 3,410,300 3,962,800 4,264,600 812,483 19% Jobs 3,753,460 3,475,840 4,040,690 4,379,900 626,440 14% Source: Association of Bay Area Governments, Projections 2009 Pacifica has few major employers. Employment is greatest in education, government, and food retailing. Table II-4 summarizes Pacifica’s largest employers in 2013.

7 Unemployment data from 2011 were provided for consistency with other statistics in the housing element. However, by 2013 the Pacifica economy had improved to 22,082 residents in the labor force with an unemployment rate of 4.2 percent.
8 Employment figures may vary somewhat between the narrative and the table due to the former’s reliance on U.S.

Census Bureau 2009-2011 American Community Survey data and the latter’s reliance on ABAG Projections 2009 data.

City of Pacifica Housing Element: 2015-2023
23 TABLE II-4
Major Employers in Pacifica, 2013
Employer Name Persons Employed Business Type
Pacifica School District 301 Education
City of Pacifica 225 Government
Safeway Stores, Inc. 210 Food Retailer
Jefferson Union High School District 90 Education
Lucky (Save Mart Supermarkets) 90 Food Retailer
Recology of the Coast 49 Solid Waste Mgmt.

Rite Aid Pharmacy 40 Pharmacy
Ross Dress for Less 40 Clothing Retailer
North Coast County Water District 22 Government
Source: City of Pacifica Comprehensive Annual Financial Report (CAFR), 2013 Clearly, Pacifica’s residents have access to jobs not only within the city, but also jobs in large employment centers throughout the Bay Area. Employers outside of Pacifica represent a broader variety of sectors than those found in the city. Table II-5 provides a more compressive depiction of the San Mateo County and Bay Area job market, including employment projections through 2025. (Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
24 TABLE II-5
Projections for Types of Jobs (2000-2025)
Geographical Area 2000 2010 2020 2025
2000-2025
Change
2000-2025
Percent
Change
Pacifica
Agriculture and Natural
Resources 70 70 70 70 0 0%
Manufacturing, Wholesale
and Transportation 380 360 320 330 -50 -13%
Retail 830 690 770 820 -10 -1%
Financial and Professional
Services 1,010 1,260 1,380 1,460 450 45%
Health, Educational and
Recreational Service 2,390 2,920 3,270 3,310 920 38%
Other 900 1,060 1,210 1,300 400 44%
Total 5,580 6,360 7,020 7,290 1,710 31%
San Mateo County
Agriculture and Natural
Resources 1,910 1,900 1,910 1,900 -10 -1%
Manufacturing, Wholesale
and Transportation 93,260 73,940 84,490 86,860 -6,400 -7% Retail 45,930 33,840 39,030 45,540 -390 -1%
Financial and Professional
Services 95,150 90,990 104,950 118,880 23,730 25%
Health, Educational and
Recreational Service 94,330 93,420 113,320 117,650 23,320 25% Other 56,010 52,230 60,700 69,020 13,010 23%
Total 386,590 346,320 404,400 439,850 53,260 14%
Bay Area Regional Total
Agriculture and Natural
Resources 24,470 24,520 25,070 25,270 800 3%
Manufacturing, Wholesale
and Transportation 863,420 717,180 819,010 861,170 -2,250 0% Retail 402,670 347,400 399,950 453,870 51,200 13%
Health, Educational and
Recreational Service 1,056,030 1,120,700 1,322,650 1,403,080 347,050 33% Financial and Professional
Services 851,610 766,860 893,550 990,840 139,230 16%
Other 555,260 499,180 580,460 645,670 90,410 16%
Total 3,753,460 3,693,920 4,280,700 4,595,170 841,710 22% Source: Association of Bay Area Governments, Projections 2009 Note: Employment data includes jobs within the jurisdictional sphere of influence Major Bay Area employment sectors in 2010 included Health, Educational and Recreational Services, and Financial and Professional Services. The greatest regional employment growth projected by ABAG is in Health, Educational and Recreational Services. In Pacifica, ABAG projects the greatest growth in Financial and Professional Services.

City of Pacifica Housing Element: 2015-2023
25 4. Household and Housing Characteristics
A. Income

In 2011, median household income in Pacifica was $96,289. Household income increased by 2.1 percent over the 2000 figure of $94,300. When adjusted for inflation, however, real household income decreased by 22 percent during this period. Shrinking purchasing power can pose a serious challenge for individuals and families seeking quality, affordable housing, especially in the expensive Bay Area housing market. Still, Pacifica’s households had 4.7 percent higher household income compared to San Mateo County households, which in 2011 had a median household income of $91,958. This is a significant change from 2000, when Pacifica’s household income trailed San Mateo County by 17 percent.

Median income is a helpful measure to demonstrate community-wide economic strength. Yet, it does not provide a complete picture of the earnings of different subsets of the population. For instance, Table II-6 demonstrates income levels of seniors in Pacifica.

TABLE II-6
Senior Citizen Income Levels
Pacifica County State
Below Poverty Level 3% 6% 10%
Income under $30,000 30% 28% 38%
$30000-$49,000 18% 19% 20%
$50,000-$74,999 15% 16% 16%
$75,000-$99,999 13% 11% 9%
$100,000+ 23% 26% 17%
Total Seniors 2,517 55,093 2,474,879
Source and Notes: 2009-2011 American Community Survey, Seniors are age 65+ More than two-thirds of seniors had incomes below the Pacifica median household income level in 2011. Lower incomes can present challenges to finding adequate, affordable housing for seniors, especially at market rate. Considering the growing proportion of Pacifica’s population comprised by seniors, these figures demonstrate the importance of understanding housing needs of this key population segment. There are likely other segments of Pacifica’s population, such as persons with disabilities or female-headed households, which require special housing considerations.

B. Housing Costs
Pacifica’s median single-family detached home sale price in 2011 was $527,638. Attached singlefamily homes had a median sale price of $314,363. These sales prices were 24 percent and 31 percent lower than San Mateo County, respectively. Pacifica is fortunate to enjoy a more affordable housing stock than in nearby communities.

City of Pacifica Housing Element: 2015-2023
26 Overpayment
Affordability is a relative concept, not an absolute one. Affordability is relative not only to surrounding communities, but also to resident income. Overpayment for housing involves a household paying more than 30 percent of its gross income on housing expenses. Table II-7 shows the number of Pacifica households that overpaid for housing in 2011, and the proportion of each income group that overpaid.

TABLE II-7
Households Overpaying for Housing
Income Pacifica County State
Number Percent
OwneroccupiedLess than $35,000 713 63% 68% 68%
$35,000-$ 51% 53% 54%
$75,000+ 2044 31% 33% 27%
RenteroccupiedLess than $35,000 811 94% 95% 90%
$35,000-$ 81% 61% 49%
$75,000+ 167 9% 11% 9%
Source: 2009-2011 American Community Survey
Note: Excludes Households with no income or cash rent.

Of the 14,061 total households in Pacifica in 2011 (Table I-16), 42 percent overpaid for housing.

Those with the lowest household incomes were the most likely to over pay for housing, although 40 percent of those in the highest income category still overpaid. The figures in the table are indicative of the high expense of housing in Pacifica relative to household income.

Another helpful way to assess housing affordability is to view the “amount” of housing a household can afford, both in terms of purchase price and monthly rent. Tables II-8 and II-9 demonstrate the maximum purchase price and monthly rent affordable to persons of various income levels from Extremely Low (30 percent of County median) to Moderate (120 percent of County median) income. A median price detached home in Pacifica was unaffordable to households at all income levels except those well above Moderate income. A median price attached home was affordable only to those slightly above Moderate income.
(Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
27 TABLE II-8
Ability to Pay for For-Sale Housing
Annual
Income
Maximum
Affordable
Home
Price
Median
Priced
Single-family
Detached
Home
Affordability
Gap for
Singlefamily
Home
Median
Priced Singlefamily
Attached
Affordability
Gap
Single Person
Extremely Low Income $23,750 $97,114 $535,846 -$438,732 $314,363 -$217,249 Very Low Income $39,600 $161,925 $535,846 -$373,921 $314,363 -$152,438 Low Income $63,350 $259,039 $535,846 -$276,807 $314,363 -$55,324 Median Income $72,100 $294,818 $535,846 -$241,028 $314,363 -$19,545 Moderate Income $86,500 $353,699 $535,846 -$182,147 $314,363 $39,337 Source: Baird + Driskell Community Planning; San Mateo County Association of Realtors; www.hsh.com/calchowmuch.html Note: Maximum Affordable House Price is based on the following assumptions: 4.5% interest rate; 30-year fixed loan; 50% Yearly Salary as Down Payment; 1% property tax; PMI, .5% insurance rate; and no other monthly payments/debt.

The situation for renters was only slightly better. Affordable rental housing was available only to those earning at the Median (100 percent of County median) and Moderate income levels.

TABLE II-9
Ability to Pay for Rental Housing
Annual
Income
Maximum
Affordable
Monthly
Rent
2012
Market
Rent
Affordability
Gap
Single Person
Extremely Low Income $23,750 $594 $1,778 -$1,184
Very Low Income $39,600 $990 $1,778 -$788
Low Income $63,350 $1,584 $1,778 -$194
Median Income $72,100 $1,803 $1,778 $24
Moderate Income $86,500 $2,163 $1,778 $385
Source: Baird + Driskell Community Planning; RealFacts (2013) Note: Estimates based upon upper end of income bracket. Single person analysis based upon 1 bedroom 1 bath unit, information to conduct the four person estimate is based on 3 bedroom 2 bath unit and was not available fromRealFacts. Ability to pay is based upon 30% of income devoted to housing.

Overcrowding
Overcrowding is typically defined as more than one person per room, based on the Census Bureau’s definition of “room,” which excludes bathrooms, porches, balconies, foyers, halls, or half-rooms.

Severe overcrowding occurs when there are more than 1.5 persons per room. Overcrowding can result when there are not enough adequately sized units within a community, or when high housing costs relative to income force too many individuals or families to share housing.

In 2011, there were 282 overcrowded households in Pacifica. These comprised 2.0 percent of total households. Overcrowding was worse for owner-occupied households, where the rate of City of Pacifica Housing Element: 2015-2023
28 overcrowding was four times greater than in renter households. Pacifica had no “extremely” overcrowded households. Rates of overcrowding in Pacifica were substantially lower than elsewhere in San Mateo County, where rates of overcrowding among owner-occupied and renter households reached 4 percent and 13 percent, respectively.

TABLE II-10
Number of Overcrowded Units
Occupied Homes Percent
Pacifica Pacifica County State
Owner Not overcrowded 9,440 97% 96% 96%
Overcrowded 254 2.6% 3% 3%
Extremely overcrowded 0 0.0% 1% 1%
Renter Not overcrowded 4,339 99% 86% 86%
Overcrowded 28 0.6% 8% 8%
Extremely overcrowded 0 0.0% 5% 6%
Source: 2009-2011 American Community Survey
Note: More than one person per room is overcrowded, while more than 1.5 people per room is extremely overcrowded
C. Rehabilitation
Pacifica has a relatively old housing stock (see Table II-11). In 2011, more than one-third of homes had been built more than 50 years ago and nearly two-thirds had been built more than 40 years ago. The last period of major residential construction was in the 1970s, when 22 percent of houses were built. By comparison, within the last 30 years, only 16 percent of the housing stock had been constructed. The advancing age of the housing stock means ongoing rehabilitation and preventative maintenance will be necessary to maintain homes in a habitable condition.

TABLE II-11
Year Structure Built
Pacifica County State
Built in 2000 or more recently 3% 5.4% 12%
Built in 1990s 5% 6% 11%
Built in 1980s 8% 9% 15%
Build in 1970s 22% 17% 18%
Built in 1960s 26% 17% 14%
Built in 1950s or Earlier 37% 45% 30%
Total 14,577 271,140 13,688,351
Source: 2009-2011 American Community Survey
Homes in Pacifica are exposed to more extreme weather than elsewhere in the Bay Area. Strong winds, near-constant exposure to salty air, and frequent heavy rains during the winter months (in non-drought years) combine to degrade paint, rust metal objects, and blow away roof shingles. Frequent maintenance and repairs are necessary, especially for houses west of Highway 1. Neighborhoods where homes are the oldest and rehabilitation needs are greatest include Sharp Park, Pacific Manor, Edgemar, Pedro Point, Fairmont and Vallemar.

City of Pacifica Housing Element: 2015-2023
29 Yet, despite the harsh weather conditions and aging nature, Pacifica’s housing stock remains in good condition. The Building Official and Code Enforcement Officer, who frequently inspect residential properties, estimate that no more than 2 percent, or 291, of Pacifica’s 14,577 housing units require rehabilitation. Still, rehabilitation of homes that do become distressed is important to preserve their viability as housing choices and to sustain neighborhood attractiveness.

5. Regional Housing Needs
The State of California, Association of Bay Area Governments (ABAG), and local governments determine each locality’s share of regional housing needs through a process known as the Regional Housing Needs Allocation (RHNA). The RHNA allocations set housing production goals for the planning period that runs from January 31, 2015, through January 31, 2023, using a “fair share” approach. The approach is based mainly on projected household and employment growth.

San Mateo County benefits from the ability to more precisely allocate planned housing units among the 21 local jurisdictions (20 cities/towns and unincorporated San Mateo County). Through the creation of a subregion – known as the City/County Association of Governments (C/CAG) – local governments were able to exercise more control over the allocation process. Those jurisdictions with a higher likelihood or ability to accommodate more housing units received a greater allocation, while others with limited development capacity received a lower allocation.

Overall, ABAG has determined that the Bay Area region must plan for 187,990 new housing units during the planning period. Of those, San Mateo County must plan for 16,418 units, and Pacifica must plan for 413 units. Table II-12 shows the income categories for which Pacifica must plan.

TABLE II-12
Pacifica’s Regional Housing Needs Allocation (RHNA) 2014 - 2022 Extremely
Low Income
Very Low
Income
Low
Income
Moderate
Income
Above
Moderate
Income Total
30% of
Median
Income
50% of
Median
Income
80% of
Median
Income
100% of
Median
120% of
Median
# of Units 60 61 68 70 154 413
Source: Association of Bay Area Governments, Final 2014-2022 Regional Housing Need Allocation by County The table depicts planning requirements for housing units affordable to a range of income levels. In practical terms, it means a mix of housing types may be necessary to meet future housing needs, to include low-density single-family housing and higher-density housing in mixed-use developments.

City of Pacifica Housing Element: 2015-2023
30 Unmet Need During Past Planning Period (2007-2014)
The City of Pacifica had an adjusted RHNA of 115 housing units for the 2007-2014 planning period (revised downward from 275 units, to reflect units constructed prior to the late adoption of the 2007- 2014 Housing Element in 2012). Subsequent to 2007 Housing Element adoption, the City approved 10 total units. When combined with the 195 units approved prior to 2007 Housing Element adoption but during the planning period, the City ultimately met 75 percent of its original 275-unit allocation. Table II-13 demonstrates the income-level breakdown of approved units, as well as unmet housing needs.

ABAG did not carry forward Pacifica’s unmet housing needs from the 2007-2014 planning period into the City’s total allocation for the 2014-2022 planning period. The allocation for the 2014-2022 period is based upon new analysis of regional growth projections.

TABLE II-13
Unmet Housing Unit Needs for 2007 - 2014 Planning Period Planned Units
Needed
Units
Approved/Per
mitted/ Built
Second
Units
Approved
/Permitted
/Built
Unmet
Housing
Needs
Extremely Low Income 32 0 3 29
Very Low Income 31 0 0 31
Low Income 45 1 0 44
Median Income 53 48 0 5
Moderate Income 114 210 0 0
TOTAL 275 259 3 109
Section III “Land Inventory,” found later in the Housing Element, analyzes land in the City to determine sites suitable for housing unit construction. The Land Inventory will assess whether adequate sites exist to meet the RHNA for the current planning period.

6. Special Housing Needs
A. Large Families
The Census Bureau defines “large family households” as households containing five or more persons. Due to the limited supply of adequately sized units to accommodate large family households, large families face above-average difficulty in locating adequately-sized, affordable housing. The lack of supply, compounded with incomes stretched thin by the greater needs of large families, can result in large families living in overcrowded conditions. Table II-14 shows household sizes in 2011.

City of Pacifica Housing Element: 2015-2023
31 TABLE II-14
Household Size
Number Percent of Households
Pacifica Pacifica County State
1-person 3,387 24% 25% 24%
2-person 4893 35% 31% 30%
3-person 2381 17% 16% 16%
4-person 2059 15% 16% 15%
5-person 924 6.6% 7.2% 8%
6-person 257 1.8% 2.8% 3.7%
7-or-more person 160 1.1% 2.3% 3.0%
Total Households 14,061 256,305 12,433,049
Source: 2009-2011 American Community Survey
In 2011, 9.5 percent of Pacifica's households had five or more persons. Fewer large family households live in Pacifica than in either San Mateo County or statewide. Fortunately, reported overcrowding does not appear to be widespread in the City (Table II-10). Yet, it is apparent large family households are facing challenges finding appropriate housing in light of Pacifica’s existing housing stock.

Table II-15 shows the number of bedrooms per housing unit in the City. Only 3 percent of units have five or more bedrooms, although nearly 10 percent of households have more than five members.

Despite low reported levels of overcrowding, large families must be using large areas of housing units for sleeping purposes. Doing so is unfortunate, as it denies them optimal use of their housing, which should include open areas for relaxation or recreation (living rooms, offices, etc.).

TABLE II-15
Bedrooms in Housing Stock
Pacifica County State
No bedroom 2% 4% 4%
1 bedroom 12% 16% 14%
2 bedrooms 19% 26% 28%
3 bedrooms 44% 34% 33%
4 bedrooms 21% 16% 16%
5 or more bedrooms 3% 5% 4%
Total 14,577 271,140 13,688,351
B. Single Parent Households
Single-parent households frequently have lower incomes and higher living expenses than dual-head households. Lower incomes make the search for adequate, affordable housing more important, but also more difficult. Single-parent households also need convenient access to other support services to assist with their parenting responsibilities while balancing employment, such as childcare, recreation programs, proximity to public transit, and other social services. These needs influence their housing decisions and should shape future housing developments in Pacifica.

City of Pacifica Housing Element: 2015-2023
32 In 2011, a single parent headed 7.2 percent of Pacifica households, as shown in Table II-16. Singleparent households were more than twice as likely to be female-headed. These figures were higher than in San Mateo County but lower than elsewhere in the State.

TABLE II-16
Single Parent Households
Pacifica County State
Number Percent
Living with own children 1,018 7.2% 6.2% 10%
Female-headed, no husband 717 5.1% 4.4% 7.3%
Male-headed, no wife 301 2.1% 1.8% 2.7%
Total Households 14,061 100% 256,305 12,433,049
Source: 2009-2011 American Community Survey, Table DP02 Income levels of single-parent households are also of critical importance when considering housing needs. Single parents must provide for themselves and for their children on one income, stressing their abilities to afford housing. The poverty rate in Pacifica in 2011 for female-headed households with children was 12 percent, as compared to 0.6 percent for married households with children. Comparable figures for male-headed single-parent households were unavailable.

To address both the housing needs and the supportive service needs of single-parent households, the City may consider encouraging development of additional multi-family housing units with integrated child care facilities.

C. Seniors
The 2010 U.S. Census found that 12.1 percent of Pacifica’s population was age 65 years or older, up from 9.7 percent in the 2000 Census. The number of seniors as a percentage of the total population is expected to continue increasing due to the aging of the "Baby Boom" generation, lower birth rates, and extended life expectancies. San Mateo County’s share of population over 65 years is higher than Pacifica’s, although Pacifica has a higher median age – 41.5 years – than both the County and the State. Table II-17 shows comparative figures for Pacifica, San Mateo County, and California. (Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
33 TABLE II-17
Population by Age Group
2000 2010
Pacifica County State Pacifica County State
Under 5 years 5.7% 6.4% 7.3% 5.4% 6.5% 6.8%
5 to 14 years 13.5% 12.8% 15.6% 11.5% 12.1% 13.7%
15 to 24 years 11.6% 11.6% 14.2% 11.4% 11.3% 15.0%
25 to 34 years 14.4% 15.9% 15.4% 12.3% 13.8% 14.3%
35 to 44 years 18.4% 17.4% 16.2% 14.6% 15.0% 13.9%
45 to 54 years 17.3% 14.5% 12.8% 17.4% 15.5% 14.1%
55 to 64 years 9.3% 8.9% 7.7% 15.2% 12.5% 10.8%
65 years and over 9.7% 12.5% 10.6% 12.1% 13.4% 11.4%
Median age 37.6 36.8 33.3 41.5 39.3 35.2
Total population 38,390 707,161 33,871,648 37,234 718,451 37,253,956 Source: 2000 and 2010 US Census SF1
Seniors comprised the largest group in Pacifica with special housing needs in 2011. There were 4,519 residents 65 years of age or older and demographic trends suggest this segment of the population will continue to grow. The growing senior population has distinct housing needs, considering seniors are more likely than the general population to have one or more disabilities (Section I.3.C) and to have lower incomes (Tables II-6, II-18, and II-19). In fact, some seniors subsist on Social Security income alone. The average pension under this program in 2013 was $1,294 monthly ($15,528 annually). For a family of two, each receiving his or her own pension, an annual income of $31,056 would result in the household being considered to have Very Low income. The situation is more acute for a senior living alone, as he or she would be considered to have Extremely Low income. It is apparent then that the combination of disabilities and low incomes present unique challenges to seniors searching for accessible, affordable housing.

TABLE II-18
Median Household Income by Age for
Family Size of Two
Pacifica Income Category
25 to 44 years $103,397 Moderate
45 to 64 years $97,766 Median
65 years and over $52,422 Very Low
Source: 2009-2011 American Community Survey, Table S1903 City of Pacifica Housing Element: 2015-2023
34 TABLE II-19
Seniors by Income, Tenure and Age
Extremely
Low Very Low Low
Lower
Moderate
Above
Median
<30% of
Median
Income
50% of
Median
Income
80% of
Median
Income
100% of
Median
>100% of
Median
All Ages Owner 48% 58% 56% 74% 76%
Renter 52% 42% 44% 26% 24%
Total 1,315 1,440 2,515 1,490 7,215
Age 62-74 Owner 75% 81% 72% 95% 89%
Renter 25% 19% 28% 5% 11%
Total 415 315 710 215 1,225
Age 75+ Owner 71% 79% 92% 100% 95%
Renter 29% 21% 8% 0% 5%
Total 245 380 180 175 205
Sources: CHAS Data 2006-2010
Housing choices for seniors are further complicated by their homeownership status. As shown in Table II-20, 69 percent of Pacifica households own their homes. Among the senior population, however, that figure is 87 percent. The incredibly high homeownership rate for seniors provides both opportunities and risks as they age. Having a large asset such as a home can help to provide the financial means for a senior to pursue alternative housing, whether by downsizing to a home requiring less maintenance or to an assisted living facility that provides for their daily needs. Yet, many seniors are reluctant to sell the homes they have owned and lived in for years. And retrofitting single-family homes to be accessible to persons with disabilities can be complex and costly. The result is that many seniors are not living in housing optimized to the needs they have later in life.

TABLE II-20
Homeownership by Senior Households
Pacifica County State
All Ages Owners 69% 60% 57%
Renters 31% 40% 43%
Total 14,153 256,423 12,433,172
Age 65-74 Owners 89% 79% 75%
Renters 11% 21% 25%
Total 1,460 27,053 1,265,873
Age 75-84 Owners 84% 81% 75%
Renters 16% 19% 25%
Total 744 18,014 823,750
Age 85 + Owners 82% 75% 69%
Renters 18% 25% 31%
Total 304 9,136 342,029
Source and Notes: 2009-2011 American Community Survey, Seniors are age 65 + City of Pacifica Housing Element: 2015-2023
35 D. Extremely Low Income
Households with low incomes often experience difficulty finding affordable housing. Housingrelated challenges are greatest for those in the lowest defined income category, Extremely Low. The California Department of Housing and Community Development (HCD) defines “Extremely Low” income as household income at or below 30 percent of County median. The threshold values vary by family size from one to eight members. In San Mateo County, that ranges from $23,750 for an individual to $44,800 for a family of eight (see Table I-12). For the purposes of this section, the analysis will rely upon the threshold value for a family of four, $33,950.

Households with Extremely Low income (ELI) encompass those in many different life situations.

This includes households with one or more full-time wage earners. A person working a full-time, 2,080 hour-per-year job earning an $8.00 hourly wage (the 2011 California minimum wage) would earn $16,640 annually, well below the ELI level. Even with two minimum wage incomes, a family of four would still have ELI.

Available household income statistics do not categorize household income to align precisely with HCD income levels. However, the income data in Table I-12 approximate the ELI level for a family of four. Using this rough measure, as many as 1,968 Pacifica households have ELI, representing 14 percent of total households. The same rough measure, based on the data in Table II-7, demonstrates that as many as 63 percent of homeowner and 94 percent of renter households with ELI overpay for housing (1,524 total households). These figures, especially for households that rent, demonstrate the acute need for housing affordable to those with ELI.

E. Families and Persons in Need of Emergency Shelters
Many groups in Pacifica have ongoing special needs, but none are more urgent than the needs of families and persons who are homeless or in immediate risk of becoming homeless. Government Code Section 65583(a)(7) requires cities to provide an analysis of these needs in order to plan for appropriate shelter. Measuring the scale of the homeless population has historically been very difficult as it tends to be transient and strives to remain unseen (and thus, undisturbed). In response, the County of San Mateo spearheads an annual Homeless Census and Survey to attempt to obtain a maximum count of the County’s homeless population. An accurate count is a prerequisite to marshalling resources appropriate for the problem.

The 2013 San Mateo County Homeless Census and Survey found there were 2,281 homeless persons in San Mateo County. The number of homeless counted increased by 217, or 11 percent, since 2007.

Within Pacifica, census takers identified 150 homeless persons, all of whom were unsheltered.

Table II-21 lists the various locations where census takers found homeless (based on countywide figures). The most common location was on the street, followed by a car, recreational vehicle (RV), or encampment. These locations accounted for more than half of the homeless population identified.

Around 34 percent were found in a shelter or transitional housing, while the remaining 13 percent were institutionalized (hospital, jail, or substance abuse treatment). Using an annualization formula the Census and Survey estimated there were 6,737 homeless persons in San Mateo County in 2013.

City of Pacifica Housing Element: 2015-2023
36 TABLE II-21
County Homeless Population Location – 2007 & 2013
2007 2013 Change
On the Street 29% 15% -41%
In Car, R.V., or Encampment 24% 41% 90%
In Emergency Shelter 14% 11% -18%
In Motel with Motel Voucher 5% 1% -73%
In Transitional Housing 15% 19% 41%
In Institution 13% 12% 7%
Total: 2,064 2,281 217
Source: 2013 San Mateo County Homeless Census and Survey, 2011 San Mateo County Homeless Census and Survey, 2009 San Mateo County Homeless Census and Survey, prepared by the San Mateo Human Services Agency, Center on Homelessness
The demographics of homelessness in San Mateo County show that there are certain characteristics commonly associated with the homeless. Table II-22 shows several categories including marital status, gender, race, and others. Nearly all homeless identified in the County were single male adults, white, non-veteran, and suffering from one or more incapacities such as alcohol/drug addiction, disability, and physical/mental illness.

TABLE II-22
Demographics of Homeless Population
County
Unsheltered
Homeless
Sheltered
Homeless
Single Adult or Living w/Another Adult 94% 79%
Family 6% 21%
Male 71% 60%
Female 29% 40%
White 60% x
Latino 19% x
African American 13% x
Other Races 10% x
Non-Veteran 89% 76%
Veteran 11% 24%
Alcohol / Drug Problems 72% 8%
Physical Disability 52% x
Chronic Health Problem 47% x
Mental Illness 37% 10%
Source: 2013 San Mateo County Homeless Census and Survey, prepared by the San Mateo Human Services Agency, Center on Homelessness. May not total 100% due to rounding
The complexity of the individual situations of homeless persons makes providing shelter and support services all the more difficult. Providing a place to sleep is but one part of the solution, along with physical and psychological treatment programs. Homeless families with children and homeless, unaccompanied children are among the neediest categories. Additional support services are needed to help children cope with the mental and other stigmas associated with homelessness. The County City of Pacifica Housing Element: 2015-2023
37 Census and Survey found many instances of homelessness involving children, as summarized in Table II-23. Fortunately, all homeless children without parents had been sheltered, but sadly, many families with children remained without proper shelter (all but one “adults with children” household were found in cars or RVs, and none were found in encampments).

TABLE II-23
County Homeless Households with Children
Adults with
Children
Children
Only
On the Street 1 0
In Car, R.V., or Encampment 64 0
In Emergency Shelter 7 6
In Motel with Motel Voucher 11 0
In Transitional Housing 97 3
In Institution 0 0
Total: 180 9
Source: 2013 San Mateo County Homeless Census and Survey The City of Pacifica has strived to expand shelter opportunities for homeless families and persons. To that end, it has removed any zoning obstacles to establishment of emergency shelters in several zoning districts. The Pacifica Municipal Code in Title 9 “Planning and Zoning” permits by-right in all residential districts “special care facilities” for up to six persons. A special care facility includes “twenty four (24) hour shelters for victims of family violence, homeless persons, or other need categories” (PMC Section 9-4.273.1). Residential zones are inherently suitable for establishment of small shelters due to the wide availability of existing structures available for conversion to shelter use.

There are also sufficient undeveloped areas with residential zoning that could accommodate new construction of a shelter. The clean, quiet, and safe character of Pacifica’s residential neighborhoods also provides a welcoming environment to those in need of emergency shelter.

Any special care facility seeking to open in any residential zoning district would simply need to comply with the objective development standards for residential construction. Residential development standards regulate physical aspects of development such as setbacks, height, lot coverage, landscaping, and off-street parking, and there is no public notice requirement. Notwithstanding the City’s zoning, however, special care facilities proposed for construction within the Coastal Zone Appeals Zone would still require a discretionary Coastal Development Permit under the Coastal Act (see PMC Title 9, Article 43 “Coast Zone Combining District). Additionally, certain additions to a single-family residential structure resulting in floor area over 2,800 square feet, or additions increasing floor area by 50 percent or more in certain residential zoning districts, would require issuance of a discretionary Site Development Permit.9 Special care facilities for more than six persons in a residential zone, and any special care facility in a commercial zone, must obtain a discretionary conditional use permit.

According to the San Mateo County Human Services Agency, there were a total of 1,258 shelter beds in the County in 2010, the most recent year for which data were available. This figure includes agencies that are not a part of the County of San Mateo such as Samaritan House, Shelter Network,

9 The residential districts subjected to the 50 percent floor area threshold by Pacifica Municipal Code Title 9, Article 32 “Site Development Permit” are R-1-H, R-3, R-3.1, R-3-G, R-3/L.D., and R-5.

City of Pacifica Housing Element: 2015-2023
38 and Telecare, among others. Of the 1,258 beds, 142 were in emergency shelters, 660 were in transitional shelters, and 456 were in permanent supportive housing.

An insufficient number of shelter beds exist in Pacifica to accommodate the number of homeless observed during the 2013 count. By applying the County’s annualization formula to Pacifica’s 2013 count, there were an estimated 469 homeless in the City in 2013. The annualization formula also estimates the number of individuals that became homeless within the last seven days, which was 10 persons based on Pacifica’s overall count. The “last seven-day” figure should serve as a minimum figure for determining the number of emergency shelter beds needed in the City. Ultimately, at least 150 emergency shelter beds should be available to accommodate actual need by all homeless individuals on any night. Using these figures, it is next important to estimate the specific needs of these homeless groups in order to provide appropriate shelter and services. Applying countywide demographics of the unsheltered homeless population to the number of persons needing shelter within Pacifica, Table II-24 shows specific needs.10
TABLE II-24
Estimated Shelter and Support Needs of Pacifica’s Population Minimum Beds
(10 Homeless)
Optimal Beds
(150 Homeless)
Single Adult or Living w/Another Adult 9 141
Family 1 9
Male 7 107
Female 3 43
Non-Veteran 9 134
Veteran 1 16
Alcohol / Drug Problems 7 108
Physical Disability 5 78
Chronic Health Problem 5 71
Mental Illness 4 56
Note: Totals for Alcohol/Drug Problems, Physical Disability, Chronic Health Problem, and Mental Illness may exceed the number of homeless in each need category since these are not mutually exclusive characteristics.

Source: Derived from 2013 San Mateo County Homeless Census and Survey homeless population demographics applied to Pacifica’s population in need of emergency shelter.

Other, non-shelter resources exist in Pacifica to help families and persons experiencing or at-risk of homelessness. The Pacifica Resource Center provides families and individuals with shelter referral, housing assistance, food, clothing and other information and on available services. Shelter referral requires a screening interview at the Resource Center and an intensive interview at the shelter site before acceptance. The Pacifica Resource Center also provides referrals to Communities Overcoming Relationship Abuse (CORA), which provides emergency shelter for battered women.

10 The year-round and seasonal shelter beds needed in Pacifica are equal given the city’s temperate year-round climate.

City of Pacifica Housing Element: 2015-2023
39 F. Transitional and Supportive Housing
Transitional and supportive housing are two important links in the continuum of care for homeless families and persons. Emergency shelters provide immediate relief from the jarring impacts of sudden homelessness, but transitional and supportive housing provide the basis for long-term improvement in the situations of the homeless. Transitional housing is rental-type housing that allows residency for not less than six months, but that ultimately requires the termination of assistance and recirculation of the unit to another eligible recipient. Supportive housing provides long-term residency with no limit on length of stay for target populations, and links the target populations to on- or off-site services that improve health or enhance their ability to live and work in the community. The target populations for supportive housing are those suffering from mental illness, human immunodeficiency virus (HIV) or acquired immune deficiency syndrome (AIDS), substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Services Act.

Senate Bill 2 (SB 2), enacted in 2007, expanded protections for transitional and supportive housing from local zoning discrimination. Pursuant to SB 2, the City must explicitly permit transitional and supportive housing and apply development standards to these uses in an identical fashion as applied to other residential uses in the same zone. The City of Pacifica has yet to amend its zoning ordinance to explicitly permit by-right these uses in residential zoning districts, but the City is aware of SB 2’s requirements and will process any application for a transitional or supportive housing facility in accordance with state law. The City also will amend its zoning code within one year of adoption of the housing element in order to comply with SB 2, as described in an action program.

G. Persons with Disabilities
A disability is a physical or mental impairment that substantially limits one or more major life activities. Persons with disabilities in Pacifica face unique problems in obtaining adequate and affordable housing. This segment of the population, which includes individuals with mental, physical, and developmental disabilities, needs affordable, conveniently-located housing which is near supportive services and which is adapted to special needs, such as wheelchair accessibility.

In 2011, 7.6 percent of Pacifica’s residents, or 2,849 persons, experienced a disability of some sort (Table I-6). The single largest category of disabilities was ambulatory disability. Ambulatory disabilities limit or restrict one’s ability to walk, significantly affecting the suitability of many housing options. Many individuals experienced multiple disabilities, compounding the challenges to finding appropriate housing. Living arrangements for persons with disabilities depend on the severity of their disabilities. Independent living, or mostly independent living with limited assistance from family members, are options for some persons with disabilities. Others, including those with severe developmental disabilities, require dedicated caregivers and housing with special design features to accommodate a specific disability or combination of disabilities. A common example is wheelchair accessible housing, which might include a single-story residence without interior level changes; or, apartment housing with an elevator, wide hallways and doorways, and other design factors that enable full wheelchair mobility throughout. Additionally, certain disabilities – or even the costs of owning a specially-equipped automobile – make it impossible to drive. In such cases, housing proximate to public transportation is important.

City of Pacifica Housing Element: 2015-2023
40 Persons with disabilities face heightened challenges with securing adequate, affordable housing. In addition to the special requirements of the built environment briefly discussed above, there are significant financial challenges, as well. The majority of persons with disabilities live on incomes that are significantly lower than the non-disabled population. Many disabled individuals live on a small fixed income which severely limits their ability to pay for housing. Table II-25 demonstrates that in 2011 the annual earnings of persons with disabilities were 31 percent lower than persons without disabilities. For females with disabilities, the situation was even more challenging. They earned 25 percent less than males with disabilities, and 41 percent less than the non-disabled population overall.

TABLE II-25
Median Earnings of Disabled Persons (2011 Dollars)
Pacifica County State
With Disability Total $21,389 $26,401 $21,389
Male $24,352 $27,961 $24,352
Female $18,244 $25,082 $18,244
No Disability Total $31,138 $42,807 $31,138
Male $35,697 $47,869 $35,697
Female $26,596 $38,852 $26,596
Source: 2009-2011 American Community Survey, Table B18140 Employment is also a challenge for persons with disabilities. Table II-26 demonstrates the employment status in 2011 for those aged 18-64 years, with and without disabilities. Persons with disabilities were employed at less than half the rate as those with no disabilities. Unemployment was also higher among persons with disabilities, but not substantially greater.

TABLE II-26
Employment Status by Disability Status – Persons 18-64 Years Pacifica County State
Employed Total 19,040 -
Disability 471 32% % %
No Disability 18,569 77 % % %
Unemployed Total 1,832 -
Disability 155 10% % %
No Disability 1,677 7% % %
Not in labor force Total 4,595 -
Disability 855 58% % %
No Disability 3,740 16% % %
Source: 2009-2011 American Community Survey, Table B18120 Percentages are of total population subsets in Pacifica, as follows: Aged 18-64 years – Disability (1,481 persons); and, No Disability (23,986 persons) The greatest difference between the disabled and non-disabled working age populations, however, was among those not in the labor force. Persons with disabilities were nearly four times as likely not to be in the labor force, meaning they were either unable to work or not seeking employment. This much higher rate reflects the economic disadvantage faced by persons with disabilities, which City of Pacifica Housing Element: 2015-2023
41 translates into additional difficulty finding suitable housing. Accordingly, housing affordability at all income levels is a major consideration for the disabled population.

A large proportion of disabled persons are also seniors. Forty-two percent of those with disabilities in Pacifica, or 1,195 persons, were aged 65 years or above in 2011. The multi-faceted nature of housing needs for this population presents many challenges, but also a unique opportunity. By providing adequate and affordable senior housing, with design features and support services suitable to persons with a variety of disabilities, the City can meet the housing requirements of two or more special needs categories. Due to the unique opportunity it presents, the City may consider making affordable senior housing a priority for future housing development in order to make the most of scarce building sites.

The State Department of Social Services Community Care Licensing Division indicated that in 2014, there were four adult residential facilities in Pacifica that provided 24-hour non-medical care for adults aged 18-59 years who were unable to provide for their own daily needs. These four facilities provided capacity for 28 adults. Consistent with State law, group homes such as these (known under the City’s zoning regulations as “special care facilities”) with six or fewer residents per facility are allowed by right in all residential zones. The City may allow special care facilities with more than six residents in residential and commercial zoning districts with the approval of a Conditional Use Permit.

The purpose of a Conditional Use Permit is to establish a procedure for approving or denying land uses that are not automatically permitted because of their unique nature. The City can approve a unique land use if its effect on the surrounding environment is found to be acceptable through the application of conditions of approval. Several findings need to be made to approve a Conditional Use Permit, including that the proposed use will not, under the circumstances of the particular case, be detrimental to the health, safety, and welfare of persons residing or working in the neighborhood or to the general welfare and that it will be consistent with the applicable provisions of the General Plan and other applicable laws of the City and, where applicable, the local Coastal Plan, and where applicable that the use is consistent with the City's adopted Design Guidelines.

Other appropriate housing for persons with disabilities includes very low cost units in large group home settings; supervised apartment settings with on- or off-site support services; outpatient/day treatment programs; inpatient/day treatment programs; crisis shelters; and, transitional housing.

Ideally, these housing types would be near retail services and public transit. The age of Pacifica’s housing stock, with much of it built prior to the Americans with Disabilities Act of 1990, unfortunately complicates locating accessible housing within existing structures. Often times, expensive upgrades are necessary to make housing accessible for persons with a variety of disabilities. Fortunately, Federal and State law now require that all multi-family residential construction projects containing five or more dwelling units be accessible and adaptable to disabled persons. This means any new multi-family housing projects should be more suitable for conversion to housing for disabled persons.

The City ensures that new housing developments comply with California building standards in the California Building Code (Title 24 of the California Code of Regulations), including disabled accessibility requirements. The City also works with applicants who wish to retrofit their single- or multi-family residences to make them suitable for persons with disabilities and to ensure that application of the building code requirements does not create a constraint. There are no identified City of Pacifica Housing Element: 2015-2023
42 zoning or other land use regulation practices that could discriminate against persons with disabilities and impede the availability of such housing for this special segment of the population. In fact, the City’s regulations encourage production of housing for persons with disabilities. Projects that provide housing for persons with disabilities in accordance with the City’s Density Bonus Program are entitled to a reduction of planning application fees and certain other incentives, including greater allowable unit density.

Additionally, the City of Pacifica's Zoning Ordinance allows second units constructed on single-family properties to be larger than standard size if they are designed to be accessible to persons with disabilities. The standard second unit size limitation is 750 square feet. Accessible units may measure up to 850 square feet. Zoning allows second units in the R-1(Single-Family Residential) zoning district on lots measuring at least 5,000 square feet. Other development standards also apply, but in many cases it is possible to construct a second unit accessible to disabled persons with a building permit application only, without undergoing a discretionary review process.

In order to explicitly communicate its support for housing retrofits that expand accessibility for persons with disabilities, the City will undertake an action program to adopt a reasonable accommodation policy and procedures. Reasonable accommodation policies provide a formal mechanism to waive local zoning standards that might otherwise inhibit the construction of access-related architectural features.

For instance, a minimum front setback of 15 feet might prohibit construction of a wheelchair ramp to provide access to a front door. By following the reasonable accommodation procedure, a property owner or resident can petition the City for waiver of the setback requirement, and can also appeal any adverse decisions by City staff.

H. Farm Workers
Farm workers are traditionally defined as persons whose primary incomes are earned through permanent or seasonal agricultural labor. Farm workers are generally considered to have special housing needs due to their limited income and the often unstable nature of their employment.

Traditional leases for rental property can be a barrier for farm workers to access adequate, affordable housing. Lower incomes make it difficult for them to qualify for leases, and the mobility they require to pursue work in different regions limits makes it difficult for them to commit to typical long-term leases.

The housing needs of farm workers are many throughout the state, but in Pacifica there is little need for farmworker housing. Pacifica is an urbanized area of San Mateo County and does not have any working farms. In 2011, U.S. Census data found that only 70 residents worked in agriculture, forestry, fishing, hunting, and mining. The figure increased from 23 residents in 2000, but remains a very small segment of the population.

The City has several parcels of land zoned for agriculture use, but none of those parcels are being actively used for agriculture purposes. Should agricultural employment increase during the planning period and a need for farmworker housing arise, it will be possible to accommodate the need. The City’s A (Agricultural) zoning district allows ranch and farm dwellings appurtenant to the agricultural district without a Use Permit or Site Development Permit. These dwellings could house a small number of workers depending on the size of the farm. Larger agriculture operations requiring more housing, City of Pacifica Housing Element: 2015-2023
43 such as a labor camp, could construct farmworker housing consisting of no more than 36 beds in a group quarters or 12 units or spaces designed for use by a single family or household without issuance of a Conditional Use Permit, in accordance with Health and Safety (H&S) Code Section 17021.6.

Development of larger farmworker housing developments is permissible subject to approval of a Conditional Use Permit and Site Development Permit. Within the Coastal Zone, all housing developments would require a Coastal Development Permit.

Residential zones provide another alternative for lower-cost farmworker housing. In all residential zones, farmworker housing for six or fewer employees is permissible subject to development standards applicable to other single-family housing in the same zone, in accordance with H&S Code Section 17021.6. The R-3 (Multiple-Family Residential) zoning district further allows rooming houses and boarding houses for more than six farm workers upon approval of a Conditional Use Permit and Site Development Permit. Sites located within the Coastal Zone would require approval of a Coastal Development Permit for any residential development.

The City has yet to amend its zoning code to explicitly permit by-right the types of housing described in H&S Code Sections 17021.5 and 17021.6, but will process any application in accordance with state law. It will consider an action program amending all residential zones and the A zone to comply with these provisions.

7. Constraints Upon Housing Maintenance, Improvement, and Development State housing element law requires local agencies to analyze actual and potential constraints upon the maintenance, improvement, or development of housing for all income levels. The following section discusses governmental, nongovernmental, and environmental constraints affecting housing in Pacifica.

A. Governmental Constraints
Several actual and potential constraints upon housing maintenance, improvement, and development exist in Pacifica as a result of City regulations and procedures. They include:
 Building Codes and Improvement Fees
 Land Use Controls
 Processing and Permitting Procedures
 Growth Control Ordinance
i. Building Codes and Improvement Fees
State law requires local agencies, including the City of Pacifica, to enforce the California Building Code (CBD) and other construction-related codes when reviewing and inspecting new developments and modifications to existing developments. In addition to the minimum standards set forth in the CBC, the City has adopted minor amendments to address certain unique aspects of development in Pacifica. For example, the requirement for the installation of fire sprinkler systems was adopted in 1998 to better City of Pacifica Housing Element: 2015-2023
44 protect life and property from fire hazards. The City has also prohibited wood shake shingle roofing due to fire hazards. Building codes, to include the CBC and local amendments, preserve the public welfare by setting standards for structural, electrical, plumbing, and environmental safety. Application of these building codes does, however, lead to increased housing costs. It takes architects, engineers, and contractors additional time to comply with detailed provisions of the codes. Code-compliant construction materials and fixtures may also have additional associated costs as compared to lesser quality items. It also takes the time of City staff to review project plans and to conduct inspections in the field to ensure compliance.

There are many tangible examples of building codes that enhance public safety but that also increase maintenance, improvement, and development costs for housing projects. Once such example is that of fire sprinkler installations. All new buildings and additions to existing structures in excess of 1,000 square feet require fire sprinkler systems. These improvements can cost tens of thousands of dollars, yet provide greatly enhanced protection to life and property in the event of a fire. Another example is the California Energy Code. Energy Code requirements can increase construction costs (and the subsequent sales prices) by several dollars per square foot.

Improvement fees can also constrain maintenance, improvement, and development of housing. The most common improvement fee is the building permit fee. Building permit fees include initial review of construction plans and subsequent inspections of the work at the job site. Plan review fees are related to the floor area of projects and the number of electrical, plumbing, and other specialized fixtures installed. Inspection fees relate to the number of inspections and time spent during each inspection at an hourly rate. Simple projects, such as a 500 square foot addition of two bedrooms and a half-bathroom to a single-family residence would typically incur approximately $3,000 in review fees and $570 in inspection fees. Building permit fees for a small project of this sort are modest. However, cumulative fees for larger multi-family new development projects can be much higher. Total fees for a substantial multi-family residential apartment complex renovation to improve housing might also be so costly as to discourage property owner investment to enhance the housing stock. Fees are also likely to increase annually in response to increased City staff administrative costs. The City Council has mandated that staff recover actual costs of providing services to the community. During the last fiscal year, the City Council altered how staff calculated building permit fees to better align with industry standard practices, and the results was an overall increase in fees. However, Pacifica's fees are average when compared to those found in other communities in the Bay Area.

There are other improvement fees associated with maintenance, improvement, and development of housing. The Planning Department assesses fees for its review of entitlement applications, which generally precede building permit reviews and fees. Entitlement applications include major efforts, like amending the City’s General Plan to allow housing or processing a subdivision or condominium map for new single-family housing. Entitlements can also be smaller, such as a Use Permit to allow an addition to a house that does not conform to the City’s current zoning standards. A common entitlement in Pacifica is a Coastal Development permit, mandated by the state for many types of work within the Coastal Zone. In some areas of the Coastal Zone (the Coastal Zone Appeals Zone), additions exceeding 10 percent of existing floor area require a Coastal Development Permit.

The cost of Planning Department fees generally will not be cost prohibitive to a project. Planning Department fees relate directly to the scale of a project, with the City charging an hourly fee for actual City of Pacifica Housing Element: 2015-2023
45 time spent working on a project. For instance, a modest-sized multi-family development project of 30 units may typically take 40 hours of staff time to complete the Planning process, not including environmental review. Planning fees would amount to $7,200 or $240 per dwelling unit, based on a 2014 hourly rate of $180 per hour. Like building permit fees, Planning Department fees are subject to annual increases if administrative costs increase. However, the true cost of entitlement processing can be in the time it takes to receive an approval. Common entitlement processing can take three to four months, with larger projects sometimes taking a year or more to clear all review and appeal processes.

Major delays add uncertainty and cost to housing projects, and may act to discourage pursuit of certain housing-related activities. The City maintains its annual list of user fees in Administrative Policy No.

2. An attachment to the Housing Element is the 2014-2015 Master Schedule of Fees.

Beyond basic permit review and inspection fees, the City commonly assesses fees for infrastructure or other improvements associated with development. These fees are generally described as “impact fees.” Frequently, these come in the form of off-site improvements, although sometimes developers pay fees in lieu of physical improvements. The City's requirements regarding off-site improvements vary, depending on the scale of the project or its relative location within the city.

Redevelopment or in-fill development of existing sites in some cases may incur fewer impact fees.

However, the City’s Complete Streets Policy, adopted in 2012, requires developers of in-fill sites to either install sidewalks, curbs, and gutters along the site frontage, or sign a deferred improvements agreement to install them at a later time. In-fill developers must install on-site utilities underground between structures and utility poles, but in most cases need not “underground” the utility poles. Larger projects (i.e. subdivisions of more than four parcels) may have to underground utility poles in addition to providing other improvements listed above.

Street construction is a major off-site improvement cost for new developments. Where a development requires new streets, the slope of the development site determines the minimum street width requirement. The wider the street, the more expensive it is to construct. In general, the steeper the slope the narrower the required street width. However, with rare exception, the City’s minimum street width requirement is 22 feet.

The City's Subdivision Ordinance allows the Planning Commission to relax utility and street improvement standards where topography, probable future traffic, or other circumstances justify a lesser standard. The City Engineer may waive the requirement to underground utilities if he finds that the subdivision is within an area where previous developers had not installed underground utilities, that underground utility installation is impractical due to physical constraints, or that overhead utilities will have no significant visual impact. While the City Engineer can waive certain off-site improvements, he can also require others such as street lights, street signs, street trees, fire hydrants, and monuments.

These requirements are consistent with most surrounding jurisdictions. ii. Land Use Controls
The City of Pacifica mostly relies on two sources of authority to regulate all development, including housing – the General Plan and Zoning Code. The Land Use Element of the General Plan provides overarching guidelines for land categories and includes a map of assigned land uses. The Local Coastal Land Use Plan is a companion to the General Plan, and contains additional provisions for City of Pacifica Housing Element: 2015-2023
46 land uses in the Coastal Zone. The Zoning Code also includes a map and contains detailed standards for development, regulating specific uses and imposing physical development standards. These development standards can impact the type and intensity of development, which can directly translate into the cost to maintain, improve, and develop housing units. In the event of any conflict, the provisions of the General Plan are controlling.

Zoning Development Standards
Table II-27 summarizes Pacifica’s residential development standards. The table includes standards for minimum lot size, minimum site area per unit, minimum setbacks, maximum height, maximum lot coverage, minimum landscaping, minimum open space, and minimum parking. The standards apply to each of the City’s residential zoning districts; different standards apply to mixed-use developments within commercial zones.

TABLE II-27
Development Standards by Residential Zoning District
Zoning District
Standard R-1 R-2 R-3 R-3-G
Lot Area (min.) 5,000 sq. ft. 5,000 sq. ft. 5,000 sq. ft. 7,500 sq. ft.

Lot Area Per Dwelling Unit (min.) 5,000 sq. ft. 2,900 sq. ft. 2,075 sq. ft. 2,300 sq. ft.

Lot Width (min.) 50’ 50’ 50’ 60’
Front Setback (min.) 15’ 15’ 15’ 15’
Front Setback to Garage (min.) 20’ 20’ 20’ 20’
Side Setback (min.) 5’ 5’ 5’ 5’
Rear Setback (min.) 20’ 20’ 20’ 20’
Maximum Lot Coverage 40% 50% 60% 50%
Landscaped Area (min.) 20% 20% 20% 25%
Usable Open Space Per Unit (min.)11 N/A N/A 400 sq. ft. 450 sq. ft.

Height (max.) 35’ 35’ 35’ 35’
Parking Spaces (min.) 2 covered 2 covered 1 per studio;

1.5 per 1 BR; 2
per 2+ BR;
and, 1 guest
per 4 units
Same as R-3
Source: Pacifica Municipal Code, Title 9, Chapter 4 “Zoning” The City’s main residential zoning districts are the R-1 (Single-Family Residential), R-2 (Two-Family Residential), R-3 (Multiple-Family Residential), and R-3-G (Multiple-Family Residential Garden) districts. The City’s zoning regulations also permit residential development in the C-1 (Neighborhood Commercial) and C-2 (Community Commercial) zoning districts. The allowable densities for residential development based on the zoning development standards range from 9 to 21 dwelling units per acre in the residential zones (R-1, R-2, R-3, and R-3-G) and up to 22 dwelling units per acre (2000 square feet of lot area per dwelling unit) in the commercial zones (C-1 and C-2).

11 Usable open space shall mean common or private outdoor living, recreation, domestic use, or landscaping. Such area may be on the ground or on, a roof, porch, deck, court, or balcony.

City of Pacifica Housing Element: 2015-2023
47 The development standards in each zoning district can restrict the maximum number of housing units it is possible to construct on a given site. Sometimes a trade-off is made to reduce density in order to preserve other desirable aspects of development, including open space, views, and reduced congestion. These trade-offs can increase the per-unit cost of housing. Trade-offs among zoning districts notwithstanding, the internal consistency that exists between the General Plan densities and Zoning Code standards results in a situation where it is feasible for developers to achieve maximum allowable residential densities within each respective zoning district. Furthermore, in certain cases, the Density Bonus Ordinance (discussed later) may allow density up to 50 percent beyond the basic allowance.

Listed below are various types of residential uses allowed in the City and a description of which zoning districts in which they are permitted. The lower the density of development, the higher the per-unit cost of housing.

Single-Family Residential – The Zoning Code allows single-family residential development byright in the R-1 and R-2 districts and subject to a conditional use permit in the R-3 and R-3-G districts.

The R-1 district includes most of the City’s established neighborhoods. It allows detached singlefamily residential development on lots of 5,000 square feet or greater. Subject to more restrictive regulations, it is also possible to develop housing on lots of less than 5,000 square feet. The purpose of the R-1 district is to retain the low-density character of these areas and its development standards are structured accordingly.

The R-2 district encourages the development of slightly more dense, attached single-family housing that blends easily with single family neighborhoods. Minimum lot sizes are 5,000 square feet and the minimum lot area per dwelling unit is 2,900 square feet. It permits single-family detached housing on lots of 5,800 square feet or less.

In both the R-1 and R-2 districts, a Coastal Development Permit is necessary if a development is located in the Coastal Zone.

Multiple-Family Residential – The Zoning Code allows multiple-family residential development in the R-3 and R-3-G districts subject to a Site Development Permit and in the C-1 and C-2 districts subject to a Conditional Use Permit. A Coastal Development Permit is necessary if a development is located in the Coastal Zone.

Pacifica’s multi-family residential districts vary only slightly. In each one, duplexes and multi-family dwellings are permitted, while single-family detached houses are permitted with approval of a Conditional Use Permit. Multi-family residential zoning covers a significant area between the coastal bluff and Highway 1 at the north end of the city, sections of West Sharp Park, and other pockets of the city.

Most of the recent large developments in Pacifica have been within the Planned Development (P-D) zoning district. The purpose of the P-D district is to allow diversification of the relationships of various buildings, structures and open spaces in planned building groups, while ensuring substantial compliance with the district regulations and other provisions. The P-D section of the Zoning Code City of Pacifica Housing Element: 2015-2023
48 states that development standards shall be guided by the regulations of the zoning district most similar in nature to the proposed use. In some of these cases, the R-3 development standards guided the developments. The P-D designation allowed development of these sites with more flexibility and in some cases included new parks and open space.

Parking Standards
Parking can account for a substantial share of residential development expenses. Surface parking – the least expensive parking option – can occupy large portions of a development site, rendering the underlying areas unsuitable for other development. Covered parking, especially garage parking, requires effort and expense to incorporate it into the architecture of the associated structure. Parking structures – the most expensive parking option –– can allow development above or below the parking area, but require substantial engineering and construction resources.

The Zoning Code sets different parking requirements depending on the type of housing development. Single- and two-family structures have a parking requirement of two garage spaces per unit. Attached or detached garages satisfy this requirement. Multi-family structures, including apartments, townhouses, and condominiums, have parking standards that vary by the size of the units. Standards range from one parking space per studio unit to two spaces for units with two or more bedrooms. Every four units require a guest parking space. At least one of the required spaces for each unit must be in a garage or carport. A carport is less expensive to construct than a garage space, which can make a housing unit more affordable. The Zoning Code does not allow tandem parking to satisfy parking requirements except in mobile home developments, which can further add to development costs on smaller lots or those with unique design challenges. The Zoning Code does, however, allow for a reduced parking requirement for senior housing (1 space for every 2 units and 1 guest parking space for each 5 units), which can reduce the cost of senior housing development.

Certain other parking requirements exist for mobile home parks, lodging and boarding houses, and projects with affordable units. The standards for each are less restrictive and assist with reducing the housing unit development costs.

Clustered Housing Standards
The Zoning Code’s Residential Clustered Housing Development Standards apply to condominiums, community apartments, stock cooperatives, zero lot line projects, and similar developments.

Clustered housing standards impose additional requirements onto such developments in order to ensure high-quality site design and resident amenities. Additional requirements imposed on clustered housing, but which do not automatically apply to multi-family rental housing, include minimum amounts of usable open space, private open space, building separation, laundry facilities private storage, and individual utility metering. Furthermore, every clustered housing development must undergo a discretionary review process for a Conditional Use Permit and Site Development Permit, unless the site is within the P-D zoning district (which has its own process for discretionary review). The high level of design and lengthy processing required by the clustered housing standards result in greater development costs per housing unit.

City of Pacifica Housing Element: 2015-2023
49 Park Dedication Fees
The City's Subdivision Ordinance requires that any subdivision of more than four (4) parcels either:
 Dedicate land for park and recreation facilities sufficient in size and topography to serve present and future needs of subdivision residents (.02 acre per unit), or  Pay a fee in-lieu of dedication equal to the value of the land which would otherwise be dedicated.

The City uses in-lieu fees it has collected for developing new or rehabilitating existing neighborhood or community parks or recreational facilities reasonably related to serving the subdivision. Parkland dedication can add substantially to the cost of housing development. Dedication of land in the case of single-family detached dwellings can comprise as much as 15 percent of the area developed, or between 17 and 30 percent for multi-family developments.

The City's parkland dedication requirement is consistent with those of neighboring communities. This requirement is typically associated with mitigating environmental impacts of a development. If it is found that the parkland dedication requirement is impossible or impracticable in a particular case for a subdivider to conform fully to the subdivision regulations, the Planning Commission may approve a modification to the subdivision regulations. Additionally, where a substantial private park and recreational area is provided in a proposed subdivision, and the space is to be privately owned and maintained by the future residents of the subdivision as permanent open space, partial credit, not to exceed fifty percent, may be given against the requirement of land dedication or the payment of fees in lieu of dedication if the Parks, Beaches, and Recreation Commission finds that it is in the public interest to do so and certain standards are met. In addition, the Density Bonus Ordinance allows the Planning Commission to grant additional incentives if necessary to make the housing units economically feasible.

Inclusionary Zoning Ordinance
The City’s Below Market Rate (Inclusionary) Program (i.e. Inclusionary Ordinance) codified in Pacifica Municipal Code Title 9, Article 47 establishes requirements for housing developers to provide housing units affordable to a range of income levels under certain circumstances. The Inclusionary Ordinance applies to all residential developments of eight or more units, lots, or parcels, including those in which eight or more units will be added to existing projects. Projects subject to the requirement must ensure at least 15 percent of all units, lots, or parcels are affordable to persons with very low, lower, or moderate income.

The Inclusionary Ordinance establishes affordability as follows:

Outside the redevelopment project area, the first required below-market rate (BMR) unit and at least 50 percent of the required BMR units shall be restricted to occupancy by lower income households and the remaining required BMR units shall be restricted to occupancy by moderate income households. Provided, the developer has the right but is not required to increase the percentage of lower income household BMR units.

The City approves sales prices and rental rates to ensure their affordability to low, lower, or moderate income individuals and families. The Inclusionary Ordinance also establishes minimum periods of City of Pacifica Housing Element: 2015-2023
50 affordability of 45 years for ownership units and 55 years for rental units, in addition to other use restrictions. In lieu of constructing affordable units, a developer may pay a fee to the City’s housing trust fund to enable housing construction by another developer at a different site. Developers providing affordable housing on-site can qualify for a density bonus and other development incentives.

Permit and Impact Fees for Two Sample Developments
In order to provide some context for prospective developers considering the development of housing in Pacifica, Table II-28 presents two sample developments that could foreseeably occur during the planning period and estimated permit and impact fees associated with them. The estimates rely on certain assumptions regarding the size and architectural details of the sample developments.

Considering the number of variables inherent in any land use development, estimating permit and impact fees is challenging. Accordingly, these estimates may not be applicable to an actual development undertaken in the future. Furthermore, the estimates reflect fees set in the Fiscal Year 2014-2015 Master Schedule of Fees and Charges, which is subject to change.

TABLE II-28
Estimated Permit and Impact Fees for Sample Developments Fee Type
5-unit Detached Single-Family
Residential (R-1 Zone)
20-unit Attached MultipleFamily Residential (R-3
Zone)
Planning Entitlement12 $7,500 $4,500
Legal $10,000 $10,000
Environmental $40,000 $40,000
Building Permit $37,000 $60,500
Sewer $15,000 $45,000
Encroachment Permit
Park Dedication $35,000 $34,000
Highway Impact $25,000 $92,000
Total: $169,500 $286,000
The 5-unit SFR fee estimate is based on three-bedroom,1.5 bathroom, 1,500 sq. ft. units, with an overall site area of 25,000 sq. ft. (0.574 acres). The 20-unit MFR fee estimate is based on a mix of three unit types, each with one bathroom: 5 studio units of 500 sq. ft. each; 10 one-bedroom units of 750 sq. ft. each; and, 5 two-bedroom units of 1,000 sq. ft. each. Overall site area estimated at 41,500 sq. ft. (.953 acres).

Highway Impact Fees reflect the maximum anticipated amount based on a project located North of Sharp Park Road. Projects located south of Sharp Park Road are assessed a lower fee of $1,485 per unit, plus Oceana Boulevard trip-based fees of $309 per estimated trip (10 trip minimum per development).

Source: Pacifica Planning Department Staff

12 Typical entitlements required for a 5-unit detached single-family residential development include Tentative and Final Subdivision Maps and a Negative Declaration. Typical entitlements required for a 20-unit attached multiple-family residential development include a Site Development Permit and Negative Declaration. See Table II-29 for typical processing times for these permits.

City of Pacifica Housing Element: 2015-2023
51 iii. Processing and Permitting Procedures
Special processing and permitting procedures required for certain types of housing projects may increase the costs of development and delay the start of construction. Even projects that may otherwise meet zoning development standards and General Plan development guidelines still must undergo special processing due to requirements established in the Zoning Code. For example, all projects within the R-3 (Multiple-Family Residential) or any commercial zone require issuance of a Site Development Permit prior to authorizing construction. Furthermore, housing developments within any commercial zone require approval of a Use Permit. Typical processing times for projects of this sort are between three and eight months. Appeals to the City Council or Coastal Commission can extend that timeline further. Delays and uncertainty complicate the investment decisions of developers. For those that choose to proceed, they often must price housing units higher to account for the delays and risks they incurred to reach the construction phase.

Projects within the P-D (Planned Development) district also receive careful scrutiny through the discretionary review process. Review and approval of an overarching Development Plan is necessary for any project within the P-D (Planned Development) zone as a pre-requisite to considering more detailed plans for each parcel. After Development Plan approval, a developer must then seek approval of a Specific Plan for each structure or parcel within the Development Plan area. The only housing projects in the city that may avoid discretionary review in most cases are single-family homes and duplexes outside of the Coastal Zone. These types of housing developments are unlikely to meet the total housing demand in Pacifica given the scarcity of buildable land for these housing types and their relatively high per-unit development costs.

Therefore, the bulk of the city’s future housing development will undergo lengthy develop processing and permitting prior to receiving construction approvals.

The City’s Zoning Code vests the Planning Commission with authority to approve, deny, or approve with conditions most developments in Pacifica. Decisions of the Planning Commission are subject to appeal to the City Council. The Planning Commission must make certain findings in order to approve each permit type. A summary of these findings for the most common permit types is below.

In addition to these findings, in most cases the Planning Commission must also affirm environmental findings unique to each development site.

Site Development Permit Findings – A permit shall not be issued if the Commission finds:
1) That the location, size, and intensity of the proposed operation will create a hazardous or inconvenient vehicular or pedestrian traffic pattern, taking into account the proposed use as compared with the general character and intensity of the neighborhood; 2) That the accessibility of off-street parking areas and the relation of parking areas with respect to traffic on adjacent streets will create a hazardous or inconvenient condition to adjacent or surrounding uses;
3) That insufficient landscaped areas have been reserved for the purposes of separating or screening service and storage areas from the street and adjoining building sites, City of Pacifica Housing Element: 2015-2023
52 breaking up large expanses of paved areas, and separating or screening parking lots from the street and adjoining building areas from paved areas to provide access from buildings to open areas; 4) That the proposed development, as set forth on the plans, will unreasonably restrict or cut out light and air on the property and on other property in the neighborhood, or will hinder or discourage the appropriate development and use of land and buildings in the neighborhood, or impair the value thereof;
5) That the improvement of any commercial or industrial structure, as shown on the elevations as submitted, is substantially detrimental to the character or value of an adjacent R District area;
6) That the proposed development will excessively damage or destroy natural features, including trees, shrubs, creeks, and rocks, and the natural grade of the site, except as provided in the subdivision regulations as set forth in Chapter 1 of Title 10 of this Code; 7) That there is insufficient variety in the design of the structure and grounds to avoid monotony in the external appearance;
8) That the proposed development is inconsistent with the City's adopted Design Guidelines; or
9) That the proposed development is inconsistent with the General Plan, Local Coastal Plan, or other applicable laws of the City. If the proposal, however, does not have any of the impacts listed above, the Site Development Permit may be granted.

Conditional Use Permit Findings – A permit shall be issued only if the Commission finds:
1) That the establishment, maintenance, or operation of the use or building applied for will not, under the circumstances of the particular case, be detrimental to the health, safety, and welfare of the persons residing or working in the neighborhood or to the general welfare of the City; 2) That the use or building applied for is consistent with the applicable provisions of the General Plan and other applicable laws of the City and, where applicable, the local Coastal Plan; and
3) Where applicable, that the use or building applied for is consistent with the City's adopted Design Guidelines.

Development Plan Findings (P-D District) – Approval shall be granted only if the Commission finds that:
1) The proposed P-D District can be substantially completed within the time schedule submitted by the applicant;
City of Pacifica Housing Element: 2015-2023
53 2) Each unit of the development, as well as the total development, can exist as an independent development capable of creating an environment of sustained desirability and stability or adequate assurance that such objective will be attained; 3) The land uses proposed will not be detrimental to the present or potential surrounding uses but will have a beneficial effect which would not be achieved through other districts;
4) The streets and thoroughfares proposed are suitable and adequate to carry anticipated traffic, and increased densities will not generate traffic in such amounts as to overload the street network outside the P-D District;
5) Any proposed commercial development can be justified economically at the location proposed and will provide adequate commercial facilities for the area; 6) Any exception from the standard district requirement is warranted by the design of the project and amenities incorporated in the development plan; 7) The area surrounding the development can be planned and zoned in coordination and substantial compatibility with the proposed development, and the P-D District uses proposed are in conformance with the General Plan and, where applicable, the Local Coastal Plan, or that changes in the General Plan or Local Coastal Plan are justified; 8) The project is consistent with the City's adopted Design Guidelines; and 9) The project is consistent with the City's General Plan and, if applicable, Local Coastal Plan.

Specific Plan Findings (P-D District) – Approval shall be granted only if the Commission finds:
1) That the specific plan is consistent with the approved development plan; and 2) That the specific plan is consistent with the City's adopted Design Guidelines.

The time required to process a project varies greatly from one project to another and is directly related to the size and complexity of the proposal and the number of actions or approvals needed to complete the process. Table II-29 identifies typical entitlement processing timelines. It should be noted that each project does not necessarily have to complete each step in the process (i.e., smallscale projects consistent with General Plan and zoning designations do not generally require Environmental Impact Reports (EIR), General Plan Amendments, Zone Changes, or Variances).

Also, in most cases certain review and approval procedures run concurrently. For example, a review for a condominium project would be processed concurrently with the Site Development Permit, Conditional Use Permit, and Tentative Subdivision Map, as well as any necessary Variances, Parking Exceptions or other permits. Environmental review is also processed simultaneously.

City of Pacifica Housing Element: 2015-2023
54 TABLE II-29
Timelines for Discretionary Permit Processing
Permit/Approval Type Typical Processing Time Approval Body Site Development Permit,
Conditional Use Permit, Variance,
Coastal Development Permit,
Parking Exception
6-8 weeks Planning Commission
Zone Change 12-24 weeks Planning Commission/City Council General Plan Amendment 12-24 weeks Planning Commission/City Council Tentative Subdivision Map 12-24 weeks Planning Commission/City Council General Plan Amendment 12-24 weeks City Council
Final Subdivision Map 6-8 weeks City Council
Negative Declaration 12-30 weeks Planning Commission/City Council Environmental Impact Report 6-18 months Planning Commission /City Council Source: Pacifica Planning Department Staff
Planning Department processing fees also act as a constraint to housing maintenance, improvement, and development. The Planning Department bases its review fees on the City Council-adopted fee schedule, which for 2014-2015 established an hourly rate of $180.00. Some projects require minimal staff review and are relatively inexpensive to process for entitlements. However, large projects – such as those requiring an environmental impact report (EIR) – require a public hearing and can take from 6 to 8 months to process, with a corresponding increase in staff time and cost. The City works closely with developers to expedite approval procedures so as not to put any unnecessary timing constraints on development. Other agencies including Public Works, Fire, Building, and Police review submittals concurrently for consistency with City ordinances, Design Guidelines and General Plan consistency.

After project approval by the Planning Commission or City Council, City permitting and processing continues during the Building Permit stage. The Building Division of the Planning Department performs plan checks and issues building permits. Throughout construction, the Building Division performs building inspections to monitor the progress of the project. Corrections needed during the plan review portion of the building permit stage, or failed inspections during the construction phase, can delay project completion. State law requires local agencies to implement plan reviews and construction site inspections to ensure compliance with the California Building Code, limiting Pacifica’s ability to mitigate this constraint.

Table II-30 lists the typical discretionary permits required for the sample developments presented in Table II-28. Certain discretionary permit requirements tend to be site specific, and will depend on site location, topography, zoning, and other factors. Thus, as with the fee estimates for these sample developments, determining the discretionary permits required for the sample developments relied on certain assumptions that may be different for an actual project.

City of Pacifica Housing Element: 2015-2023
55 TABLE II-30
Discretionary Permit Requirements for Sample Developments Permit Type
5-unit Detached Single-Family
Residential (R-1 Zone)
20-unit Attached MultipleFamily Residential (R-3 Zone) Site Development Permit X
Conditional Use Permit Req’d for
condominium/townhome
projects only
Coastal Development Permit Only within Coastal Zone Only within Coastal Zone Tentative Subdivision Map X
Final Subdivision Map X
Negative Declaration X X
Environmental Impact Report
Total Review Time: 6-8 months 6-8 months
The 5-unit SFR permit estimate is based on an development site comprised of a single 25,000 sq. ft. (0.574 acres) parcel requiring subdivision. The 20-unit MFR permit estimate is based on an apartment project on a single 41,500 sq. ft. (.953 acres) parcel not requiring subdivision. Neither site is within the Coastal Zone, nor within a wetlands or other highly sensitive area for environmental purposes, nor requiring a deviation from any development standards (variance or parking exception).

Source: Pacifica Planning Department Staff
Second Units
Construction of second dwelling units in conjunction with existing single-family detached residential structures is an important way to expand the City’s housing stock. It can benefit property owners with additional income, or allow them to care for a family member that needs to be close to care, but still desires some independence. Pacifica’s zoning regulations allow construction of second units in many situations within the R-1 zoning district subject only to issuance of a building permit, in accordance with state law. Government Code Section 65852.2(a) allows a local agency to establish regulations for construction of second units. The City of Pacifica has adopted regulations that impose certain limited restrictions on second unit construction.

Pacifica’s ordinance allows second units only within the R-1 district. In the R-1 district, the ordinance limits by-right construction of second units to lots in full conformance to development standards. It further limits the density of second units to no more than 25 percent of lots on any block. Additional development standards and density limitations exist, as provided in Pacifica Municipal Code Section 9-4.453. The City’s current ordinance requires more than one parking space for a second unit; prohibits the use of tandem parking spaces to meet the minimum parking requirements; and prohibits locating a required parking space for a second unit within a required front yard setback. These provisions are inconsistent with state law, and the City has included an action program in this housing element to adopt a revised ordinance to comply with the Government Code.
iv. Growth Control Ordinance
In January 1982, the Pacifica City Council adopted Ordinance No. 322-C.S., an initiative ordinance known as the “Growth Control Ordinance” which provided for controlled residential growth through 1992. A series of ordinances have extended growth control policies to present day. The current City of Pacifica Housing Element: 2015-2023
56 ordinance controlling growth in Pacifica is set to terminate on June 30, 2017. The purpose of the Growth Control Ordinance (GCO) is to manage the timing of residential growth in Pacifica so that development does not outpace the City’s ability to provide essential services and infrastructure to support the growth. The Ordinance does not place a cap on residential development. The GCO contains findings concerning adverse effects of rapid residential growth in Pacifica and, as a result, limits new dwelling units to a maximum of 70 units annually. To ensure an equitable distribution of units and to encourage in-fill, the GCO provides that no applicant for development approval shall receive greater than 20% of the annual allotment each year.

There are a number of factors that determine actual development allocations under the GCO. Since enactment, the City has interpreted the GCO to allow accumulation of unallocated units for development in subsequent years. As of December 2014, the balance of units available for allocation was 1,415, resulting from a large number of unused development applications in recent years. A single housing developer could propose a project at any time for up to 283 housing units, or 20 percent of the available allocations. There are also a number of exclusions from the annual development limitations.

These include one single-family dwelling unit on an individual existing lot; affordable, senior, or accessible dwelling units; second units; any statutory housing programs which are excluded from growth controls limitations; and any future amendments to the Growth Control Ordinance. At the beginning of fiscal year 2008-2009, there were 1067 allocations available. As of July 2010, a balance of 1,144 permits remained. An excess of permits (over the 70 units allotted per year) has accumulated due to a carry-over of unused permits from previous years.

The GCO provides for a competitive evaluation system to distribute development allocations. The competitive allocation procedure includes criteria and a ranking process. Criteria include, but are not limited to, the following: ability of public facilities, utilities and services to meet the demands created by the project; presence or absence of adverse environmental impacts; site and architectural design quality; the provision of private or public usable open space; consistency with neighborhood character; and, provision of affordable housing, senior housing and housing for persons with disabilities. Low and moderate income projects receive preferential ranking. The Planning Commission must consider each application for a residential development allocation at a public meeting and evaluate and rank the applications according to these criteria. The Planning Commission recommendations are forwarded to the City Council for review and approval. At the public hearing, the City Council must consider the Planning Commission's recommendations and ranking. The City Council then adopts a final ranking list and award residential development allocations pursuant to that list. The City Council may adopt, reject or modify the recommendations and ranking of the Planning Commission.

To permit phasing of multi-unit projects, where such projects exceed the available annual allotment of residential development allocations, the allocation procedure includes a procedure for the phasing of such projects over more than one fiscal year by reservation of succeeding year allotments. Such reservations can be deducted from the number of residential development allocations to be awarded for the fiscal year under consideration. When the number of available residential development allocations exceeds demand for the allocations, the City Council may issue the allocations on an “as needed basis” (i.e., without following the competitive evaluation system process) throughout the year.

The GCO also provides that property zoned A (Agricultural) or HPD (Hillside Preservation) district may not be rezoned out of agriculture or hillside preservation uses without a vote of the people. The City of Pacifica Housing Element: 2015-2023
57 purpose of retaining agricultural zoning is to prevent premature conversion of agricultural land to urban uses, to prevent urban sprawl, and to conserve coastal and open space resources upon which Pacifica's economy depends. The purpose of retaining hillside areas is to protect against potentially hazardous conditions peculiar to hillsides, to ensure development compatible with Pacifica's hillside resources, to preserve open space, and to retain natural terrain by encouraging the concentration of dwelling within developed areas of the city.

The GCO in its current state is not constraining housing maintenance, improvement, or development.

Several large developments could occur simultaneously before depleting the existing balance of housing unit allocations. However, should several years of strong residential development occur during the planning period, it is possible the GCO could constrain housing development in the mid- to long-term, especially for larger mixed-use developments with many units. Developments of this sort are essential to meeting Pacifica’s housing needs, especially for affordable housing units for extremely low-, very low-, and low-income families, seniors, and persons with disabilities.

B. Nongovernmental Constraints
Many nongovernmental factors can constrain the maintenance, improvement, and construction of housing. Factors include access to financing, costs of land and construction, and community opposition.
i. Availability of Financing
Housing prices continue to recover from the devastating economic downturn that occurred during the Great Recession starting in 2007. The median sales price of a single-family detached home in 2007 was $841,860, while in 2012 it was down to $535,846 (in 2013 dollars). The median sales price for a singlefamily attached home was similarly depressed, falling from $589,120 in 2007 to $314,363 in 2012.

Falling housing prices makes access to financing for purchases more difficult for home buyers. Lenders face uncertainty about the future value of the property serving as collateral for the loans, and as a result are less likely to lend to prospective purchasers. This limits the ability of purchasers, especially those with lower incomes or imperfect credit histories, to pursue home ownership. When individuals and families are unable to access financing to purchase homes, residential developers in turn are less likely to pursue permits for housing developments. The cycle results in fewer home ownership opportunities for Pacificans.

Limited access to financing not only affects home buyers and residential developers, but it also affects existing owners seeking to maintain or improve their housing. Financing plays an important role in funding additions to accommodate growing families or aging family members. It also helps with renovations and upgrades to beautify or improve energy efficiency of the housing stock.

Unfortunately, the City of Pacifica can do little to affect the mortgage lending market. Until mid-2008, home mortgage financing was readily available at attractive rates throughout San Mateo County and California. Rates varied, but ranged from 6.25 percent to 7 percent from 2006-2008 for a 30 year fixed rate loan (HSH Associates Financial Publishers).13 Starting in late-2008, it became difficult to
obtain a home purchase loan, even though the average interest rate had fallen to around 5 percent. In

13Source: San Mateo County Department of Housing and Baird + Driskell Community Planning.

City of Pacifica Housing Element: 2015-2023
58 particular, people with short credit histories, lower incomes, or self-employment incomes, or those with other unusual circumstances, have had trouble qualifying for a loan or were charged higher interest rates.

Small changes in the interest rate for home purchases can dramatically affect affordability. A 30- year home loan for $400,000 at 5 percent interest would result in monthly payments of roughly $2,150. A similar home loan at 7 percent interest would result in payments of roughly $2660, an increase of more than 20 percent.

Many builders have also struggled recently to find construction loans for residential properties.

Complicated projects, like mixed-use developments, are often the hardest to finance. Nonprofit developers find it especially difficult to secure funding from the private sector. In past years, lenders would provide up to 80 percent of the cost of new construction. Yet in recent years, due to market conditions and government regulations, banks require larger investments by builders. All of these factors combine to constrain residential development in Pacifica. ii. Land Costs
The cost of land is one of the most basic elements of housing development. The more expensive the underlying land, the more expensive the resulting units for prospective purchasers or renters. Opinions vary as to the relative importance of land costs in contributing to housing price increases, although the price of land undoubtedly plays a major role.14
For example, in 1990 a standard size (5,000 square feet) vacant infill lot in Pacifica, zoned for residential use, sold for $150,000 to $175,000 (in 2013 dollars).

In 2001, a similar lot sold for $165,000 to $295,000 (in 2013 dollars). In 2009 a standard lot for residential use sold for $325,000 to $540,000 (in 2013 dollars). 15 Prices have moderated for some inland lots, with several selling for approximately $155,000 in 2014. Still, land prices in Pacifica are high, equating to well over a $1,000,000 per acre based on recent sales data. It is difficult to estimate the cost of land zoned for multi-family residential development since so few vacant sites exist.

However, an estimate of $107,000 to 200,000 per unit is generally considered satisfactory.16 iii. Construction Costs
According to the Pacifica Building Division, in 2014 the cost of developing a 2,000 square foot singlefamily residence in Pacifica ranged from $180 to $220 per square foot, including the price of land.

Construction costs for multi-family developments ranged from $150 to $200 per square foot. Costs vary depending upon the type of construction, building materials, and quality of finishes. Soft costs, such as architectural and engineering services, development fees, etc., usually comprise an additional 10 to 15 percent of the construction and land costs. The City attempts to mitigate the cost of construction of affordable rental and ownership housing through granting density bonuses and allowing second residential units.

14Schwartz, Seymour and Johnson, Robert, Local Government Initiatives for Affordable Housing, U.C. Davis, 1981. 15Estimate based on August 2009 MLS listings.
16Estimate based on August 2009MLS listings.

City of Pacifica Housing Element: 2015-2023
59 iv. Community Opposition
Community opposition can be a significant obstacle to obtaining approvals for new housing developments. Traffic, parking, and/or visual impacts are usually the greatest concerns of residents opposed to new developments. Among the visual impacts that are most sensitive in Pacifica is the concept of “private open space.” Many residents have become accustomed to certain privately-owned properties in their neighborhoods remaining undeveloped for many years. These undeveloped properties have served as open space for them, and there is a perception they will remain indefinitely in this state. However, these properties are owned by private individuals who may have expectations of development and corresponding financial returns. When owners finally unveil development plans, resident opposition can be fierce. Affordable housing developments also elicit community concerns about crime and property values. Residents can exert significant political pressure on the elected City Council to oppose developments on vacant land or affordable housing developments. Unknown likelihood of approval or a bruising public engagement process that could tarnish a developer’s reputation can discourage new developments in these circumstances. The City can strive to provide accurate information on all aspects of new developments, but cannot always satisfy resident concerns and quell community opposition.

C. Other Constraints
Pacifica has two constraints to development which are not governmental or nongovernmental limitations. They include geologic hazards and highway capacity. i. Geological Hazards
In January 1982, Pacifica experienced widespread and severe landslides and flooding which caused loss of life and significant property damage. These events caused Pacifica to undertake a new approach to development, including instituting a new geological review process and retaining an independent engineering and geology firm to review all hillside projects. According to Pacifica's geotechnical consultant, slope stability has been overrated in the past in Pacifica, and standards used to evaluate hillside development must be reassessed and strengthened. Pacifica's Seismic and Safety Element (adopted in September 1983) addressed and assessed these geologic events.

Pacifica also experienced coastal bluff retreat of approximately 75 feet in some areas as a result of winter storms during 1983 and 2009. Areas previously considered stable were undercut, houses and trailers were damaged, destroyed, or had to be relocated further inland. Coastal bluff retreat continued throughout 2014 in the northwest section of the City west of Esplanade Avenue. Several apartment buildings have been deemed uninhabitable, and another is at risk of becoming uninhabitable if bluff retreat continues. City staff continues to encourage property owners to implement mitigation measures to prevent the loss of valuable rental housing stock and to restore habitability to those units already lost.

The City now recognizes that geologic hazard mitigation will be required in many areas of Pacifica.

This may affect the timing, location, and intensity of future development. For example, geologic studies of some bluff top properties may result in lowered densities by reducing the amount of net developable acreage. Additionally, densities on inland sloping properties may be affected where geologic studies indicate that the revenue produced by locating units to achieve maximum densities City of Pacifica Housing Element: 2015-2023
60 does not justify the cost of providing engineering solutions sufficient to achieve those densities. In these cases, hazard avoidance may be the only acceptable mitigation measure because mitigation of both on- and off-site geotechnical hazards is a requirement of project approval or building permit issuance.

Pacifica expects that mitigation of existing and potential geologic hazards will, to some extent, reduce its growth rate; however, this effect cannot be quantified at this time, since these constraints are to some extent site specific. It is possible that land use designations may be revised to reflect changed conditions and policies, and this, too, may constrain Pacifica's future housing development potential. ii. Highway Capacity
The primary north-south traffic corridor to, from, and through Pacifica is State Highway 1. The roadway is also known as Coast Highway and Cabrillo Highway. In 1978, Caltrans noted that considerable vehicular and pedestrian traffic was present (Report of Engineering and Traffic Survey - March 31, 1978). Studies prepared in 1979 (Mori Point Project and Rockaway Beach Condominiums Draft Environmental Impact Reports) indicated that service at critical intersections was at or below Level of Service (LOS) D. Roadway operation at LOS D results in unstable flow and tolerable delays.

The Environmental Impact Report (EIR) for each anticipated development concluded that without mitigation, roadway operation would drop to LOS E and possibly LOS F (unacceptable and intolerable congestion and delays).

The 1985 Rockaway Beach Redevelopment Plan EIR indicated that the Highway 1/Reina Del Mar intersection operated at LOS E and F during both A.M. and P.M. peak hours. While the Highway 1/Fassler Avenue intersection operated at LOS E in the A.M. peak hour and LOS C in the P.M. peak hour, the EIR also described alternative Highway 1 improvement options to improve roadway operations.

More recent traffic studies and impact analyses along Highway 1 between Reina Del Mar and Fassler Avenue confirmed that the level of service at the Highway 1/Reina Del Mar intersection operated at LOS F during A.M. and P.M. peak hours while the Highway 1/Fassler Avenue intersection operated at LOS F in the A.M. peak hour and LOS C in the P.M. peak hour. The City has long held that LOS C (stable flow, acceptable delay) or better is a satisfactory level of service for Highway 1 and facilitates movement and commerce while preserving public safety.

In response to the ongoing peak hour congestion on Highway 1, Caltrans has proposed highway widening improvements between Westport Drive and Fassler Avenue. Known as the “Calera Parkway Project,” it would (if ultimately constructed) add a third lane for both northbound and southbound traffic along Highway 1 between the intersection with Reina Del Mar and the intersection with Fassler Avenue. Caltrans expects the project would improve peak hour traffic level of service to LOS C from the current LOS F. Construction of the project is not a certainty, however. In mid-2013, opponents of the highway widening challenged Caltrans’s Environmental Impact Report (EIR) for the project in Superior Court. After conclusion of the trial, the Superior Court took no action to stop the project, and instead issued a ruling rejecting the petitioners’ claims on March 10, 2015. Despite the Court’s ruling to allow Caltrans to continue preparations for the project, the agency has yet to obtain approval of all required permits for the Calera Parkway Project. Whether the Calera Parkway Project is eventually City of Pacifica Housing Element: 2015-2023
61 constructed or not, the City should still identify the constraint that traffic flow on Highway 1 may pose to future housing development.

Another important roadway within Pacifica is Sharp Park Road. Sharp Park Road is the city’s major east-west thoroughfare, handling approximately half of the total peak hour trips leaving Pacifica each day. Drivers exit Highway 1 at Sharp Park Road to drive towards South San Francisco, San Bruno, and other Peninsula cities along Skyline Boulevard or Interstate 280. The remainder of trips continue northbound on Highway 1 to San Francisco or the East Bay via Interstate 280. In the fall of 1990 the reconstruction of lower Sharp Park Road commenced. Construction lasted for one year and was reopened in 1991. This new section of Sharp Park Road now has 2 lanes for both westbound and eastbound traffic directions. The improvement resulted in a roadway with greater capacity that is less winding and safer to travel due to a new concrete median barrier. However, severe slopes along the roadway limit opportunities for future widening, and this could be a major constraint on housing development.

D. Mitigation of Constraints
The City has a strong interest in mitigating constraints on the maintenance, improvement, and development of housing. Its residents need adequate and affordable housing options so persons with extremely low, very low, and low incomes can pursue their livelihoods and care for their families.

Quality housing development can strengthen the community and the economy, enhancing the already desirable character of Pacifica. The summary below addresses the City’s attempts to mitigate the constraints identified above. Some constraints are extremely difficult to mitigate, but the City will continue to consider ways to promote appropriate housing development. i. Governmental Constraints
Land Use Controls
Exemptions from Standards
Pacifica’s Zoning Code contains provisions that allow relief from the strict application of development standards. Allowing flexibility for developers can result in lower construction expenses or higher densities, which lead to more housing units affordable to persons with extremely low, very low, and low incomes. In extreme cases, relaxing a particular requirement can mean the difference between pursuing project approvals and abandoning a housing development altogether.

The Planning Director, acting as the Zoning Administrator, may grant Minor Modifications to standards governing area, yard requirements, distance between buildings, lot coverage, fence/wall height, and off-street parking. Modifications approved by the Zoning Administrator may not exceed 20 percent of the respective standards, except in the case of off-street parking, where a reduction of one space is allowable.

When circumstances warrant a greater departure from development standards, the City may grant a permit known as a Variance. A Variance authorizes any deviation from zoning regulations the City of Pacifica Housing Element: 2015-2023
62 Planning Commission finds is necessary to allow a property owner to enjoy the same privileges enjoyed by other owners with similarly situated property. The main limitation to a Variance is that it may not authorize a use not permitted by the zoning of the subject site.

The Planning Commission may grant a Variance only if it finds:
1) That because of special circumstances applicable to the property, including size, shape, topography, location, or surroundings, the strict application of the provisions of this chapter deprives such property of privileges enjoyed by other property in the vicinity and under an identical zoning classification;
2) That the granting of such variance will not, under the circumstances of the particular case, materially affect adversely the health or safety of persons residing or working in the neighborhood of the subject property and will not, under the circumstances of the particular case, be materially detrimental to the public welfare or injurious to property or improvements in the area; 3) Where applicable, that the application is consistent with the City's adopted Design Guidelines; and
4) If located in the Coastal Zone, that the application is consistent with the applicable provisions of the Local Coastal Plan.

Definition of "Family"
The term "single-family residential" can be confusing or misleading in some cases. In the traditional sense a family includes members such as parents, their children, and perhaps an elderly relative for whom the family provides care. The City's Zoning Code does not define a family in these same terms, however. The City has a more flexible definition that respects different associations of individuals, whether related by blood or not, that choose to live with one another.

The Zoning Code defines "family" as "one or more persons occupying a premises and living as a single housekeeping unit, as distinguished from a group occupying a hotel, club, or fraternity or sorority house. A family shall be deemed to include necessary servants." Pacifica's definition of family does not discriminate against unrelated individuals living within a single dwelling unit, whether in a singlefamily or multi-family residential development. The only requirement to qualify as a "family" is that the individuals living together must function as a single housekeeping unit. Generally, this means cooking and sharing meals in a common kitchen as well as sharing other housing-related expenses with one another (i.e. utility bills, insurance, groceries). Pacifica’s definition of “family” provides flexibility to those seeking adequate, affordable housing. These persons can safely and lawfully form a household with unrelated persons in order to share housing-related expenses.

City of Pacifica Housing Element: 2015-2023
63 ii. Nongovernmental Constraints
Land & Construction Costs
Allowances for Residential Uses in Commercial Zoning Districts Most of the City’s future housing development potential lays in commercially-zoned sites. The days of large tract housing development on vacant sites are over in Pacifica. The few remaining vacant sites zoned for residential development are small, fragmented, and often have geological challenges to development. Therefore, it is important to consider commercial sites for their ability to meet Pacifica’s future housing need.

The City permits housing development in several commercial zones, most notably the C-1 (Neighborhood Commercial) and C-2 (Community Commercial) zones. Residential development in commercial districts must have a mixed-use configuration with residential uses above ground floor commercial spaces. Approval of mixed-use housing developments is not by-right, but is subject to approval of a Conditional Use Permit and Site Development Permit. Table II-31 indicates the development standards for residential uses in the City’s main commercial zones. For clarity in presentation below, the table will only display standards for the C-1 and C-2 districts. The Zoning Code applies standards from the C-1 district to developments in the C-1-A district and from the C-2 district to developments within the C-R and O districts.

TABLE II-31
Allowances for Housing in Commercial Districts
Zoning District
Standard C-1 & C-2
Lot Area (min.) 5,000 sq. ft.

Lot Area Per Dwelling Unit (min.) 2,000 sq. ft.

Lot Width (min.) 50’
Setbacks (min.) None, unless req’d by Site
Development Permit
Maximum Lot Coverage None
Landscaped Area (min.) 10%
Usable Open Space Per Unit (min.)17 450 sq. ft.

Height (max.) 35’
Parking Spaces (min.) 1 per studio; 1.5 per 1 BR; 2 per 2+ BR; and, 1 guest per 4 units
Source: Pacifica Municipal Code, Title 9, Chapter 4 “Zoning” Development standards in commercial zones are generally favorable to mixed-use (residential and commercial) development. These commercial zones have no front, side, or rear setbacks, no floor area ratio limitations, and no lot coverage limits. The flexibility inherent in these regulations create larger developable areas than comparably sized residential sites, helping to mitigate land costs, construction costs, and delays associated with processing and permitting. Larger developable sites

17 Usable open space shall mean common or private outdoor living, recreation, domestic use, or landscaping. Such area may be on the ground or on, a roof, porch, deck, court, or balcony.

City of Pacifica Housing Element: 2015-2023
64 result in greater density, which in turn reduces the per-unit cost of development and ultimately can make housing more affordable to persons with extremely low, very low, and low incomes.

In terms of parking, multi-family units in mixed use projects are subject to the same requirements that apply to other multi-family dwellings. The requirements are cumulatively added to the requirements for the commercial portions of the project to determine the total number of spaces needed. In certain cases, the Planning Commission can grant a lower parking requirement if a developer can show the characteristics of uses within a development can offset parking demands from one another. For instance, certain commercial uses may have large parking requirements during business hours when many residents are away from the site at work. Correspondingly, during evening hours the residential use has a large parking demand while most businesses are closed.

Combined, the favorable treatment of mixed-use housing developments in commercial zones mitigates the constraints of land and construction costs. Given that the City is relying on commercial sites to accommodate housing, the City will encourage and facilitate residential development on commercial sites (mixed-use) for lower-income households.

Density Bonus Ordinance
The Density Bonus Ordinance, adopted in April 1984, offers the incentive of increased density and flexibility in development standards in exchange for housing which will meet the City's need to provide ownership and rental housing affordable to persons with extremely low, very low, and low incomes.

Multi-family residential projects can exceed their maximum density, reduce unit floor area, or provide less parking, if provision is made for rental housing, affordable housing, or housing for the elderly or persons with disabilities. The amount of the density bonus ranges from 15 percent for rental housing (including market rate projects) to 50 percent for housing affordable to persons with extremely low, very low, and low incomes, elderly persons, or persons with disabilities. The Density Bonus Ordinance ensures the continued availability of housing granted a density bonus by requiring deed restrictions or other legal arrangements on properties so developed.

Higher housing density combined with relaxed floor area and parking requirements allows developers to mitigate the constraints imposed by land and construction costs. Lower per-unit costs of construction can result in lower per-unit sales costs or rental rates, making housing more affordable to persons with extremely low, very low, and low incomes. An added advantage of the Density Bonus Ordinance is that it provides the greatest bonus for providing housing to the neediest groups: those with extremely low, very low, and low incomes, and seniors or persons with disabilities.

Pacifica’s Density Bonus Ordinance requires certain revisions to remain consistent with state law, and the City will undertake an action program to initiate the amendment.

Manufactured Housing
The City’s development standards allow construction of manufactured housing in any zoning district that permits single-family dwellings. The R-1 (Single-Family Residential) zoning district permits single-family dwellings by-right, and a property owner or developer can construct manufactured housing without undergoing discretionary review. In the R-2 (Two-Family Residential) and R-3 City of Pacifica Housing Element: 2015-2023
65 (Multiple-Family Residential) zoning districts, single-family dwellings – including manufactured housing – require a Use Permit.

The City enacted its Manufactured Housing Ordinance in January 1982. A manufactured house is a structure comprising two or more modules, including mobile homes, which is manufactured off-site and later assembled or installed on a property. Manufactured housing, by virtue of being mass-produced, can be significantly less expensive to develop and to purchase than traditional single-family structures.

The design of manufactured housing has improved greatly in recent years, and is a viable option for many lower-income residents. The City’s main requirement for manufactured housing is that it meets all California Building Code requirements so that the housing is safe.

Community Opposition
Study Sessions
The City offers study sessions to developers seeking to gauge community and Planning Commission receptiveness to various development proposals. Ahead of a study session, the City sends notices to property owners within 300 feet of a potential development site and holds a public meeting hosted by the Planning Commission. Commissioners, members of the public, and City staff have an opportunity to discuss details of the project in an informal setting. Developers can then build on feedback to revise their development proposals before investing substantial time in finalizing detailed plans.

Offering study sessions allows the City to help developers minimize review time and associated costs by identifying major issues prior to formal application processing. Study sessions fees for commercial projects are refundable if a developer pursues to final building permit inspection the entitlements covered in the study session. For mixed-use projects including housing, the fee refunded is proportional to the amount of the project dedicated to commercial use. iii. Other Constraints
Highway Capacity
Collection of Improvement Fees
Pacifica has established special funds for the deposit of impact fees to assist in the construction of needed improvements to meet or approach LOS C. Developers of residential projects must contribute a per-unit fee according to the location of their projects within the City. The primary impact area south of Westport Drive in the Fairway Park neighborhood requires relatively higher contributions per unit than the secondary impact area to the north. The fee schedule has been established because the majority of improvements will be necessary along the southern stretch of the highway. Until traffic flow along Highway 1 improves – either by roadway widening or other improvements – the City intends to control the timing of residential development through its Growth Control Ordinance.

City of Pacifica Housing Element: 2015-2023
66 8. Affordable Units at Risk
A potential threat to existing housing units affordable to persons with extremely low, very low, and low incomes is the termination of rental contracts by owners of properties subject to federal subsidy programs. Such contracts may be terminated through cancellation of a Section 8 contract ("opting out") after a certain number of years, or early pay-off of the interest loan after 20 years ("pre-payment").

Project owners who opt-out or pre-pay their rental contracts are free to rent at market rate or, with City approval, may convert rental units to condominiums or a nonhousing use.

The following analysis complies with Section 65583 of the Government Code, which requires that cities analyze and develop programs to preserve assisted housing developments:

A. Inventory of Units At-Risk of Losing Use Restrictions. i. Period of Analysis
This analysis includes the ten-year period between July 2015 and June 2025. a. July 2015 – June 2025
Pacifica has only one project subject to risk of losing use restrictions during this ten-year period. Relevant project information is provided below.

Project Name and Casa Pacifica
Address: 1060 Terra Nova Boulevard
Type of Assistance HUD Sec. 221(D)(3)
Received: Market Rate Interest Program
Earliest Date of January 10, 2020 (Opt-out Date)
Possible Change From
Low-Income Use:

Number of Elderly Elderly: 101
and Non-Elderly Non-Elderly: 1
Units:

Elderly units are assisted by the Section 8 New Construction rental Assistance Program.

Bedroom Mix: All units are one (1) bedroom
Building Age: Approximately 40 years old
Building Condition: Good - No rehabilitation necessary
City of Pacifica Housing Element: 2015-2023
67 How Units are at Risk: The owner has already renewed the Section 8 which was due on January 30, 2015. If the owner fails to renew its Section 8 participation by January 30, 2020, the project could lose its low-income use restrictions. The project could then be
"converted" to market rate units. One-bedroom units rented for $2,021 per month in 2015, an increase from $1,292 per month in 2014. The substantial increase reduced market pressure for the owner to discontinue participation in the Section 8 program. However, if annual increases allowed by HUD do not keep pace with market rates over the term of participation, the owner may at some point feel financial pressure to pursue greater financial returns.

Factors Which May
Eliminate or Reduce Risk: 1. Should the owner decide to "opt-out" of the Section 8 contract, this action would be subject to provisions of federal and state law designed to minimize hardship for the project's tenants.

2. The owner has had renewal options in the past (1987, 1992, 1997, 2005, 2010, 2015) and has always renewed.

3. An "opt-out" is only valid if a one-year notice is provided, allowing time to develop a strategy for preservation of units affordable to persons with extremely low, very low, and low incomes.

4. The Casa Pacifica project includes a condition of approval making the Use Permit valid only for a multi-family senior housing complex. Should the owner attempt to convert the project to non-senior housing, it would require a new Use Permit from the City. However, the condition of approval does not require that the owner maintains the units for low-income occupancy.

5. The City also granted the Casa Pacifica project a Variance from the required number of parking spaces on the condition that the property is used solely as residential housing for seniors.

Should the owner attempt to convert the project to non-senior housing, the Variance would no longer be valid and the parking would have to meet current standards. Alternatively, the property owner could request a new Variance. However, the condition of approval does not require that the owner maintains the units for low-income occupancy.

No other projects are "at risk" during this ten-year period.

City of Pacifica Housing Element: 2015-2023
68 B. Cost Analysis of Preserving Versus Replacing At-Risk Units i. Cost to Replace
It is estimated that replacing the Casa Pacifica units would cost approximately $14,962,967 ($150 per square foot plus $50,000 per unit). ii. Cost to Preserve
It is estimated that the cost to preserve the units would be substantially less than to replace due to the cost and scarcity of developable land and increased construction costs.

C. Resources for Preservation
i. Public Agency and Nonprofit Housing Corporations Listed below are agencies that have the ability to assist in preserving the Casa Pacifica project.  City of Pacifica
170 Santa Maria Avenue
Pacifica, CA 94044

 Mid-Peninsula Housing Coalition
303 Vintage Park Drive
Foster City, CA 94404

 National Church Residences
2335 North Bank Drive
Columbus, OH 43220

 BRIDGE Housing
600 California Street, Suite 900
San Francisco, CA 94108

ii. Public Financing and Subsidy Programs
Listed below are financing and subsidy programs that could be used to preserve the Casa Pacifica project for low-income use.
 Community Development Block Grant Program (CDBG) funds for the purpose of preserving low-income housing.

The City does not currently receive any CDBG funds for the purpose of preserving low-income housing.

City of Pacifica Housing Element: 2015-2023
69  Administrative fees (reserves) of any housing authority operating within the community.

There is no local housing authority operating within Pacifica.  Pacifica Housing Fund
The City has limited financial resources that in some instances may assist with preservation of senior housing units. The primary source of funding for affordable housing development or preservation in the future is expected to be the City’s in lieu housing fee. The City adopted an inclusionary zoning ordinance in April 2007 which contains a provision allowing developers to pay an amount of money "in lieu" of constructing an affordable unit. The in-lieu payment for each below market rate unit (BMR) shall reflect the estimated cost to provide the BMR unit.

D. Other Projects

Three other projects in Pacifica offer subsidized low-income housing for seniors. The Ocean View Apartments at 555 Crespi Drive are entirely occupied by seniors receiving Section 8 rental assistance.

However, the owners of the project (National Church Residences) have already fulfilled their mortgage obligations, and the City is not required to analyze the "at-risk" potential of the project. National Church Residences has previously expressed its commitment to continuing Section 8 rentals at the site.

Nevertheless, the City should continue to monitor the status of the Ocean View Apartments. As with the Casa Pacifica project, the City granted a Parking Variance to the Ocean View project on the condition that the project remains senior housing, and the Variance will become "null and void" if converted to market rate housing (and the site will require additional parking). This condition will encourage the maintenance of senior housing at the Ocean View project. If necessary, the City could use the resources noted above to help preserve the project for low-income use. In 2015, BRIDGE Housing was in the process of purchasing the project from National Church Residences. BRIDGE Housing is a non-profit affordable housing development and property management organization.

Another project for low-income seniors in Pacifica is the Pacific Oaks project at 750 Oddstad Boulevard. The covenants, conditions, and restrictions for Pacific Oaks run with the life of the project, and no preservation efforts by the City are necessary.

The Good Shepherd Senior Housing project has added an additional 42 units for the elderly population of Pacifica. The Good Shepherd project is located at 901 Oceana Boulevard and has restrictions protecting the status of the units as senior housing. No preservation efforts by the City are necessary.

9. Opportunities for Energy Conservation
In December 2013, the City of Pacifica adopted the state Green Building Standards Code in California Code of Regulations, Title 24, Part 11. These standards, more commonly known as the “Green Building Code,” regulate many aspects of construction to reduce the impacts of buildings on the environment. The City’s regulations are in conformance to statewide standards.

City of Pacifica Housing Element: 2015-2023
70 There are several benefits of green building:

Environmental benefits
 Reduces use of natural resources
Health and safety benefits
 Enhances occupant comfort and health, as well as that of the greater community
Community benefits
 Minimizes strain on local infrastructure, improves the quality of the building stock, and extends the useful life of structure
Economic benefits
 Improves the bottom line for owners, building professionals, and the community
Prior to its adoption of statewide standards, in May 2008, the City of Pacifica created a Citizens’ Green Building Task Force to provide a forum for development of “green building” regulations. The City thereafter developed and adopted its own Green Building Ordinance in late-2010. The City also adopted a Climate Action Plan in 2014 which identifies strategies to reduce energy consumption, thereby reducing greenhouse gas (GHG) emissions. The City of Pacifica has demonstrated a strong commitment to pursuing energy conservation in the built environment. (Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
71 III. LAND INVENTORY

1. Purpose
State housing law (Government Code Section 65583(a)(3)) calls for "an inventory of land suitable for residential development, including vacant sites and sites having potential for redevelopment and an analysis of the relationship of zoning and public services to these sites." In 2009, a City consultant completed a survey of vacant or undeveloped sites. These sites were identified by field surveys, aerial photographs, and County Assessor data. Despite being five years old, the survey remains valid due to the low-level of residential development in Pacifica during the interceding period.

Furthermore, no zoning changes with significance for housing development have occurred. Based on an updated review of the survey in 2015, the City has concluded that sufficient land exists to accommodate residential development within the eight-year planning period covered by this Housing Element update.

The following section summarizes the survey results and identifies sites in Pacifica where development of housing can occur within the current housing element planning period. More detailed site specific information is available in the "Pacifica General Plan Existing Conditions and Key Issues” report from July 2010.

2. Sites Available Within the Eight-Year Planning Period The land identified in the survey is designated in the Land Use Element of the General Plan for residential or mixed-use (commercial/residential) development, and public services are available to all the sites. For the eight-year planning period covered by this Housing Element, the 2009 survey referenced above indicated that adequate land is available for Pacifica to meet its regional housing needs. Many of the sites are easily served with utilities and roads, are close to community services and shopping, have no major physical hazards, would be consistent with adjoining development, and are zoned for residential development. These sites can also accommodate housing for all income levels.

For a discussion of farm worker housing, see Section II.6.H.

It should be noted that the survey did not include second unit potential or density bonuses. Significant variability in the factors contributing to eligibility and suitability for second units and density bonuses made such analysis infeasible. Therefore, the potential number of new units presented for each site could be higher than the range of units presented in the survey.

At the time of adoption of the 2015-2023 Housing Element, the City was in the process of updating its General Plan, including the Land Use Element. Some General Plan land use designations affecting housing may change if the City Council adopts the draft Land Use Element of the General Plan in its current form. Notably, the residential component permissible in all “Commercial” designations in the current General Plan may be consolidated within new mixed use designations in the draft Land Use Element of the General Plan. The result would be that housing would be allowed in fewer areas of the city but at higher densities. In order to circumvent the need to amend the Housing Element after adoption of a new Land Use Element, the Housing Element contains two maps and two tables of potential housing development sites. The first map/table set identifies sites suitable for housing City of Pacifica Housing Element: 2015-2023
72 development under the current Land Use Element of the General Plan, adopted in 1980. The second map/table set identifies sites suitable for housing development under the draft Land Use Element of the General Plan if it is adopted in its current form (March 2014 version). The City will take appropriate steps to ensure General Plan consistency and RHNA accommodation within the Housing Element if there are any changes to the draft Land Use Element of the General Plan that affect the housing sites identified below.

Figure III-1 displays the locations of potential housing sites suitable under the current Land Use Element of the General Plan, and Table III-1 summarizes site-specific details pertaining to the development potential of these sites. The City has identified sites capable of accommodating 434 housing units.
(Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
73 City of Pacifica Housing Element: 2015-2023
74 TABLE III-1
Potential Housing Development Sites – Current General Plan18 Site APN
Location/
Condition Zoning
General Plan
Designation
Lot Area
(Acres)
Allowable
Density
Allowable
Units (#) Existing Use
1 009-412-060 Hack’s Auto
Body/Flat C-1/CZ Commercial .230 21.8 du per acre
5 Commercial
2 009-132-020 Rainbow Island
Restaurant/Flat C-1/CZ Commercial .18 21.8 du per acre
4 Commercial
3 009-132-030 Pacifica
Tribune/Flat C-1/CZ Commercial .23 21.8 du per acre
5 Commercial
4 009-132-040
Pacific Manor
Multi-tenant
Commercial/
Flat
C-1/CZ Commercial .32 21.8 du per
acre
7 Commercial
5 009-132-050
U Save Liquors
& Pamper Me
Nail Spa/Flat
C-1/CZ Commercial .20 21.8 du per
acre
4 Commercial
6 009-134-330
009-134-340
009-134-350
009-134-360
009-134-390
009-134-400
009-134-410
009-134-520
Pacific Manor
Shopping
Center/Flat
C-1 Commercial 2.1 21.8 du per
acre
46 Commercial
7 009-162-590
Save More
Meat
Market/Flat
C-1/CZ Commercial .157 21.8 du per
acre
3 Commercial
8 009-381-010 Monterey &
Norfolk/Flat R-3 LDR 1.0 8.7 du per acre
9 Vacant
9 009-253-280
Spanky’s
Restaurant/
Partially Flat &
Partially
Moderate
slopes
C-2 Commercial .662 21.8 du per
acre
14 Commercial &
Vacant

18 The height limit for all potential housing development sites is 35 feet above grade.

City of Pacifica Housing Element: 2015-2023
75 Potential Housing Development Sites – Current General Plan18 10 009-245-010
Oceana Blvd
& Connemara
Dr/Moderate
slopes
C-1 Commercial 2.67 21.8 du per
acre
58 Vacant
11 009-320-200 Oil
Changers/Flat C-1
Commercial &
MDR .512

21.8 du per
acre/15 du
per acre
9 Commercial
12 016-041-090
El Grano de
Oro
Restaurant/Flat
C-1/CZ Commercial .119 21.8 du per
acre
3 Commercial
13 016-
Francisco
Blvd/Flat C-1/CZ Commercial .183 21.8 du per acre
4 Commercial
14 016-032-310
Palmetto Ave
& Santa Maria
Ave/Flat
R-3 &
C-1/CZ Commercial &
HDR .360 21 du per acre
8 Vacant
15 016-050-050
Salada Ave
b/t Beach Blvd
& Palmetto
Ave/Flat
R-2/CZ MDR .207 15 du per
acre
3 Vacant
16 016-060-110
016-060-120
Pacifica Thai
Cuisine/Flat C-1/CZ
Mixed Use
(HDR &
Commercial)
.135 21 du per
acre
3 Commercial
17 016-191-320 Seahorse
Saloon/Flat C-1/CZ Commercial .186 21.8 du per acre
4 Commercial
18 016-192-320
Montecito Ave
& Palmetto
Ave/Flat
C-1/CZ Commercial .31 21.8 du per
acre
7 Vacant
19 016-204-020
016-204-999
016-
Beach
Blvd/
Flat
P-D/CZ
Mixed Use
(HDR &
Commercial)

3.5 21 du per
acre
74 Public Facility
20 016-211-180
Hilton Way &
Francisco
Blvd/Flat
C-1/CZ
Mixed Use
(HDR &
Commercial)
.117 21 du per
acre
2 Vacant
City of Pacifica Housing Element: 2015-2023
76 Potential Housing Development Sites – Current General Plan18 21 016-400-280 7-Eleven Sharp
Park/Flat C-1/CZ Commercial .23 21.8 du per acre
5 Commercial
22 016-355-150 Clarendon/Flat R-1 LDR 1.35 8.7 du per
acre
12 Vacant
23 022-012-020
Rock/
Moderate
slopes
C-1+ Commercial 2.87 21.8 du per
acre
63 Vacant
24 022-042-260
022-043-010
022-043-020
022-043-200
022-043-220
022-045-010
022-045-999
Fassler
Ave/Moderate
slopes
C-1 VLDR 2.65 2 du per
acre
5 Vacant
25 022-142-140 575 Crespi
Drive/Flat C-1 Commercial .36 21.8 du per acre
8 Commercial
26 023-222-080 Adobe/Flat R-3-G HDR .418 21 du per
acre
9 Vacant
27 023-593-140 Sanchez
Library/Flat C-1 Commercial 2.77 21.8 du per acre
60 Library
Source: City of Pacifica, 2015; San Mateo County, 2009; Dyett & Bhatia, 2009.

Note: Maximum building height for all sites is 35 feet under current zoning.

Figure III-2 displays the locations of potential housing sites suitable under the draft Land Use Element of the General Plan (March 2014 version), and Table III-2 summarizes site-specific details pertaining to the development potential of these sites. The City has identified sites capable of accommodating 494 housing units. These sites will not take effect in the Housing Element unless and until the City Council adopts an updated Land Use Element so designating the sites in Table III-2.

City of Pacifica Housing Element: 2015-2023
77 City of Pacifica Housing Element: 2015-2023
78 TABLE III-2
Potential Housing Development Sites – Draft General Plan19 Site APN
Location/
Condition Zoning
Draft General
Plan
Designation
Lot
Area
(Acres)
Allowable
Density
Allowable
Units (#) Existing Use
1 009-132-020 Rainbow Island
Restaurant/Flat C-1/CZ Mixed Use Neighborhood .18 26 du per acre 5 Commercial
2 009-132-030 Pacifica
Tribune/Flat C-1/CZ Mixed Use Neighborhood .23 26 du per acre 6 Commercial
3 009-132-040
Pacific Manor
Multi-tenant
Commercial/
Flat
C-1/CZ Mixed Use
Neighborhood .32 26 du per acre
8 Commercial
4 009-132-050
U Save Liquors
& Pamper Me
Nail Spa/Flat
C-1/CZ Mixed Use
Neighborhood .20 26 du per acre
5 Commercial
5 009-134-330
009-134-340
009-134-350
009-134-360
009-134-390
009-134-400
009-134-410
009-134-520
Pacific Manor
Shopping
Center/Flat
C-1
Mixed Use
Neighborhood 2.1 26 du per acre
55 Commercial
6 009-162-590
Save More
Meat
Market/Flat
C-1/CZ Mixed Use
Neighborhood .157 26 du per acre
4 Commercial
7 016-032-310
Palmetto Ave
& Santa Maria
Ave/Flat
R-3 &
C-1/CZ Mixed Use
Neighborhood .360 26 du per acre
9 Vacant
8 016-050-050
Salada Ave
b/t Beach Blvd
& Palmetto
Ave/Flat
R-2/CZ MDR .207 15 du per
acre
3 Vacant
9 016-060-110 &
016-060-120
Pacifica Thai
Cuisine/Flat C-1/CZ Mixed Use Center .135 50 du per acre 7 Commercial

19 The height limit for all potential housing development sites is 35 feet above grade.

City of Pacifica Housing Element: 2015-2023
79 Potential Housing Development Sites – Draft General Plan19 10 016-220-150 U.S. Bank/Flat P
Mixed Use
Center .322 50 du per acre
16 Commercial
11 016-191-320 Seahorse
Saloon/Flat C-1/CZ Mixed Use Neighborhood .186 26 du per acre 5 Commercial
12 016-192-320
Montecito Ave
& Palmetto
Ave/Flat
C-1/CZ Mixed Use
Neighborhood .31 26 du per acre
8 Vacant
13 016-204-020
016-204-999
016-
Beach
Blvd/
Flat
P-D/CZ Mixed Use
Center 3.5 50 du per acre
8420 Public Facility
14 016-211-180
Hilton Way &
Francisco
Blvd/Flat
C-1/CZ Mixed Use
Neighborhood .117 26 du per acre
3 Vacant
15 016-400-280 7-Eleven Sharp
Park/Flat C-1/CZ Mixed Use Neighborhood .23 26 du per acre 6 Commercial
16 016-355-150 Clarendon/Flat R-1 LDR 1.35 9 du per
acre
12 Vacant
17 022-042-260,
022-043-010,
022-043-020,
022-043-200,
022-043-220,
022-045-010,
022-045-999
Fassler
Ave/Moderate
slopes
C-1 LDR 2.65 9 du per
acre
24 Vacant
18 022-142-140 575 Crespi
Drive/Flat C-1
Mixed Use
Neighborhood .36 26 du per acre
9 Commercial
19 022-162-350
022-162-380
Crespi
Storage/Flat C-3
Mixed Use
Center 1.357 50 du per acre
68 Commercial

20 The City Council’s approval on September 23, 2013, limited the site to no more than 84 housing units, less than the maximum permissible General Plan density.

City of Pacifica Housing Element: 2015-2023
80 Potential Housing Development Sites – Draft General Plan19 20 022-171-190
Crespi
Shopping
Center/Flat
C-1/P Mixed Use
Center 1.51 50 du per acre
76 Commercial
21 023-222-080 Adobe/Flat R-3-G HDR .418 21 du per
acre
9 Vacant
22 023-593-140 Sanchez
Library/Flat C-1
Mixed Use
Neighborhood 2.77 26 du per acre
72 Library
Source: City of Pacifica, 2015; San Mateo County, 2009; Dyett & Bhatia, 2009.

Note: Maximum building height for all sites is 35 feet under current zoning.

A. Environmental and Physical Constraints
Environmental constraints known to the City that could affect residential development in areas planned for such use are the potential presence of the San Francisco garter snake and the California red-legged frog. These species are present in various locations throughout Pacifica, and only site-specific biological analysis can confirm their presence. When biological investigations for earlier developments have located populations of these species, the City has worked with developers to provide mitigation by protecting potential affected areas of habitat for these species. Mitigation has included altering development plans so as not to disturb site areas comprising habitat. Although the City does not consider the presence of these species a significant constraint to the accommodation of the City's share of regional housing needs, identification of these species at any given housing development site could be quite impactful on an individual project basis.

Physical constraints to housing development in Pacifica include hillside erosion, coastal erosion, and seismic hazards. Landslides and slope failures can result from any of the listed hazards and have presented serious problems in the past. The City is unaware of any immediate or direct threat to any of the identified housing sites from these constraints, but further geological analysis as part of a development review process could jeopardize initial site plans. Unstable or unsuitable soils for development could reduce maximum density at housing sites. It is possible, however, to address most physical constraints of this sort through enhanced engineering techniques and appropriate residential design. The trade-off to this approach is greater development expense, which can jeopardize housing affordability. None of the sites identified for residential development during the planning period are within known hazard areas. Seven of the selected sites, however, are identified in the Open Space Task Force report as candidates for preservation. These parcels include the Calson, Fish, Hacienda Court/Place, Lower Gypsy Hill, Rock, San Pedro Road, and Zeebros properties. Although these properties have been identified in the Open Space Task Force report as candidates for preservation, they have not been designated as open space and there are no development limitations imposed on these properties.

City of Pacifica Housing Element: 2015-2023
81 All sites identified for residential development are within existing service areas for water, sewer, and electrical utilities. The City is unaware of any service limitations that would affect any of the residential development sites.

B. Zoning Appropriate to Accommodate Lower Income Housing Government Code Section 65583.2 provides two options to demonstrate zoning appropriate to accommodate housing affordable to lower income households. A jurisdiction may provide an analysis demonstrating how identified zoning and densities encourage and facilitate the development of housing for lower income households, or may utilize a default density deemed appropriate for the jurisdiction.

State law specifies the default density for Pacifica as 30 units per acre based on its “metropolitan” location within a Metropolitan Statistical Area (MSA) with a population of 2,000,000 or greater.

However, Pacifica’s highest density residential designation allows 16-21 units per acre, less than the State’s default density. Therefore, the City will not rely upon the default density method, and instead will conduct the alternative analysis.

The following analysis, based on factors including market demand, financial feasibility, and development project experience, will demonstrate Pacifica’s existing adopted densities are appropriate to accommodate housing affordable to lower income households, including those with extremely low, very low, and low incomes.

As indicated above, the City is relying primarily on sites with High-Density Residential (HDR) and Commercial land use designations within its General Plan. The corresponding zoning for these sites is R-3, R-3-G, C-1, or C-2. The HDR land use designation has a minimum density of 16 units per acre.

When combined with R-3 zoning, R-3/HDR sites allows up to 21 units per acre, the maximum permissible density under the HDR designation. Sites with Commercial land use designations have no minimum residential density. The maximum density of Commercial sites with C-1 or C-2 zoning is 22 units per acre. The calculated maximum densities for each site in Table III-1, above, are realistically attainable, as will be shown in the analysis that follows.

Affordable housing developers have stated that Pacifica’s adopted densities are appropriate for the City and that several developments at similar densities have been constructed in jurisdictions similar to Pacifica. The City evaluated its current multi-family development standards and on-site improvement requirements (e.g., setbacks, building height, parking and open space requirements, commercial component requirement in commercial zones), and determined that maximum densities could be obtained in R-3, R-3-G, C-1, and C-2 zones. As an example, using a typical site plan design for a threestory mixed-use development on a .96-acre site with a 35-foot building height requirement, 2 parking spaces per unit parking, and 450 square feet per unit open space requirement, maximum densities of 21 or more units per acre can be achieved.

Supporting the realistic capacity estimates are the high land costs. For example, residential parcels in Pacifica in 2014 cost over $1,000,000 per acre, with associated construction costs exceeding $150 per square foot (Section II.7.B). These costs promote development at maximum densities to make multifamily residential development economically feasible by maximizing the number of residential units per acre.

City of Pacifica Housing Element: 2015-2023
82 In addition, a review of recent multi-family residential developments approved and constructed reveal that multi-family developments, as a result of incentives for housing affordable to lower income households and a local density bonus, achieved densities greater than the maximum density of 21 units per acre. This is a direct result of City efforts to assist developers in making residential development economically feasible in a high cost area by maximizing density. See Table III-3.

TABLE III-3
Actual Build-out Density
Name Zoning
Site
Acreage
Allowable
Density
Per Acre
Approved/
Constructed
Units Per
Acre
Allowable
Units at Site
Approved/
Constructed
Units at Site
Casa Pacifica R-3 2.25 21 45 47 101
Cypress Walk P-D 10.34 21 9 217 95
Oceano R-3 1.334 21 31 28 42
Ocean View R-3 1.51 21 66 32 100
Pacifica Oaks R-3 3.965 21 26 83 104
Source: City of Pacifica Planning Department, 2014
In addition to State Density Bonus Law, the City’s Density Bonus Ordinance offers the incentive of increased density and flexibility in development standards in exchange for housing which will help meet the City’s need to provide rental housing and housing affordable to persons with extremely low, very low, and low incomes. Multi-family residential projects can exceed their maximum density if provision is made for rental housing, affordable housing, housing for seniors, or housing for persons with disabilities. The amount of the density bonus ranges from 15 percent for entirely rental housing to 50 percent for housing affordable to persons with extremely low, very low, and low incomes, seniors, or persons with disabilities. The ordinance allows, in addition to a density increase, a reduction in the floor area of affordable units and a relaxation of City parking standards. This has resulted in densities that exceed those allowable under the density bonus alone.

Commercially Zoned Sites
As discussed earlier, the City’s Commercial-zoned sites will accommodate a majority of the housing need for lower income units based on the minimum and average expected densities. The City based this conclusion upon two assumptions: First, most sites identified in districts allowing mixed-use (C-1, C-2 and C-R), will be developed with residential components, and second, developers will build to the average expected densities for each of these districts.

The first of these assumptions is prudent in light of recent trends. As shown in Table III-4, all recently proposed mixed use projects in Commercial zone sites were almost exclusively residential use projects.

City of Pacifica Housing Element: 2015-2023
83 The commercial to residential ratios show that the developments were more residential and commercial uses were only proposed on ground floors that faced a major street. Additionally, every project listed in Table III-4 exceeded the average allowable density of the zone it was located in.

TABLE III-4
Recent Mixed-Use Developments
Address
Commercial
Area (sq. ft.)
Residential
Area (sq. ft.)
Commercial-toResidential Ratio
1267 Danmann Ave 800 3,600 18%
1275 Danmann Ave 800 1,700 47%
411 Dondee Way 1,158 3,118 27%
2270 Palmetto Ave 1,235 3,246 27%
2304 Palmetto Ave 650 3,480 16%
2307 Palmetto Ave 3,245 4,969 39%
2310 Palmetto Ave 605 1,390 30%
2318 Palmetto Ave 2,018 4,056 33%
Source: City of Pacifica Planning Department, 2014
There are several other reasons why the majority of commercial sites are likely to develop as mixed-use projects during the planning period:

1. Mixed use zones have minimal commercial component requirements.

2. The City supports housing in the City’s mixed-use areas.

3. The General Plan supports residential development in mixed-use areas with incentives and programs for reduced parking and other cost-reducing measures.

4. The majority of mixed-use sites are not prime corner sites favored by commercial establishments.

5. The sites are located in close proximity to other sites where new residential development has been built or approved.

Thus, it is reasonable to assume that while not all future mixed-use sites will be developed as majority residential-use projects, the vast majority of them will be developed as such with densities at or above the average allowable densities. As mentioned previously, high land costs in Pacifica will require developers to maximize density in order to ensure sufficient returns on their investments. Finally, the City’s Draft General Plan amendment that is underway also suggests increasing housing densities to as many as 50 units per acre in one of the new mixed-use designations that would be created.

Small Sites
Many of the available vacant sites identified by the City are located on smaller parcels. While it can be difficult to develop housing affordable to lower income households, the City has provided incentives and assistance resulting in such affordable housing on small sites. For example, the City approved an affordable 10-unit project on a small 11,831 square foot lot that provides rental housing for families.

Three of the units are marketed to low-income families whose incomes are at or below 40 percent of the Area Median Income. Five of the units are offered to low-income families whose incomes are at or City of Pacifica Housing Element: 2015-2023
84 below 50 percent of the Area Median Income, and the remaining two units are leased to families whose incomes are at or below 60 percent of the Area Median Income. This project, Pacifica Pines Apartments, was financed by HOME funds, tax credit equity, and Community Development Block Grant (CDBG) funds. Based on this example, it is clear that delivering affordable housing on small lots is feasible in Pacifica. As listed in Table III-1, the Fish site is comprised of eight small parcels ranging from 3,920 to 6,818 square feet. An opportunity exists to promote parcel consolidation to ensure that minimum densities are achieved and integrated site planning occurs by working in partnership with affordable housing developers to develop a Priority Lot Consolidation List with the goal of creating a list of “ready to go” development sites that can be shown to potential developers. The list should:

1. Prioritize sites located in General Plan land use areas designed for multi-family residential development (High-Density Residential and Commercial sites);

2. Consider common ownership patterns, the physical condition of existing buildings, on-site constraints, and the Assessor’s ratio of improvement value to land value – an indicator of underutilization of land; and

3. Focus efforts on specific geographic areas with the greatest development potential according to the latest development trends and expressed developer interest, further identifying sites that may be candidates for the Affordable Housing Overlay District designation. The identified sites should be ideally located to meet the criteria for affordable housing grants and financing.

Vacant and Underutilized Properties
While the recycling (redevelopment) of sites would be new to the community, there are several examples of existing mixed-use developments in Pacifica. The mixed-use aspect of such developments is not only consistent with the City’s policies, but also recent trends throughout the County and neighboring jurisdictions.

The City will assist developers in the redevelopment of nonvacant sites with residential uses by:

1. Providing regulatory incentives;

2. Developing and distributing promotional materials and public outreach;

3. Tracking and monitoring the redevelopment of nonvacant sites identified in Table III-1 to identify best practices and cite examples of successful redevelopment to residential uses; and

4. Review and revise programs as necessary if monitoring reveals that residential development of nonvacant sites is not occurring and if residential development on the sites is not resulting in appropriate affordable units to accommodate the City’s housing needs for each income group, specifically those with extremely low, very low, and low incomes.

The City will also:

1. Contact owners of contiguous vacant and underutilized sites and introduce them to the idea of parcel consolidation; explaining the City’s regulations and how standards may be modified to make site assembly feasible and the use of affordable housing resources for financial or technical assistance;
City of Pacifica Housing Element: 2015-2023
85 2. Conduct outreach to affordable housing developers informing them of development opportunities in the City through targeted mailings, emails and phone calls;

3. Provide information on these “ready to go” sites on the City’s website and in response to inquiries by interested prospective affordable housing developers;

4. Sharing examples with housing developers of successful development projects in the City on consolidated parcels;

5. Offer incentives to developers to promote parcel consolidation, such as:
a. Density bonuses;
b. Priority permit processing;
c. Exemptions for zoning requirements;
d. Ministerial review of lot line adjustments;
e. Deferred development fees; and
f. Other incentives under the proposed Affordable Housing Overlay Zone program.

The City’s analysis of vacant and undeveloped sites identified approximately 926 acres of undeveloped land within City limits. Underutilized sites were identified by using a ratio of the assessed value of improvement to the assessed value of land (AV ratio). Parcels with an AV ratio of less than 1.0, where the value of the building is less than the value of the land, were assumed to have redevelopment potential. Parcels zoned for single-family residential use were not included in this analysis; neither were protected open space, churches and institutional uses, or sites in public ownership. The analysis found 121 acres of “underutilized” land in Pacifica in designations other than agricultural, public, community, or institutional use.

City-owned Sites
City-owned housing sites provide unique opportunities to maximize the affordability of new housing.

This is especially important when considering how to accomplish development of housing for extremely low income (ELI) individuals and families. Development of ELI housing is challenging given the lower financial return to developers. Without appropriate incentives, developers typically target affordable units to very low or low income categories.

When it owns a development site, the City may offer additional incentives if a development proposal satisfies a special housing need or a special affordable housing need, including ELI units. The Cityowned Sanchez Library site shown in Table III-1 is zoned C-1 (Neighborhood Commercial) and may provide an opportunity for ELI unit development. This site was originally developed in the early 1960’s with a relatively low intensity, single-story library use. While the site houses an existing library, the use will be discontinued if a new library is constructed elsewhere in the city, leaving the site available for potential redevelopment. The site is near both residential and commercial areas, and has existing infrastructure (water delivery and sewage treatment). These factors make the site available and attractive for new and more intensive residential redevelopment. The development of this site in a City of Pacifica Housing Element: 2015-2023
86 mixed-use configuration, consisting of commercial and residential uses, would be consistent with the City’s economic and land use development strategies.

The Sanchez Library site holds additional promise as an affordable housing site in that the City, as property owner, will possess greater control of its development potential. At the Sanchez Library site, the City can exert leverage on any developer to encourage to the maximum extent practicable the development of housing affordable to those with ELI. The City’s leverage may include an appropriate array of development incentives, contributions from the housing trust fund, fee waivers, or other incentives. The City will consider extending this philosophy to other sites it owns should their development or redevelopment occur during the planning period.

Developable Units
As noted above, the majority of the affordable units constructed in the City are located in the R-3 (Multiple-Family Residential) district which allows for a density of 16-21 dwelling units per acre. A total of five projects with 357 affordable units have been developed at this density. Another 15 acres of vacant or underutilized land is within the R-3 zone. Based on this land availability, there is a possibility for development of another 315 units at existing General Plan densities.

Further, approximately 95 acres of vacant or underutilized land exists in the C-1 (Neighborhood Commercial), C-2 (Community Commercial), and C-R (Commercial Recreation) Districts. These commercial zoning districts provide an opportunity for extremely low, very low and low income housing. In the commercial districts density is controlled by a minimum lot area per dwelling unit of 2,000 square feet. Sites available within these zoning districts have the potential for an additional 2,069 residential units at maximum density.
(Continued on Next Page)
City of Pacifica Housing Element: 2015-2023
87 IV. GOALS, QUANTIFIED OBJECTIVES, AND POLICIES TO

MAINTAIN, PRESERVE, IMPROVE AND DEVELOP HOUSING

1. Purpose
The City has a number of ongoing policies and ordinances guiding its actions related to housing development. These resulted from past efforts and completed programs from prior housing elements.

Policies in this section are integrated into the everyday activities of the City, and support the development and preservation of housing at all income levels. In certain cases, however, the City’s existing policy and legal framework are inadequate to fully support and foster housing development.

State Housing Law requires each housing element to document such situations where a local agency must undertake additional policy or legislative actions related to the need to maintain, preserve, improve and develop housing. The following section identifies these shortfalls, identifying action programs with quantified objectives the City will undertake during the planning period. Specifically, California Government Code, Article 10.6, Section 65583, states that the Housing Element shall include:
"an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs for the preservation, improvement, and development of housing..."
The following complies with state law, and also provides an analysis of Pacifica's success in achieving the objectives identified in the 2007 Housing Element. The "2007 Objectives" are stated with a brief overview of accomplishments, followed by new "2015 Objectives."

2. Overall Goals
Pacifica's General Plan contains overall goals that are applicable to each of the General Plan's 12 elements. Goals most relevant to the Housing Element are as follows:
 Strive to provide a decent home and satisfying environment for each resident.  Protect the social mix, variety, and fundamental character of each neighborhood by providing for the safety and welfare of all residents equally.

3. Quantified Objectives
The goals, objectives, and programs contained in the City of Pacifica Housing Element strive to encourage and incentivize the maintenance, preservation, improvement, and development of housing affordable to persons of all income levels and special needs categories. Actions to be undertaken by the City during the planning period seek to address City processes and policies (governmental constraints) and external factors such as development costs (nongovernmental constraints) to reduce barriers to the development of housing affordable to those with extremely low, very low, or low incomes.

City of Pacifica Housing Element: 2015-2023
88 Based on its goals, objectives, and programs outlined in the Housing Element, the City expects its combined efforts and resources to achieve the following quantified objectives during the planning period:

TABLE IV-1
Quantified Objectives
Income Category
New Construction
(Development)
Rehabilitation
(Maintenance &
Improvement)
Conservation
(Preservation)
Extremely-low 60 95 101**
Very-low 61 158 93*
Low 68 135 5
Moderate 70 72 8
Above Moderate 154 80 16
TOTAL 413 540 223
GRAND TOTAL 1,176
Source: City of Pacifica Planning Department, 2014
* Includes preservation of 93 mobile home units at Pacific Skies Estates. All of these units are subject to the provisions of Pacifica Municipal Code Title 9, Chapter 1, Article 2 “Rent Stabilization Regulations.”
** Includes preservation of 101 senior housing units at Casa Pacifica.

4. Ongoing Policies
The City of Pacifica embraces the need to maintain, preserve, improve, and develop housing for persons at all income levels and for persons with certain special housing needs. As a result of its past efforts, including action programs in previous housing elements, the City has incorporated various activities related to housing best practices into its standard policies and operations. The following summary lists the City’s orientation to the four key aspects of housing element actions: maintenance, preservation, improvement, and development. The list is not inclusive of all housing policies of the City, but rather is representative of Pacifica’s supportive orientation to housing projects. Some of the items listed were previous action programs that the City accomplished, and it is no longer appropriate to list them as action programs during the planning period. Other items listed do not have a timeline for implementation given their ongoing nature, making it inappropriate to list them as action programs during the planning period in response to SB 375’s requirements pertaining to action programs. Such items included in this list may lack specific beneficial impacts and a defined date for accomplishment City of Pacifica Housing Element: 2015-2023
89 given the uncertain nature and timing of applications for housing-related permits. Nevertheless, the items below are best described as ongoing policies which are in place to facilitate housing projects whenever necessary.

A. Maintenance of Housing
i. Implement the safe and sanitary criteria of the Housing Code.

To encourage Code compliance and rehabilitation of housing in a degraded condition, City staff will note Housing Code violations during all field inspections. Common inspections include those for building permits or investigative inspections related to code enforcement complaints.

The emphasis will be on voluntary compliance; however, where violations include immediate threats to life, safety, or sanitary conditions, staff will implement immediate corrective actions to mandate compliance. Staff will coordinate with the San Mateo County Health Department whenever necessary to leverage maximum resources to quickly resolve unsafe conditions.

Specific Action - Document Housing Code violations during all inspections.

Responsible Agency - Building Division and Code Enforcement Division This policy was Action Program No. 1 in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. City staff contacted more than 298 property owners related to housing maintenance issues during the 2007-2014 planning period.
ii. Prevent blight and the deterioration of housing units resulting from deferred maintenance.

The City has a large housing stock but relatively few building inspectors and code enforcement officials. Therefore, staff is unlikely to proactively identify all blighted or deteriorated conditions that exist at housing units. Staff will continue to respond to resident complaints about such conditions in their neighborhoods, partnering with property owners to make needed improvements.

Specific Action - Document Housing Code violations during all inspections.

Responsible Agency - Building Division and Code Enforcement Division This policy was Action Program No. 2A in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. City staff responded to 209 complaints regarding blight and deterioration during the 2007-2014 planning period; staff resolved all cases with the completion of necessary upgrades to abate the blight and deterioration of the respective housing units.

City of Pacifica Housing Element: 2015-2023
90 iii. Conserve energy through implementation of the California Green Building Code.

The City adopted the California Green Building Code on 12/25/2013. Building Division staff review all building permit applications for new construction and building alterations for compliance with the Green Building Code.

Specific Action - Adopt a Green Building Ordinance to assure that all new buildings and significant remodels incorporate green
building practices and materials into the design.

Responsible Agency - Building Division
This policy was Action Program No. 4B in 2007-2014 Housing Element (and program accomplishment is demonstrated under Action Program No. 4 in this Housing Element). The City will continue to implement this policy on an ongoing basis.

B. Preservation of Housing
i. Smoke Detectors
In 1983, the City Council enacted Ordinance 363-C.S. requiring the installation of Fire Detection Systems in all housing units within the City. The Building Division verifies installations whenever there is an inspection related to other City permits. Otherwise, the Ordinance requires property owners to maintain smoke detectors as specified in Pacifica Municipal Code Article 4, Chapter 13.

Specific Action - During all building permit inspections, verify installation of smoke detectors in accordance with the City Ordinance. - Issue correction notices and conduct follow-up inspections of housing units without required smoke detectors.

Responsible Agency - Building Division and Fire Department This policy was Action Program No. 3 in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. City inspectors conducted more than 2,254 building permit inspections at different housing units during the 2007-2014 planning period, verifying smoke detector installation in each case. The performed number of inspections – 322 – far exceeded the goal of inspecting 50 units per year. ii. Conditions of Approval
As a condition of approval for housing developments dedicated to housing for seniors and/or lower income occupants and where the City grants a parking exception, parking waiver, or variance (typical Density Bonus Ordinance provisions), the City will impose a condition of approval requiring the developer to record a deed restriction on the property. The deed City of Pacifica Housing Element: 2015-2023
91 restriction will place in the chain of title notice that approval of the development was based upon a waiver or exception from City standards and that conversion of such development from its originally approved purpose may be infeasible unless it meets all applicable standards.

Specific Action - Impose this condition of approval on all permits benefitting from a Density Bonus Ordinance approval or
other projects receiving authorization to deviate from
development standards in order to develop affordable
housing types.

Responsible Agency - Planning Division
This policy was Action Program No. 5f in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. The Casa Pacifica Apartments development received a variance during its development, and any subsequent use will need to comply with all City development standards or else apply for a new variance permit.
iii. Condominium Conversion
The City minimizes housing impacts to renters by regulating the conversion of rental apartment housing to condominiums. The City’s Condominium Conversion Ordinance codified in Pacifica Municipal Code Title 9, Chapter 4, Article 24.5 requires an apartment property owner to demonstrate satisfaction of one of three pre-requisites prior to pursuing a conversion:
a. Multi-family vacancy rates exceed 5 percent citywide; or, b. A super majority (75 percent) of existing tenants vote for conversion; or, c. The property owner agrees to sell or rent 40 percent of converted units at rates affordable to persons with low or moderate income.

Specific Action - Implement the provisions of the Residential Condominium Conversions ordinance to minimize impacts on low- and
moderate-income persons.

Responsible Agency - Planning Division
iv. Designation of Historical Structures
The City supports and encourages property owner-designation of historic structures as set forth in Pacifica’s Historic Preservation Ordinance. Enacted in 1984, one of the purposes of the Ordinance is to encourage preservation of historic structures. The Pacifica Historical Society has prepared a detailed inventory of historical and cultural sites and structures that would benefit from the appropriate designation. Additional structures and sites not included in the inventory are also eligible for designation subject to certain criteria.

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92 Specific Action - City staff will educate and encourage property owners about the benefits of pursuing historic preservation
designation, including tax benefits. The financial benefits of designation can help owners dedicate additional
resources toward property maintenance and/or
improvements.

Responsible Agencies - Planning Division, Pacifica Historical Society This policy was Action Program No. 8 in 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. The City has observed little interest from property owners in pursuing historical designations for their properties. Since 2010, only one site – the Dollar Radio Station – received a historical designation. Pacifica's ability to designate historical structures and sites is contingent upon property owner willingness. However, the City will continuously monitor opportunities to designate appropriate historical resources to protect and enhance their historical character, educating property owners about the benefits of historical designation. The City will strive to designate one site every other year.

C. Improvement of Housing
i. Engage with Property Owners of Deteriorated or Deteriorating Housing City Building Division and Code Enforcement staff will respond to complaints of substandard housing and unsafe building conditions. Upon initiating contact, City staff will inform property owners of the funding resources available to assist lower income property owners with housing improvements. The City will pursue a collaborative code enforcement posture when investigating and resolving these types of complaints whenever possible, except where immediate life or safety issues are present.

Specific Action - Respond to complaints pertaining to blight or deterioration of housing units, providing informational materials on
programs and funding available to eligible property
owners in order to restore substandard housing.

Responsible Agency - Building Division and Code Enforcement Division See Section 4.A.i and ii for related policies.

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93 D. Development of Housing
i. Prioritize In-fill Residential Development
Specific Action - Discuss this option with individual developers on a project-by-project basis. Encourage inclusion of second floor residential units where feasible.

Responsible Agency - Planning Division, Economic Development Division This policy was Action Program No. 9 in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. The City has encouraged in-fill development in its meeting with developers. In 2013, the City encouraged infill within the Rockaway Beach neighborhood which resulted in the construction of three housing units in a mixed-use development on Dondee Way. The City will continue to work with property owners to facilitate mixed-use development on underutilized and vacant lots.

However, the timing of individual development applications is difficult for the City to predict, and it is thereby difficult to establish a specific timeline and quantification for goal achievement.

The main ways the City will prioritize in-fill development is by encouraging developers to intensify already developed sites with residential units above ground floor commercial spaces; by encouraging developers to develop vacant lots interspersed among developed sites, ensuring housing wherever possible; and, if the pace of development was to increase during the planning period, by ranking higher in the Growth Management Ordinance scoring process those developments planned for in-fill.
ii. Provide an Encouraging Environment for Construction of Second Units City staff shall encourage and foster construction of second units when interacting with property owners and development professionals. Staff shall strive to find solutions to challenging development standards and to provide a clear explanation of necessary permit approvals required to construct a second unit, including estimated time frames and costs.

It is not possible to assess the number of second units that will be developed in the City. The amount of such development will depend on a variety of factors including the size of individual properties, the placement and design of structures on individual sites, and neighborhood acceptance. The Second Unit Ordinance is discussed further under Action Program No. 11.

Specific Action - Discuss this option with individual property owners.

Explain and encourage the development of second units
where feasible.

Responsible Agency - Planning Division
This policy was Action Program No. 10 in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. Since 1982, when the City of Pacifica Housing Element: 2015-2023
94 City of Pacifica passed a Second Residential Unit Ordinance, it has permitted construction of second units on single family properties. It is still confusing and intimidating for many property owners to consider construction of a second unit, however. Planning and Building Division staff shall reduce barriers to second unit construction whenever possible. iii. Identify Opportunities to Include Housing Incentives in Development Applications Despite the dissolution of redevelopment agencies in California, the City still has tools and programs available to encourage development of housing affordable to those with extremely low, very low, and low incomes. These include the inclusion of Section 8 units in new developments; granting additional density and relaxing development standards under the Density Bonus Ordinance; requiring affordable housing through the Inclusionary Zoning Ordinance; allowing manufactured housing in residential zones; and, ensuring sufficient zoning for mixed-use development. City staff will seek all opportunities to encourage affordable housing development using these tools and others.

Specific Action - Train staff on available housing tools. - Require staff to identify opportunities to explain
affordable housing incentives to prospective developers.

Responsible Agency - Planning Division
iv. Assist Affordable Housing Developers with Preparation of Funding and Development Applications
The City can assist with affordable housing development by providing nonfinancial support.

City staff can provide assistance with affordable housing developer applications for government and nonprofit funding by serving as co-applicant or by endorsing applications. Staff can also assist developers to submit more complete planning applications by scheduling no-cost preapplication meetings to discuss City requirements and processes. More complete applications can undergo the City review process more quickly, thus saving time and money, and resulting in faster construction of affordable housing units.

Specific Action - Co-apply or endorse funding applications. - Provide no-cost pre-application meetings for affordable housing projects.

Responsible Agency - Planning Division
v. Require a Geotechnical Site Investigation Prior to Permitting Site Development Some potential building sites in Pacifica have unknown geological hazards that only a geotechnical site investigation can uncover. The potential of these hazards to threaten newly developed housing units warrants a careful investigation of each proposed housing site prior to City of Pacifica Housing Element: 2015-2023
95 granting development approvals. In most cases, appropriate structural engineering can allow a development project to proceed. However, in extreme cases, identifying geotechnical hazards will allow the City to prohibit development in hazardous areas, including flood zones.

Specific Action - Require geotechnical reports for all development applications where a property may be susceptible to
hazardous impacts.

Responsible Agency - Planning Division, Building Division, Public Works Department
This policy was Action Program No. 19 in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. The City has implemented expanded requirements for geotechnical investigation since 1999, and strictly applies the requirements.
vi. Reference the Open Space Task Force Report When Evaluating Development Proposals for Sites Identified in the Report
Open space preservation is an important community priority. In 1988, the City Council accepted a report prepared by the Open Space Task Force, a group comprised of Pacifica residents interested in protecting undeveloped lands within the City (the report was updated in 2000). While not regulatory in nature, the Open Space Task Force Report identifies sites within Pacifica where proposed development should receive enhanced review. The purpose of the enhanced review is to consider ways to achieve the goals of a developer while preserving the natural aesthetic of a site whenever possible.

Specific Action - Refer to the Open Space Task Force Report when reviewing residential development applications.

Encourage developers to retain natural features of
development sites whenever possible.

Responsible Agency - Planning Division
This policy was Action Program No. 14 in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy. The City will implement this ongoing policy as part of a broader framework of General Plan objectives and policies and Municipal Code ordinances that address development of open space areas. vii. Encourage development of a shared living community (co-housing) in an appropriate location to provide diversity in housing opportunities.

The City has included this action program in at least its previous two housing elements (covering 20 years or more). During this time, no shared living/co-housing communities have been developed in Pacifica. However, the Planning Commission and some members of the community believe this remains an important type of development that the City should City of Pacifica Housing Element: 2015-2023
96 encourage. The City’s existing Zoning Code could accommodate such a development if proposed.

Specific Action - Discuss the potential for development of a co-housing project with owners, prospective developers, and
organizations specializing in shared living
communities. Encourage applications in appropriate
locations.

Responsible Agency - Planning Division
This policy was Action Program No. 17 in the 2007 Housing Element. It had a continuous time frame for implementation, and is more appropriate as an ongoing policy.

5. Housing Maintenance
A majority of residents in Pacifica live in high-quality, safe housing. The City strives to keep the good condition of the housing stock by promoting property maintenance. It is far less expensive to maintain housing units than it is to build new housing or to renovate substantially deteriorated housing.

Therefore, maintenance is an essential aspect to providing adequate, affordable housing. However, there are housing units in Pacifica that require rehabilitation. The City’s Building Official estimates that approximately 3 to 5 percent of all units within the City need rehabilitation.

A. Policies, Programs and Objectives to Maintain Housing

POLICIES - ENCOURAGE UPGRADES TO AND MAINTENANCE OF THE CITY'S EXISTING HOUSING UNITS;
- IMPROVE NEIGHBORHOOD AESTHETICS;
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97 Action Program No. 1
Advertise available grant and loan funding for lower income property owners to rehabilitate substandard housing units.

Specific Action - Display program literature at the Planning Department counter and website. - Distribute program literature to potential participants identified during housing-related inspections.

Responsible Agency - Building Division; Code Enforcement Division; San Mateo County Housing and Community Development Division
Financing - Community Development Block Grants, California Housing Finance Agency, Federal Housing Authority
2007 Objectives - Continue to assist the San Mateo County Housing and Community Development Division with advertisement of their programs on the City's web site and by distributing literature from the County at the Planning Department, Sharp Park Library, Sanchez Library, Pacifica Resource Center, City Community Center, and other public locations while decreasing the 18 unit per year rehabilitation goal to 2 units per year. In addition, the City will explore the feasibility of applying for housing rehabilitation funds.

Accomplishments - Distributed more than 75 program brochures throughout all City facilities. - The San Mateo County Housing Authority Rehabilitation Program rehabilitated 37 Pacifica housing units between 2007-2014 with approximately $105,000 in funding.
2015 Objectives - The City has observed little interest from residents to apply for housing rehabilitation loans. Additionally, County program staff has indicated that budget reductions have impacted its ability to administer the program, resulting in a lower program capacity to assist Pacifica residents. The City will, however, continue to market the County’s rehabilitation program to provide the opportunity to apply to any interested residents. The City will strive to refer enough residents to ensure two residents will successfully apply for the program each year.

Time Frame - 1/31/2015 through 12/31/2015: Two applicants - 1/1/2016 through 12/31/2016: Two applicants
- 1/1/2017 through 12/31/2017: Two applicants
- 1/1/2018 through 12/31/2018: Two applicants
- 1/1/2019 through 12/31/2019: Two applicants
- 1/1/2020 through 12/31/2020: Two applicants
- 1/1/2021 through 12/31/2021: Two applicants
- 1/1/2022 through 1/31/2023: Two applicants
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98 Action Program No. 2 (formerly Action Program No. 4A in 2007-2014 Housing Element) Reduce potential loss of life and property damage from earthquakes by requiring seismic upgrades (structural strengthening and hazard mitigation) to unsafe buildings, which includes unreinforcedmasonry buildings and soft-story buildings (those with ground floors having a lateral stiffness significantly less than that of the stories above).

Specific Action - Consider development of a mandatory seismic upgrade ordinance. - Develop long-term funding sources to assist property owners with the expenses of upgrading housing units.

Responsible Agency - Building Division
Financing - City funds; Grant funding from federal or state agencies, or nonprofit organizations.
2007 Objectives - Develop funding sources to minimize the financial impact of retrofits on lowand moderate-income residents.

Accomplishments - The City has not enacted a mandatory seismic upgrade ordinance. Therefore, it has not developed a funding program to implement an ordinance. The City continues to consider whether such an ordinance and funding program are feasible. In the meantime, property owners may perform seismic upgrades on a voluntary basis and obtain private financing for the work. Since 2007, zero property owners have performed voluntary seismic upgrades. 2015 Objectives - Continue to distribute program literature. - Successfully refer five households per year.

Time Frame - 12/31/2016: Determine whether development of a mandatory seismic upgrade ordinance and sourcing of sufficient funding to implement upgrades are feasible.
- 12/31/2017: If feasible, complete enactment of ordinance and implementation of seismic upgrade funding program(s).

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99 6. Housing Preservation
Development of rental housing affordable to persons with extremely low, very low, and low incomes in Pacifica has lagged behind demand for affordable units for many years. Therefore, preservation of existing affordable units is essential to meeting affordable housing demands. The loss of any affordable units due to preventable circumstances would exacerbate the housing affordability problem in Pacifica.

A continued supply of affordable rental housing is important to meet the housing needs of Pacifica's population.

Rental housing, dedicated housing for lower income persons, seniors, and persons with disabilities, as well as mobile homes all provide vital affordable housing. The City has many market rate apartment developments, several dedicated senior housing developments, and a 93-unit mobile home park. All of these units are essential to a mixed, affordable housing stock. Yet, units of this sort are particularly threatened by potential decisions of property owners to pursue market rate returns. Apartment owners could pursue conversion to condominiums to generate immediate capital from the long-term value of their properties. Owners of subsidized developments could choose to terminate their participation in the programs, triggering a chain of events leading to displacement of long-time low-income tenants.

Additionally, the mobile home park operator could seek to develop other housing types at the site, causing the relocation of low-income tenants with existing support systems in place in the community.

There are three main ways to preserve existing rental housing affordable persons with extremely low, very low, and low incomes in Pacifica: a) to monitor rental units developed with a density bonus or other development concessions; b) to regulate conversions of rental housing to condominiums; and, c) to monitor long-term plans for the mobile home park operator. The Density Bonus Ordinance permits certain housing projects (see Section 7.D.ii) to exceed the maximum density designation for a site and also to develop the site with relaxed standards. The City grants these allowances subject to the continued affordability of units for a defined period of time. The City must monitor housing units to ensure property owners are operating the sites in conformance with their development approvals.

Conversions of apartments to condominiums can also result in significant losses of rental housing when market conditions are suitable for conversion. When conversions occur, many renter occupants are unable to obtain financing necessary to purchase their units, which can lead to their displacement. The City has enacted an ordinance regulating condominium conversions, and limits conversions to a defined set of circumstances.

The Land Use Element recognizes the importance of preserving the mobile home park. Accordingly, the City adopted an ordinance in 1990 which regulates conversion of mobile home parks to other uses.

The ordinance provides procedures and standards for closure of the mobile home park to mitigate adverse impacts of displacement of existing residents while providing economically viable and reasonable use of the land.

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A. Preservation of Housing Affordability

POLICY - PREVENT THE CONVERSION OF EXISTING AFFORDABLE

HOUSING UNITS TO LESS AFFORDABLE HOUSING TYPES
Action Program No. 3
Develop programs to help preserve the "at risk" units at Casa Pacifica senior housing complex.

Specific Actions - Contact the Casa Pacifica owner to inquire about ongoing intentions to continue participation in the Section 8 program. The property owner is currently bound by a five year program participation agreement. Any decision to end program participation would require a notice by1/31/2019. - Respond to any notice of intent required by Government Code Section 65863.10 or federal law, and send copies of any notice received to the California Department of Housing and Community Development (HCD). - Upon any indication of owner intent to end Section 8 program participation, partner with HCD and other county, state, federal, and nonprofit partners to assess potential impacts and to formulate a strategy to mitigate any negative impacts on apartment residents.

Responsible Agency - Planning Division
Financing - City funds
2007 Objectives - The 2007 Housing Element did not contain clear objectives related to this goal.

The intent of the action program was to preserve affordability of the Casa Pacifica Apartments.

Accomplishments - Casa Pacifica Apartments continued its participation in the Section 8 subsidy program throughout the 2007-2014 planning period.
2015 Objectives - Monitor Casa Pacifica Apartments for any indication of intent to cease participation in the Section 8 program. Formulate a comprehensive response with affordable housing partners to any notice of intent to cease Section 8 participation.

Time Frame - 12/31/2018: Contact property owner to inquire about long-term intentions for the site. Due to the length of the current participation agreement (1/31/2015 through 1/31/2020), a single inquiry will suffice during the planning period.

Additional Discussion: The 2007 Housing Element contemplated a variety of potential responses to a notice to cease participation in the Section 8 program at Casa Pacifica Apartments. Those responses follow, for future reference:

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- Help finance project buyout by nonprofits or other public entities through equity or gap financing, advancing purchase-option funds, carrying of second mortgages, interest write-downs, issuance of tax-exempt bonds for financing acquisition or rent reductions.
- Help finance project buyout by nonprofits or other public entities through equity or gap financing, advancing purchase-option funds, carrying of second mortgages, interest write-downs, issuance of tax-exempt bonds for financing acquisition or rent reductions.
- Provide grants and/or low interest or forgivable loans to potential purchasers to finance preliminary feasibility studies of acquisition. - Provide financial relocation benefits for households dislocated from units with terminating affordability controls.
- Provide grants to create tenant management groups and/or local nonprofits capable of acquiring and managing the project.
- Where public acquisition on a permanent basis is not feasible, assist a public entity or nonprofit in purchasing the project on a temporary basis until a qualified long term owner can be found.
- Provide rent subsidies to ensure continued affordability by lower income tenants.
- Assess a conversion "impact fee" or "in-lieu contribution" for projects that convert to market rate rents.
- Adopt conversion protections, e.g., develop stricter condominium standards, require one-for-one replacement of units converted to market rate rents, where not preempted by State or Federal law.
- Enact some form of rent control, unless preempted by State or Federal law. - Require owners of "at-risk" units to provide relocation assistance for displaced tenants where not already required by federal, state, or local statute. - At such time as the project owners file a notice of intent, provide tenant and community education by involving affected constituencies in assessing the preservation problem, and provide information required for legally valid notices of intent and Plans of Action (POA) submitted by project owners, through local workshops. Include Casa Pacifica owners whenever possible. - Submit comments on a proposed POA for the Casa Pacifica Apartments and communicate the City's concerns to HUD throughout the application process.

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Advise tenants of the Casa Pacifica Apartments immediately upon receipt of a POA. Also, upon receipt of a POA, hold a public hearing pursuant to Government Code Section 65863.10.

Action Program No. 4
Encourage preservation of the existing mobile home park as an important source of low- and moderateincome housing.

Specific Actions - Contact mobile home park operator to inquire about ongoing intentions to maintain the use. The City has an established relationship with the operator of the 93-unit Pacific Skies Estates mobile home park on Palmetto Avenue. The operator recently made substantial investments into park improvements, and has stated its intention to operate the mobile home park on a long-term basis. - Maintain in effect the mobile home park conversion ordinance (Ordinance No. 550-C.S.) and monitor the city’s only mobile home park for any indications of a potential conversion.
- Upon any indication of park operator intent to pursue site conversion, administer and enforce Ordinance No. 550-C.S. to regulate conversion of mobile home parks to other uses without relocation assistance to tenants and other mitigation measures.

Responsible Agency - Planning Division
Financing - City funds
2007 Objectives - Continue preservation of the existing 93 mobile home units.

Accomplishments - The mobile home park is still in operation, providing a valuable source of housing for low- and moderate-income individuals and families. There were no applications for conversion of the mobile home park during the 2007-2014 planning period.
2015 Objectives - Monitor mobile home park operator’s long-term intentions for the site, encouraging maintenance of the mobile home park use. Administer Ordinance No. 550-C.S. if necessary. Unless development of additional mobile home parks occurs during the planning period, the maximum performance related to this policy would be one mobile home park conversion.

Time Frame - By 12/31 in 2017 and 2020: Contact property owner to inquire about longterm intentions for the site.

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Action Program No. 5
Ensure proper marketing of housing affordability programs and groups by partner agencies, including the Reverse Annuity Mortgage (RAM) program, Human Investment Project (H.I.P.) Homesharing Program, Lease-Purchase Program, emergency shelters, Project Sentinel, and Center for the Independence of the Disabled. These programs and organizations assist lower income persons, seniors, and persons with disabilities to stay in their homes. Project Sentinel specifically, and other organizations generally, will provide fair housing services to the City’s residents and property owners.

Services may include:
- Distributing educational materials to property owners, apartment managers, and tenants.
- Conducting public presentations with different community groups. - Responding to complaints of discrimination (e.g. complaint intake, investigation, and resolution).
- Referring services to appropriate agencies.

Specific Action - Periodically train City staff with frequent public interactions on available resources.
- Periodically contact partner agencies to verify referrals and cross-referrals are ongoing.

Responsible Agencies - Planning Division; Parks, Beaches, and Recreation Department Financing - City funds
2007 Objectives - One (1) home per year
Accomplishments - Despite repeated attempts, staff was unable to obtain performance data indicating the number of Pacifica residents enrolled in the RAM program and participating in the H.I.P Homesharing program.
2015 Objectives - Pacifica will change the focus of this goal to staff training and encouragement of partner organizations. City staff will train other staff on available housing referral resources, and will contact partner agencies to determine the level of service they are providing to Pacifica residents. The City has no control over the quantity of persons served by the referral programs, but can monitor the level of service being provided to residents.

Time Frame - Bi-annually by 12/31 in 2015, 2017, 2019, and 2021: Conduct training of Planning Division, Code Enforcement Division, and Parks, Beaches, and Recreation staff regarding available housing referral programs, services, and agencies.

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- Bi-annually by 12/31 in 2015, 2017, 2019, and 2021: Contact partner agencies to verify whether they continue to make referrals and cross-referrals to other assistance agencies.

The following is a summary of the above-mentioned housing referral programs and organizations:

The Reverse Annuity Mortgage (RAM) Program
This program allows people over 62 to borrow from their home equity at a fixed interest rate for up to 10-12 years. To qualify, RAM loan recipients must live in their homes and have little or no mortgage balance. The loans allow homeowners to live in their homes, and convert equity into income.

Human Investment Project (H.I.P.) Homesharing Program
H.I.P – funded through private and public sources – matches homeowners seeking housemates with tenants seeking housing. Income provided to senior and single-parent homeowners from renting a room in their home can help them to afford monthly housing payments. The H.I.P. program identifies and screens potential tenants for program participants. Although not explicitly limited by income, the program focuses on assisting lower income individuals.

Lease-Purchase Program
The California Home Source Lease-Purchase Home Ownership Program is a new tool for cities, counties, and other government agencies in the Bay Area to help their constituents achieve home ownership. The program helps individuals and families overcome the cash and credit barriers they often face when attempting to purchase a home. California Home Source is a service of the Association of Bay Area Governments (ABAG) Finance Authority for Non-Profit Corporations. The program provides down payment and closing costs assistance to help working individuals and families with credit problems.

Project Sentinel
A program that advances fair housing by investigating complaints of discrimination in housing due to race, religion, marital status, sex or national origin.

Center for Independence of Individuals with Disabilities An organization that provides services to persons with disabilities, including housing rehabilitation assistance and accessibility modifications.

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Action Program No. 6
Create a reasonable accommodation program and procedures to allow deviations from zoning standards for projects that improve access for persons with disabilities.

Specific Action - Adopt an ordinance with a reasonable accommodation program and procedures.

Responsible Agencies - Planning Division
Financing - City funds
2007 Objective - None. New program in 2015 Housing Element.

Accomplishments - None. New program in 2015 Housing Element.

2015 Objectives - Adopt an ordinance by the end of 2016.

Time Frame - 12/31/2016: Enact Reasonable Accommodation Ordinance.

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7. Housing Improvement
There are many expenses associated with owning housing. Whether one owns a single-family home or a multi-family apartment complex, the challenges of paying monthly loans, annual taxes and insurance can leave few resources remaining to maintain the property. After extended neglect, many properties decline in exterior appearance and interior functionality. Neighborhood aesthetics and character can suffer as disinvestment by a single property owner can encourage disinvestment by others. Inside housing units, deterioration can lead to violations of building, health, and safety codes, creating substandard housing conditions.

Property owners, especially those with lower incomes, can feel trapped by declining properties. Unable to afford less expensive maintenance activities, many remain unable to afford costly repairs stemming from neglect. The result is the continued decline of distressed properties until they detract from neighborhood character and are unsuitable for habitation. Proactive measures are necessary to restore declining housing stock to a safe and attractive condition. To the maximum extent feasible, the City shall seek to leverage its own investments and available funding from external partners to improve the quality of its housing stock and neighborhoods. Energy conservation also can play an important role in improving housing. Less energy consumption means lower monthly utility bills, saving property owners money each month and allowing them to direct some of the savings towards improving their housing.

A. Policies, Objectives, and Programs to Improve Housing

POLICIES - ENCOURAGE CODE COMPLIANCE THROUGH PROACTIVE
ENGAGEMENT, EDUCATION, AND ENFORCEMENT;

- LEVERAGE CITY INVESTMENTS TO IMPROVE THE CHARACTER OF NEIGHBORHOODS;
- ENHANCE HOUSING AFFORDABILITY THROUGH ENERGY
CONSERVATION AND OTHER STRATEGIES.

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Action Program No. 7
Emphasize housing rehabilitation to forestall decline in the housing stock. Utilize government subsidies including Section 8 or other rental assistance programs to enhance owner affordability. Use the Code Enforcement process to refer owners to apply for Community Development Block Grant (CDBG) funds for housing rehabilitation.

Specific Action - Distribute program literature to property owners contacted during deteriorated housing-related inspections.
- Include rehabilitation program information on the City’s website.

Responsible Agencies - Building Division; Code Enforcement Division; San Mateo County Housing and Community Development Division
Financing - Community Development Block Grants, California Housing Finance Agency, Federal Housing Authority
2007 Objective - Pacifica's goal is to increase awareness of the San Mateo County Department of Housing and Community Development's housing rehabilitation programs through more aggressive advertising on the City's web site and through the distribution of brochures at the City Hall (annex), Sharp Park Library, Sanchez Library, Pacifica Resource Center, community center and other public locations. Pacifica will modify its Action Program goal from 34 rehabilitated units per year to 10 units per year - 2 low-income rental units and 8 lowincome owner occupied units.

Accomplishments - The San Mateo County Housing Authority Rehabilitation Program rehabilitated 37 Pacifica housing units between 2007-2014.

2015 Objectives - Distribute rehabilitation and housing affordability program information to 300 property owners during building code or property maintenance code interactions with City inspectors. Building Division and Code Enforcement staff responded to 298 housing-related complaints between 2007-2014 (42 per year), and the City estimates the figure will remain consistent during the planning period.

Time Frame - 1/31/2015 through 12/31/2015: Three referrals - 1/1/2016 through 12/31/2016: Four referrals
- 1/1/2017 through 12/31/2017: Four referrals
- 1/1/2018 through 12/31/2018: Four referrals
- 1/1/2019 through 12/31/2019: Four referrals
- 1/1/2020 through 12/31/2020: Four referrals
- 1/1/2021 through 12/31/2021: Four referrals
- 1/1/2022 through 1/31/2023: Five referrals
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Action Program No.8 (formerly Action Program No. 7A in 2007-2014 Housing Element) Establish an incentive program for voluntary housing rehabilitation.

Specific Action - Review each development application for opportunities to improve community infrastructure and aesthetics. Pursue all available funding sources to upgrade and enhance infrastructure and public property/right-of-way aesthetics with improvements to streets, gutters, sidewalks, street trees, sewer laterals, and other infrastructure.

Responsible Agencies - Department of Public Works; Planning Division Financing - Property owner funds; City funds
2007 Objectives - The City shall support voluntary housing rehabilitation by upgrading streets, gutters, sidewalks, street trees, sewer laterals, etc. Information will be provided to developers and homeowners on the City's web site by early-2011.

Accomplishments - In 2008, the City developed a Palmetto Avenue streetscape improvement plan to underground utilities and improve the sidewalks, roadway, and landscaping between Paloma Avenue and Clarendon Road. The plan has multiple phases and timing of improvements is funding dependent. The City continues to seek funding to proceed with Phase I (Utility Undergrounding). Once completed, the project will mark a significantly improved aesthetic environment along Palmetto Avenue and should spur additional private investment in real estate improvements.
- The City Council in December 2011 enacted Ordinance No. 784-C.S. requiring inspection of sewer laterals concurrent with transfer of title to property, certain renovations, and in several other instances. Property owners must improve sewer laterals to reduce the likelihood of blockage or failure when inspections identify blockages or other substandard conditions. Since enactment, the Ordinance has led to nearly 1,000 sewer lateral inspections, of which almost two-thirds resulted in upgrades.
- The City Council took another infrastructure-related action in November 2012 with adoption of a resolution calling for complete streets throughout Pacifica. The resolution approved a new administrative policy emphasizing a connective street network and consideration of all modes of travel. Since adoption, City staff has conditioned seven development approvals to require installation of sidewalks and other pedestrian- and bicyclist-oriented improvements.
2015 Objectives - Continue implementation of Complete Streets policies. Condition all development approvals to require improvements infrastructure and multimodal connectivity. Pursue funding to implement Phase I of the Palmetto streetscape improvements and planning for subsequent phases.

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Time Frame - 1/31/2015 through 1/31/2023: Condition 80 projects (10 per year) requiring Complete Streets improvements.
- 12/31/2018: Secure sufficient funding to initiate Phase I improvements under the Palmetto streetscape improvement plan. Enhance the neighborhood quality of the 92 housing units in the vicinity of the streetscape improvements.

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Action Program No. 9 (formerly Action Program No. 4 in 2007-2014 Housing Element) Promote Pacific Gas and Electric (PG&E) Company’s "Energy Savings Assistance Program." The program is free and helps income-qualifying homeowners and renters make vital energy saving improvements to their homes, including weatherstripping, caulking, insulation, minor home repairs, compact fluorescent bulbs, and appliance replacement.

Specific Action - Display program literature at the Planning Department counter and Planning Department website.
- Distribute program literature to potential participants identified during housing-related inspections.

Responsible Agency - Building Division; Planning Division; PG&E Financing - City funds, PG&E funds
2007 Objectives - 35 units per year
Accomplishments - Since 2007, PG&E has provided free weatherstripping, caulking, insulating, and minor home repairs to 882 low income Pacifica residents. These improvements have led to average energy savings of 391 kilowatt-hours (kWh) for single-family residential participants; 229 kWh for multi-family residential participants; and, 401 kWh for mobile home participants. Pacifica also obtained literature regarding the free weatherization/home repair program from PG&E and distributed the literature to all interested parties. 2015 Objectives - Continue to distribute program literature. - Successfully refer 35 households per year.

Time Frame - 1/31/2015 through 12/31/2015: 32 applicants - 1/1/2016 through 12/31/2016: 35 applicants
- 1/1/2017 through 12/31/2017: 35 applicants
- 1/1/2018 through 12/31/2018: 35 applicants
- 1/1/2019 through 12/31/2019: 35 applicants
- 1/1/2020 through 12/31/2020: 35 applicants
- 1/1/2021 through 12/31/2021: 35 applicants
- 1/1/2022 through 1/31/2023: 38 applicants
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8. Housing Development
As discussed in Section 5 “Regional Housing Needs,” Pacifica must approve or develop an average of 52 housing units per year between 2015 and 2023 to meet its housing needs across all income levels.

Categorized by income level, that equates to annual approval or development of 8 units each for extremely low-income and very low-income persons, 9 units each for low-income and median-income persons, and 20 units for moderate income persons. Considering the residential development trends in Pacifica in recent decades, the City faces significant challenges to meeting these needs. It must ensure to mitigate as many constraints as possible and undertake other activities to encourage and incentivize housing development.

A. Policies, Objectives, and Programs to Improve Housing POLICY - PRIORITIZE MIXED-USE RESIDENTIAL DEVELOPMENT ON INFILL SITES.

Action Program No. 10
Prioritize in-fill mixed-use and residential development on underutilized sites and vacant sites interspersed with developed areas.

Specific Action - Encourage property owners to redevelop underutilized sites into mixed-use developments with housing. Also encourage property owners of vacant lots within developed areas to construct mixed-use or multi-family housing at these sites.

Responsible Agency - Planning Division, Economic Development Division Financing - City funds
2007 Objectives - None. New program in 2015 Housing Element.

Accomplishments - In 2013, the City encouraged infill within the Rockaway Beach neighborhood which resulted in the construction of three housing units in a mixed-use development at 411 Dondee Way.
2015 Objectives - Contact two property owners of identified underutilized sites per year to encourage redevelopment with higher density, mixed-use projects.

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Action Program No. 11
Encourage and facilitate construction of second residential units on properties zoned for single-family residential uses in conformance with existing zoning regulations.

Specific Action - The City should periodically evaluate the second unit requirements and review procedures to ensure minimal constraints exist to their construction.

Responsible Agency - Planning Division
Financing - City funds
2007 Objective - Encourage the construction of two second residential units per year. There is potential that approximately 14 second residential units will be developed during this planning period. To further encourage the development of second residential units, the City shall explore the feasibility of relaxing some of the development regulations such as on-site parking. Other incentives to encourage the development of second residential units may include fee reductions and priority permit processing.

Accomplishments - Three (3) second units were constructed from January 2007 to December 2014, resulting in an 11 unit shortfall from its 14 unit goal. Pacifica currently promotes the second-unit program by providing property owners and developers development information about adding a second unit. 2015 Objectives - Encourage construction of two second residential units per year, or 16 second units during the planning period. Periodically evaluate the City’s second unit zoning regulations and inquire with residents and construction professionals as to the perceived level of difficulty and expense associated with second unit construction. Where perceptions suggest second unit construction is difficult, develop strategies to revise the City’s regulations, such as by relaxing second unit parking requirements.

Time Frame - Bi-annually by 12/31 in 2016, 2018, 2020, and 2022: Review and revise, as necessary.

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Action Program No. 12 (formerly Action Program No. 10A in 2007-2014 Housing Element) Amend Second Unit Ordinance to incorporate updates in state law.

Specific Action - Initiate the amendment of the Second Unit Ordinance to conform to state law.

Responsible Agencies - Planning Division
Financing - City funds
2007 Objective - Amend Second Unit Ordinance to comply with state laws by the end of 2011.

Accomplishments - The City did not amend its Second Unit Ordinance as planned, but processed all second unit applications in accordance with state law notwithstanding the City’s codified ordinance.

2015 Objectives - Amend Second Unit Ordinance to comply with state law by the end of 2016.

Time Frame - 12/31/2016: Enact amendments to Second Unit Ordinance to conform to state law.

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POLICIES - PROVIDE HOUSING OPPORTUNITIES FOR ALL INCOME GROUPS; - PROVIDE A CHOICE OF HOUSING TYPES AND DENSITIES
Action Program No. 13 (formerly Action Program No. 15A in 2007-2014 Housing Element) Amend Density Bonus Ordinance to reflect updates to state law.

Specific Action - Amendment the Density Bonus Ordinance to reflect the latest provisions of state law.

Responsible Agencies - Planning Division
Financing - City Funds
2007 Objective - Amend Density Bonus Ordinance to comply with state law by mid-2011.

Accomplishments - The City did not amend its Density Bonus Ordinance as planned.

2015 Objectives - Amend Density Bonus Ordinance to comply with state law by the end of 2016. The City will process density bonus applications in compliance with state law until it amends the local code provisions.

Time Frame - 12/31/2016: Enact amendments to Density Bonus Ordinance to conform to state law.

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Action Program No. 14 (formerly Action Program No. 16A in 2007-2014 Housing Element) Consider amending the Zoning Ordinance to allow Rooming Houses and Boardinghouses for farmworker housing as a permitted use in the R-3 (Multiple-Family Residential) District.

Specific Action - Planning Commission shall discuss and consider whether to amend the Zoning Ordinance to allow Rooming Houses and Boardinghouses for farmworker housing as a permitted use in the R-3 zone.21

Responsible Agency - Planning Division
Financing - City funds
2007 Objectives - Consider the zoning amendment.

Accomplishments - The City has not yet considered the described amendments to the Zoning Code.
2015 Objectives - Consider the zoning amendment and enact amendments if determined desirable and feasible.

Time Frame - 12/31/2016: Complete consideration of the amendment. - 12/31/2017: Enact amendments to Zoning Code, if determined desirable and feasible.

21 Farmworker housing for six or fewer occupants is already and will continue to be permitted in any residential zone as a residential use, subject only to those regulations that apply to other residential dwellings of the same type (e.g., single family, duplex, condominiums, apartments) in the same zone.

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Action Program No. 15 (formerly Action Program No. 16B in the 2007-2014 Housing Element) Amend A (Agricultural) Zoning District to allow farmworker housing.

Specific Action - Amend the Zoning Code to comply with Health and Safety Code Sections 17021.5 and 17021.6 to allow housing for agricultural employees without discretionary approval.

Responsible Agencies - Planning Division
Financing - City funds
2007 Objectives - Amend A zoning district to comply with state law.

Accomplishments - The City did not amend A zoning district as planned

2015 Objectives - Amend A zoning district to comply with state law.

Time Frame - 6/30/2016: Enact amendments to Zoning Code.

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Action Program No. 16 (formerly Action Program No. 16C in 2007-2014 Housing Element) Amend Zoning Ordinance to allow Emergency Shelters, Transitional and Supportive Housing.

Specific Actions - Amend the Zoning Code to comply with Senate Bill (SB) 2 to allow Emergency, Transitional and Supportive Housing without discretionary approval.
- Create a definition of “emergency shelter” as “housing with minimal supportive services for homeless persons that is limited to occupancy of six months or less by a homeless person. No individual or household may be denied emergency shelter because of an inability to pay.” - Create a definition of “transitional housing” as “buildings configured as rental housing developments, but operated under program requirements that require the termination of assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance.” - Create a definition of “supportive housing” as “housing with no limit on length of stay, that is occupied by the target population, and that is linked to an onsite or offsite service that assists the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. For the purposes of this definition, “target population” means persons with low incomes who have one or more disabilities, including mental illness, human immunodeficiency virus (HIV) or acquired immune deficiency syndrome (AIDS), substance abuse, or other chronic health condition, or individuals eligible for services provided pursuant to the Lanterman Developmental Disabilities Services Act (Division 4.5, commencing with Section 4500, of the Welfare and Institutions Code) and may include, among other populations, adults, emancipated minors, families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, and homeless people.” - Create a new permitted use in the R-1 (Single-Family Residential) zoning district, an overlay zone, or another zoning district to permit emergency shelters for up to 15 occupants, subject only to those development and management standards that apply to residential development within the same zone, except that the City may develop written, objective standards for those criteria identified in Government Code Section 65583(a)(4)(A). - Create new permitted uses in all residential districts and in commercial districts permitting residential uses to permit transitional housing and supportive housing as a residential use, subject only to those restrictions that apply to other residential dwellings of the same type (e.g., single family, duplex, condominiums, apartments) in the same zone in accordance with City of Pacifica Housing Element: 2015-2023
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Government Code Section 65583(a)(5). For example, transitional housing located in an apartment building is permitted in the same manner as an apartment building in the same zone or supportive housing located in a singlefamily home is permitted in the same manner as a single-family home in the same zone.

Responsible Agencies - Planning Division
Financing - City funds
2007 Objectives - Amend zoning ordinance to make explicit provisions for transitional and supportive housing, and emergency shelters. Develop objective standards to regulate emergency shelters as provided for under SB 2.

Accomplishments - The City’s Zoning Code already permits by-right establishment of emergency shelters under the zoning classification “special care facility” in all residential districts. The by-right allowance pertains to facilities serving six or fewer individuals. The special care facility classification also allows shelters for “other need categories,” which can include transitional and supportive housing. However, the City should consider enacting explicit authorization for these types of uses as well as development standards for their establishment and operations.

2015 Objectives - Amend the Zoning Code to create new definitions for emergency shelters, transitional housing, and supportive housing. Create new permitted uses for these types of facilities to clarify their treatment by the City. Create development standards for the establishment and ongoing operations of these facilities.

Time Frame - 9/30/2015: Develop and discuss at the Planning Commission potential development standards for emergency shelters, transitional housing, and supportive housing.
- 1/31/2016: Amend the Zoning Code to explicitly permit by-right emergency shelters, transitional housing, and supportive housing.

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Action Program No. 17 (formerly Action Program No. 16D in 2007-2014 Housing Element) The City shall initiate contact with developers from the private and nonprofit sectors interested in development opportunities in the City of Pacifica for rental housing affordable to persons with extremely low, very low, and low incomes.

Specific Action - Proactively engage for-profit and not-for-profit housing developers on a periodic basis. Consider hosting an annual developer roundtable to discuss development opportunities sites and other development issues. Provide permit material and information about the review process at the public counter explaining the various steps in the process.

Responsible Agencies - Planning Division
Financing - City funds, Community Development Block Grants (CDBG), Affordable Housing Innovative Program (AHIP) Loan Fund, Home Investment Partnership Program (HOME), Multi-Housing Program General Component (MHP-General) Fund, and Predevelopment Loan Program (PDLP). 2007 Objectives - Initiate meetings with developers from the private and nonprofit sectors interested in affordable rental housing on a regular basis. Consider hosting an annual developer roundtable to discuss development opportunities sites and other development issues. Provide permit material and information about the review process at the public counter explaining the various steps in the process. This includes what materials need to be submitted and when and how long review will take at each juncture, and support applications for funding.

Accomplishments - The City frequently receives inquiries from developers of market rate and affordable housing. Staff provides them with information related to Pacifica’s development process and encourages them to proceed with their projects.

2015 Objectives - Begin a bi-annual housing developer roundtable hosted by the City to provide factual information on development sites and the City’s development process, as well as to demonstrate a strong City commitment to affordable housing development.

Time Frame - Bi-annually by 12/31 in 2016, 2018, 2020, and 2022: Host developer roundtable.

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POLICY - MAINTAIN A BALANCED RESIDENTIAL ENVIRONMENT WITH ACCESS TO

EMPLOYMENT OPPORTUNITIES, COMMUNITY FACILITIES AND
ADEQUATE SERVICES.

Action Program No. 18 (formerly Action Program No. 20 in 2007-2014 Housing Element) Encourage development of housing for all income levels, including lower income individuals, in suitable areas to meet ABAG's projected housing need.

Specific Action - Prepare, publish, and distribute a regularly-updated inventory of available housing development sites to facilitate the housing development process.

Responsible Agencies - Planning Division
Financing - City funds
2007 Objectives - Pacifica will encourage annual development of three low-income housing units, five moderate-income housing units, and 30 above-moderate income housing units. The City will continue to update the inventory of sites for distribution to potential developers and other interested parties. The City will advertise its sites by posting a list on the City’s web site and at the Planning Department, and by distributing hard copies to any persons interested in obtaining a list.

Accomplishments - Pacifica regularly updated its inventory of sites available for development.

The City posted the inventory on its website and made the list available to persons interested in the list at its public counter.
2015 Objectives - Update available development site inventory annually to encourage development of housing units to satisfy the City’s RHNA.

Time Frame - Annually by 12/31: Post updated inventory on City’s website.

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POLICY - ACTIVELY MONITOR HOUSING ELEMENT IMPLEMENTATION.

Action Program No. 19 (formerly Action Program No. 26 in 2007-2014 Housing Element) Form a committee to monitor housing trends affecting needs and development, as well as implementation of action programs. Devise strategies to accommodate housing needs that arise during the planning period that the Housing Element does not adequately address.

Specific Action - Form a committee which includes members of the Planning Commission and housing advocates. Hold meetings to discuss implementation of the Housing Element. Review annual Housing Element Status and Annual Progress Report prior to City Council consideration.

Responsible Agency - Planning Division
Financing - City funds
2007 Objectives - The committee should be constituted and continue to hold meetings to discuss implementation of the 2007 Housing Element.

Accomplishments - The City did not establish a committee to oversee 2007 Housing Element implementation.
2015 Objectives - Form a committee to assert more active oversight in Housing Element implementation. Review the draft Housing Element Status and Annual Progress Report prior to the public hearing and consideration by City Council.

Time Frame - 8/31/2015: Establish a Housing Element implementation committee. - Annually by 6/30: Planning Division staff conducts an internal review of implementation during first-half of year and projected implementation during remaining-half of year.
- Annually between 1/1 and 2/28: Hold a committee meeting to discuss prior year Housing Element implementation and to review the draft Housing Element Status and Annual Progress Report.
- Annually between 3/1 and 3/31: Present the Housing Element Status and Annual Progress Report at a City Council public hearing and seek Council approval and transmittal of the Report to the California Department of Housing and Community Development (HCD) by the April 1 deadline.

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9. Discontinued Programs
The City of Pacifica is a dynamic place, continually evolving and changing over time. This evolution impacts the City across numerous dimensions, including the natural, built, political, legal, and financial environments, The result is that certain programs proposed or undertaken in previous housing elements are no longer relevant or feasible within the context of the current planning period. The following is a summary of discontinued programs, including a brief listing of their accomplishments (if any) during the 2007-2014 Housing Element planning period.

A. Discontinued Program Listing
i. Action Program No. 4B
Complete and Adopt Green Building Ordinance.

Specific Action Adopt a Green Building Ordinance to assure that all new buildings and significant remodels incorporate green building practices and materials into the design.

Reason for Discontinuance The City enacted a local Green Building Ordinance on 12/13/2010, thereby establishing local standards for new and altered buildings.

The City superseded its ordinance with the adoption of the California Green Building Code on 12/25/2013. The program is no longer necessary because the City completed this activity, achieving the desired outcome.
ii. Action Program No. 11
Develop program for establishment of Housing Fund from tax increment revenues to increase and improve low and moderate-income housing.

Specific Action Develop a program which will set forth the means of distributing funds generated by the Redevelopment Agency. Establish priority system.

Reason for Discontinuance In 2012 the California Legislature dissolved redevelopment agencies statewide with passage of Assembly Bill (AB) x1 26 and AB 1484. Dissolution of the City’s Redevelopment Agency rendered this activity infeasible.
iii. Action Program No. 13
Develop regulations to encourage density-open space trade-offs, such as clustering development, transferring development rights from sensitive to less sensitive land, and dedication of open space.

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Specific Action Amend Zoning Ordinance to include procedure for transfer of development rights. Prepare inventory of potential "receiver sites." Continue to administer open space dedication policies.

Reason for Discontinuance The City enacted an ordinance governing transfer of development rights in 1989 (Ordinance No. 539-C.S.). The City also already has development provisions within the P-D (Planned Development) zoning district that allow deviation from strict implementation of development standards in order to achieve clustered development when it would lead to superior site design. This program was carried forward erroneously into the 2007-2014 Housing Element. iv. Action Program No. 13A
Encourage housing development in clusters.

Specific Action Review clustered housing standards for incentives to build housing development in clusters

Reason for Discontinuance The City already has codified development provisions within the P-D (Planned Development) zoning district that allow deviation from strict implementation of development standards in order to achieve clustered development when it would lead to superior site design. The P-D district regulations have existed in Pacifica since 1975, and this program was carried forward erroneously into the 2007-2014 Housing Element.
v. Action Program No. 15
Promote the Density Bonus Ordinance in all new multifamily residential development.

Encourage a mix of rental and owner housing types, including senior, low income, moderate, above moderate income, and entry-level home ownership for teachers, City employees, and others in Pacifica's workforce.

Specific Action Discuss the ordinance with individual developers. Stress incentives for inclusion of affordable units.

Reason for Discontinuance Incorporated into ongoing policies related to Development of Housing (Section 4.D).
vi. Action Program No. 16
Encourage development of small houses which will fit more appropriately on small lots.

Encourage development of small units in multi-family projects to provide more density without increasing massing. The market should limit cost of the units based on size.

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Specific Action Utilize the City’s Design Guidelines, design review process, and adaptable zoning provisions to encourage developers to build small units under appropriate circumstances.

Reason for Discontinuance The City has reviewed its Zoning Regulations and procedures and believes they are sufficient to encourage small unit development without undertaking an additional housing element program. vii. Action Program No. 16E
Apply for State and Federal monies for direct support of extremely low-income housing.

Specific Action The City shall consider applying for State and Federal monies for direct support of low-income housing construction and
rehabilitation. The City shall assess potential funding sources, such as, but not limited to, the Community Development Block Grant (CDBG), and HOME. The City shall also seek State and Federal funding specifically targeted for the development of housing affordable to extremely low-income households, such as the Proposition 1-C funds. The City shall promote the benefits of this program to the development community by posting
information on its web page and creating a handout to be distributed with land development applications.

Reason for Discontinuance The City does not have a housing authority and does not have staff dedicated to housing programs. Given current budget constraints, establishment of such an agency with staff is infeasible. The San Mateo County Housing Authority administers the activities described in this action program and pursues funding on behalf of the City of Pacifica and other cities in San Mateo County. viii. Action Program No. 16F
Consider using redevelopment funds for affordable housing.

Specific Action Consistent with State law, the City shall consider directing 20 percent of the tax increment funds accruing to the Redevelopment Agency to affordable housing. If successful in receiving matching funds from other sources, the City shall encourage the
Redevelopment Agency to work with affordable housing
developers to utilize a portion of set-aside funds for development of housing affordable to extremely low-income households.

Reason for Discontinuance In 2012 the California Legislature dissolved redevelopment agencies statewide with passage of Assembly Bill (AB) x1 26 and AB 1484. Dissolution of the City’s Redevelopment Agency rendered this activity infeasible.

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ix. Action Program No. 18A
Consider streamlining the permit process to expedite housing construction.

Specific Action Ensure that projects are reviewed and acted on in the shortest possible time consistent with the City's interest in complete review.

Reason for Discontinuance The City’s permitting process has not caused delays to housing development in any fashion that would benefit from streamlining actions. Major delays to projects typically stem from
environmental review under the California Environmental Quality Act (CEQA), a state statute the City cannot affect with streamlining actions.
x. Action Program No. 18B
Amend Manufactured Housing Ordinance regulations.

Specific Action Initiate the amendment of the manufacture housing building regulations to comply with state law.

Reason for Discontinuance The City has assessed its ordinance and believes it complies with state law. It allows manufactured housing to be installed in the R-1 zoning district subject to a non-discretionary building permit. xi. Action Program No. 18C
Consider streamlining the permit process to encourage and facilitate residential development on commercial sites (mixed-use).

Specific Action Ensure that commercial/residential projects are reviewed and acted on in the shortest possible time.

Reason for Discontinuance The City’s permitting process has not caused delays to housing development in any fashion that would benefit from streamlining actions. Major delays to projects typically stem from
environmental review under the California Environmental Quality Act (CEQA), a state statute the City cannot affect with streamlining actions.

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xii. Action Program No. 20A
Encourage development of lower and moderate income housing in suitable areas to meet ABAG's projected housing need.

Specific Action Prepare, publish, and distribute inventory of available sites.

Facilitate development process.

Reason for Discontinuance Action program combined with 2015-2023 Housing Element Action Program No. 22.
xiii. Action Program No. 21
Continue to cooperate with the Pacifica Resource Center and emphasize its role in housing assistance.

Specific Action Refer interested parties to Center staff.

Reason for Discontinuance Action program combined with 2015-2023 Housing Element Action Program No. 5.
xiv. Action Program No. 22
Promote the Human Investment Project's Shared Homes Program directed to seniors and single parents who are homeowners or tenants.

Specific Action Obtain literature for display and distribution. Refer interested individuals to Project staff.

Reason for Discontinuance Action program combined with 2015-2023 Housing Element Action Program No. 5.
xv. Action Program No. 23
Promote Project Sentinel, a program that investigates complaints of discrimination in housing due to race, religion, marital status, sex or national origin.

Specific Action Obtain literature for display and distribution. Refer interested individuals to Project staff.

Reason for Discontinuance Action program combined with 2015-2023 Housing Element Action Program No. 5.

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xvi. Action Program No. 24
Promote the Center for Independence of Individuals with Disabilities, an organization that provides services to the disabled, including housing rehabilitation assistance and accessibility modifications.

Specific Action Obtain literature for display and distribution. Refer interested individuals to Center staff.

Reason for Discontinuance Action program combined with 2015-2023 Housing Element Action Program No. 5.
xvii. Action Program No. 25
Provide the opportunity for conversion of existing facilities to shelters for victims of family violence, or other special needs facilities.

Specific Action Advise interested individuals that Special Care Facilities which include shelters for victims of family violence, homeless persons, or “other needs categories” such as transitional housing and emergency shelters are permitted in the R-1 (Single-Family Residential) district.

Reason for Discontinuance The City’s existing Zoning Code permits by-right “special care facilities” for six or fewer persons in all residential zoning districts.

The City does not need to pursue opportunities for conversion of existing facilities as this is already permitted.

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V. COASTAL ZONE HOUSING

1. Purpose
The coastal zone in Pacifica is that area west of Highway 1 with a small extension east of the highway between Reina del Mar and Burns Court. Pacifica has six coastal neighborhoods, which include (from north to south) Fairmont West, West Edgemar/Pacific Manor, West Sharp Park, Rockaway Beach, West Linda Mar, and Pedro Point. The coastal zone contains 16 percent of Pacifica’s land area but only 13 percent of its population.

State law includes several requirements for housing in the coastal zone. Specifically, Government Code Section 65588 calls for jurisdictions to include in their housing elements information on the following:
 The number of new housing units approved for construction within the coastal zone after January 1, 1982;
 The number of existing residential dwelling units occupied by persons and families of low or moderate income that have been authorized to be demolished or converted since January 1, 1982, in the coastal zone;
 The number of housing units for persons and families of low or moderate income required to be provided in new housing developments either within the coastal zone or within three miles of the coastal zone;
 The number of residential dwelling units for persons and families of low or moderate income that have been required for replacement or authorized to be converted or demolished. The review shall include the location of the replacement units in or within three miles of the coastal zone.

State law calls for replacement of demolished if determined to be feasible. In addition, all new development in the coastal zone is required to include low and moderate income units if feasible. Due to the small size of all new development in Pacifica's coastal zone, only one project approved since 1982 has included affordable units. Future projects within the coastal zone are also unlikely to yield affordable units unless they develop eight or more housing units, and which point they become subject to the City’s Inclusionary Zoning Ordinance.

2. Housing Unit Construction, Demolition, and Replacement During the 2007-2014 Housing Element planning period, 11 housing units were constructed in the coastal zone. When including areas in or within three miles of the coastal zone, the figure rose to 17 housing units (note: all developable areas of the City are located within three miles of the coastal zone).

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these units underway in the construction phase. The replacements occurred on the same sites within the coastal zone. One unit, on Carmel Avenue, was not replaced.

While not demolished, other coastal zone housing units have been impacted during the 2007-2014 Housing Element planning period in such a way as to have the effect of demolition. The City’s Building Official has determined that 20 rental housing units located at 320 Esplanade Avenue and 12 rental housing units located at 330 Esplanade Avenue (all 32 of which were affordable to low-income persons) are unsafe for habitation due to severe coastal erosion.22 The units have not been replaced, and
it is unlikely they will ever be replaced on the same site. The City’s opinion of conditions at the site is that coastal erosion is too severe and that future development at the site is unlikely, including remedial measures to make the buildings once again habitable.

Since January of 1982, a total of 25 housing units have been demolished in the coastal zone. Of these, 5 were low-income units, 17 were moderate-income units, and 3 were above-moderate income units.

Two of these homes, located west of Beach Boulevard in West Sharp Park were lost in a storm.

Another unit on Olympian Way in Pedro Point was demolished because it was threatened by a slide.

Eight of the units demolished since 1982 did not suffer storm damage. One moderate-income structure on Salada Avenue was demolished because it was not up to Building Code standards. It was not replaced. Two moderate-income units on Francisco Boulevard were demolished because they were not up to Building or Fire Code standards. These units have not yet been replaced.

Additionally, in 1998 seven homes, located on Esplanade Avenue in Pacific Manor were lost in a storm.

Another above-moderate income unit on Blackburn Terrace in Pedro Point was demolished. It was replaced in 1998 by an above-moderate income unit. Two above-moderate income units in the West Rockaway Beach area were also demolished.

Twenty-two mobile homes threatened by the 1983 storm were moved out of the Pacific Skies Estates Mobile Home Park on Palmetto Avenue. To date, 14 of the mobile homes have been replaced in the park and the park operator will continue to replace older mobile homes.

Nine structures outside the coastal zone have been demolished since January of 1987. Four destroyed in a 1982 storm included two on Valdez Way in Linda Mar and two on Oddstad Boulevard in Park Pacifica. Three other structures on Reina del Mar in Vallemar were demolished. They were replaced in 1984, 1998, and 2000, respectively. Another unit was demolished in 1999 on Crespi Drive in the West Linda Mar neighborhood. In 1992 a unit was demolished on Perez Drive in the Linda Mar area. The unit was replaced on-site.

No housing units for persons and families of low or moderate income were required to be provided in new housing developments either within the coastal zone or within three miles of the coastal zone during the 2007-2014 Housing Element planning period.

22 The Building Official notified tenants of 330 Esplanade Avenue December 17, 2009, and tenants of 320 Esplanade Avenue on April 29, 2010.

City of Pacifica Housing Element: 2015-2023
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VI. PUBLIC PARTICIPATION
On December 16, 2014, the Planning Commission held a study session public review workshop to discuss the draft Housing Element and to solicit new ideas for policies and action programs from residents, housing advocates, and other interested parties. Additionally, on April 20, 2015, the Planning Commission held a public hearing to consider the Housing Element, including public testimony. The Planning Commission forwarded the Housing Element to the City Council with a recommendation of approval. The City Council held a public hearing on the Housing Element on May 11, 2015, again seeking public input from residents, housing advocates, and other interested parties. As the public review process progressed, the City posted a draft version of the Housing Element on the City’s website, as well as on the “21elements.com” website for convenience of public review.

Notices of the study session workshop and public hearings were published in the Pacifica Tribune newspaper, e-mailed via the City’s public information system, posted on the Nextdoor community engagement web platform, posted on the City’s website, mailed to interested parties, and posted in the following locations:

1. Sanchez Library (Park Pacifica)

2. Pacifica Library (West Sharp Park)

3. Pacifica Community Center (Linda Mar)

4. Pacifica City Hall

5. Planning Department
Additionally, the City sent notices to 50 nonprofit housing organizations and service providers servicing special needs populations, including Bay Area Legal Aid, Center for the Independence of the Disabled, Center on Homelessness, Community Legal Services, Golden Gate Regional Center, HIP Housing, InnVision/Shelter Network, Mental Health Association of San Mateo County, and the San Mateo County Commissions on Aging/Disabilities.

VII. CONSISTENCY WITH GENERAL PLAN
The City will review the Housing Element during the annual review of the General Plan to ensure consistency is achieved and maintained during the planning period with all other legally required elements, and revise as necessary. The City will consider whether major changes in objectives and policies are necessary to achieve its goals, and undertake revisions as necessary.

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VIII. SUMMARY AND CONCLUSION
Pacifica’s population decreased by 3 percent between 2000 and 2010. In the last 30 years the largest population change occurred between 1980 and 1990, with an increase of 804 residents (+2.2 percent).

The City is becoming more diverse as the white population shrinks and the Asian and Latino populations increase.

The City is no longer experiencing periods of rapid population growth as it did during the mid-twentieth century, and development of housing units has slowed as a result. Slowing development of housing units places greater emphasis on maintenance, preservation, and improvement activities by the City.

Yes, development of new housing units will be critically important to meet the increasing needs of seniors and persons with disabilities. Maintenance, preservation, and improvement alone will not meet the housing needs of these groups and other lower income persons.

The City has identified sites where focused housing development can occur. Sufficient sites exist to meet the City’s Regional Housing Needs Allocation (RHNA) for the period from January 31, 2015, through January 31, 2023. The City has also identified certain programs and activities it can implement and undertake to encourage development of housing, or to enhance maintenance, preservation, and improvement of existing housing.

Constrained housing resources in a post-redevelopment environment will make development of affordable housing more challenging for Pacifica, but the City is determined to apply all available resources to meet the housing needs of current and future residents.

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IX. CONTACT INFORMATION
The names, addresses and telephone numbers of the agencies named in this Housing Element are listed below. Whenever possible, the names of contact persons at the agencies are identified. Also listed are the Action Programs for which the agencies are responsible.

Agency Action Program No. Ongoing Policy No.

Pacifica Planning Department,
Planning Division
1800 Francisco Boulevard
Pacifica, CA 94044
Lee Diaz, Acting Planning Director
3, 4, 5, 6, 8, 9, 10, 11,
12, 13, 14, 15, 16, 17,
18, 19
IV.4.B.ii, IV.4.B.iii,
IV.4.B.iv, IV.4.D.i,
IV.4.D.ii, IV.4.D.iii,
IV.4.D.iv, IV.4.D.v,
IV.4.D.vi, IV.4.D.vii
Pacifica Planning Department,
Building Division
1800 Francisco Boulevard
Pacifica, CA 94044
Liz Ryder, Building Official
1, 2, 7, 9 IV.4.A.i, IV.4.A.ii,
IV.4.A.iii, IV.4.B.i,
IV.4.C.i, IV.4.D.v
Pacifica Planning Department,
Code Enforcement Division
1800 Francisco Boulevard
Pacifica, CA 94044
Lawrence Ngai, Code Enforcement Officer
1, 7 IV.4.A.i, IV.4.A.ii,
IV.4.C.i
Pacifica Fire Department
616 Edgemar Boulevard
Pacifica, CA 94044
Rich Johnson, Deputy Chief
IV.4.B.i
Pacifica Public Works Department
155 Milagra
Pacifica, CA 94044
Van Ocampo, Director
8 IV.4.D.v
Pacifica City Manager’s Office,
Economic Development Division
170 Santa Maria Avenue
Pacifica, CA 94044
Anne Stedler, Econ. Development Manager
10 IV.4.D.i
City of Pacifica Housing Element: 2015-2023
133
Agency Action Program No. Ongoing Policy No.

Pacifica Finance Department
170 Santa Maria Avenue
Pacifica, CA 94044
Lorenzo Hines, Assistant City Manager
Pacifica Parks, Beaches, and Recreation
Department
1810 Francisco Blvd.

Pacifica, CA 94044
Michael Perez, Director
5 Housing and Community Development
Division, County of San Mateo
264 Harbor Boulevard, Building A
Belmont, CA 94002
1, 7
Pacific Gas & Electric Company (PG&E)
P.O. Box 997300
Sacramento, CA 95899
9 Pacifica Resource Center
1809 Palmetto Avenue
Pacifica, CA 94044
Anita Rees, Director
7 Pacifica Historical Society
P.O. Box 752
Pacifica, CA 94044
IV.4.B.iv
Abilities United
525 E. Charleston Road
Palo Alto, CA 94306
The Arc
1500 Howard Street
San Francisco, CA 94103
BRIDGE Housing
600 California Street, Suite 900
San Francisco, CA 94108
City of Pacifica Housing Element: 2015-2023
134
Agency Action Program No. Ongoing Policy No.

Center for Independence of Individuals with
Disabilities
2001 Winward Way, Suite 103
San Mateo, CA 94404
Human Investment Project ("HIP")
364 South Railroad Avenue
San Mateo, CA 94401
Kate Comfort Harr
Poplar ReCare
1764 Marco Polo Way
Burlingame, CA 94010
Project Sentinel
1615 Hudson St., Suite A
Redwood City, CA 94061
Puente Clinic
1950 Alameda de las Pulgas
San Mateo, CA 94403
West Bay Housing Corporation
1390 Market Street, Suite 405
San Francisco, CA 94102
Master Schedule of Fees and Charges 2014-2015
Fee Description Adopted Fee
9/08/14

CITY CLERK
City Council Agenda Packets
One meeting packet $45.00
Photocopies (per page) $0.25
Other
Pacifica Municipal Code $181.00
Annual Code Maintenance Fee $90.00
Ordinances and Resolutions $0.25
City Council Agenda Packets $1,091.00
Appeal of Planning Commision Decisions to the City Council $100.00

FINANCE
Bond Search Requests
Current $60.00
Delinquent $60.00
Fireworks Permit
Part 1 $303.00
Part 2 $484.00
Other
Bond Reports $43.25
Business License: Penalty for False Reporting of Gross Receipts $500.00 Annual Financial Report $34.00
Computer Review $99.00
Non-Sufficient Funds Charge $26.00
FIRE
Permits
Annual Fire Code Permits (Each) $200.00
Permitted activities less than 90-days. Initial fee includes 1 hour; hourly charge thereafter. Temporary Permit Required.
$140.00
Plan Review Fire Sprinklers/Stand Pipes
Alteration/repair of existing underground pipe systems. Includes underground, hydro/flush, rough and final. $345.00
Commercial underground pipe system installations. Includes underground, hydro/flush, rough and final. Hourly thereafter. $490.00 Fire sprinklers - tenant improvements. 9 or less sprinkler heads Unlimited head change-outs. (Permit required only). Initial fee includes 1 hour; hourly thereafter. $135.00 New commercial & residential sprinkler installations. First 3,000 sq. ft. Includes underground, hyrdro/flush, rough and final inspections. Hourly thereafter. $665.00 New manufactured home sprinkler systems. Includes underground, hyrdro/flush, rough and final inspections. Hourly thereafter.
$455.00
A-1
Master Schedule of Fees and Charges 2014-2015
Fee Description Adopted Fee
9/08/14
Standpipe system installation, per standpipe and includes underground, hydro/flush, rough and final inspections.
$595.00
Tenant Improvements - installation/alteration of 10 or more heads. (Head changeouts are not included in count). First 300 sq. ft.; hourly thereafter. $245.00
Plan Review General
Additional Plan review beyond the first 3000 sq. ft.; per hour. $104.00 Plan Check Re-Submittals; initial fee includes first hour; hourly charge thereafter. $135.00 Plan Review New Construction and/or Tenant Improvements Additional plan review for major changes, additions, as-builts, or resubmittals; initial fee includes first hour; hourly charge thereafter. $140.00
Misc. items w/o sq. footage - e.g. Install hazardous material, storage tank, HVAC smoke detection, partition wall, etc. Initial fee includes first hour; hourly charge thereafter.
$140.00
Subdivision map review; per hour fee. $150.00
Base rate - all occupancies. Initial fee includes first 3,000 sq.ft.; hourly thereafter, includes rough and final inspections.
$350.00
Plan Reviews Fire Alarms
Existing Fire Alarm Panel Upgrades. Initial fee includes first 3,000 sq.ft.; hourly thereafter, includes rough and final inspections.
$245.00
Installation of additional devices on existing system. Initial fee includes first 3,000 sq.ft.; hourly thereafter, includes rough and final inspections. $385.00
New installations. Initial fee includes first 3,000 sq.ft.; hourly thereafter, includes rough and final inspections.
$455.00
New installations -- Other Fire Protection Systems. Initial fee includes first 3,000 sq.ft.; hourly thereafter, includes rough and final inspections. $700.00
Requested Services
All Other Reports. Cost per report. $38.00
Digital Photographs - CD, plus $1 for CD cost $64.00
Digital Photographs - Print. Plus $1.40 per photo cost. $69.00 Fire Code Variance Application; per request and none-refundable. $546.00 Fire incident reports (per report charge) $38.00
Inspection Outside Normal Business Hours (Per hour, OT rate) O.T. Rate Non-Subpoenaed Fire Investigation Reports (per report) $38.00 Pre-Inspection / Consultation for daycare facilities, construction projects, etc. Initial $119.00 Pre-Inspection of care facilities with 25 or fewer occupants. (Flat Fee) $119.00 Pre-Inspection of care facilities with 26 or more occupants. (Flat Fee) $225.00 Processed Photographs, plus cost of developing $72.00
Subpoenaed Fire Investigation Report - through City Attorney's Office, plus attorney's fees per evidence code.
$54.00
Site Inspections
Additional inspections beyond the first 3000 sq ft $104.00 A-2
Master Schedule of Fees and Charges 2014-2015
Fee Description Adopted Fee
9/08/14
Fire alarms - repair or exchange devices and radio transmitters; Initial Fee includes first hour; hourly charge thereafter.
$135.00
Inspection for which no fee is indicated; Initial Fee includes first hour; hourly charge thereafter.
$135.00
Installation of hazardous materials storage tank $178.00 Re-inspections; Initial Fee includes first hour; hourly charge thereafter. $104.00 Removal of hazardous material storage tank. Per tank charge. Temporary permit required.
$135.00
Replacement of hazardous material storage tank piping, dispensers. Per tank charge. If piping work is done as part of tank installation, there is no charge. $178.00
Penalties
Unpermitted construction work Fee plus 2 times fee
False Alarms - 1st Response $0.00
False Alarms - 2nd Response $283.00
False Alarms - 3rd Response $361.00
False Alarms - 4th+ Response $515.00
ANNUAL Commercial Fire Inspection & Re-inspections
A 1 -4 Assembly Occupancies $158.00
B Business Office Occupancies $90.00
E Educational Occupancies $158.00
F Factory Occupancies $158.00
H Hazard Occupancies $158.00
I Institutional (Nursing Homes) Occupancies $158.00
M Mercantile Occupancies $118.00
M Mercantile Occupancies (Motor Fuel Sales) $131.00
R-1 Occupancies Hotels $158.00
R-2 Residential 3 to 20 units $80.00
R-2 Residential 21 - 40 Units $96.00
R-2 Residential 41 - 70 Units $118.00
R-2 Residential 71 - 90 Units $141.00
R-2 Residential 91 - 120 Units $186.00
R-2 Residential Over 120 units $233.00
R-3 Residential Care less than 24 hours $131.00
R-3.1 Licensed Residential Care 24 hour 6 or less $158.00 R-4 Residential care 6 or more $158.00
S Storage Facilities $131.00
U Utility Structures $131.00
POLICE
False Alarms
First Response No Charge
Second through fifth responses $125.00
Six or more responses $195.00
False Alarms without permit
A-3
Master Schedule of Fees and Charges 2014-2015
Fee Description Adopted Fee
9/08/14
First Response No Charge
Second through fifth responses $195.00
Six or more responses $195.00
Photograph (digital)
First Page of Photographs (4 to a page) $22.00
Subsequent pages of photographs (4 to a page) $7.00
Disc of photos $30.00
Arcade Permit
Annual Renewal Fee $49.00
Application Fee $29.00
Block Party Permits $50.00
Massage Parlor/Outcall
New $162.00
New - State Certified/Outcall $50.00
Renewal Fee $50.00
Renewal Fee - State Certified $25.00
Masseur / Masseuse
New $331.00
New - State Certified $50.00
Renewal Fee $100.00
Renewal Fee - State Certified $25.00
Massage Trainee - State Certified $50.00
Administrative Fee for Firearms (Per Penal Code 12021.3J1) For release to owner $384.00
Taxi Cab Operation
Permit / Background Investigation $129.00
Fingerprinting and Submittal to DOJ $94.00
Vehicle Inspection $99.00
General
Case Reports (Per Public Records Act) No Charge
Good conduct letter for Visa (record review) $53.00
Bingo Permit: New $29.00
Bingo Permit: Annual Renewal Fee $29.00
Second Hand Dealers $130.00
Tow Service Contract $197.00
Massage Trainee $162.00
Alarm Permit $82.00
Alarm Permit Renewal $43.00
A-4
Master Schedule of Fees and Charges 2014-2015
Fee Description Adopted Fee
9/08/14
Application for Concealed Weapon (To be paid to licensing agency) $100.00 Application for Concealed Weapon: Renewal Fee (To be paid to licensing agency) $25.00 Fortune Telling $58.00
Audio / Video "CD/DVD" duplication $30.00
Private Property abatement $220.00
Vehicle Release Administrative Costs (all but victims) $133.00 General Research $83.00/Per Hour
Storage of Property $1.00/Per Day
Tobacco Retailer License $76.00
Police Officer Subpoena (Per G.C. 68097.2) $275.00
Live Scan Fingerprinting $45.00
Loud Party Response $179.00
San Mateo County Booking Fee Based on Current
County Fee
DUI with Incident Cost of hours and car
TapeTransaction Cost of Outside Service
Dance Permit $49.00
Repossession Fee (Per G.C. 26751) $15.00