Agenda, special meeting — Pacifica City Council, July 11, 2022 (part 29 of 45)

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Packet Pg. 4922 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 497
Letter Commenter Date Comment Combined Response
Individuals (C)
Bridge), Coastside Commute Hours (M-F morning
and evening, Sat-Sun 10AM-3PM) - don't want a
bus operator to add another bus to an existing
route that takes 45 minutes to and hour to get to
BART or Caltrain and call it satisfying the SB-743
requirement.
more information about GP- or SPSPrelated responses.

C94-6 Rick Nahass 2/20/22 Possible exemptions or fee relief for low-income housing development
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

C94-7 Rick Nahass 2/20/22 Councils sit on the commute.org Board. As housing development is approved and potential fees
identified, a budget can be forecast for
establishing and growing a shuttle program based
on capital income (one time developer fee) and
yearly operating income (yearly owner fee)
The comment is not related to the
adequacy of the DEIR, therefore no further
response is required in the FEIR. However,
the comment addresses the content of the
Proposed Plan and will be shared with
decision-makers in that context. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

C94-8 Rick Nahass 2/20/22 If a coastside transit corridor is established per the General Plan definition, then the fees are reduced.

See attached illustrative worksheet for Pacifica
stops.

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

C94-9 Rick Nahass 2/20/22 This makes housing growth mandates (RHNA ABAG) dependent on both developers' willingness
to pay to reduce VMT and Regional Transportation
Operators and Caltrans ability to deliver a high
quality transit corridor to the coastside. Also
serves to mitigate GHG, Climate and Circulation
elements of the GP.

1.f
Packet Pg. 1162 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4923 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 498
C95: Mark Hubbell, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C95-1 Mark
Hubbell
3/8/22 Having said that, the absence of opportunities for current citizen participation in the process is clearly evident and rather disappointing. Particularly disturbing is the safety element failure in addressing the likelihood of devastating wildfires throughout the Park Pacifica and eastern Linda Mar neighborhoods with a presentation of specific,
comprehensible, and effective plans for the prevention of and protection from these deadly hazards.

Thank you for your comment. The
adequacy of the DEIR in addressing
wildfire hazards is addressed in
Master Response 5: Wildfire.

C95-2 Mark
Hubbell
3/8/22 HISTORY:

Thirty years ago, the Oakland Hills firestorm – Tunnel Fire -- of 1991, swept through a nearby residential neighborhood with surprisingly similar terrain and autumn weather
conditions as the Back Of The Valley neighborhoods in
Pacifica, burning through 1520 acres; killing 25 people and injuring 150 others; destroying 2,843 single-family homes and 437 apartment and condominium units. The economic
loss from the fire was estimated at $2.59 billion in 2020 dollars. Division Chief Riley and Oakland Police Officer John Grubensky were killed while trying to help citizens escape the fire. Both Chief Riley and Officer Grubensky were found with the remains of those people they were trying to help. (Source: Wikipedia)
Let’s also dispel the notion that eucalyptus trees aren’t flammable: “The leaves produce a volatile highly
combustible oil, and the ground beneath the trees is
covered with large amounts of litter which is high in
phenolics, preventing its breakdown by fungi. Wildfires burn rapidly under them and through the tree crowns. It has been estimated that other than the 3,000+ homes that burned in California’s 1991 Oakland Hills Fire, about 70 percent of the energy released was through the
combustion of eucalyptus” — Bill Gabbert (Author of
Wildfire Today) Why is there is no mention of city support and assistance for fire mitigation through tree removal and replacement with less flammable native foliage in this
General Plan? Most likely, the opportunity for community participation would have brought this to The City’s
attention.

In 2021, a record number of wildfires burned across the western states. As of December 16, 2021, a total of 8,619 fires had been recorded, burning 2,569,009 acres across California. So far in just the first couple months of 2022, there have already been two significant fires, the Alpine Fire on the Sonoma Coast and The Colorado Fire near
Camel By The Sea, burning a combined 700 acres of nearby coastal area, in the middle of winter, in what is normally the rainy season.

The first two months of 2022 are shaping up to be the
driest January and February in California history, prompting state officials to warn of dire water conditions ahead.

Please see response to comment
C7-1 for more information on how
vegetation/fuel is included in fire
mapping. Please see Master
Response 5: Wildfire for more
information.

1.f
Packet Pg. 1163 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 4924 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 499
Letter Commenter Date Comment Combined Response
Individuals (C)
“There’s no precipitation forecast through the remainder of February. And there’s very little precipitation in the longrange forecast for March,” Erik Ekdahl, a deputy director with the State Water Resources Control Board, said at a board meeting Tuesday. “All this is pointing to, again, some pretty dire conditions statewide for drought.” In the 1970s, Pacifica, as did many other California cities, started TreesFor-ADollar campaigns with Planting Parties. Many trees were planted in the indefinable spaces between fence lines weaving through hillside neighborhoods.

Today, most of those trees are dead or dying tinder-towers, and they are fire and falling hazards costing from $5,000 to $9,000 apiece for the individual homeowner to remove. If only it had been a more enlightened program providing
fire-resistant native species, like coastal live oaks or redwood trees, we wouldn’t be having this problem. Many years later, it is hard to get neighbors to agree on
responsibility; so the trees become an increased danger for everybody.

Somehow and soon, those trees will have to be equitably removed for the safety of residents in these
neighborhoods.

C95-3 Mark
Hubbell
3/8/22 Understandably, it is challenging to extrapolate current conditions with data trends decades into the future. But isn’t that the point of creating The 2040 General Plan? So the question for validating this Environmental Impact
Report is:

What will The City do over the next few years to potentially ensure the safety of thousands of citizens, as well as
firefighters and police for decades to come, by eradicating these life-threatening conditions?
Please see Master Response 5:

Wildfire for more information on
how the DEIR analyzes impacts of
future development under the
Proposed Project.

C95-4 Mark
Hubbell
3/8/22 CURRET HAZARD ASSESSMENTS:

The City has very recently been distributing inconsistent versions of its wildfire hazard maps. Map ‘A’ below is the map included in this DEIR. This map does seem to represent the actual concerning levels of wildfire severity in the Park Pacifica / East Linda Mar neighborhoods. Map ‘B’ is
incorporated into the General Plan tethered to this same DEIR project is substantially different by eliminating the actual severity of most wildfire threats within the Pacifica City limits – an obvious inconsistency. Map ‘C’ was provided By The City last summer to the San Mateo County Hazard
Risk Ranking program, possibly by accident, yet assuring them that Pacifica is indeed fireproof. Image ‘D’ is the response from The County acknowledging that the risk of wildfire in Pacifica is less than “dams breaking,” even though there are no dams in Pacifica.*
Please see Master Response 5:

Wildfire for more information on
data used for mapping. Map D is a
map from the 2014 DEIR that was
not certified; it does not use the
2008 CAL FIRE Recommended LRA
maps and thus do not represent the
latest and best available data.

C95-5 Mark
Hubbell
3/8/22 For the sake of accuracy, here are the actual Cal Fire percentages.

The comment is noted.

C95-6 Mark
Hubbell
3/8/22 *Note: Dam Failure -- There are no dams within or above Pacifica, and therefore the city is not at risk from a
seismically induced dam failure. However, water tanks
The comment is noted. Proposed
General Plan policy SA-I-13 has the
City work with the NCCWD to

1.f
Packet Pg. 1164 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4925 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 500
Letter Commenter Date Comment Combined Response
Individuals (C)
located in the hills above populated areas could burst and inundate areas below due to a seismic event. (Pacifica
Planning Dept.)
determine areas potentially
affected by flooding from ruptured
water tanks in the event of a
seismic event and inform property
owners. In addition, analysis under
Impact 3.13-1, specifically on pages

3.13-6 to 3.13-7 states that
NCCWD’s current Capital
Improvement Plan focuses on
minimizing the risk to the water
supply that could result from a
major seismic event.

C95-7 Mark
Hubbell
3/8/22 Earthquake damage facts show fires caused by earthquakes are the second most common hazard. Earthquake fires start when electrical and gas lines are dislodged due to the
earth’s shaking. Gas is set free as gas lines are broken and a spark will start a firestorm (Source: Cal Fire). The main natural gas pipeline (blue line) running into Pacifica is an extension of the one that exploded in San Bruno, 2010. As you can see, the pipeline crosses the San Andreas Fault, which moves northward at the rate of 4 to 6 cm (1.6 to 2.4 inches) per year since the early 20th century. Parts of the fault line moved as much as 6.4 meters (21 feet) during the 1906 earthquake. (Source: Enc. Britannica, Feb 7, 2022) The comments is noted. The
addition of "fires that could result
from earthquake" will be added to
errata. This addition does not
change findings of significance in
the DEIR.

C95-8 Mark
Hubbell
3/8/22 The good news is that there are many grant funding programs available for areas in high wildfire threat areas:

Cal Fire: Urban and Community Forestry Grant Programs – Reforesting With More Fire Resilient Foliage
PG&E: The10,000-mile Undergrounding Program –
Undergrounding Utility Lines In High Treat Wildfire Areas FEMA: Fire Service Grants and Funding -- Assist fire
prevention programs and
support firefighter health and safety research and
development.

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

C95-9 Mark
Hubbell
3/8/22 So the question for validating this Environmental Impact Report is: Why not come clean about our situations to
qualify for available resources, instead of hiding or
confusing the hazards that threaten us?
The DEIR uses the latest and best
available data regarding hazards in
the DEIR. Please see Master
Response 5: Wildfire for more
information.

C95-10 Mark
Hubbell
3/8/22 FIREWORKS:

Senator Dianne Feinstein’s office can speak to that:
“The drought in California has created dangerous
conditions for wildfires this summer. And the risk will spike this weekend as millions celebrate the July 4 holiday. I urge all Californians to leave fireworks to the professionals this year.
“Last year we saw how much damage irresponsible use of
fireworks can cause. The San Francisco Fire Department
reported at least 100 grass fires, Fresno saw at least 135 fires and the Los Angeles Fire Department responded to
The comment states the proposed
General Plan should address the risk
of wildfires from fireworks, which
are illegal in Pacifica. Enforcement
of existing City of Pacifica Municipal
code is beyond the necessary scope
of the Draft EIR. Please see more
information about fire hazard and
threat mapping, descriptions, and
policies that reduce the impacts.

The Draft EIR is concerned with
analyzing the risk to exposure from

1.f
Packet Pg. 1165 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 4926 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 501
Letter Commenter Date Comment Combined Response
Individuals (C)
nearly 400 fires, many started by fireworks.
“Fireworks at one party in Yucaipa last September sparked a wildfire that burned more than 20,000 acres. Just last week, firefighters in Fresno County responded to a brush fire caused by illegal fireworks.
“The bottom line is that with the hot, dry conditions
California is currently experiencing, using fireworks risks sparking destructive and deadly wildfires. And using illegal fireworks can lead to fines of up to $50,000 and a year in jail. Parents are also liable for any damage or injuries caused by their children using fireworks.
“Do your part to prevent wildfires and celebrate the holiday safely by skipping fireworks at home and instead watch a public show in your community.”
wildland fires, rather than providing
a comprehensive list of causes of
wildland fires, which include illegal
fireworks.

C95-11 Mark
Hubbell
3/8/22 Pacifica may not be able to qualify for wildfire prevention grants. So the question for validating this Environmental Impact Report is: Would any safe and sane professional
person approve grant funding for wildfire safety to a city offering legal fireworks?
This comment inaccurately states
that fireworks are legal in Pacifica;
they are illegal. See response to
comment C95-10
C95-12 Mark
Hubbell
3/8/22 EVACUATION:

In the event of a wildfire emergency, it would be a very bad idea for hundreds or potentially thousands of families in cars to try evacuating to the beaches via only two available routes for sanctuary. The Zonehaven Evacuation program
seems to be a brilliant solution to avert a horrible disaster.

So the question for validating this Environmental Impact Report is: Why won’t The City concentrate on promoting
this program more effectively?
Thank you for your comment. As
stated in the DEIR, The Safety
Element of the General Plan
provides policies that address
conformance with local emergency
response programs and continued
cooperation with emergency
response service providers. For
example, policies have been
developed to ensure that all
applicable disaster plans are
updated regularly and a
coordinated emergency response
system is maintained with other
agencies. As such, implementation
of the Proposed Project would not
physically impede the response
times of emergency response
vehicles or delay implementation of
an evacuation plan, resulting in a
less than significant impact."
Policies that reduce the impacts of
evacuation deficiencies include
those described under Impact 3.11-

6. The Zonehaven program is also
addressed in Pacifica's MJ-LHMP
Annex, incorporated by reference in
the DEIR.

1.f
Packet Pg. 1166 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4927 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 502
C96: Judy Yamahiro, 1/26/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C96-1 Judy
Yamahiro
1/26/2
2 Please fix the documents as Mr. Shoemaker described via next door Linda Mar to make them more easily accessible and please extend the deadline for review. As a resident, my tax dollars are being used to compose this document and all residents deserve good value for our tax dollars.

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

1.f
Packet Pg. 1167 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 4928 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 503
C97: Christine Boles, 1/29/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C97-1 Christine
Boles
1/29/22 I tried working with the word documents today in parallel with the pdfs and it just added to the cumbersome, time consuming task you have so disrespectfully dumped on the public. Page numbers don’t even match. Now I have to scroll thorough multiple windows at once, with a third window for writing my comments and a fourth window for checking references online, because so many are outdated.

I think I made it through 5 whole pages of the DEIR on seismic risks today and already have two pages of comments. Only 1008 pages to go…
Do you not understand that we actually want to help you improve these documents so that the General Plan can be properly used for the next 20 years? The many errors and inconsistencies in these documents leave the city exposed to litigation not just by the public and environmental groups, but also by developers. Is that the legacy and risk this council wants to leave the city saddled with? As Tygar said so eloquently at the last Council meeting, this is your decision, and you need take the responsibility. The buck stops with you; Staff is just waiting for the word from the 5 of you, who were elected to represent us. Remember your names will be on this document for posterity.

And planning commissioners, please, you have a voice too. Have you started your own review? Are these documents good enough for you and for those who will follow you in those seats to do the jobs to ensure the public and our environment are protected? Can you please put the General Plan discussion on your agenda for February 7? I really want to hear what you think.

We’ve already been waiting 43 years, we can wait a few more months.

Do the right thing. Fix the documents into one searchable pdf, provide an index, update the bibliography and links, and reset the clock.

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

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

1.f
Packet Pg. 1168 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 4929 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 504
C98: Christine Boles, 1/7/2022
Letter Commenter Date Comment Combined
Response
Individuals (C)
C98-1 Christine
Boles
1/7/2
2 Both the Tribune and the City’s website say the General Plan review process starts today, but I can’t find the documents on the city website. The links given are circular. Can you confirm that the review process will be extended as necessary so that we have the full minimum 45 days?
https://www.cityofpacifica.org/civicax/filebank/blobdload.aspx?t=62428.95&BlobI D=19363
Please confirm when the documents will be made available.

I am really disappointed to read that there will be no public launch giving an overview of the documents and explaining how residents and businesses can best contribute. My guess is that most Pacificans don’t even know what a General Plan is, much less understand its importance. The fact that after 40+ years the General Plan release is not even an item for discussion on the City Council’s agenda for Monday leads me to believe that the city lacks the desire for public education and engagement on the future vision of our city.

I understand that staff resources are limited and that the City Manager would want to minimize their time and expense, but Council Members, I ask you as elected representatives to question whether this is the right decision. It is obviously your call to make, not that of staff.

Documents
were posted on
1/7/2022; the
review period
was extended
to 3/8/2022.

1.f
Packet Pg. 1169 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 4930 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 505
C99: Michelle Pitte, 2/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C99-1 Michelle Pitt 2/17/22 After watching a Docu-Series on Netflix, Down To Earth, where they traveled around the world for healthy and sustainable ways to live I have put together this bulleted list of what I hope for the future of this town based on what I saw:
-Greenery walls along with every building Site, rooftops, sidewalks, or gathering areas.
-No plastic water bottles, no plastic anything
-Filtered Water fountains everywhere
-Sustainable building
-Carbon sequestering gardens
-More walking/biking/shuttle options
-Energy efficiency, those small windmills,
-Communities to live, work and shop in the same center or -Live, shop, and access to smart commuting
The comment is not
related to the
adequacy of the DEIR,
therefore no further
response is required in
the FEIR. However, the
comment addresses
the content of the
Proposed Plan and will
be shared with
decision-makers in that
context. Please see
Master Response 1: EIR
Comments for more
information about GPor SPSP-related
responses. Please also
see Master Response
3: Buildout and RHNA
for more information.

1.f
Packet Pg. 1170 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4931 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 506
C100: Shona Keating, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C100-1 Shona
Keating
3/8/22 I am writing with some input and concerns about the general plan.

The walking path that connects Pacifica is a wonderful asset to all of the communities in our city and so many visitors to our area. I am grateful for its ease of accessibility from nook to neighborhood and all of it’s beautiful views and
stretches in between.

My concerns come from those neighborhoods that are
intersected by the path, and how we can best direct the public's use, with the least impact on the people who live here. My specific concerns are about the verbiage and lack of continuity between areas in the Pedro Point district, that leave room for interpretation as well as some confusion and possible misuse of private properties in this plan. Here is a list of my concerns. The walking path that connects Pacifica is a wonderful asset to all of the communities in our city and so many visitors to our area. I am grateful for its ease of accessibility from nook to neighborhood and all of it’s beautiful views and stretches in between.

1. Pg. 97, LU-I-28 PedroPoint Shopping Center.
“Maintain beach access along Shoreside Drive.”
Shoreside Drive is a privately owned “driveway” that
enables it’s resident’s to access their homes by car and foot, there is no public access point here. I believe the access you are indicating is the San Pedro Creek access at the north east end of the shopping center parking lot. This is the safest, most convenient, least impactful, and only public access South of the San Pedro Creek. The public
(especially visiting Public) should have clear signage
directing them towards this access. By using the terms
"access along Shoreside Drive” you give the impression that there is public access on or at Shoreside Dr.

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

C100-2 Shona
Keating
3/8/22 LU-I-29 Undeveloped San Pedro Ave site.
"Establish a Coastal Recreational Mixed use zoning district." I am opposed to any rezoning of this property without
further study, updated EIR reports and traffic reports, and neighbors, and until the safety (or lack of) for ingress and egress by current Pedro Point residents is addressed. This is a one way in, one way out community which has been held hostage in the past when a tragedy has occurred. If there is any unforeseen issue, where San Pedro Ave is blocked
The comment is noted. Congestion
is not a required topic for CEQA
analysis and the DEIR correctly
analyzed and mitigated VMT
impacts on pages 3-40 to 3-43.

Comments regarding land use
designations do not pertain to the
adequacy of the DEIR, thus no
further response is required.

1.f
Packet Pg. 1171 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 4932 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 507
Letter Commenter Date Comment Combined Response
Individuals (C)
anywhere before Danman Ave, there is no other way out
for a majority of the community. I am concerned about the weight of new development here, the amount of cars and
people this will bring, and how this small area can handle it.

I plea for deep consideration that you listen to and consider all residents of the neighborhood, and for you to truly weigh out and choose the least impactful designation.

However, the comment addresses
the content of the Proposed Project
and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or
SPSP-related responses. See
response to comment C15-2
regarding emergency access.

C100-3 Shona
Keating
3/8/22 Coastal trail
Where is the precise location of this "connection and
improved segment" you refer to throughout this plan? The use of differing names and terminology for the same site and or or landmark is confusing and not suitable language for a City plan to be adopted and be referred to for clarity for years to come. It is equally unclear on the 6-2 Trail System map on pg. 152, way to much room for
interpretation. I have given more detail on these concerns below.D312
The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses.

C100-4 Shona
Keating
3/8/22 Coastal Trail at Devil’s Slide and Between Pacifica and Devil’s Slide
I am concerned about the verbiage used in connecting the Pedro Point Shopping center path and Devils slide trailhead.

The wording is unclear and image of the trail map 6-2 pg. 152 clearly shows Grand Ave., but not the shopping center.

Are you planning to keep the trail in front of the shopping center where it should stay go bring it behind through
multiple layers of private property and into our residential area? There is no reason to have the trail continue west, through the privately owned shopping center, along the
privately owned Shoreside Drive, through the privately
owned field, to end at San Pedro Ave., and The Anchor Inn.

This is all Privately owned, and the “Colts Property “ section of the Devils slide trail does not begin here, it begins at the South East side of Ace Hardware.

I am with hopes that the trail is developed, crossing
SanPedro Ave., from the ocean side path to the Mountian side trail, where the path nears it’s end and turns towards the ocean. well before Ace Hardware. There is a long
straight-away on the frontage road section of San Pedro ave. here, with a clear view of, and for, all oncoming traffic.

On the Hwy 1 side there is a “No parking” zone, and a well used path under the highway that connects with the Old
Coast Rd. If at this point, there was a crosswalk and
sidewalk created, pedestrians could easily and safely cross over the frontage road in clear view of all oncoming traffic, to access both the Devil Slide and headland trail as well as the Old Coast Road. Please see image below.

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

C100-5 Shona
Keating
3/8/22 #24 “Improve new segment of coastal trail along former railroad berm.”
The only existing railroad berm ends near the end of
Shoreside Dr. A privately owned drive. This again needs to The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment

1.f
Packet Pg. 1172 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4933 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 508
Letter Commenter Date Comment Combined Response
Individuals (C)
be more clear, are you meaning on the East side of San
Pedro Creek or where the old Fassler house once stood?
There was old railroad berm there at one point but has
eroded to almost beach level. What and where is this “New segment “ you are referring to? This statement leaves much room for interpretation as well as possibly directing the public towards and through private property for no reason.

This trail needs to end at the San Pedro Creek outlet,
thoughtfully dissuading parking in, and trampling through, this single entrance and exit neighborhood. The map seems to show it staying adjacent to Hwy 1, which makes sense however the language does not match the map.
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses. Please also
see Master Response 3: Buildout
and RHNA for more information.

C100-6 Shona
Keating
3/8/22 #24 North Side PedroPoint Shopping Center
#25 Ocean Shore Railroad Berm
This coincides with my concerns stated above. #24 Again you state “ Improve new segment of Coastal Trail along
former railroad berm”. Where exactly are you referring to, the map and description do not match.
#25, "Ocean Shore Railroad Berm", is also referred to as "Shoreside Drive” in other segments of this plan, these two are one in the same, yet the titles are used as if they are different points. This is confusing and lacks continuity and clarity. This land is privately owned and has never had public beach access, but because of the use of “Railroad Berm”, the exact location and section of trail you are
referring to is muddled, leaves room for interpretation.

There is confusion, frustration and sometimes anger from the public, as well as residents, who do not have knowledge and or signage giving them the proper direction to tread lightly, on publicly designated trails and accesses, while respecting and avoiding the privately owned property.

There should not be any new "improved segment" through
privately owned land, although signage is greatly needed.

The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses. Please also
see Master Response 3: Buildout
and RHNA for more information.

C100-7 Shona
Keating
3/8/22 Implementing Policies
-Maintenance of Public Coastal Access
Require a public or private entity to be responsible for required public access ways. Until such an entity agrees to be responsible for liability and maintain maintenance of such access ways, they are not required to be open for
public use. Dedicated public access ways should be
designated to provide views as well as access connections or along the shore.

Shoreside Dr. Has been designated as an overlook point, ( I apologize for not having the exact table to give you) which creates overuse and dangerous conditions for the public as well as residents of this privately owned area. The
incredible number of visitors has increased at an alarming, overwhelming rate in the past two years of the pandemic.

The impact on those who live there, most of whom are
elders, has had a chrushing impact to their emotional and mental health, as well as creating a physically dangerous situation for them as well as the general public. People climbed up and between houses, used the private decks
and paths as bathrooms, allowed kids and dogs to run
THROUGH the homes and yards, left litter, dangerously
The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses. Please also
see Master Response 3: Buildout
and RHNA for more information.

1.f
Packet Pg. 1173 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4934 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 509
Letter Commenter Date Comment Combined Response
Individuals (C)
parked and blocked the one way narrow dirt driveway,
preventing our ingress/egress. We were vocal to the city during that time, and were given cones and temporary
signage to alert visitors and protect the property with.

These measures were respected by only a small few. We
were also asked by Pacifica PD, during beach closures, to try and eliminate any arteries of access that might be used to get to the beach in order to support their efforts. This has been and continues to be a constant struggle.

The families who live her, should not be required or "be responsible for liability and maintain maintenance” of this area for the pleasure of others many of whom are
completely unaware others who feel entitled to its use.

Please do not advertise this as a public area.

Thank you for this opportunity, let's keep our residents and visitors on our beautiful trails, off private land and keep them, and the property owners safe.

1.f
Packet Pg. 1174 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4935 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 510
C101: Christine Boles, 1/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C101-1 Christine Boles 1/11/2
2 Could you please forward a copy of the instructions to the State Clearinghouse, OPR along with the distribution list to responsible and optional agencies that will be reviewing the City's DEIR? The NOC is available
on the State
Clearinghouse website,
which includes a list of
reviewing agencies.

1.f
Packet Pg. 1175 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4936 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 511
C102: Patricia R. McGregor, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C102-1 Patricia R.

McGregor
2/11/22 I am writing to you again to ask that the time to review and accept comments on the General Plan be extended beyond the February 21st deadline. I, and several others, need more time to read all of the large amount of material.

The public comment
period was extended
until March 8, 2022 to
allow for additional
public review time.

1.f
Packet Pg. 1176 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4937 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 512
C103: Alex Strachan, 1/19/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C103-1 Alex
Strachan
1/19/22 Hello, First off, the document is pretty hard to navigate. If you need help putting together hyperlinked documents, i'm more than willing to help.

Please see response to
comment C62-8.

1.f
Packet Pg. 1177 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4938 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 513
C104: Penelope Keating, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C104-1 Penelope
Keating
3/8/22 The Old Railroad Berm also known as Shoreside Dr. is a privately owned driveway that is of a delicate
(though gritty) nature and cannot serve the greater
general public without safety issues as well as
degradation to either the public or this somewhat
frail area.

Particularly through the pandemic but also growing
due to other trends, the south end of San Pedro
Beach has been overwhelmed overt he past several
years. This south end is separated from the Pacifica
State Beach by the San Pedro Valley Creek and is a
rather private and delicate area. The old railroad
berm is merely compacted earth which is subject to
erosion as in crumbling along its edge from end to
end. To direct any of the general public to that area
is to cause unnessessary harm to that area and
potentially to the public encouraged to access it.

No. 25 should not encourage the public to this area.

A small earthen path for the owners of the property
has been abused by a large number of individuals
from all over and even outside the Bay Area.

Neither the City nor the resident’s are willing or
able to take the responsibility of liability and thus
should not be in a public plan. No area of the old
Railroad Berm, Shoreside Dr., should be used for
access or Bluff top viewing due to these issues.

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

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

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

C104-2 Penelope
Keating
3/9/22 I am also against making decisions on use of the Calson Field until traffic challenges are remedied.

Pedro Point is particularly victim to any emergency
especially focused at the entrance/exit to our
hillside area.

The comment is noted. Please see
response to comment C46-31.

1.f
Packet Pg. 1178 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4939 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 514
C105: Kathi Porter, 1/19/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C105-1 Kathi Porter 1/19/22 I tried to read the new General Plan, couldn’t really get to any content other than photos. I have heard it can be challenging to navigate once you find some information. We all want what’s best for our city, and need to have some input. Please make corrections so that we all can navigate this very important information.

Please see response to
comment C62-8.

1.f
Packet Pg. 1179 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4940 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 515
C106: Debbie Young Lynch, 1/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C106-1 Debbie Young
Lynch
1/17/2
2 I’m trying to read the General Plan and the EIR that the City made available last week. If the goal was to make it as tedious and frustrating to use, mission accomplished. I am trying to do what is right as a resident of Pacifica. The very least you can do is make that a bit easier for us but making it user friendly. No index or search functions? Really? Please correct this and do it in a timely fashion.

There are lots of us interested in being informed on what is in the 1013 page document. I’m still scrolling through it, but there is no reason it should have been made this difficult to navigate.

Please see response to
comment C62-8.

1.f
Packet Pg. 1180 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4941 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 516
C107: Ellen Natesan, 3/6/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C107-1 Ellen
Natesan,
PhD
3/6/22 General Comment - DEIR and GP Policy Discrepancies The policies in the General Plan do not always match those in the DEIR. Not only are there textual differences, but the numbering seems to have changed. For example – CO-G-10 appears as a policy about “Other Environmentally Sensitive Areas” on page E70 of the DEIR but also as a policy about “Trees” on page 3.3-34 of the DEIR. CO-I-26 in the DEIR is a “Sanitary Sewer Discharge” policy but CO-I-26 in the General Plan is about “Protection of Biological Resources
with New Development.”
When I inquired about these discrepancies to the Pacifica Planning Department, I was instructed (in an email from Christian Murdoch dated January 29, 2022) to use the Policies in the General Plan as the basis for my comments. My comments below are therefore focused on the versions of the Policies found in the General Plan. Where possible I have attempted to refer to the corresponding policy in the DEIR. All of my comments should also be considered to be comments to the DEIR, except where I specify “General Plan Only.”
These policies will be renumbered
in errata. They do not change
findings of significance.

C107-2 Ellen
Natesan,
PhD
3/6/22 Policy OC-G-5 – Open Space Preservation - DEIR and General Plan Recommended Edits:

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

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

Rationale:

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

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

C107-3 Ellen
Natesan,
PhD
3/6/22 Policy OC-I-28 - Highway 1 Over-Crossing at Mori Point - General Plan Only
Recommended Edits:

Highway 1 Over-Crossing at Mori Point. Support the development of a new wildlife friendly over-crossing between Shelldance Nursery and Mori Point, in coordination with GGNRA and Caltrans to enhance visitor facilities in Pacifica. Pacifica should also encourage GGNRA and Caltrans to place wildlife barriers at strategic locations in this area to reduce roadkill and risk of wildlife collisions on Highway 1. Underpasses such as the Calera Creek underpass could potentially be modified to improve wildlife passage and connectivity between habitats. Pacifica should encourage Caltrans to improve these structures whenever The comment is not related to the
adequacy of the DEIR, therefore
no further response is required in
the FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses. Please see
Master Response 1: EIR Comments

1.f
Packet Pg. 1181 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4942 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 517
Letter Commenter Date Comment Combined Response
Individuals (C)
these road segments are upgraded or replaced. As an interim alternative, strengthen signage and safe connections to the existing Sharp Park Golf Course undercrossing in the East Fairway Park neighborhood.

Rationale:

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

C107-4 Ellen
Natesan,
PhD
3/6/22 Policy CO-G-7 - Protect Habitat for Special Status Wildlife - DEIR and General Plan
Recommended Edits:

CO-G-7 Protect Habitat for Special Status Wildlife and Critical Habitat. Conserve and protect indigenous threatened,
endangered, and other special status species by preserving critical habitat that is important for the protection of these species. Habitat can be protected by allowing very limited or no development, by identifying habitat areas as top priorities for permanent conservation, and by managing public land to ensure species protection.

Rationale:

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

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

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

C107-5 Ellen
Natesan,
PhD
3/6/22 Policy CO-G-10 – Trees – DEIR and General Plan (note also appears as Policy CO-G-9 in DEIR)
Recommended Edits:
*NOTE – this policy should be edited in both the DEIR and General Plan. The numbering seems to be incorrect in the DEIR and so the numbers should also be updated in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure
The comment is not related to the
adequacy of the DEIR, therefore
no further response is required in
the FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master

1.f
Packet Pg. 1182 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4943 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 518
Letter Commenter Date Comment Combined Response
Individuals (C)
consistency between the two documents.

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

Rationale:

In general, the trend on the San Francisco Peninsula has been towards increased afforestation rather than deforestation. Most of the region’s sensitive and special status species depend on grassland and shrubland communities, which are being lost through time to afforestation. Planting trees (even native trees) should be considered an impact except in the narrow
circumstances of urban planting or planting in areas known to historically support trees. For more background information on these ecological trends see the Peninsula Watershed Historical Ecology Study here:
https://www.sfei.org/documents/peninsula-watershed-historicalecology-study Response 1: EIR Comments for
more information about GP- or
SPSP-related responses.

Numbering of policies in the DEIR
will be corrected in a redline
version.

C107-6 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-1 - Creek Protection and Restoration - DEIR and General Plan
Recommended Edits:
*NOTE – The edits below are to the version of Policy CO-I-1 in the General Plan which is different from the version of Policy CO-I-1 in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.

CO-I-1 Creek Protection and Restoration. Maintain, protect, and restore Pacifica’s creeks, including San Pedro, Calera, Sanchez, and Milagra creeks, as environmental and aesthetic resources.

Actions will include, but are not limited to:
• Continuing restoration efforts along San Pedro Creek to improve conditions for steelhead by removing obstacles to fish passage, placing rock weirs to facilitate fish passage, and by monitoring the effectiveness of these projects;
• Partnering with local organizations, such as the San Pedro Creek Watershed Coalition, Go Native, the Pacifica Land Trust, and others, on restoration efforts;
• Exploring opportunities to collaborate with other agencies and organizations on stream restoration and riparian habitat restoration along Sanchez and Calera creeks;
• Enforcing restrictions on the planting of invasive species near creek areas;
• Identifying and working with property owners to take
advantage of unique opportunities where human active use (e.g., through trail development) would enhance creek appreciation without disrupting ecological function;
• Requiring a minimum of 100-foot set- backs from the top of The comment is not related to the
adequacy of the DEIR, therefore
no further response is required in
the FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses.

Numbering of policies in the DEIR
will be corrected in a redline
version.

1.f
Packet Pg. 1183 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4944 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 519
Letter Commenter Date Comment Combined Response
Individuals (C)
creek banks, or from the outer edge of riparian vegetation, where it exists, for development proposed adjacent to creeks, in keeping with City regulations and Best Management Practices. Exceptions to such buffer requirements should be supported by a biological report demonstrating that the adjusted buffer, in combination with incorporated siting, design or other mitigation measures, shall prevent impacts that significantly degrade the creek. A Qualified Hydrologist with professional experience evaluating natural creek geomorphology shall evaluate the potential for impacts in coordination with a Qualified Biologist with professional experience evaluating the riparian and freshwater aquatic ecosystems found in the project area. This analysis shall be provided in writing and shall consider impacts to creek form and function, aquatic species, and to riparian habitat. Buffer adjustments should also be limited to where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the buffer would have a greater impact on the creek.

Rationale:

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

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

C107-7 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-11 - Protect Water Quality through Best Management Practices - DEIR and General Plan
Recommended Edits:

CO-I-11 Protect Water Quality through Best Management
Practices. Continue to require the use of best management practices to reduce water quality impacts from construction and development. Measures include:
• Site Design and Source Control. Ensure that all new
development incorporates site design and source control BMPs into the project design in order to pre- serve the infiltration, purification, and retention functions of each site’s natural drainage systems, and to prevent or minimize the runoff of pollutants, sediments, waste, and pathogens from the site. • Construction Pollution Control. Require all construction projects to adopt measures to avoid when possible, or minimize erosion and runoff of pollutants and sediments from construction-related activities, and to limit activities that result in the disturbance of land or natural vegetation.
• Construction projects will be required to use appropriate erosion prevention techniques, sediment control measures, and best management practices in accordance with City specifications and the San Mateo Countywide Water Pollution Prevention Program.
• Treatment Control. Require that new development implement treatment control BMPs (or structural treatment BMPs) where As noted on DEIR p. 3.5-20,
"potential impacts associated with
implementation of the Proposed
Project include increased rates of
storm water runoff and
subsequent flooding hazards,
erosion, increase in nonpoint
source pollutants affecting
receiving water quality, and
coastal erosion and flooding that
may be intensified by sea level
rise. These impacts would be
reduced to less-than-significant
levels through regulatory
compliance and with
implementation of proposed
policies." The DEIR describes how
"adherence to the Construction
General Permit under the NPDES
program would require that a
SWPPP with best management
practices (BMPs) be prepared for
construction sites; it would include
measures to protect water quality
of stormwater that is discharged

1.f
Packet Pg. 1184 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4945 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 520
Letter Commenter Date Comment Combined Response
Individuals (C)
the combination of site design and source control BMPs is not sufficient to protect water quality and comply with applicable water quality permits.
• Site Design and Source Control. Ensure that all new
development incorporates site design and source control BMPs into the project design in order to preserve the infiltration, purification, and retention functions of each site’s natural drainage systems, and to prevent or minimize the runoff of pollutants, sediments, waste, and pathogens from the site. • Runoff Capacity Management: Ensure that new developments do not cause flooding for communities downstream. Evaluate downstream drainage capacity for runoff that cannot be captured on-site during large storm events (100 year storms). If a development will increase peak runoff volumes during large storms (because of increased impervious surfaces or other factors), downstream capacity improvements should be part of the project, using a design standard of 100 year storm.

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

Rationale:

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

Climate change is expected to increase the frequency of atmospheric rivers and high intensity precipitation events and so designing to a 100 year storm standard is a bare minimum. This measure might be more appropriate as a standalone new
mitigation/policy.
offsite and practices to limit
erosion or unintentional releases
of hazardous materials used
during construction. Additionally,
any development that would occur
under the Proposed Project would
be subject to the erosion and
runoff control provisions described
in the regional Basin Plan."
It also describes how " in general,
existing local stormwater
management plans and policies,
and State Water Board
regulations, which implement
federal Clean Water Act
requirements, would prevent
these potential impacts from rising
to a level of significance under
CEQA through requirements that
minimize the creation of pollution
generating surfaces. Clean Water
Act Section 402 NPDES MS4
Permit, which covers many Bay
Area jurisdictions including the
City of Pacifica, requires
stormwater management plans,
which in turn require source and
treatment control measures. In
many cases, as part of the NPDES
program to reduce the severity of
impacts, stormwater drainage
control/Low Impact Design (LID)
measures may be required as
standard conditions of approval
and building permit application
submittals, along with compliance
with RWQCB Municipal Regional
Stormwater Permit Order No.
2011-0083 Provision C.3 (Provision
C.3).

Site-specific stormwater
management planning is also
required, as noted on DEIR p. 3.5-
30 and 3.5-31: "The increasing
incorporation of stormwater
management in site planning [as
described in policy CO-I-16] will
further reduce the need for
development of new storm
drainage infrastructure." Finally,
the DEIR notes on p. 3.5-31 that
"flood flows may change over the
horizon of the Proposed Project
due to sea level rise caused by

1.f
Packet Pg. 1185 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4946 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 521
Letter Commenter Date Comment Combined Response
Individuals (C)
climate change; the proposed
General Plan includes policies from
the Local Coastal Land Use Plan
which commit to using the best
available science to plan for sea
level rise, as well as continuing to
monitor and map changes in flood
flows and high water marks." Thus,
the impact remains less than
significant.

C107-8 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-26 – Protection of Biological Resources - General Plan and DEIR (see Policy
CO-I-27 in DEIR)
Recommended Edits:
*NOTE –This Policy does not appear in the DEIR (and it should), however Policy CO-I-27 in the DIER may be an earlier version of this policy. This policy should be added to the DIER. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure
consistency between the two documents.

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

1. Discourage development and/or buildout in critical habitat of special status species habitat during the development review process in a manner consistent with Policy CO-G-7.

2. Pre-construction Conduct plant and wildlife surveys prior to vegetation clearing or earth disturbing activities: Project applicants shall engage a qualified biologistQualified Botanist and Qualified Wildlife Biologist (as defined below) to conduct presence/absence biological surveys for sensitive plant and wildlife species prior to construction adjacent to
or within identified special status communities and other sensitive areas identifiedcommencement of work in areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan. If special status
species are identified, the qualified biologist shall consult with the California Department of Fish and Wildlife (CDFW) and establish no-disturbance buffers around avian nests, bat roosts, dusky footed woodrat nests, sensitive plant communities, special status plants, and sensitivespecial status butterfly host plants, wetlands, or other sensitive and special
status natural resources to avoid disturbance and direct impacts to these resources during construction. If no special status species or plant communities are detected during surveys, then construction-related or earth disturbing activities may proceed.

Nesting birds, in particular, are protected by two means; they receive protection under the Migratory Bird Treaty Act, and nesting raptors (in the order Falconiformes or Strigiformes) are protected under the State Fish and Game Code, §3503.5.

3. Incorporate bird, bat, and wildlife impact avoidance measures into vegetation removal activities. Prior to felling, prune trees to increase detectability of nesting birds, and disturb trees (eg. with The comment is not related to the
adequacy of the DEIR, therefore
no further response is required in
the FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses.

Numbering of policies in the DEIR
will be corrected in a redline
version.

1.f
Packet Pg. 1186 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4947 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 522
Letter Commenter Date Comment Combined Response
Individuals (C)
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

1.f
Packet Pg. 1187 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4948 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 523
Letter Commenter Date Comment Combined Response
Individuals (C)
mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the General Plan, a Qualified Wildlife Biologist will survey for special status wildlife species and their habitat. A qualified wildlife biologist must be familiar with identification of essential physical and biological features for special status wildlife species, including space for individual and population growth and for normal behavior; cover or shelter; food, water, air, light, minerals, or other nutritional or physiological requirements; sites for breeding and rearing offspring; and habitats that are protected from disturbances or are
representative of the historical geographical and ecological distributions of the species.

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

C107-9 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-27 - Page E-65 of DEIR and Page 7-26 of General Plan Recommended Edits:
*NOTE – The edits below are to the version of Policy CO-I-27 in the General Plan which is different from the version of Policy COI-27 in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.

CO-I-27 Verification of Environmentally Sensitive Habitat Areas (ESHA) within the Coastal Zone and identification of sensitive habitats or special status species that should be protected outside of the Coastal Zone. Prior to any proposed development or other earth disturbing project in an ESHA or potential ESHAin areas not identified as “Urban and Non Urban with Little or No Habitat Value” Figure 7-3 of the proposed General Plan, require that a habitat survey be conducted by a Qqualified Bbotanist or Qualified Wildlife Bbiologist. The habitat survey will verify whether the site is an ESHA or has special status under CEQA, and document the extent of the sensitive resources, document potential negative impacts to the habitat, and recommend appropriate mitigation measures. Verification of an ESHA or special status plant communities, plant or animal species, or habitat shall be based on the following considerations:
• Presence of natural communities identified as rare by the California Department of Fish and Wildlife (determined by a state rarity ranking of S1 to S3).
• Recorded or potential presence of plant or animal species designated as rare, threatened or endangered under State or federal law.
• Recorded or potential presence of plant or animal species for which there is compelling evidence or rarity, such a designation of 1B (rare or endangered in California or elsewhere) or 2 (rare, threatened, or endangered in California, but more common The comment is not related to the
adequacy of the DEIR, therefore
no further response is required in
the FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses.

Numbering of policies in the DEIR
will be corrected in a redline
version.

1.f
Packet Pg. 1188 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4949 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 524
Letter Commenter Date Comment Combined Response
Individuals (C)
elsewhere) by the California Native Plant Society.
• Presence of coastal waterways.
• Presence of drainages or wetlands.
• Integrity of the habitat and its connectivity to other natural areas.

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

1.f
Packet Pg. 1189 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4950 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 525
Letter Commenter Date Comment Combined Response
Individuals (C)
A Qualified Wildlife Biologist must meet the following
requirements:
• Demonstrated professional experience identifying all of the target wildlife species at all life history stages;
• Experience and knowledge of the natural history, habitat affinities and wildlife species needs;
• Familiarity with federal, state, and local statutes and regulations; and
• State and federal handling permits (as needed).

Rationale:

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

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

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

For additional supporting information see:

1.f
Packet Pg. 1190 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4951 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 526
Letter Commenter Date Comment Combined Response
Individuals (C)
https://www.cnps.org/wp-content/uploads/2019/10/BotCert_2018-CDFW-Plant-and-Vegetation-Survey-Protocols-LR.pdf C107-
10 Ellen
Natesan,
PhD
3/6/22 CO-I-32 – Monitoring Requirements – General Plan and DEIR (not found in DEIR)
Recommended Edits:
*NOTE – This policy is an extremely important component of impact reduction and it should be added as a mitigation requirement to the DEIR.

CO-I-32 - Restoration and Monitoring Requirements. Require a Restoration and Monitoring Proposal for any proposed habitat restoration or mitigation. The Proposal should describe the methods and practices to be employed, and include:
• A clear statement of the goals of the restoration or mitigation for all habitat types;
• Sampling of reference habitat, with reporting of resultant data; • Designation of a qualified biologist as the Restoration or Mitigation Manager responsible for all phases of the restoration; • A specific grading plan, if the topography must be altered; • A specific erosion control plan, if soil or other substrate will be disturbed during restoration, which should utilize erosion control materials free of invasive species (including invasive plant seeds), plastic microfibers and materials that are free of weed seeds, pests, pathogens, and other invasive species;
• An invasive species introduction avoidance plan to minimize introduction of new weeds, pests, or pathogens to the site. This should include
- a plan to clean equipment and vehicles before they arrive on site, and inspections to confirm that equipment and vehicles are free of soil, organic material, and vegetative debris prior to entering the work site,
- a plan to reject seed lots that contain invasive species that are not already present on the site or adjacent areas so they will not introduce new invasive species to the area, and
o a plan to require that all imported organic materials such as mulch, compost, and erosion control materials be free of new invasive species including invasive plants, animals, pests, or pathogens;
• A weed eradication plan designed to eradicate existing a specified list of target weeds (non-native invasive plant species expected to interfere with the restoration goals such as all CalIPC high and moderate species that form monocultures) and control future invasion by exotic species maintaining target invasive plant cover below 5% total
absolute cover site-wide of target invasive plant species (unless restoration goals or reference sites justify a higher percent cover);
• A planting plan based on the natural habitat type using seeds wherever possible and using best management practices for avoiding introduction of plant pests and pathogens if container plants must be used;
• An irrigation plan that describes the method and timing of watering and ensures removal of watering infrastructure by two years prior to the end of the monitoring period;
• An interim monitoring plan with annual reporting and a 5 year The comment requests that the
noted policy be added as a
mitigation requirement. The
policy will be added to the DEIR
Impact 3.7-1 as a policy that
reduces the impact and does not
need to be added as a mitigation
measure. The addition of this
measure would not change
findings of significance and would
only serve to amplify conclusions
of "less than significant" for
potential biological resource
impacts.

1.f
Packet Pg. 1191 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4952 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 527
Letter Commenter Date Comment Combined Response
Individuals (C)
minimum reporting period with performance goals, assessment methods, and a schedule; and
• A final monitoring planperformance criteria to determine whether the restoration has been successful.

Rationale:

Restoration is an extremely important component of impact mitigation and this measure should be robust (and in the DEIR!).

Ecological restoration is complex and difficult and if done poorly, not only will fail, but can actually have significant impacts to surrounding natural areas. Incorporating the specific added guidance I suggest above into the DEIR will help these restoration projects be successful.

Many erosion control materials contain plastics. The natural fibers in these materials degrade, while the plastic fibers do not.

These bundles of loose plastic fibers pose wildlife entrapment hazards for special status and non-special status wildlife. For more information see:
https://documents.coastal.ca.gov/assets/waterquality/permits/WildlifeFriendly_Netting_in_Erosion_&_Sediment_ControlFactsheet_r5_Sept_2016.pdf Not all invasive species can be controlled, for example, some CalIPC high and moderate nonnative perennial grasses generally grow intermixed with native plant species in such a way that controlling them could be excessively destructive and undermine the success of a restoration project. Non-native invasive plant species should be selected for control depending on
controllability, presence in San Mateo County (not just the site), and the restoration goals. Once selected, presence of these target species should be maintained so that the sum-total of the absolute cover by all target invasive plant species is less than 5% absolute cover. This is an achievable objective that keeps the seed bank, rhizomes, or other propagules of invasive plant species sufficiently under control so that the native plant species have room to become established.

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

Introducing a new invasive plant species, plant pest or pathogen to a restoration site has the potential to not only undermine the success of the restoration project but devastate surrounding natural areas. Planting should be done using direct seeding (not rooted plants) as much as possible to avoid unintentional introduction of invasive species. Imported materials should be free of invasive species to the degree possible as well and

1.f
Packet Pg. 1192 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4953 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 528
Letter Commenter Date Comment Combined Response
Individuals (C)
equipment and vehicles should be inspected as they arrive on site and only allowed to enter if they are free of organic matter. Also see my comments on CO-I-36 below.

Best management practices for avoiding spread of plant
pathogens during restoration projects
can be found here:
http://www.suddenoakdeath.org/welcome-to-calphytos-orgphytophthoras-in-nativehabitats/#WG More information about how restoration activities have
introduced destructive plant pathogens into natural areas in California and the Bay Area can be seen here:
https://www.mdpi.com/1999-4907/11/12/1291
C107-
11 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-36 – Minimizing Introduction of Invasive Plant Species Through Plantings (see CO-I-38 of DEIR)
CO-I-36 Minimizing Introduction of Invasive Plant Species Through Plantings. Encourage planting of locally appropriate native plants directly from seed. If direct seeding is not possible, encourage sourcing of plants from nurseries which use
techniques that minimize the risk of accidental introduction and spread of invasive species (such as, plant pests, plant pathogens, and invasive insects). Prohibit the use of invasive plant species (i.e., any California Invasive Plant Council (Cal- IPC)-listed species with a status of high or moderate, or identified such as locallythreatened under the limited, alert, or watch status).

Rationale:

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

Use of container plants in restoration has been documented as an introduction pathway for plant pathogens in California and the Bay Area. For more information see Phytophthora Introductions in Restoration Areas: Responding to Protect California Native Flora from Human-Assisted Pathogen Spread at the link below:
https://www.mdpi.com/1999-4907/11/12/1291
Best practices for avoiding spread of plant pathogens during restoration projects can be found here:
http://www.suddenoakdeath.org/welcome-to-calphytos-orgphytophthoras-in-nativehabitats/#WG The comment is not related to the
adequacy of the DEIR, therefore
no further response is required in
the FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses.

C107-
12 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-37 – Beach Grooming – DIER and General Plan (See DEIR CO-I-39)
Recommended Edits:

Note: The numbering seems to be incorrect in the DEIR, the numbering in the DEIR should be updated to reflect the
numbering in the General Plan
These inconsistencies are
corrected in errata. These
clarifications do not change
findings of significance in the DEIR.

1.f
Packet Pg. 1193 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4954 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 529
Letter Commenter Date Comment Combined Response
Individuals (C)
C107-
13 Ellen
Natesan,
PhD
3/6/22 Policy CO-I-37 – Beach Grooming. Work with the State of California, GGNRA, and other partners in the management of beaches in Pacifica to ensure biological resources are NOT adversely affected by beach grooming. Specifically, protect beach wrack (the piles of plant and animal debris that wash ashore), which plays an important role in the beach ecosystem.

Rationale: This appears to be a typo.

This comment is noted. The policy
text edit mentioned in the
comment is not required.

DEIR p. 3.12-58: "CO-I-39 Beach
Grooming. Work with the State of
California, GGNRA, and other
partners in the management of
beaches in Pacifica to ensure
biological resources are not
adversely affected by beach
grooming. Specifically, protect
beach wrack (the piles of plant and
animal debris that wash ashore),
which plays an important role in
the beach ecosystem."
C107-
14 Ellen
Natesan,
PhD
3/6/22 Policy SA-I-95 DEIR and General Plan
Recommended Edits:

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

Rationale:

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

The comment is not related to the
adequacy of the DEIR, therefore
no further response is required in
the FEIR. However, the comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response 1: EIR Comments for
more information about GP- or
SPSP-related responses. Please see
Master Response 5: Wildfire for
more information on mapping
wildfire threat in addition to
wildfire hazard zones.

C107-
15 Ellen
Natesan,
PhD
3/6/22 San Pedro Creek watershed – Page 3.5-4 of DEIR
Recommended Edits: Please add two more special status fish species to the list for San Pedro Creek
• Pacific lamprey (Entosphenus tridentatus) which is a CDFW Species of Special Concern and is mentioned in the General Plan as being present in San Pedro Creek; and
• northern tidewater goby (Eucyclogobius newberryi) which has been detected in San Pedro Creek (Sutter and Kinziger, 2019) and The comment is noted. The
following clarification is thereby
made in the first paragraph on
page 3.7-14: "Fish species that
may be present, as identified by
the San Pedro Creek Conservancy,
include the prickly sculpin (Cottus
asper), the Pacific lamprey
(Lampetra tridentate), and the

1.f
Packet Pg. 1194 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4955 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 530
Letter Commenter Date Comment Combined Response
Individuals (C)
is listed as Endangered under federal ESA by the Fish and Wildlife Service
threespine stickleback
(Gasterosteus aculeatus)."
However, no records of these fish
have been identified in the CNDDB
database at time of survey (June
2021).

This clarification does not change
findings of significance in the DEIR.

The Pacific lamprey is also not
identified in an updated May 2022
CNDDB survey.

No occurrences of northern
tidewater goby were identified at
the time of CNDDB survey, or in
updated CNDDB data from May
2022. The commenter makes
reference to a 2019 study; official
guidance from the US Fish and
Wildlife Service Tidewater Goby
Survey Protocol
(https://www.fws.gov/sites/defaul
t/files/documents/surveyprotocol-for-tidewater-goby.pdf) did not recognize eDNA as a
recommended survey.

San Pedro Creek is designated as a
potential ESHA. While the
compliance with federal, state,
and local regulations for sensitive
biological resources such as the
Pacific lamprey and northern
tidewater goby, including FESA,
CESA, and the Coastal Act. The
beneficial impacts of Proposed
Project policies to protect and
restore creeks (CO-I-I), preserve
wetlands (CO-I-4), maintain
biological activity (CO-I-38), verify
and manage ESHA (CO-I-27 and
CO-I-28), preserve habitat (CO-I31), requirement of a Restoration and Monitoring Proposal for an
proposed habitat mitigation (CO-I32), and protection of biological resources with new development
(CO-I-26), which would require
biological resource assessments to
be conducted for any
development within 300 feet of
creeks would reduce impacts to
less than significant.

1.f
Packet Pg. 1195 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4956 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 531
Letter Commenter Date Comment Combined Response
Individuals (C)
C107-
16 Ellen
Natesan,
PhD
3/6/22 Annual Grasslands - Page 3.7-2 of DEIR and Page 7-16 of General Plan
Recommended Edits:

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

Grasslands provide essential basking, foraging, and sheltering habitat for reptiles and amphibians including the federally protected (Threatened) California red-legged frog, and state and federally protected (Endangered) San Francisco garter snake.

Grassland communities with higher proportions of native species support more complex biological community of insects, over a wider range of seasonal conditions, and are therefore a better source of food for insectivorous wildlife such as adult California red-legged frog and Sierran tree frog, which are both important prey species for the San Francisco garter snake.

Rationale:

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

For more information about the relative importance and rarity of grasslands in California, please also see the California Native Grassland Association (CNGA) website which points out, “To date, our state has already lost 99% of our native grasslands. With only 1% of our native grassland remaining statewide it is critical that we protect every remaining acre.”
https://cnga.org/Conservation#:~:text=The%20California%20Nati ve%20Grassland%20Association,UC%20Santa%20Cruz%20East%2 0Meadow.&text=To%20date%2C%20our%20state%20has,99%25
The comment is noted. Please see
response to comment C1-7.

1.f
Packet Pg. 1196 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4957 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 532
Letter Commenter Date Comment Combined Response
Individuals (C)
%20of%20our%20native%20grasslands
In the absence of a complete survey of existing grasslands within the study area, this DEIR should not assume the absence of remnant patches of special status grasslands (CDFW designated California Sensitive Natural Communities) or special status native grassland and for species.

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

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

The following species are ranked as California Rare Plants in CalFlora and are present or likely to be present in Pacifica.

Although these species are mostly only documented in protected areas of Pacifica, the lack of observations in unprotected areas are likely due to lack of surveys rather than lack of actual presence on privately owned lands.

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

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

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

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

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

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

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

7. Piperia michaelii, a monocot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.2 (limited distribution). Present PPH* and Aramai Point
See also Appendix below for a list of native grassland species that have been observed in Pacifica and documented in the iNaturalist database.

C107-
17 Ellen
Natesan,
PhD
3/6/22 Vegetation Map - Figure 3.7-1 - Page 3.7-4 of DEIR & Figure 7-2 on Page 7-15 of General Plan
Recommended Edits:

The comment is noted. Please see
response to comment C1-7 .

1.f
Packet Pg. 1197 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4958 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 533
Letter Commenter Date Comment Combined Response
Individuals (C)
Change the label on the legend and map from “Annual
Grasslands” to “Grasslands/Prairie.” Update the landscape and vegetation map using recent GIS layers available for San Mateo County through the Fine Scale Vegetation Map and Landscape Database Project. See links and explanation below.

Rationale:

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

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

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

For more information and access to this data, please see the websites below.
https://www.nps.gov/articles/vegetation-mapping-projectsunderway.htm https://www.nps.gov/articles/000/new-draft-lifeform-mapavailable-for-san-mateo-county.htm

1.f
Packet Pg. 1198 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4959 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 534
Letter Commenter Date Comment Combined Response
Individuals (C)
C107-
18 Ellen
Natesan,
PhD
3/6/22 Comment on the Regulatory Setting (in General Plan and DEIR) Please cross check and update special status of species named in the conservation chapters and include all special status species found in Pacifica. Specific examples include:
• tricolored blackbird is listed as Threatened under California ESA and is mentioned in the General Plan as present in Pacifica but its special status is not mentioned
• Pacific lamprey is a CDFW Species of Special Concern and is mentioned in the General Plan as present in San Pedro Creek but its special status is not mentioned
• monarch butterfly was not mentioned but is a candidate for listing under federal ESA and is likely present in Pacifica • mountain lion is not mentioned and is a candidate species under California ESA
• northern tidewater goby (Eucyclogobius newberryi) has been detected in San Pedro Creek (Sutter and Kinziger, 2019) and is listed as Endangered under federal ESA by the Fish and Wildlife Service and should be mentioned (currently is not mentioned in the General Plan or DEIR)
The tricolored blackbird is
described on DEIR p. 3.7-9. There
no recorded occurrences in the
CNDDB during the time of survey.

The tricolored blackbird will be
added to Appendix D. The General
Plan references this appendix.

Please see response to comment
C107-15 for more information on
the Pacific lamprey.

Monarch butterflies are included
on p. 3.7-21. Please see response
to comment A2-12 for more
information on additional policies
to address monarch butterflies.

No occurrences of mountain lion
were found in the CNDDB. Please
see response to comment A2-10
for more information on additional
policies to address mountain lions.

The northern tidewater goby is
described in Appendix D. please
see response to comment C107-18
for more information about the
northern tidewater goby.

These changes do not represent
significant new information or
change findings of significance in
the DEIR.

1.f
Packet Pg. 1199 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4960 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 535
Letter Commenter Date Comment Combined Response
Individuals (C)
C107-
19 Ellen
Natesan,
PhD
3/6/22 Fire Hazards and Public Safety Services - Figure 6.11-3 on page

3.11-4 of DEIR and Figure 8-7 on Page 8-36 of General Plan Recommended Edits:

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

This should be corrected. The GIS layers available for San Mateo County through the Fine Scale Vegetation Map and Landscape Database Project include a 5 m fuels model as well as LiDAR slope data. These should be combined to generate a basic fire hazard map for the undeveloped portions of Pacifica. Additional refinements could be added later. This fire hazard map should be calibrated to use similar criteria for hazard classifications used by CalFire so the mapping is consistent throughout the plan area.

This map should be reviewed by the North County Fire Authority prior to finalization. For more information about the 5 m fuels and LiDAR data see links below.
https://www.nps.gov/articles/vegetation-mapping-projectsunderway.htm https://www.nps.gov/articles/000/new-draft-lifeform-mapavailable-for-san-mateo-county.htm The DEIR characterizes wildfire
hazards within the Planning Area
on pages 3.11-4 through 3.11-6
and 3.14-1 through 3.14-4, making
use of data and information from
CALFIRE and from the MultiJurisdictional Local Hazard
Mitigation Plan (MJ-LHMP) for San
Mateo County. The
characterization in the DEIR
includes a description of
vegetation in the Planning Area, a
history of wildfire occurrence in
the Planning Area, the probability
of a fire occurring in the future,
and identification of Fire Hazard
Severity Zones designated by
CALFIRE based on factors such as
fuel, slope, and weather. Two
maps are included:

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

1.f
Packet Pg. 1200 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4961 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 536
Letter Commenter Date Comment Combined Response
Individuals (C)
increased severity for the higher
threat classes. Please see Master
Response 5: Wildfire for more
information.

C107-
20 Ellen
Natesan,
PhD
3/6/22 Appendix
Additional native species below are confirmed in Pacifica’s grassland/prairie communities according to iNaturalist, Calflora, and as compiled by *Kramer Botanical, Vascular Plant Species within the Pedro Point Headlands Trail Improvement and
Restoration Project Area, February 2016.
https://www.calflora.org//app/ipl?vrid=ce891&bloom=t
https://www.inaturalist.org/check_lists/3273-Mori-Point-CheckList?iconic_taxon=47126&without%5B%5D=page&without%5B% 5D=q
https://www.inaturalist.org/check_lists/5529-Milagra-RidgeCheckList?iconic_taxon=47126&without%5B%5D=page&without%5B% 5D=q
Native plants commonly present on grassland/prairie in Pacifica Alliaceae Allium dichlamydeum Coast Onion
Anacardiaceae Toxicodendron diversilobum Pacific Poison Oak Apiaceae Angelica hendersonii Henderson's Angelica
The comment is noted. As noted
on DEIR p. 3.7-49, the DEIR used
the California Native Plant Society
Inventory of Rare and Endangered
Plants (online edition, v8-02).

California Native Plant Society.

Sacramento, CA. This database
was accessed on June 11, 2021.

1.f
Packet Pg. 1201 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4962 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 537
Letter Commenter Date Comment Combined Response
Individuals (C)
Daucus pusillus American Wild Carrot
Heracleum maximum Cowparsnip
Lomatium utriculatum Lomatium
Sanicula arctopoides Footsteps of Spring
Sanicula crassicaulis Pacific Sanicle
Agavaceae Chlorogalum pomeridianum Wavy-leafed Soap Plant Dipterostemon capitatus Blue Dicks
Triteleia laxa Ithuriel's Spear
Asteraceae Achillea millefolium Common Yarrow
Anaphalis margaritacea Pearly Everlasting
Centromadia parryi ssp. parryi Papoose Tarplant 1B.2
Cirsium occidentale Cobweb Thistle
Circium quercetorum Brownie Thistle
Grindelia stricta Pacific Gumplant
Lasthenia californica Goldfields
Lasthenia minor Coastal Goldfields
Layia platyglossa Tidytips
Madia sativa Coast Tarweed
Pseudognapthalium californicum California Cudweed
Pseudognaphalium ramosissimum Pink Everlasting
Solidago velutina ssp. californica Goldenrod
Symphyotrichum chilense Pacific Aster
Wyethia angustifolia Narrowleaf Mule-Ears
Boraginaceae Amsinckia menziesii Coast Fiddleneck
Phacelia californica California Phacelia
Phacelia malvifolia Stinging Phacelia
Brassicaceae Arabis blepharophylla Coast Rockcress 4.3
Erysimum franciscanum San Francisco Wallflower 4.2
Caryophyllaceae Silene scouleri ssp. scouleri Scouler Catchfly 2B.2 Convolvulaceae
Calystegia purpurata ssp
purpurata Smooth Westerng Morning glory
Calystegia subacaulis Hill Morning Glory
Curcurbitacea Marah fabacea California Manroot
Marah oregonus Coast Manroot
Fabaceae Astragalus nuttallii Bladder Pod
Lupinus nanus Sky Lupine
Lupinus variicolor Varied Lupine
Lupinus albifrons Silver Lupine
Lupinus bicolor Miniature Lupine
Vicia gigantea Giant Vetch
Iridaceae Iris douglasiana Douglas Iris
Iris longipetala Central Coast Iris
Sisyrinchium bellum Western Blue-eyed Grass
Lamiaceae
Clinopodium douglasii (Satureja
douglasii) Yerba Buena
Monardella villosa Coyote Mint
Stachys bullata Hedgenettle
Salvia spathacea Hummingbird Sage
Liliaceae Calochortus albus White Fairy-lantern
Fritillaria affinis Checker Lily
Toxicoscordion fremontii Fremont's Deathcamus
Malvaceae Sidalcea malviflora Checkerbloom
Onagraceae Clarkia rubicunda Ruby Chalice Clarkia
Taraxia ovata Sun Cup

1.f
Packet Pg. 1202 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4963 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 538
Letter Commenter Date Comment Combined Response
Individuals (C)
Orchidaceae Piperia michaelii Michael's Rein orchid 4.2 Orobanchaceae
Castilleja densiflora ssp
densiflora Dense Flower Owl Clover
Castilleja exserta ssp exserta Purple Owl's Clover
Castilleja wightii Wight’s Paintbrush
Orobanche californica ssp
californica California Broomrape
Triphysaria pusilla Dwarf Owl's Clover
Papaveraceae Eschscholzia californica California Poppy
Plantaginaceae Plantago erecta Dotseed (Dwarf) Plantain Poaceae Agrostis pallens Leafy Bentgrass
Agrostis exarata Spike Bentgrass
Bromus carinatus California Brome
Bromus sitchensis var. maritimus Maritime Brome
Calamagrostis nutkaensis PacificReed Grass
Danthonia californica California Oatgrass
Deschampsia cespitosa Tufted Hair Grass
Elymus glaucus ssp. Glaucus Blue Wild Rye
Elymus triticoides Beardless Wild Rye
Festuca californica California Fescue
Festuca rubra Red Fescue
Hordeum brachyantherum Meadow Barley
Hordeum depressum Dwarf Barley
Koeleria macrantha Junegrass
Leymus triticoides Beardless Wildrye
Melica californica California Melicgrass
Melica torreyana Torrey's Melica
Stipa pulchra Purple Needlegrass
Stipa lepida Foothill Needlegrass
Poa unilateralis San Francisco Bluegrass
Polemoniaceae Navarretia squarrosa Skunkweed
Leptosiphon rosaaceus Rose Leptosiphon 1B.1
Polygonaceae Eriogonum latifolium Seaside Buckwheat
Chorizanthe cuspidata sp
cuspidata San Francisco Spineflower 1B.2
Portulacaceae Calendrinia ciliata Red Maids
Ranunculaceae Ranunculus californicus California Buttercup Rosaceae Acaena pinnatifida Biddy-biddy, Sheepburr
Horkelia californica California Horkelia
Rubus ursinus Califonria Blackberry
Themidaceae Triteleia laxa Ithuriel's spear

1.f
Packet Pg. 1203 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4964 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 539
C108: John Keener, 2/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C108-1 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 The board of the Pacifica Land Trust has the
following comments on and proposed changes
to the General Plan Update. They center around
inaccuracies regarding trails at Pedro Point
Headlands. The current text is shown in bold.

The comment is noted.

C108-2 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-3 Fig 6-1 Parks and Open Space System,

Page 6 ends

Coastal Access Trail, and Page 6-28 Fig 6-4
Schools and Community Facilities Shows
“GGNRA” as owner of the Pedro Point
Headlands (and shows GGNRA as the owner of
the city-owned Catlle Hill property).

Proposed Changes: Delete “GGNRA” under
Pedro Point Headlands on this and other maps
throughout the Draft General Plan and DEIR. The
property is owned by the City of Pacifica and the
State of California (California Coastal
Conservancy). It is uncertain whether GGNRA
will take title. Separate the cityowned Cattle Hill
property from GGNRA property on Sweeney
Ridge.

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

C108-3 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-15 OC-I-15 Pedro Point Headlands.

Complete the planned transfer of City-owned
land on Pedro Point Headlands to an
appropriate public or private land steward, and
pursue land and/or trail easement acquisition if
necessary to connect Headlands trails with the
Coastal Trail in Pacifica.

Proposed Change: OC-I-15 Pedro Point
Headlands. Complete the planned transfer of
City-owned land on Pedro Point Headlands to an
appropriate public or private land steward.
(Delete the rest of the sentence, as the
necessary parcels have been acquired,
as noted on Pages 6-9 and 6-17).

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

C108-4 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-16 Fig 6-2 Trail System Shows "Pedro
Point Trail” as a proposed trail or trail
improvement
Proposed change: The restoration efforts of the
Pacifica Land Trust Stewards have completed the
trails as mapped, and they should be shown as
"Existing Trails" (Also, the Devil's Slide Trail
should be shown as an "Existing Trail")
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C108-5 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-18 Trails at Pedro Point bring hikers from a trailhead on Highway 1 to an overlook point
and to Pedro Summit. They are minimally
improved, although the trailhead created with
the opening of the Devil’s Slide Tunnel in 2014
has created a new public parking lot.

Proposed change: Trails at Pedro Point bring
hikers from a trailhead on Highway 1 to an
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses. Please see

1.f
Packet Pg. 1204 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4965 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 540
Letter Commenter Date Comment Combined Response
Individuals (C)
overlook point and to Pedro Point Summit. The
trailhead created with the opening of the Devil’s
Slide Tunnel in 2014 has created a new public
parking lot. (Delete "They are minimally
improved, although".)
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C108-6 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-19 OC-I-25 Pedro Point Headlands Trails.

In coordination with GGNRA and the California
Coastal Conservancy, support trail
improvements on Pedro Point Headlands, and
extension of these trails to the new trailhead at
the north end of Devil’s Slide.

Proposed change: Pedro Point Headlands Trails.

In coordination with GGNRA and the California
Coastal Conservancy, support connection with
the proposed Coastal Trail between Pedro Point
Shopping Center and the Devil’s Slide.

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

C108-7 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-21 Fig 6-3 Coastal Access Trail and access improvements expected under land steward
management; new trails should provide coastal
views from Pedro Beach
Proposed change: Trails provide coastal views.

Access improvements expected upon
completion of Coastal Trail segment from Devil's
Slide to Pedro Point Shopping Center.

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

C108-8 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-23 Table 6-5: Coastal Access Points Item 27 Pedro Point Headlands Detail: Headlands
with steep cliffs. Limited trail access exists from
trailhead at Highway 1. Proposed Improvement:

Trail and access improvements expected under
land steward management; new trails should
provide coastal views.

Proposed changes:

Detail: Headlands with steep cliffs. Trails on the
headlands provide coastal views. Informal trails
provide access from the north end of the Devil's
Slide Trail and from south end of Pedro Point
Shopping Center. Proposed Improvement:

Access improvements expected as a result of
proposed construction of the Coastal Trail
between Pedro Point Shopping Center and the
Devil's Slide north trailhead.

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

C108-9 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-29 OC-I-52 Pedro Point Headlands.

Extend trails on Pedro Point Headlands to a
coastal overlook point. (See Point 27 on Figure
6-3.)
Proposed change: Pedro Point Headlands.

Improve access to trails on Pedro Point
Headlands by supporting the Coastal Trail
segment from Devil's Slide to Pedro Point
Shopping Center. (See Point 27 on Table 6-5.)
[[Note - Incorrect location for Point 27 - should
be Table 6-5]]
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

1.f
Packet Pg. 1205 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4966 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 541
C109: Mark Hubbell, 2/21/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C109-1 Mark Hubbell 2/21/2
2 How can I view public comments already submitted on the General Plan DEIR?
All submitted comments will
become part of the public
record.

1.f
Packet Pg. 1206 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4967 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 542
C110: Christine Boles, 1/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C110-1 Christine
Boles
1/8/22 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.

The comment is noted.

C110-2 Christine
Boles
1/8/22 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 DEIR chapter related to Seismic Hazards uses two
maps to characterize landslide threat in Pacifica: The
Seismic Hazard Zone map, which shows landslide
prone areas that are required to undergo geotechnical
investigation and appropriate mitigation measures
incorporated into the project design. The Landslide
Zone data was released by the Department of
Conservation in 2021, the authoritative source for
mapping Zones of Required Investigation. As noted in
the map methodology, "As a part of the geologic data
compilation, an inventory of existing landslides in the San Francisco South Quadrangle, San Mateo County
was prepared by analysis of shaded relief maps
(various illumination directions) and contour data,
limited field reconnaissance, and a review of
previously published (Harding-Lawson, 1983; Bonilla,
1988; Jacobs Associates, 1999; Brabb and others,
2000; Wentworth and others, 1998) and unpublished
geologic-landslide mapping. Landslides were reviewed
using the lidar shaded-relief map (USGS, 2005), Google
Earth Pro DigitalGlobe and Historical Imagery, and
stereo-paired aerial photos. For each landslide
included on the map several characteristics
(attributes) were collected and compiled in a
geodatabase. These characteristics include recency of
activity, type, thickness, associated geologic unit(s), and the confidence of interpretation (definite,
probable, or questionable). The completed landslide
map was digitized, and the attributes were entered
into a database. Landslides rated as definite or
probable were carried into the landslide zone..."
Methodology for the Montara Mountain Quadrangle is
as follows: "As a part of the geologic data compilation, an inventory of existing landslides in the Montara
Mountain Quadrangle was prepared by analysis of
lidar-derived shaded relief maps (various illumination
directions) and contour data, 3D Google Earth Pro
DigitalGlobe and historical imagery, limited field
reconnaissance, and a review of previously published
(Brabb and others, 2000; Wentworth and others,

1.f
Packet Pg. 1207 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4968 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 543
Letter Commenter Date Comment Combined Response
Individuals (C)
1998) and unpublished geologic-landslide mapping.

Landslides were mapped using the 2005 USGS lidar
shaded relief images as base map. For each landslide
included on the map several characteristics
(attributes) were collected and compiled in a
geodatabase. These characteristics include recency of
activity, type, thickness, associated geologic unit(s), and the confidence of interpretation (definite,
probable and questionable). The completed landslide
map was digitized, and the attributes were entered
into a database..." As such, all relevant historical
landslides should be captured in Landslide Zone maps
released by the Department of Conservation.

The Slope Failure Threat and Coastal Erosion map,
Figure 3.6-3, shows areas of slope failure threat
categories. Risks due to landsliding are described in
detail on p. 3.6-8, and 3.6-13. Descriptions of coastal erosion and past events are described on p. 3.6-14,
and critical coastal erosion is also shown on Figure 3.6-

3. Projections of coastal erosion were studied as part
of the 2018 Sea Level Rise Vulnerability Assessment
(referenced on p. 3.6-1), which used best available
data to provide projections of future coastal erosion.

Taken together, this analysis adequately characterizes
risks due to landslides and coastal erosion in the
Planning Area. As noted in Impacts 3.6-1, the impacts
from landslides on development of future land uses
associated with the Proposed Project would be
addressed through site-specific geotechnical studies
prepared in accordance with CBC requirements and
standard industry practices, which would specifically
address landslide hazards located in landslide hazard
areas. Development would conform to the current
design provisions of the CBC to mitigate losses from
landslides. Proposed developments would also adhere
to the hillside development requirements contained in
the proposed policies below, as well as the existing
regulations in the Hillside Preservation District to
resist landslides through modern construction design
and slope stabilization techniques. General Plan
Policies SA I-2 and I-9 maintain restrictions on
hazardous areas including those in the hillside
Preservation District, while Policy SA I-8 requires that proposed development in hillside areas undertake
geotechnical studies which analyze erosion and
landslide potential. Policy LU-I-14 extends the Hillside Preservation District on the zoning map to ensure that
all steep and sensitive terrain is subject to these
regulations. Given State and local regulations,
including those in the Proposed Project, the potential
for adverse landslide impacts due to the
implementation of the Proposed Project at the
regional and local level is considered less than
significant.

1.f
Packet Pg. 1208 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4969 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 544
Letter Commenter Date Comment Combined Response
Individuals (C)
As noted in Impact 3.6-2, 1982–1983, the entire
coastline of San Mateo County contains areas
susceptible to severe erosion and slope failure.25
Coastal areas within the Planning Area include
locations that the USGS have determined to have
critical erosion hazards and unstable segments where
the sedimentary rocks are susceptible to failure from
heavy wave action. Areas within the Coastal Zone are
vulnerable to coastal erosion. Proposed development
within the Coastal Zone would be regulated by the
Coastal Act and certified Local Coastal Plans. The
proposed General Plan shares policies with the LCP,
including policies SA I-28 and SA-I-29, which commit to mapping areas vulnerable to coastal erosion and other
coastal hazards on a regular basis, and to
implementing a Sea Level Rise Adaptation Plan to
safeguard against coastal hazards, including coastal
erosion. Policy SA-I-70 requires geo-technical reports
for new development on the shoreline, and SA-I-71
requires that new development be sited and designed
to be safe from erosion for at least 100 years without
shoreline protection. Therefore, the potential for
adverse erosion impacts related to land use changes
from implementation of the proposed General Plan is
less than significant with implementation of the
proposed policies.

C110-3 Christine
Boles
1/8/22 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?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C110-4 Christine
Boles
1/8/22 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
The comment is noted.

1.f
Packet Pg. 1209 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4970 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 545
Letter Commenter Date Comment Combined Response
Individuals (C)
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."

1.f
Packet Pg. 1210 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4971 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 546
C111: Reina Heinz, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C111-1 Reina Heinz 3/8/22 The Environmental setting for the DEIR incomplete and out of date. Please
update using the best available data
and current technological practices.
- In particular, there seems to be
omitted and/or outdated biological
data – regarding species and
vegetation.
- Hydrology and watershed maps are
not up to date/not utilizing using best
available tools (i.e. GIS layers).

The commment is noted. Please see response to comments 14- 2, 163-3, 37-21, and C112-15 for more information on the adequacy of data informing biological settings. The DEIR uses the latest and best available data from FEMA to map areas of flooding on the Hydrology map, Figure 3.5-1 (National Flood Hazard Layer for San Mateo County, FEMA, 2019).

C111-2 Reina Heinz 3/8/22 Many policies in the DEIR do not match the correspondingly numbered
policies in the GP. Please update the
DEIR to track with the GP for
recirculation.

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

C111-3 Reina Heinz 3/8/22 Land use maps in both the GP and DEIR are difficult to distinguish
variation in color coding.

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

1.f
Packet Pg. 1211 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4972 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 547
Letter Commenter Date Comment Combined Response
Individuals (C)
C111-4 Reina Heinz 3/8/22 Please plan to review fire-prone areas and provide an updated fire map.

Indicate potentially fire prone areas,
highlighting those in the urbanwildland interface when new information becomes available.

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

WUI maps inform development of Fire Hazard Severity Zones designated by CALFIRE, and the Fire Hazard Severity Zone maps adopted by the State depict only WUI areas that include both a hazard and a housing demographic element (i.e. an exposure model) . While CALFIRE is currently in the process of updating its mapping to incorporate improved fire science, data and
mapping techniques and while that process may ultimately identify new areas where California’s defensible space standards and wildland urban interface building codes are required, updated mapping is not currently publicly available. Therefore, the data and information used in the DEIR represent the latest best available data at time of preparation. Please see more information in Master Response 5: Wildfire.

C111-5 Reina Heinz 3/8/22 This fire risk topic also relates to wildlife corridors and the need to
maintain habitat connectivity as
related for viable mammal
populations. Looking ahead climate
change will affect changes in the way
we view land. In this time of “extreme
wildfires” (where one in 100-year fire
burns out of control for more than
several weeks) - set to increases by
50% by the middle and end of this
century, we need to better plan for
land use and development, especially
with regards to protecting sensitive
wildlife habitat. Please consider the
following with respect to development
and puma habitat:
o Wildlife zones are something we
The comment is noted. Impacts of wildfire on animal
populations is not a required topic of analysis under CEQA, thus no further response is required. However, the comment
addresses the content of the Proposed Plan and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments for more information about GP- or SPSP-related responses.

1.f
Packet Pg. 1212 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4973 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 548
Letter Commenter Date Comment Combined Response
Individuals (C)
should be more concerned about.

Particularly in a time when globally
California is now one of the most fire
prone places in the planet.
o Unlike the areas of Hillsborough and
neighboring cities in the northern
region of the Santa Cruz mountains,
Pacifica has better potential habitat
sites for the Santa Cruz puma
population which is the population we
see here.
o It is well established that
development affects habitat quality,
habitat connectivity and reproductive
behavior of pumas1,2 and the
subpopulation in Pacifica is genetically
isolated and a provisionally listed
species.
o Further development may force
dispersal aged males to live in
subquality habitat/zones.

C111-6 Reina Heinz 3/8/22 7. Conservation (GP)
• Surface
water/Groundwater/Wetlands pp.7-2
to 7-6
Why are minor creeks (such as Big Inch
creek) omitted from the report? Big
inch creek is an ephemerally flowing
creek, serving as a potential seasonal
wetland and source of season surface
water, from the upslope watershed.

Thus, I suggest including this example
as a minor creek by indicating a creek
icon in the hydrology map in Figure 7-
3, especially as there is clear evidence
bolstered by local knowledge that this
creek supports wildlife such as deer.

Alternatively, this example might be
included as a seasonal wetland in the
wetland section of water resources.
• Figure 7-1: Hydrology Map p.7-3
It seems that the analysis of water
resources could use more current and
locally updated datasets as well as
more up to date available technology.

See prior question about minor creek
inclusion. This hydrology and
watershed map fails to use the most
accurate and up to date data available.

Suggestions include updating
watershed data delineations and
drainage points using best practice
techniques, the best available and
appropriate technology on a regional
or more granular level such as updated
The comment is noted. Figure 3.5-1, Hydrology and Flood Zones Map, will be amended to add Big Inch Creek to the map. This amendment represents a minor clarification and does not affect the findings of the DEIR.

Water resources analysis uses the most recent available data including from the National Flood Hazard Layer for San Mateo County, FEMA, 2019; Tsunami Hazard Area for San Mateo
County, Department of Conservation, State of California, 2020; U.S. Fish & Wildlife Service, National Wetlands Inventory, 2011; FEMA, 2008; ESA, 2009; City of Pacifica, 2020; San Mateo County, 2020.

In regards to wetlands, proposed policy CO-I-4 prohibits new development in existing wetlands except as allowed under the federal Clean Water Act and the California Coastal Act. It continues to require formal delineations wetlands subject to State or federal regulations prior to any proposed development project in an area where potential wetlands have been
identified. If impacts on wetlands are unavoidable,
compensation measure should be in line with the State’s no-netloss goal regarding wetlands.

The recommended citation is not available freely or publicly online. The DEIR uses the best available public information; please see response to comment C122-9 and C1-7.

The stormwater citation is from the City of Pacifica website, 2021. This information will be updated in the General Plan.

In addition, the typo "“Areas with riparian mixed hardwood habitat occur Areas with riparian mixed hardwood habitat occur” on page 7-18 of the General Plan will be amended.

1.f
Packet Pg. 1213 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4974 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 549
Letter Commenter Date Comment Combined Response
Individuals (C)
GIS layers - watershed boundary or
hydrography dataset - from the US
Geological Survey (USGS). There
should be a note about potential
watersheds in this map or in the
wetlands section.
• Wetlands p.7-5
The National Wetlands inventory does
not take into account actual wetlands
that have not been delineated. It
should be required that pre-project
approval as required by CEQA, in areas
indicating potential habitat for unique
flora or fauna a delineation be
completed by a qualified biologist.
• Stormwater 7-6
Where is the citation for this
statement? ‘Overall, the City maintains
290,000 linear feet of storm drain
pipes and 986 inlets.’
• 7.2 Biological Resources Section. p.
7-16 to 7-24 of GP and corresponding
sections in DEIR.

Suggested edits: Utilize this citation to
update all fields with relevant
information, especially plant
communities and Wildlife Habitat
descriptions. Mooney, H., & Zavaleta,
E. (2016). Ecosystems of California.

Univ of California Press.
• Riparian Mixed Hardwood p. 7-18
(18 of PDF)
Fix typo, (delete double line of the
same text): “Areas with riparian mixed
hardwood habitat occur Areas with
riparian mixed hardwood habitat
occur”
C111-7 Reina Heinz 3/8/22 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. Should a
funding mechanism require property
owners with land adjacent to creeks to
pay proportionate share? Creeks are a
common pool resource and creative
solutions are available that would
allow the City of Pacifica to support
property and landowners through cofinancing such maintenance projects.

For instance the city might qualify for
(or support acess for owners to apply
for) Payment for Ecosystem Service
(PES) programs as well as federal and
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR. However, the comment addresses the content of the Proposed Plan and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments for more information about GP- or SPSP-related responses.

1.f
Packet Pg. 1214 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4975 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 550
Letter Commenter Date Comment Combined Response
Individuals (C)
state grant programs that are
currently increasing in availability. See
https://www.landcan.org/Grant-andAssistance-Programs/.

Suggested edit: CO- I-3 Funding for
Creek Maintenance. Establish a
mechanism supporting collaborative
funding solutions between the city and
property owners with land adjacent to
creeks to distribute the share of creek
improvement maintenance.

Alternative edit: CO- I-3 Funding for
Creek Maintenance. Establish a
mechanism to support property
owners with land adjacent to creeks to
pay proportionate share of creek
improvement maintenance.

C111-8 Reina Heinz 3/8/22 CO- I-4 Wetlands Preservation.

Prohibit new development in existing
wetlands except as allowed under the
federal Clean Water Act and the
California Coastal Act. Continue to
require formal delineations (of)
wetlands subject to State or federal
regulations prior to any proposed
development project in an area where
potential wetlands have been
identified. If impacts on wetlands are
unavoidable, compensation measure
should be in line with the State’s nonet-loss goal regarding wetlands.

Suggested edit: CO- I-4 Wetlands
Preservation. Prohibit new
development in existing wetlands
except as allowed under the federal
Clean Water Act and the California
Coastal Act. Continue to require
formal wetland delineations subject to
State or federal regulations prior to
project approval for any proposed
development project in an area where
potential wetlands have been
identified. Delineations should be
completed in areas with indicator
species presence (i.e. Arroyo willow)
or any riparian zones where potential
wetlands are present, and required
prior to any permit or modification to
property. If impacts on wetlands are
unavoidable, compensation measure
should be in line with the State’s nonet-loss goal regarding wetlands.

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

1.f
Packet Pg. 1215 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4976 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 551
Letter Commenter Date Comment Combined Response
Individuals (C)
*See language in LU-I-29: A wetland
survey conducted according to the
requirements of Coastal Commission
regulation 13577 (Title 14, California
Code of Regulations) is required to
delineate potential wetlands on the
site as part of the development
application and environmental review
process.

C111-9 Reina Heinz 3/8/22 CO-G-7 – Wildlife and Critical Habitat.

Conserve and protect indigenous
threatened, endangered, and other
special status species by preserving
critical habitat.

Suggested Edit: CO-G-7 Protect Habitat
for Special Status Wildlife and
Vegetation. Conserve and protect
native threatened, endangered, and
other special status species by
preserving suitable habitat important
for the protection and persistence 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.

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

C111-10 Reina Heinz 3/8/22 CO-I-26 –Protection of Biological Resources with New Development.

Protect sensitive habitat areas and
special-status species through
implementation of the following
measures:

Suggested Edit: CO-I-26 –Protection of
Biological Resources with New
Development and other earth
disturbing site modifications. Protect
sensitive habitat areas and specialstatus species through implementation of the following measures:
*This CO-I-26 policy should be added
to the DIER.

The comment is noted; it is included on DEIR p. 3.7-53. The policy modification affects the General Plan and would be considered in part with other General Plan-related issues as part of decisionmaker hearings. Please see Master Response 1.

1.f
Packet Pg. 1216 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 4977 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 552
C112: Margaret Goodale, 2/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C112-1 Margaret
Goodale,
Naturalist
2/20/22 1. Remove inappropriate title “Annual Grasslands” and replace with the more accurate
“Grasslands/Prairie”
This comment is noted. The following edit has been
made for clarity:

DEIR p. 3.7-2: "Annual Grasslands Grasslands/Prairie
Annual grasslands in Pacifica 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 of unauthorized vehicle
activity, which resulting in off-road trails on
hillsides. Common dominants of grasslands include
ripgut brome (Bromus diandrus), rattail fescue
(Festuca myuros), and wild oat (Avena barbata).

Associated forbs include filaree (Erodium botrys),
sweet clover (Melilotus indicus), plantain (Plantago
lanceolata), and wild radish (Raphanus sativus).

Weedy species include foxtail (Hordeum murinum
ssp. leporinum), Italian ryegrass (Festuca perennis),
French broom (Genista monspessulanus), pampas
grass (Cortaderia selloana), cape ivy (Delairea
odorata), Bermuda buttercup (Oxalis pes-caprae),
black mustard (Brassica nigra), and sweet alyssum
(Lobularia maritima). Native species include
wild iris (Iris douglasiana), blue-eyed grass
(Sisyrinchium bellum), and California poppy
(Eschscholzia californica).4,5"
This is a minor correction made to clarify and does
not affect the findings of the DEIR.

C112-2 Margaret
Goodale,
Naturalist
2/20/22 2. Describe as follows:

Grasslands/Coastal Prairie in Pacifica occur at
Milagra Ridge, Sweeney Ridge, Cattle Ridge, Mori
Point, Aramia Point (formerly Rockaway
Headland), San Pedro Valley Park, the San Pedro
Mountain hills and Pedro Point Headlands and
often grow in a mosaic with coastal scrub.

Over the past thirty years extensive work has been
accomplished to protect, preserve and restore
native, perennial grasses and forbs at Pedro Point
Headlands (PPH), Aramai Point, Mori Point and
Milagra Ridge. The Pedro Point Headlands
restoration was supported by a grant awarded by
California State Parks and Recreation Division to
the Pacifica Land Trust to repair off- highway
vehicle damage. Grassland and prairie are being
protected in other publicly managed lands as well.

Unprotected grassland/prairie remnants continue
on Harmony 1, Rockaway Rock, the Quarry, Cattle
Hill, along Fassler, Esplanade, Palmetto, and Fish
and Bowl.

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

1.f
Packet Pg. 1217 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4978 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 553
C112-3 Margaret
Goodale,
Naturalist
2/20/22 3. The following policy should be added: "With
climate change, it is important to maintain both
genetic diversity and carbon sequestration by
protecting grassland/prairie remnants." That policy
should be implemented by "Any grassland/prairie
or scrub edge must be surveyed at the correct time
of year by a botanist prior to any disturbance."
The following species are ranked as California Rare
Plants in CalFlora and are present or likely to be
present in Pacifica:

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
The comment is noted. All species are found in
Appendix C, with the exception of Piperia michaelii,
which will be added in Appendix errata. This plant is
not federally or state listed, and it does not appear
in the CNDDB. Thus, it does not change findings of
significance in the EIR.

C112-4 Margaret
Goodale,
Naturalist
2/20/22 3. 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&blo
om=t
https://www.inaturalist.org/check_lists/3273-
Mori-Point-CheckList?iconic_taxon=47126&without%5B%5D=page& The comment is noted. As noted on DEIR p. 3.7-49,
the DEIR used the California Native Plant Society
Inventory of Rare and Endangered Plants (online
edition, v8-02). California Native Plant Society.

Sacramento, CA. This database was accessed on
June 11, 2021 to identify plants in the Planning
Area. This data source represents the best available
data from an established source of CEQA
information. As the comment does not address the
adequacy of the environmental analysis contained
in the DEIR, no further response is required.

1.f
Packet Pg. 1218 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4979 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 554
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

1.f
Packet Pg. 1219 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4980 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 555
C113: Margaret Goodale, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C113-1 Margaret
Goodale,
Naturalist
2/11/22 While our State certified LCP is sadly out of date, it remains our only real guide to coastal development.

Please see response to comment C30-8.

Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan
Update to ensure coordination between the
two documents. The City has prepared a
draft of the LCP Update in 2019, approved
by the City in 2020, and which is currently
under review for certification by the
California Coastal Commission. To the extent
the General Plan Update proposes any
policies beyond those which were sent to
the California Coastal Commission for review
and certification, a subsequent LCP
amendment would be necessary to make
the LCP consistent with the General Plan.

C113-2 Margaret
Goodale,
Naturalist
2/11/22 1. The new General Plan and DEIR must be consistent with Pacifica’s STATE CERTIFIED LCLUP.
• COASTAL ZONE LAND USE PLAN POLICIES of Pacifica’s
State certified LCLUP specify the following:

Page C-8

23. New development … shall· be located … where it wi11 not have significant adverse effects, either individually or cumulatively,. on coastal resources.

26. New development shall:

2. (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.

Page C-19
GEOLOGY (Fairmont West)
A Seismic Safety and Safety Element policy prohibits the approval of new developments which require seawal1s as
a mitigation measure. The· policy also states that projects should not be approved which eventually will need
seawalls for the safety of the structures and residents.

Page C-25 (WEST EDGEMAR-PACIFIC MANOR., ,(AMENDED
OcTOBER,24., 1984., #1-84).) GEOLOGY
As with bluff:-top lands to the north of the "Dollar Radio Station" residence, coastal bluffs in this area are subject to a high· rate of wave erosion. This average rate is exceeded during winter storm conditions when high wave run up and heavy rains are present. During these periods, sloughage of the face of bluffs occurs typically in the form of vertical slabs. The City's Seismic Safety and Safety Element requires the bluff setback to be adequate to accommodate a
minimum 100-year event, whether caused by seismic,
geotechnical, or storm conditions. The setback should be adequate to protect the structure for its design life. A Seismic Safety and Safety Element policy prohibits the
approval of projects which require seawalls as a mitigation This policy is consistent with PRC Div 20. Ch
3, article 4:. Marine Environment [30230 -
30236] ( Article 4 added by Stats. 1976, Ch.
1330. )Revetments, breakwaters, groins,
harbor channels, seawalls, cliff retaining
walls, and other such construction that
alters natural shoreline processes shall be
permitted when required to serve coastaldependent uses or to protect existing structures or public beaches in danger from
erosion and when designed to eliminate or
mitigate adverse impacts on local shoreline
sand supply. Existing marine structures
causing water stagnation contributing to
pollution problems and fishkills should be
phased out or upgraded where feasible.

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

1.f
Packet Pg. 1220 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4981 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 556
measure. The policy also states that projects should not be approved which eventually will need seawalls for the
safety of the structures
and residents.
• The new DEIR directly contradicts policy in the certified LCLUP as well as Coastal Act guidelines:

Doc p. 9 &10
New development that would require the use of seawalls
or other shoreline alterations for protection either now or in the future shall not be permitted unless this would make the property undevelopable. New coastline alteration is… permitted only where necessary to protect existing
development or public resources, and must minimize
adverse impacts to natural coastal processes.
• The above two consecutive sentences contradict each
other.
• MUST ALSO DEFINE AND SPECIFY DATE OF EXISTING
DEVELOPMENT!
ALLOWS ANY NEW DEVELOPMENT TO BUILD A WALL.

Current Coastal Act specifies only development existing at the time of its adoption.

Page C-105
SHORELINE PROTECTION .AN) DRAINAGE STRUCTIRES
Erosion is a primary problem along the Pacifica coast.

Studies by the U. S. Anny Corps of Engineers indicate that in many cases shoreline structures are not economically justified. (See LCP Background Report, Geology; General Plan Background Report,
Geology). There are, however, ·a few areas in the City
where shoreline protection may be necessary to protect
major beach access or highly sensitive habitat. (See LCP Access Component Report, Local Beach Resources and
Management). For these areas, and other areas where
protection from hazards may be needed in the future,. the following conclusions are suggested:

Dumping and other unengineered erosion protection
sha11 be prohibited. Existing unauthorized rubble or
protective devices shall be removed prior to any additional development in such areas. A qualified expert shall be
engaged to analyze the impacts -0f proposed structures
and prescribe appropriate mitigation, if necessary, prior to issuance of a,permit. Impact evaluation shall include
methods to minimize alteration of natural migration' and ~eposition of sand on shorelines within the 1ittoral cell, sufficient engineering to protect threatened area, latera1 and (if appropriate) vertical beach access, and structures as well
• THE MITIGATION DETAILS FOR THE EXCEPTION
MENTIONED ON PAGE 9 OF THE NEW DEIR MUST BE
INCLUDED.
discussion of the Coastal Commission
requirements; please refer to response to
comment C123-42 for more information.

Please see Master Response 1.

1.f
Packet Pg. 1221 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4982 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 557
C114: Andy Narraway, 3/2/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C114-1 Andy
Narraway
3/2/22 I am writing to comment and to inform you that I vociferously oppose the rezoning of the Calson Field from Commercial Recreation to Commercial Residential Mixed Use.

We, the majority of residents of Pedro Point, have for over a decade insisted that any residential buildings on this site would be both illegal and deleterious to the current residents of Pedro Point and Pacifica as a whole.

The various politicians over the last decade we entrusted with listening to us, their so-called constituents, have consistently shown a complete disregard for OUR opinions and have ignored us. Well, we have had ENOUGH. If you, the current members of the Council, will not listen to the residents, the taxpayers, the voters and even environmental experts then it will have to be resolved by litigation. We will not go away quietly and will fight this until you relent and confirm the wishes of the people involved and NOT one owner who wishes to profit at our expense.

In 2014, the residents of Pedro Point, hired experts and an attorney and they cited 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 DEIR (then) and now, fails to comply with the California Environmental Quality Act. Errors found by experts materially tied to the legal adequacy of the plan. 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 redesignated. 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.

The Draft Environmental Impact Report in 2014 (and NOW) fails to recognize the parcels as an Environmentally-Sensitive habitat for Endangered Species.

In 2019, the neighborhood of Pedro Point asked for (and never received) a Neighborhood-Specific Study to consider the robust community input and evidence presented thus-far. This request was denied. Why? If as you say, the vision and goals recommended in the GPU for a sustainable economy in Pacifica are to better leverage its coastal location and establish itself as a more successful tourist destination and call for more tourist-oriented retail districts… similar to other beachside communities along the Pacific coastline, well we have it: The Pedro Point field is directly adjacent to Linda Mar State Beach, wetlands and floodplains of San Pedro Creek (including endangered species habitat). It is also adjacent to a coastal visitor-serving commercial center (inclusive of multiple unique restaurants, surf shop, grocery store, coffee shop, etc.).

Therefore, low-intensity “visitor-serving commercial” land use is an obvious alternative that the DEIR AND council should and MUST enact.

A “Conservation” (C) land zone would be the simplest solution for rectifying these previous errors and to avoid future litigation I would urge the council to KEEP the current CR zoning or change the land use to Low-Intensity Visitor-Serving Commercial but to change to a CRMU will mean years of lawsuits.

Please see Master
Response 6: ESHA and
Master Response 4:

Undeveloped San Pedro
Ave Sites for more
information. The comment
addresses the content of
the Proposed Plan and will
be shared with decisionmakers in that context.

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

1.f
Packet Pg. 1222 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4983 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 558
C115: Camille Keating, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C115-1 Camille
Keating
3/8/22 Page153 Figure 6.2/ page 157 Figure 6-3 Coastal Access and page 84 Fig 4-8
Pacifica Southwest
The wording on #25 MAP OF COASTAL ACCESS, AS WELL AS THE MAP 6-2 IS UNCLEAR AND LEADS TO FUTURE CONFUSION.

The maps and figures of the above pages have some discrepancy and do not clearly identify where the plan is "Improve segment of Coastal Trail along former Railroad berm" The proposal shows a trail, continuing from the current beach trail ending at the bridge of San Pedro Creek, towards and behind the Pedro Point Shopping Center, parallel with both the shopping center and the East side of "The Calson field" passed the narrow portion of San Pedro ave. in front of Anchor Inn, and linking to a public trailhead at the Devils Slide trail near Ace Hardware. There is no need to encourage trail goers into several private properties, and away from the actual trail direction straight ahead of the San Pedro Bridge. Its mention to "Alongside the old railroad berm", alongside the (Calson) field property and continue towards the Pedro Point Headlands through an area "know as the Colt property" (pg. 84)
This seems like the continuation of an old plan that needs tightening up. The wording of "alongside the old Railroad berm" which is actually Shoreside drive, a private driveway should not be included at all.

Rather, the safest and most effective way to continue the trail IS TO PUT A SMALL CROSSWALK ON SAN PEDRO AVE. WEST TO

EAST, JUST PASSED THE BRIDGE, ALOWING TRAIL-GOERS TO
EITHER: 1)CONTINUE TOWARDS ACE HARDWARE AND ACCESS
THE PUBLIC TRAILHEAD TO DEVILS SLIDE, OR 2)GO UNDER THE

OLD HIGHWAY ALONG THE CREEK TO ENTER LINDA MAR

SHOPPING CENTER OR
CONTINUE TO OLD COAST ROAD. This provides the most options, for a safe and easy straightaway crossing, with a clear view of cars, directly to the access point of Devils Slide trail with adequate for pedestrians. This section is already a "No parking" zone and has enough space to accomodate a clear pedestrian or bike lane to the trail.

As well, the segment under highway 1, is already used by many residents, from the south Linda mar area, connecting them from the L.M shopping center, Old Coast road, and Higgins trails.

Therefore, it makes no sense to point trail-goers throughmultiple private properties in Pedro Point, and into cramped
neighborhood area with limited sidewalks, to then cross the street near a blind turn @ Ace hardware.

Who would be responsible for the liability and maintenance of this proposed trail segment through multiple private properties? Providing a cross walk area at the bridge at San Pedro allows for more safe connection to other trails and neighborhoods without impeding on private property owners, or pushing more
unnecessary foot traffic into an already congested area. It keeps The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

1.f
Packet Pg. 1223 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4984 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 559
Letter Commenter Date Comment Combined Response
Individuals (C)
a continuity of Public City trail, on Public property, which can be more safely maintained and insured by the city. Both visually, and strategically, its pedestrian connectivity and straight away, makes more sense to any hikers looking to get from point A to point B.

Please see attached photo of (My) Proposed crossing area on San Pedro ave. (My proposed crosswalk area; safe straight away, clear sight, plenty of pedestrian access, options for continued connection to Linda Mar or Devils slide, out of Private Property.) C115-2 Camille
Keating
3/8/22 Page 97 LU-I-28
"Maintain Access beach along Shoreside drive"
It seems that the access point that is mentioned in LU-I-28 is actually referring to the San Pedro Creek Public access at Coast Hwy in the Pedro Point Shopping center. This is the safest, most convenient, least impactful, and only public access south of the San Pedro Creek. Therefore, the public (especially visiting Public) should have clear signage directing them towards this access at the Creek .

Shoreside Drive is a privately owned driveway that enables it’s resident’s to access their homes by car and foot. Any access points from Shoreside drive, or houses to the beach are also private, and run closely along side the homes, for the use of the residents and are not to meant to handle public use. Throughout the years, and especially negatively impactful during Covid, Shoreside residents were bombarded with an influx of beach goers, unclear of how or where to park and access the beach.

People climbed up and between houses, used residents' private decks and paths as bathrooms, allowed kids and dogs to run THROUGH our homes and yards, left litter on the property and dangerously parked and blocked the one way narrow dirt
driveway preventing ingress/egress. We were vocal of our concerns to the city during that time, and were given cones and temporary signage to alert visitors and protect our property with. We were also asked by Pacifica PD during beach closures to try and eliminate any arteries of access that might be used to get to the beach. It is a constant struggle.

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

C115-3 Camille
Keating
3/8/22 This is a sensitive area vulnerable to the elements, lack of parking and to overuse.

Lack of signage near the Shopping center, and negligent trampling by visitors looking for access, adds increased liability and maintenance to our private driveway, not to mention creates hostile conflict between resident property owners, and beach visitors trying to find their way.

This is supported on Table 6-5; Coastal Access Points as "Private property with no access" but unclear on LU-I-28. I am glad to see that in OC-I-40 "Until such an entity agrees to be responsible for liability and maintenance of such access ways, they are not to be open for public use"
Please help clear up any future confusion by adding proper The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

1.f
Packet Pg. 1224 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4985 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 560
Letter Commenter Date Comment Combined Response
Individuals (C)
signage to the safely maintained and convenient Public Access at the Creek in the PP shopping center at COAST HIGHWAY
C115-4 Camille
Keating
3/8/22 PG. 97 LU-I-29 Undeveloped San Pedro ave.

I am opposed to any rezoning of this property at this time, without further study, updated EIR and traffic reports, and without broader neighborhood feedback. Until the safety (or lack of) for ingress and egress by current Pedro Point residents is addressed, the development of any portion of the "Calson Field" must be thoughtfully considered.

In March of 2014, a resident, Errol Chang was fatally shot on San Pedro ave by swat teams. For the entirety of the day, Pedro Point residents were stuck on either side, unable to access their homes or leave the point by car. This was a terrible scene on many levels. It also heightened our awareness, as to what happens in an emergency. Whether it be a road blockage, or worse, a Fire, Tsunami, or earthquake evacuation, where all residents need to leave Pedro Point via San Pedro Ave, we are held hostage to our one way in and out neighborhood. Until such considerations are met, I do not feel that the rezoning of "the Calson Field" to CRMU is acceptable with the number of homes/units it allows for. Nor do I feel it should become such a commercial draw, that exacerbates current traffic and parking on the point. We already have tight roads with little to no sidewalks facing overuse.

Whatever goes in at the field property should be small scale, and allow for a majority of open space to preserve the safety, and look and feel of Pedro Point, and have the least impact on current Pedro Point residents, as well as in the south end of Pacifica, to where the traffic bottlenecks along HWY1.

The comment is noted. Congestion is
not a required topic for CEQA analysis
and the DEIR analyzed and mitigated
VMT impacts on pages 3-40 to 3-43.

Comments regarding land use
designations do not pertain to the
adequacy of the DEIR, thus no further
response is required. However, the
comment addresses the content of the
Proposed Project and will be shared
with decision-makers in that context.

Please see Master Response 1: EIR
Comments for more information about
GP- or SPSP-related responses. See
response to comment C15-2 and
Master Response 7: Emergency Access
regarding emergency access.

C115-5 Camille
Keating
3/8/22 PG. 97 LU-I-29 Undeveloped San Pedro ave.

Whatever goes in at the field property should be small scale, and allow for a majority of open space to preserve the safety, and look and feel of Pedro Point, and have the least impact on Please see more information on
evacuation routes in Master Response
7: Emergency Access. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

1.f
Packet Pg. 1225 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4986 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 561
Letter Commenter Date Comment Combined Response
Individuals (C)
current Pedro Point residents, as well as in the south end of Pacifica, to where the traffic bottlenecks along HWY1.

C115-6 Camille
Keating
3/8/22 Pg. 159, Coastal Access #24 North Side PedroPoint Shopping Center #25 Ocean Shore Railroad Berm
This coincides with my concerns stated above regarding
Shoreside drive
#24 It is stated “ Improve new segment of Coastal Trail along former railroad berm”. To where exactly are you referring? The berm once ran the length of the beach, and parts were taken down in the upgraded beach trail between Taco Bell and the old "Fassler house." Is this the area you are referring? It is unclear, though maps and some wording point to north of the Pedro Point Shopping Center.
#25, "Ocean Shore Railroad Berm", also referred to as "Shoreside Drive" in other segments of this plan, are one in the same, so interchanging the names is confusing and lacks continuity and clarity. This is a privately owned DRIVEWAY with resident access only, but because of the wording of “Old Railroad berm”, the exact location and section of trail you are referring to is murky.

This leaves room for interpretation, confusion, and sometimes anger from the frustrated public who lacks proper direction, signage, and etiquette, regarding treading through private property.

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

C115-7 Camille
Keating
3/8/22 Lastly, On page 82 Figure 4-8 it lists two areas listed as either "View Corridor" or "Bluff top view points" in Pedro Point, that are both sensitive areas vulnerable to overuse, or on private property near eroding or unsafe bluffs. Both Shoreside drive/ Shelter Cove road, and Kent road / Blackburn Terrace. These areas when pointed out become an attractive nuisance to the already congested neighborhood, and liability to private property owners as people "searching for a view" tread over private property or sensitive habitat. On Shelter cove road and Shoreside drive about 10 years ago, a woman fell off of the cliff and died while overlooking the view. More recently, in June of 2021, a young woman drove passed the resident safety cones placed at the end of Danmann, alerting of residents' parking area, in an attempt to drive her car off the cliff. When unsuccessful, due to hitting a fence put up by residents to protect this area, the woman jumped off of the cliff in the dark of night, a second attempt at suicide. Residents found her damaged car, and later, her near lifeless body at the bottom of the cliff. I was one of those residents. I along with my family stayed with the woman, and after rescue firefighters arrived and brought her broken body up the cliff after lying helpless for over 12 hours as the tide crept up to her. It was a haunting scene that will stay with me.

When you "advertise viewpoints" especially in areas that are private, and or not maintained by the city, you are inviting more attention to sensitive areas that would be better left unbroadcasted. With that said, I am glad to read that on Page 162 Policies OC-I-38-41 Impediments to Public Access, it states "prohibit restrictions on public parking that would adversely affect public access to beaches, trails, or other recreational lands along the coast, EXCEPT WHERE NECESSARY TO PROTECT PUBLIC SAFETY" and that "THE CITY MAY GRANT EXCEPTIONS TO THIS The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.

1.f
Packet Pg. 1226 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4987 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 562
Letter Commenter Date Comment Combined Response
Individuals (C)

REQUIREMNET WHERE PUBLIC ACCESS WOULD POSE A SAFETY

RISK, OR THREAT TO FRAGILE RESOURCES, OR WHERE
ADEQUATE ACCESS EXISTS NEARBY"
Please take this into consideration when choosing to include privately owned, or sensitive or potential dangerous areas, and listing them unnecessarily as "View Corridor" or Bluff top Views." Again, No private entity should be made liable for maintenance or dangers caused by unwanted invitations to the public in the form of signage or listings and these areas SHOULD NOT BE PROMOTED.

1.f
Packet Pg. 1227 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4988 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 563
C116: Henry Ruhnke, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C116-1 Henry
Ruhnke,
Architect
3/8/22 Our office is working with the owner of the 3.48 acre undeveloped parcel (number 018-140-670) which fronts on the west side of Highway 1 situated between the Our Savior’s Lutheran Church and the Pacifica Pet Hospital. The current zoning of this parcel is C-2 and the 1980 General Plan identifies this parcel along with neighboring parcels to the north and south as commercial land use designations.

We have reviewed the Draft General Plan update and have noticed that parcel 018-140-670 is now shown as a “service commercial” land use while the other parcels to the north and south have been shown as “mixed use neighborhood 16-26 units per acre.” The “service commercial” land use is actually a downzoning of my client’s parcel since the existing C-2 zoning allows for more uses than the “service commercial” land use category. It seems inconsistent to keep parcel 018-140-670 as a commercial use while changing surrounding land-uses to mixeduse neighborhood. Furthermore, looking at the figure 4-3 in the Draft General Plan my client’s parcel appears to be a “spot zone” around mixed-use uses.

This letter is to request parcel 018-140-670 be changed in the Draft General Plan from “service commercial” use to “mixed-use neighborhood 16-26 units per acre.” Considering the City’s and State’s need for housing, identifying this parcel as mixed-use makes much more sense than the commercial “spot zone” as currently proposed.

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

1.f
Packet Pg. 1228 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4989 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 564
C117: Pete Shoemaker, 2/16/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C117-1 Pete
Shoemaker
2/16/22 The attached excel file contains all the information, plus a video link that describes my process and findings. Link is repeated here.

In summary, I looked at all 522 Policies, both Guiding and Implementing, in the DGP and checked their occurrences in the DEIR. I found that 168 of them were listed in error at least once in the DEIR, and many multiple times. By “error” I mean that the text does not match that of the same-numbered Policy in the DGP. That is an error rate of at least 32%, about one out of three.

Tracking the Consistency of Policy Numbering between the DGP and There are 522 policies (Guiding and Implementing) listed in the General Plan, I checked every one of them against their counterpart in the DEIR, in all of the I found that 168 of them were listed incorrectly at least once in the DEIR, many That is an error rate of at least 32%.

The data is listed here in the two following worksheets, one with all the raw data This video explains my process in detail.

The comment is noted. These
policies will be renumbered in
errata. They do not change
findings of significance.

1.f
Packet Pg. 1229 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4990 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 565
C118: Pete Shoemaker, 1/31/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C118-1 Pete
Shoemaker
1/31/2
2 The below video shows how I discovered 15 errors in policies between the GP and the EIR in 90 samples: 17% error rate.

There are 530 such policies, which projects to about 90 potential errors. The attached files are my documentation.

Policy errors: https://www.screencast.com/t/8rog4I2erC
The comment is noted. Policy
numbering will be clarified in a
redline version.

1.f
Packet Pg. 1230 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4991 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 566
C119: Michael Vasey, 2/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C119-1 Michael C
Vasey, PhD
2/20/22 ln reviewing the draft Plan Pacifica, the following comments will mostly be focused on the property identified as "Undeveloped San Pedro Avenue Site" in Fig.4-B: Pacifica Southwest. ln all of the maps in the document, the Undeveloped San Pedro Avenue Site is shown to have three roads going through it. ln fact, no roads actually go through this - 5 acre property. Rather, these reflect "paper streets". This is important because this relatively large, flat property is still relatively intact and provides numerous local community, public, and natural resource services to Pacifica. I will elaborate further below^
The comment is not related
to the adequacy of the
DEIR, therefore no further
response is required in the
FEIR. Maps will be modified
to remove paper streets;
this does not change any
findings of significance.

C119-2 Michael C
Vasey, PhD
2/20/22 Section 1
Referring to this property, pages 4-25 & 4-27 state that the "Plan retains flexibility for any future development on the vacant site west of the shopping center, identified as the Undeveloped San Pedro Avenue Site, which could have residential and small-scale commercial and visitor-oriented uses.

Development of the site will require detailed evaluation of coastal hazards/vulnerabilities and biological resources to ensure that any sensitive habitat and wetlands that may exist on the site are protected; thus, the footprint of development could be smaller than the area designated. Future development should include a small park and access to the berm and the beach beyond. Completion of the Devils Slide Tunnel project has provided the opportunity to create a new trailhead and trails through open space land on the headlands" (my emphasis, and similarly throughout the remainder of this comment). This important language is highlighted because it effectively summarizes the potential for this site to serve Pacifica residents, the broader public, and the conservation of diminishing coastal biodiversity in important ways.

The following guiding policies and implementing policies highlight some of these key points (P.4-31), for
example:
"LU-G-1 Coastal Development. 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.

LU-G-7 Open Space Conservation and Habitat Protection. Protect beaches, oceanfront bluffs, ridgelines, hillside areas adjacent to existing open space, and areas that support critical wildlife habitat and special status species.

LU-G-9 Citizen Participation . Continue broad-based citizen participation in the planning process."
LU -l-2 Land Divisions in the Coastal Zone. "Continue to require coastal development permits for all land divisions within the Coastal Zone. Land divisions in the Coastal Zone shall be: Prohibited on properties that include any areas that ore within or adjacent to an Environmentally Sensitive Habitat Area (ESHA) unless the resulting parcels can be developed without building or requiring vegetation clearance in the ESHA or ESHA buffer, or unless the resulting parcels are set aside for conservation. Any land division that would result in a parcel that could not be developed in accordance with the policies of this LCLUP is not allowed."
LU-l-3 Coastal Development Permit Findings. "For all development that requires a coastal development permit, continue to require written findings that it is consistent with all LCLUP policies and implementation Plan provisions of the City's certified Local Coastal Program. If there is a conflict between a provision of this LCP and a provision of the General Plan, or any other City-adopted plan, resolution, or ordinance not included in the LCP, The comment is not related
to the adequacy of the
DEIR, therefore no further
response is required in the
FEIR. However, the
comment addresses the
content of the Proposed
Plan and will be shared
with decision-makers in
that context. Please see
Master Response 1: EIR
Comments for more
information about GP- or
SPSP-related responses.

1.f
Packet Pg. 1231 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4992 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 567
and it is not possible for the development to comply with both the LCP and such other plan, resolution or ordinance, the LCP shall take precedence and the development shall not be approved unless it complies with the LCP provision.

LU-l-29 Undeveloped San Pedro Avenue Site. “Establish a Coastal Residential Mixed Use zoning district to allow small-scale visitor-oriented commercial uses as a stand-alone project without any residential development, or smallscale visitor-oriented commercial uses with residential development at a density range of three to five units per gross acre. Housing may be clustered, and uses may be mixed vertically or horizontally. Residential uses may be constructed attached to or detached from commercial uses, provided the overall site contains both commercial and residential uses". "Development must include public coastal access and must provide public open space. A wetland survey conducted according to the requirements of Coastal Commission regulation 73577 (Title 14 California Code of Regulations) is required to delineate potential wetlands on the site as part of the development application and environmental review process. An assessment of potential geotechnical hazards must also be part of the development application and environmental review process, including assessment of the Ocean Shore railroad berm under hazard and vulnerability scenarios"
This series of guiding and implementing policies well defines both the significant challenges of developing this site, the potential that represents for the community, and to some degree the potential that the best solution may be to make all or a significant portion of it public open space. I will elaborate on these ideas below.

C119-3 Michael C
Vasey, PhD
2/20/22 Section 2
To begin, most significantly, in the Draft Plan Pacifica, the issue of Environmentally Sensitive Habitat Areas (ESHA) is defined as: "any area in which plant or animal life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and which could be easily disturbed or degraded by human activities and developments." "These areas are to be protected against any significant disruption of habitat values, and only uses dependent on these resources are to be allowed within these areas. Development in areas adjacent to environmentally sensitive habitat areas must be sited and designed to prevent impacts which would significantly degrade those areas, and be compatible with the continuance of those habitat and recreation areas." (P.7- 22).

This is particularly relevant to the Undeveloped San Pedro Avenue Site because of a clear case that this site is ESHA based on the occasional presence of the California Red-Legged Frog (CRLF) in the drainage channel that borders the eastern edge of the property. Several CRLF were present at this site in 2021 and there is evidence that the population laid eggs and produced juveniles (tadpoles)" The drainage canal collects all the natural runoff from Pedro Point Headland to the south and runs in storm water drains below the residential community down to another open drainage channel along the north side of the junction of San Pedro Road and Grand Avenue. It then pools on the other side of Grand Avenue and continues intermittently north to another culvert which empties into an arroyo willow thicket and, then, through another culvert into the mouth of San Pedro Creek. This seasonal breeding population is now well validated (for example, by California Department of Fish and Wildlife). The population waxes and wanes depending on the year. Most likely, it is an important breeding site in dry years because natural breeding pools become fewer. Because of neighborhood runoff, the pool system at the foot of Grand Avenue is Please see Master
Response 6: ESHA and
Master Response 4:

Undeveloped San Pedro
Ave Sites for more
information

1.f
Packet Pg. 1232 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4993 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 568
hypothetically a refuge during dry years.

Another feature of this site that benefits the CRLF is the adjacent field. At night, CRLF individuals access the field and forage for invertebrates that are abundant during the spring and summer breeding season. This abundance of invertebrate forage is also of value to a variety of other species in the neighborhood that depend on the field for food resources. For example, a variety of different rodent species live in the field and these, in turn, provide foraging resources for nearby raptors and owls that live in the forest that is abundant on Pedro Point Headland above the residential area. There is no analogous foraging site in the neighborhood for these avian predators.

Hence, a variety of hawks, owls, and other species (for example, violet green sparrows sometimes during the year) rely on this habitat to support their breeding sites in the nearby forest. This, in essence, underscores the value of the "field" as an ESHA supporting the biodiversity of the area.

One reasonable criticism of the Draft Plan Pacifica report is that it does not recognize this drainage site on Pedro Point. For example, in Figure 7.3, it is not illustrated. Also, despite the well-reported CRLF population present at this site, the red hatched area indicating Critical Habitat for CRLF that should extend to the Undeveloped San Pedro Avenue Site does not. It is important to highlight this potential development conflict so that the property is not zoned inappropriately inviting unrealistic real
estate investment in property that is likely to be determined to be ESHA by the Coastal Commission.

C119-4 Michael C
Vasey, PhD
2/20/22 Section 3
Aside from these fundamental natural resource constraints to getting project approval for the Undeveloped San Pedro Avenue site, there are also a number of geophysical considerations that are important for permitting any future development at the site.

For example, the Undeveloped San Pedro Avenue Site was formerly an extension of the tidal wetland known as Lake Mathilda that extended far into Linda Mar Valley. This wetland was partially cut off from the field by the construction of the Ocean Shore Railroad but was still linked to the mouth of San Pedro Creek via the seasonal stream that drained Pedro Point Headland into San Pedro Creek. During the mid- 20th Century, fill from development in the back of Linda Mar Valley was placed over these wetland sediments to raise the surface of the site. Nevertheless, mucky, wetland soils lie beneath this fill and these unconsolidated soils are well known to he seismically unstable. Accordingly, Figure 8-1 identifies the Undeveloped San Pedro Avenue Site as being at high risk for liquefaction. Further, because the site is low in the tidal frame, it is well recognized as vulnerable to future Sea-Level Rise (SLR). These two factors alone, particularly along the northeast area of the Undeveloped San Pedro Avenue Site, are
sufficient to detract from any development in this area. For example, as spelled out in SA-l-78, "Except for temporary uses, as described below, uses and development within sea level rise buffer areas shall be limited to minor passive recreational uses, with fencing, de-siltation or erosion control facilities, or other improvements deemed necessary to protect the habitat, to be located in the upper (upland) half of the buffer area." ln summary, development on this former wetland is risky both at present, due to seismic instability, and in the future due to potential vulnerability due to SLR.

Please see Master
Response 4: Undeveloped
San Pedro Avenue Sites for
more information about
how proposed projects will
be required to demonstrate
compliance with Coastal
Act policies to receive a
coastal permit; and how
compliance with federal,
state, and local regulations
will reduce potential
impacts to less than
significant.

C119-5 Michael C
Vasey, PhD
2/20/22 Section 4
ln Section 6 {Open Space and Community Facilities), Fig. 6.l identifies the Undeveloped San Pedro Avenue Site as a potential "Park Opportunity Site" The comment is not related
to the adequacy of the
DEIR, therefore no further

1.f
Packet Pg. 1233 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4994 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 569
even though it is not generally recognized elsewhere in the narrative from this section. ln fact, the Undeveloped San Pedro Avenue Site has great potential as a trail connection for hikers linking Pacifica State Beach, across the Undeveloped San Pedro Avenue Site the field along an existing trail alongside the wetland drainage area on the east side of the property, and then crossing San Pedro Avenue to enter the existing trail that goes from behind the Ace Hardware up to Pedro Point Headland. Currently, this trail, and a trail to the old Ocean Shore levee a set of stairs up and down, lead one across the field from San Pedro Road to the Beach. Despite the fact that the Undeveloped San Pedro Avenue Site is private, the Coastal Commission has found that there is a constructive easement across the property.

Further, along the lines of the Pocket Parks mentioned in Section 6, the Undeveloped San Pedro Avenue Site already serves as a major gathering place for residents of Pedro Point. Working with the neighborhood and other Pacifica citizens, it would be excellent to create a pocket park for this part of Pacifica. On the ocean side of the highway and the south side of San Pedro Creek, this is the only level, relatively large area where people from the neighborhood and elsewhere can gather. It would be great to fold this area into the pocket park planning process.
response is required in the
FEIR. However, the
comment addresses the
content of the Proposed
Plan and will be shared
with decision-makers in
that context. Please see
Master Response 1: EIR
Comments for more
information about GP- or
SPSP-related responses.

C119-6 Michael C
Vasey, PhD
2/20/22 Section 5
A final but related issue is the support of recreation for the neighborhood and other people who visit the coast for a variety of reasons. Again, presumably as a result of the closure of beach parking areas 5 during early Covid times, many people began to park along San Pedro Road and use the Undeveloped San Pedro Avenue Site as an access for surfing, fishing, and other shoreline recreation. This supports the OC-G-6 Coastal Areas Suited for Water-Oriented Recreation goal. Beyond coastal access, this site is also used in essence as a dog friendly space and place for various residents to play. It has great potential become an important recreational resource for Pacifica.

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

C119-7 Michael C
Vasey, PhD
Summary
ln summary, the Undeveloped San Pedro Avenue Site is somewhat mischaracterized by the Draft Plan Pacifica document. Most importantly, it fails to recognize the wetland value of this site, the importance of the site to ESHA considerations, and its potential for linking Pacifica State Beach with Pedro Point Headland. Further, by identifying this site as one for future development and drawing in the paper streets in all the figures in the document, it is easy to assume that this property does not have the natural and cultural values that, in reality, it clearly presents. While it is possible that some limited development might take place, it would be essential for this development to be as far as possible from the biologically sensitive habitat at its eastern end. This would then entail a number of problems within the neighborhood, such as too much traffic to get to the western part of the field without negative inpats and intense local opposition. ln my view, the Plan Pacifica draft would be far improved if it included these considerations in the final document so that future people interested in potential development would not be misled by the current treatment of this site in Draft Plan Pacifica.

Please see Master
Response 6: ESHA and
Master Response 4:

Undeveloped San Pedro
Ave Sites for more
information.

1.f
Packet Pg. 1234 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4995 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 570
C120: John Sharp, 3/4/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C120-1 John E.

Sharp
3/4/22 Housing Element
Owner notes that the City of Pacifica ("the City") is, as is the case with all jurisdictions of the State of California, undergoing affordable housing review consistent with, without limitation, the multiple affordable housing bills recently signed into law, including Senate Bill 9, Government Code Sections 65915, 65852.2, 6582.22 and related statutes. In addition, pursuant to the requirements of the Association of Bay Area Governments, (ABAG), Regional Housing Needs Allocation ("RHNA) goals must be met. In or about December 2021, ABAG adopted Final Regional Housing Needs for the San Francisco Bay Area which applies to all jurisdictions, including the City.

Among the multiple references in the City's Draft Housing Element for 2015-2023, adopted by City Council Resolution No. 13-2015 on May 11, 2015, the Draft Housing Element references ABAG's RHNA allocations as applied to the City. The table at page 29 (Table II-12), relying on RHNA mandates shows planning requirements for housing units affordable to a range of income levels and goes on to state:
"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 used developments." At page 45, the land use element, under "Land Use Controls" references the Land Use Element of the General Plan as providing "overarching guidelines for land categories and includes a map of assigned land uses". That map contains the owner's property, as identified above.

At page 46, table II-27 and paragraph 3, the various residential zoning districts in the City are described. On page 4 7, the Housing Element states, at paragraph 1:
"Tradeoffs among zoning districts, notwithstanding, the internal consistency that exists between 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% beyond the district allowance."
At paragraph 7, on page 47, a description of multiple-family residential development in the various R districts and C districts is described.

Further, at page 86, the Housing Element identifies "approximately 95 acres of vacant or underutilized land in the C 1, C2 and CR districts." It is further stated that these commercial zoning districts provide an opportunity for affordable housing".

On behalf of Owner, we note in the context of the Housing Element, General Plan Update and General Plan EIR, that zoning of the abovedescribed parcel for high-density residential use provides the City with affordable housing opportunities as contemplated in the many recent state affordable housing mandates and the City's own policy document.

Owner thus requests that, the land use designation for Parcel 018-140- 670, currently zoned C-2, be zoned for high-density residential zoning, which would contribute to the City's housing requirements.

The owner's preference
for high density housing
is noted. As this
comment does not relate
to the analysis of the
DEIR, no further
response is required.

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

1.f
Packet Pg. 1235 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4996 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 571
C121: Margaret Goodale, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C121-1 Margaret
Goodale,
Naturalist
3/7/22 SA-I-14 Geologic Hazard Abatement District
>> No coastal property that is unsafe to build on without first “altering the shoreline,” building a seawall, or allowing future “Shoreline Protection” should be developed according to the currently State certified LCLUP.

A Seismic Safety and Safety Element policy prohibits the approval of projects which require seawalls as a mitigation measure. The policy also states that projects should not be approved which eventually will need seawalls for the safety of the structures and residents.

The new GP/SPSP/DEIR documents in review propose to:

SA-I-9 Maintain Restrictions on Hazardous Areas.
“Continue enforcing the existing Coastal Zone Combing (sic.) District and Hill- side Preservation District regulations that restrict development in hazardous areas where access is impractical and areas prone to hillside and coastal erosion, landslides, seismic shaking, tsunami inundation, or flooding. “ >> Note that “restrict” does not prohibit.

SA-I-14 Geologic Hazard Abatement District
Amend the Municipal Code to include provisions for formation of geologic haz- ards abatement district for coastal bluffs and hillside areas at risk of landslides
in Pacifica to enable cooperative efforts among property owners for protection of coastal bluffs from erosion and improve- ment and maintenance of drainage and protective infrastructure. The Geologic Hazard Abatement District (GHAD) is a potentially useful tool to effec- tively abate a landslide hazard that crosses property boundaries. It is a mechanism that responds to the physical realities of landslides, and allows property owners to cooperate in solving a common problem.

SA-I-33 Adaptation Funding allows property owners in
hazardous areas to
“…pursue…new funding mechanisms…”
SA-I-68 Shoreline Protection Structure Upgrades
Allow maintenance of existing or new shoreline protection structures to reduce hazards and resource impacts…
>> The three entries facilitate violation of the California Coastal Act. Every implication that indefinite new and improved walls are encouraged MUST be removed.

This comment is related to the
LCLUP. These policies have been
reviewed in a consultation draft
with the CCC, and any final
changes will be made consistent
in an update to the GP.

1.f
Packet Pg. 1236 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4997 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 572
C122: Stan Zeavin, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C122-1 Stan Zeavin
& Linda Mar
3/7/22 1. Our GP is filled with short term planning. Higher costs and duplication will follow.

Obsolescence is the bed partner of short-term planning for long term issues. See Example 1 below for dangers of short-term planning with respect to traffic and transportation.

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

C122-2 Stan Zeavin
& Linda Mar
3/7/22 2. The major question on many projects in the GP: What is best for development, not what is best for Pacifica’s citizens and what is the most up-to date information (see also #3)
To be fair, the science is considered when it doesn’t interfere with planning development. However, there are several
examples of the city rubber stamping developer’s reports in spite of multiple engineering errors and misinformation. Failure to do due diligence by choosing to ignore the most up-to-date information available is bad for Pacifica. For examples of the city’s lack of due diligence resulting in citizen safety concerns, see Example 2 below.

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

C122-3 Stan Zeavin
& Linda Mar
3/7/22 3. GP’s lack of information updating makes it impossible to formulate a realistic(?) new(updated?) GP plan. The GP has almost no contingency plans for major projects, and without accurate information to begin with, contingency planning is meaningless. Even the proposed contingencies, such as they are, do not plan for what would happen if the money dries up nor does it explain who would then pay. What if SLR accelerates faster than currently anticipated, which at this point seems a distinct possibility? Without reasonable alternatives in the plan, there could be up to years of delay for a situation that might call for an immediate response. See Example 3 below.

The comment is noted. Policies
within the LCLUP related to
effects of climate change and sea
level rise are addressed in the
LCLUP. Please see also See
response to comment C13-3 for
more information about coastal
flooding and sea level rise.

C122-4 Stan Zeavin
& Linda Mar
3/7/22 4. The GP will not have a completed LCP and the June date for the completion of the GP is both arbitrary and artificial. The GP is not close to having an acceptable LCP. This process has been going on for years. It appears that the city is attempting to get an incomplete GP on record that will take years to correct rather than take the time to do a thorough and complete GP that would minimize the risk of litigation challenging the GP. A proper GP would also minimize the risk to citizens from poorlydocumented hazards such as fire, flooding, landslides, erosion, and sea level rise. See Example 4 below for how and why the city could go broke without resilient/adaptation alternatives and long-term planning that is not now included in the GP/DEIR.

ALERT: Read Pacifica’s responses to the CCC’s suggestions. Our city council shows no intention of following the California Coastal Commission’s (CCC) guidance.

Hazards are adequately
documented in the DEIR, please
see response to comment C22-10
for adequacy of mapping.

C122-5 Stan Zeavin
& Linda Mar
3/7/22 Example 1 of short-term planning Traffic and Transportation Pacifica can only handle so many car trips in a day. Yet, the The comment is noted.

Congestion and transit adequacy

1.f
Packet Pg. 1237 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4998 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 573
Letter Commenter Date Comment Combined Response
Individuals (C)
previous GP draft had a potential of up to 750 new units up for development, including hotel rooms, condos, apartments, and homes. Now, the Quarry has been added and one can assume that others spots will be. There could be between 800-900 or more possible new units. While the city has a formula for how many car trips there are in a day per type of unit, I couldn’t find a discussion about what the number of units should be to be able to keep congestion at certain levels. This would allow the city to stop development at a preferable level of traffic control.

NOTE: It should be noted that appreciably improving the traffic patterns won’t be possible. A few years ago, a previous city council attempted to widen Highway 1 between
Rockaway/Fassler and Reina Del Mar/Vallemar from four lanes to six. CalTrans wrote the plan. The bottom line was that even with a $60M grant, there would be about 1.5 minutes saved in the morning rush and around 2.5 minutes at night --rush hour traffic wouldn’t change much, no matter how many lanes that part of Highway 1 was widened. A federal court decision resulted in CalTrans shelving the plan.

Pollution levels rise as traffic level rises. Let’s remember that most of us live in valleys. That means that we will be breathing more CO2 the more cars we have sitting at stop lights. The ocean winds will simply push the CO2 back into the valleys.

We need a sane limit on the building height. The city currently has a height limit of 35 feet. The Sharp Park Specific Plan has provisions for 5-story buildings. How high does the city want new buildings to go? More height means even more units.

More units equals more traffic. Most people in Pacifica would prefer to keep the small town feel that we have now. That means real height limits.

With SB9 and SB10 the future shows less local control on the number of units. This is a wildcard at this time but it bodes ill for traffic control. This legislation needs to be addressed in the GP and DEIR.

Having a first class bus system for Pacifica is necessary but it is not enough. The city is saying more people will use a good bus system. But we don’t know what the percentage might be. This improved bus system has to be in place before any large-scale development takes place so that the city can manage any growth through observing the actual number of people using the bus system.
are not required topics for CEQA
analysis. Buildout under the
Proposed Plan, including visitor
serving commercial buildout at
the Quarry, is included in VMT
analysis and GHG emissions in Ch

3.4, and with less than significant
impacts with mitigations
concluded.

Highway 1 remains under the
jurisdiction of Caltrans, which is
beyond the City's sole scope of
authority to mitigate. As noted
on DEIR p. 3-29, C/CAG is
primarily responsible for
administering the Statemandated Congestion
Management Program (CMP).

The C/CAG-designated CMP
roadway system components in
Pacifica include Highway 1 (SR 1)
and Skyline Boulevard (SR 35).

C/CAG’s LOS standard for
roadway segments on these
roadways is LOS E or better. With
buildout of the General Plan,
none of the intersections along
these two CMP roadway
segments would operate at LOS E
or LOS F. Congestion threshold
are not yet exceeded right now,
therefore it is appropriate to
monitor and proactively
coordinate with Caltrans until
thresholds could potentially be
reached. Potential improvements
to the roadway network could
contribute to mitigating the
impacts of GHG and air quality, as
described in Table 3.4-3,
including policies listed on 3.4-31
and 3.4-32 related to pedestrian
improvements and increased
connectivity, streetscape
improvements and traffic calming
measures, transit service, trip
reduction programs, a clean city
fleet, increased density and
affordability, reduced parking,
water conservation, and waste
reduction.

The comment also refers to
height limits and increased
traffic; height is not directly

1.f
Packet Pg. 1238 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 4999 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 574
Letter Commenter Date Comment Combined Response
Individuals (C)
associated with density, and units
that could reasonably be
expected to develop in these
areas are included in buildout
projections. The comment
addresses the content of the
Proposed Plan and will be shared
with decision-makers in that
context. Please see Master
Response: EIR comments for
more information about GP- or
SPSP-related responses.

C122-6 Stan Zeavin
& Linda Mar
3/7/22 Example 2: The GP is putting the desires of the developers above safety of its citizens.

The GP is putting the desires of the developers above safety of its citizens. The CCC upheld an appeal to a nine-unit project the city approved at 1567 Beach Blvd. This is one of several successful appeals. The commonality among these appeals is the city’s rubber stamping the developer’s reports which contained misinformation and faulty science. Just a few further examples:
• claiming the retaining wall had 40 more years of life when a simple visual of the wall showed advanced fissures;
• claiming it will be years before the overtopping by waves will reach 70 feet inland while the locals had many photographs of several storms with overtopping already at the 70-foot mark; • not even following the 1980 LCP (the active LCP at this time).

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

Potential impacts and regulations
and policies that reduce impacts
from hazards are found in DEIR
chapters 3.5, 3.6, and 3.11.

These projects may, however,
use the discussion of impacts in
this EIR as a basis of their
assessment of these regional,
citywide, or cumulative impacts.

As the commenter notes, the
Coastal Commission has
permitting jurisdiction for areas
in the Coastal Zone. Please see
Master Response 1: EIR
comments for more information

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Packet Pg. 1239 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 5000 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 575
Letter Commenter Date Comment Combined Response
Individuals (C)
about GP- or SPSP-related
responses.

C122-7 Stan Zeavin
& Linda Mar
3/7/22 Example 3: GP’s lack of information updating makes fact-based planning impossible
The use of obsolete studies and information can be found throughout the GP. One person who has been taking a close look at our GP stated that he couldn’t find any studies dated later than 2013. The lack of updating is inexcusable.

The latest Climate Change information is being ignored. The proposed armoring in front of Beach Blvd. is based on outdated information. The newest studies show: Rising temperatures are accelerating water movement between land, ocean and clouds.

Water moves from dry regions to wetter ones with 2-4 times the speed of what models had projected. This movement
creates both more storms and stronger storms (Nature).

Therefore, the old 100- year storm concept is obsolete.

NOTE: Among many relevant current studies that any due
diligence would have turned up, the latest NOAA/USGS
predictions have SLR up to 7 feet by 2100 Both the Pine Island and neighboring Thwaites Glaciers in Antarctica are speeding up due to the melting of the ice shelf that supports them
(Washington.edu/news, Hannah Hickey). Methane gas has been photographed leaking into the atmosphere in the melting northern tundra (Nova).

The DEIR uses the latest and best
publicly available information for
analysis. While coastal storms are
not a required topic for CEQA
analysis, flooding is a required
topic. Coastal flooding is
described on DEIR p. 3.5-8. In
2018, the City of Pacifica
prepared a Sea Level Rise
Vulnerability Assessment using
the best available science. The
2021 MJ-LHMP, incorporated by
reference, contains updated
information about climate
change.

C122-8 Stan Zeavin
& Linda Mar
3/7/22 Risk of extreme wildfires will increase 14% by 2030 and 30% by 2050 (U.N. Environment Program report). This report also states the U.S. has invested $50 billion over the next decade to aggressively thin forests around “hot spots” where nature and neighborhoods collide. If grants are available, Pacifica should apply for one. Also, the latest West Coast Plover Conference has reported that coastal fog has decreased 30%. We can’t expect fog protection for our highly burnable Eucalyptus trees as we go into the future. We need serious wildfire alternatives AND escape routes other than Highway 1.

The comment is noted. Analysis
and policies related to
impairment of an adopted
emergency response plan or
emergency evacuation plan
evacuation are described in
Impact 3.11-1. Please see also
Master Response 5: Wildfire and
Master Response: Evacuation.

C122-9 Stan Zeavin
& Linda Mar
3/7/22 Habitat studies in the GP are poorly done with most being outdated. As an example, the grasslands study in the GP was completed in 1992! There is no way to make any serious
decisions using this type of data.

The DEIR uses the best and latest
available data from credible
government sources, such as
from the California Department
of Fish & Game; California
Department of Forestry; National
Wetlands Inventory, U.S.; and
Fish and Wildlife Service National
Wetlands Inventory and the U.S.

Fish & Wildlife Services, at the
appropriate scale of a
Programmatic EIR for a General
Plan. Please also see response to
comment C1-7. The basis for the
vegetation classification system
utilized in this analysis relies on
the currently accepted California
Department of Fish and Wildlife

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Packet Pg. 5001 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 576
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Individuals (C)
List of Vegetation Alliances and
Associations (also known as the
Natural Communities List). Plant
communities generally correlate
with wildlife habitat types, and
these typically are classified and
evaluated using CDFW’s
California Wildlife Habitat
Relationship classification
system. The supplemental
grasslands data from 1992
represents a relevant,
comprehensive study conducted
by a biologist for the purposes of
the City's trail master planning
effort at a scale appropriate for a
programmatic DEIR.

C122-10 Stan Zeavin
& Linda Mar
3/7/22 Example 4: The city could go broke without resilient/adaptation alternatives and long-term planning included in the GP/DEIR The cost of armoring is prohibitive. Who pays the difference if the grants don’t cover the cost? Initial prices range from $48M to $111M with expected costs through the 50-year life running from $102M to $235M. Anyone who has dealt with these kinds of numbers knows that by the time final cost is computed, it could well be double the original figures. If you consider the GP’s business plan which includes growth in the coastal zone including flood zones, Pacifica will need a beach for tourism to thrive. With armoring, our present beach will disappear, which will create a need for sand nourishment and possibly groins.

There was a sediment study, authorized by the state, which included Pacifica about 6-7 years ago headed by the Army Corps of Engineers and included various local scientists and engineers.

The study concluded that, depending on the angle of the tide, sand nourishment would need to be replenished every 5 to 18 years and groins would be out of Pacifica’s price range. What this implies is that for a 50 year wall, you would have to replenish the sand, at a minimum, three times. The price would be prohibitive and it will continue to go up. Under the circumstances, can Pacifica afford more than one
replenishment.? Will the tourists come without a beach? Where are the alternatives, or will the citizens of Pacifica end up shouldering a large part of the cost surrounding the proposed wall/hybrid system?
With over 4000 miles of coastline in the U.S., Pacifica is nowhere near the top of the climate change food chain when it comes to grants. Even with the majority of hurricanes, along with serious SLR issues on the east and south coasts, Pacifica can certainly still get some grants at this time. But, even in our own county, we on the coast
take second place to the bigger population on the bayside. It seems unlikely that Pacifica can get the number of grants to survive the cost of the GP’s plans.

The comment is noted. Coastal
armoring is addressed in the
LCLUP and not required for
analysis under CEQA. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR, no
further response is required.

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

C122-11 Stan Zeavin
& Linda Mar
3/7/22 Experts say the key to long term planning is a functional Resiliency Policy. There is no actual Resiliency Policy in the This comment is related to
policies in the LCLUP. The LCLUP

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Packet Pg. 1241 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 5002 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 577
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GP/DEIR. A Resiliency policy infers a certain flexibility, such as managed retreat (landward relocation if you prefer) and other adaptations. However, , most of the alternatives in what is called the GP/DEIR Resiliency Policy fall into the Resistance category, e.g., walls, etc. The major reason for this manipulation is to prevent lowering the value of existing structures, i.e., privately owned residences?, in the flood zone. What this means is the LCP will not be acceptable to the CCC; all the alternatives are expensive; and there are no fiscally reasonable contingencies in place.
is not addressed as part of this
DEIR.

C122-12 Stan Zeavin
& Linda Mar
3/7/22 Sea Walls are Not the Answer:
• Given the latest Climate Change information, a good case can be made that the Beach Blvd. wall will not be effective for its expected lifetime. The wall is built to last 50 years, but this assumes that the SLR stays below 2.5 feet and one 60- year storm. But by not considering other, less optimistic scenarios, the people on Beach Blvd. could be put in a position of extreme danger. Though there are trigger points in place, it is inexcusable not to have a fallback plan in place that won’t cost an arm and a leg in case of an emergency. And who will pay? • The wall can’t be built to protect new development. The wall is being rebuilt to protect the Sharp Park sewer system. But the CCC has stated that all new development along the coast will be considered as if there is no sea wall. In the Sharp Park workshops the vast majority of the time was not spent on aspects of the sewer system and other issues, but on the desire for development. What if the development plan runs into approval problems? Pacifica will, in all probability, be responsible for all future upgrades to the infrastructure (not necessarily the original build) and removal of the new buildings when the time comes (it’s probable that businesses will dare Pacifica to sue them, even if it’s written into the contract with the city that the business is responsible for the building’s removal). It could be big money for the real estate industry and disaster for Pacifica.

NOTE: The DEIR, Doc p. 9 & 10 – New development that would require the use of seawalls or other shoreline alterations for protection either now or in the future shall not be permitted unless this would make the property undevelopable. New
coastline alteration is……permitted only where necessary to protect existing
development or public resources, and must minimize adverse impacts to natural coastal processes..

Notice that the above two sentences are contradictory.

It is unclear which sentence this
comment refers to. If commenter
is referring to "Within the Coastal
Zone, the City requires new
development to be set back from
coastal bluffs enough to
accommodate a 100-year event,
whether caused by seismic,
geotechnical, or storm conditions
(unless this limitation makes a
property undevelopable)" (DEIR
p. 3.6-17). This statement comes
from Pacifica's currently certified
LCP.

C122-13 Stan Zeavin
& Linda Mar
3/7/22 The Sharp Park sewer system services 40% of Pacifica, the proposed sea wall will protect around 5% of Pacifica’s
population. The plan is to do the upgrade to the sewer system during the life of the wall with most of the work being done near the end of the wall’s existence. With SLR there is a possibility of a storm emergency at any time, including wall failure. With a pump failure, waste backup could reach every corner of the sewer system. Even with triggers and a plan in place by that time, it would take years to add details to finish the plans, raise the money, and actually complete moving the The comment is noted. See
response to comment C9-2.

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Individuals (C)
sewer system landward. By waiting so long to complete the rebuild the cost could double or triple what it would cost if done in the near future.
o ALERT: The CC is going to vote on using increased fees from the sewer system. It is not clear where the money will go.

C122-14 Stan Zeavin
& Linda Mar
3/7/22 The Linda Mar sewer and storm water drain systems are being refitted with pipes recommended in a ten year plan that is now eleven years old. The people who live on Anza, the first street east of Highway 1, have experienced sewage bubbling up from the sewers several times in the last 15 years. We can agree that this is unacceptable. After the storm, late last year, it was reported that there was close to 7” of rain in a 24 hour period.

The 17 million gallons processed plus the 2.9 million gallons dumped into the ocean essentially, the 20 million gallons of the projected capacity of the Calera Creek water recycling plant AFTER the larger pipes are installed. The Master Plan uses the same design rainfall event as used in the 2011 Master Plan, with a 24 hour total of 3.74”. Last year’s rainfall is close to double the design rainfall event of the Master Plan. With the latest Climate Change information, we can assume that the
probability of other storms this big or bigger is high.

Recalculating the numbers before installing pipes that might have to be replaced sooner rather than might have saved the city serious money.

The comment is noted. See
response to comment C9-2.

C122-15 Stan Zeavin
& Linda Mar
3/7/22 CONCLUSION:

The GP/DEIR/SPSP needs a refocusing of its economic priorities.

Most of the visible economic energy in the GP/DEIR is aimed at financing the sea wall and development. As mentioned earlier, there are serious potential roadblocks to both. With very little discretionary money available in our city, the losers are other big ticket issues such as the Sharp Park sewer system and help for the increased wildfire dangers. The longer these items are ignored, the higher the price for a fix gets for Pacifica. Other issues, such as the Linda Mar sewer and rainwater systems could cost Pacifica serious added expense due to
mismanagement and duplication. Building in a flood zone will, again, cost Pacifica dearly in the long run. Without
contingencies based on resiliency, Pacifica’s choices are very limited, and the ability to react quickly and correctly in an emergency decline. I recognize that there is a strong
commitment to the priorities as they stand in the GP/DEIR, so I ask that if the city do nothing else, please add in the appropriate places (I’d be glad to help) alternatives based on real resiliency solutions. This would make life much easier and, hopefully, cheaper for the coming generations. Lastly, if money is not there for serious armoring, should the city put up a retaining wall north of the pier and use the money saved and refocus the grant search to start/complete the Sharp Park Sewer System reconfiguration?
The comment is not related to
the adequacy of the DEIR,
therefore no further response is
required in the FEIR. However,
the comment addresses the
content of the Proposed Plan and
will be shared with decisionmakers in that context. Please see Master Response 1: EIR
Comments for more information
about GP- or SPSP-related
responses.

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Packet Pg. 1243 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 5004 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 579
C123: Brian Gaffney,
Letter Commenter Date Comment Combined Response
Individuals (C)
C123-1 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 This office represents the Pedro Point Community Association and its members in regards to the City
of Pacifica’s General Plan Draft January 2022 (“2022
GP Update” or “Project”) and the Pacifica General
Plan Update Draft Environmental Impact Report
(“2022 Draft EIR” or “DEIR”). Attached hereto
please find specific comments about the 2022 Draft
EIR’s compliance with CEQA (the California
Environmental Quality Act), Public Resource Code
§§ 21000 et seq. and the CEQA Guidelines, and
inadequacies in the 2022 GP Update.

The 2022 Draft EIR falls short of CEQA’s
requirements as it
(1) fails to include an adequate project description,
(2) improperly segments the project,
(3) fails to include an adequate environmental
setting description, (4) fails to adequately analyze
Project impacts,
(5) fails to adequately analyze mitigation measures,
and
(6) fails to integrate required Coastal Act and other
statutory environmental analysis with this CEQA
process.

Thus, the 2022 Draft EIR does not include sufficient
information to foster informed public participation
and to enable Pacifica decision makers to consider
the environmental factors necessary to make a
reasoned decision about the proposed 2022 GP
Update.

Because the 2022 Draft EIR is fundamentally
inadequate, meaningful public review and comment
are precluded. Once the DEIR is fixed it must be
recirculated for further public and agency review
and comment.

Please include this office in further communications
regarding this proposed project and environmental
review. Please provide us with copies of a
Recirculated Draft EIR and the Final EIR for this
proposed Project.

The commenter's assertion the project fails to
include an accurate project description is
incorrect. Section 15124 of the State CEQA
Guidelines defines the types of information
that should be included in a project
description, including a map of location and
boundaries (Figure 2.1-1, 2.1-2 and Figure 2.1-
3); statement of objectives (DEIR p. 2-2, 2-9
through 2-11); a general description of the
project’s technical, economic, and
environmental characteristics (DEIR p. 2-1, 2-2,
2-6, and 2-7); and a statement briefly
describing the intended uses of the EIR (DEIR p.
1-5). The project description includes an
estimate of how much buildout is expected to
occur as result of implementing the Proposed
Project (DEIR p. 2-22 and 2-23 ) and where this
development would likely occur, as much of
the residential and nonresidential
development would occur, corresponding to
Figure 2.2-1. Project-specific detail is not
required for descriptions of general plans and
other high-level programs as details about
specific subsequent projects typically are not
known and will be addressed in future projectspecific CEQA documents. Thus, the project description is adequate. Please also see
response to comments 123-2, 3, 4, 5, and 6.

The commenter's assertion that the DEIR
segments the project is incorrect. The DEIR
does not segment the project; it analyzes the
effects of implementation of the land uses and
buildout estimate under the Proposed Plan.

Please see Master Response 3: Buildout and
RHNA for more information. See also
responses to C123-3, and 4.

The commenter's assertion that the DEIR
environmental setting description is
inadequate is untrue. The DEIR includes an
adequate environmental setting description. It
describes the existing local and regional
physical environment, as it existed when the
notice of preparation of the EIR was published
in September 2020. This specific comment
does not highlight any specific examples of
inadequate environmental settings. Please see
response to comments 123-7 through 123-13.

The commenter's assertion that the DEIR does
not address Project impacts is untrue. The DEIR
adequately addresses Project impacts for each
of the required topics under CEQA. The DEIR

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analyzes the impact of the policies by focusing
on where and what type of development the
plan would allow. The DEIR adequately
analyzes how compliance with State, regional,
and local regulations, as well proposed policies
under the Proposed Project, may or may not
reduce CEQA impacts of significance. Then it
also considered the beneficial impacts of the
policies and the extent to which they would
reduce or avoid impacts in conjunction with
existing regulations. As a programmatic
document, this EIR presents a citywide
assessment of the potential impacts of the
proposed Pacifica General Plan. It does not
assess project-specific impacts of potential
future projects under the proposed Plan, all of
which are required to comply with CEQA as
applicable. Please also see response to
comments C123-14 through 33.

The commenter's assertion that the project
does not adequately analyze mitigation
measures is untrue. Please see response to
comments C34 through 40.

The commenter's assertion that the DEIR fails
to integrate required Coastal Act and other
statutory environmental analysis is untrue. The
DEIR analyzes potential impacts due to sea
level rise, coastal erosion, sensitive habitat,
and other impacts and identifies regulations
and policies that could reduce any potential
significant impacts. Coastal Commission
permitting authority is referenced in
subsequent chapters. As noted on p. 2-7, Local
Coastal Plans (LCPs), which include Local
Coastal Land Use Plans (LCLUPs), are not
subject to CEQA. LCP amendments are exempt
from CEQA because the Coastal Commission
LCP certification process is “functionally
equivalent” to the CEQA process (State Public
Resources Code Sections 21080.5 and 21080.9,
and State CEQA Guidelines Sections 15250,
15251(f) and 15265). Therefore, the LCLUP for
Pacifica is not analyzed under this EIR. Please
see response to comments C123-41 through

59. This information, coupled with the extensive
number of public comments on the DEIR,
indicate that there has been sufficient
information to foster informed public
participation. Responses to these comments
and subsequent DEIR clarifications will enable
decisionmakers to make reasoned decisions.

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Packet Pg. 1245 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 5006 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 581
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Individuals (C)
C123-2 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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-Glendale- Pasadena
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.

The General Plan Land Use Diagram is shown in
Figure 2.2-1; the following clarification is
made: “Figure 2.32-1 shows the General Plan
Land Use Diagram.”
C123-3 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 nonresidential development that could be built under Please see response to comment C4-1 and
Master Response 3: Buildout and RHNA for
more information on adequacy of buildout
projections. Please also see response to
comment C123-22.

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Individuals (C)
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.

C123-4 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 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 Statemandated 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
Separately, the City is preparing to initiate its
6th cycle Housing Element update. The
Housing Element update and development of
the required housing sites inventory will
involve extensive community input and be
subject to separate CEQA review. The Housing
Element CEQA document will analyze the
cumulative effects of implementing the
Housing Element Update – including associated
changes to the land use diagram - in
combination with the Proposed Plan.

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

Buildout and RHNA for more information.

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Letter Commenter Date Comment Combined Response
Individuals (C)
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.

C123-5 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

The commenter's assertion that the DEIR does
not include narrative explanation on where
land uses change is incorrect. As noted on DEIR
p. 3.1-20, the “Proposed Project includes new
land use designations that replace older and
more generic land use designations in the
same or nearby areas; the new land use
designations accommodate more diverse
housing types, densities, and commercial
developments, primarily in already-developed
areas. There are three mixed use classifications
to create areas where housing and active
commercial uses may be integrated.” As shown
in Table 2.4-2, approximately 76 percent of
new units are projected to occur in these new
mixed use classifications, shown in Figure 2.2-

1. Thus, these new land use categories clearly
designate where new development will occur.

The remaining units would be accommodated
in smaller vacant “infill” lots found primarily in
the West Sharp Park, East Sharp Park,
Westview-Pacific Highlands, Rockaway, and
Pedro Point neighborhoods; these vacant
parcels are shown on the existing land use
map, Figure 3.1-1. Given environmental factors
such as slope and sensitive species, there are
some constraints on the development
potential of these sites.

Further, the City notes that buildout
projections were calculated on a parcel basis to
provide a reasonable estimate of the location
and extent of growth under the Proposed
Project for the purpose of evaluating
environmental impacts; however, the
assumptions for particular sites do not
guarantee that any given site will be developed
or redeveloped with that use or assumed
density during the planning period, as future
development will rely primarily on each
property owner’s initiative. Cumulatively
though at the citywide level these projections
represent a reasonably foreseeable basis for

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assessing the environmental impacts that
could result from Proposed Plan
implementation. Therefore, the DEIR correctly
used a reasonably foreseeable forecast of
buildout under the Proposed Plan as the basis
for the environmental analysis.

As shown in the Land Use Diagram, the Coastal
Residential Mixed Use Designation is only
shown in southern Pacifica for undeveloped
San Pedro Avenue site and adjacent parcel.

This classification permits 10 to 15 du/ac, as
described in the land use classifications. To
identify areas of possible change, vacant and
underutilized parcels were identified, and
capacity was projected based on economic and
market conditions, historical growth trends,
and approved development in the pipeline.

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

C123-6 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

This comment is untrue, Coastal Act
compliance is described on DEIR p. 2-6 and 2-7.

C123-7 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
The DEIR includes an adequate environmental
setting description. It describes the existing
local and regional physical environment, as it
existed when the notice of preparation of the
EIR was published in September 2020. This
specific comment does not highlight any
specific examples of inadequate environmental
settings or comparisons to the 1980 plan.

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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 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.

C123-8 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

Please see response to comment C34-8.

Vegetation and habitats at the Pedro Point site
are shown in figures 3.7-1 and 3.7-3,
respectively.

C123-9 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
See Master Response 2 regarding the
programmatic nature of the DEIR. Existing
baseline hydrology and flooding conditions are
also described under the Environmental
Setting section starting on page 3.5-1 of the
DEIR.

As shown on Figure 3.5-1, page 3.5-3 of the
DEIR, the site is not in a FEMA identified special
flood area, however it is subject to localized
floods as noted on page 3.5-8 ‘The broadest
mapped flood hazard areas are located along

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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.

San Pedro Creek, covering much of the Linda
Mar area north of the creek extending down to
the coast. A broad 0.2 percent annual chance
flood area is mapped at the confluence of the
main stem with the North Fork of the San
Pedro Creek.’
Figure 3.5-1 was created based on the
following sources:
-The latest tsunami evacuation zone data
which is available at the City's website
(https://www.cityofpacifica.org/civicax/fileban
k/blobdload.aspx?BlobID=2499),
-As well as the National Flood Hazard Layer for
San Mateo County mapped by the Federal
Emergency Management Agency (FEMA).

As noted on DEIR p. 3.5-20, "potential impacts
associated with implementation of the
Proposed Project include increased rates of
storm water runoff and subsequent flooding
hazards, erosion, increase in nonpoint source
pollutants affecting receiving water quality,
and coastal erosion and flooding that may be
intensified by sea level rise. These impacts
would be reduced to less-than-significant
levels through regulatory compliance and with
implementation of proposed policies." The
DEIR describes how "adherence to the
Construction General Permit under the NPDES
program would require that a SWPPP with best
management practices (BMPs) be prepared for
construction sites; it would include measures
to protect water quality of stormwater that is
discharged offsite and practices to limit erosion
or unintentional releases of hazardous
materials used during construction.

Additionally, any development that would
occur under the Proposed Project would be
subject to the erosion and runoff control
provisions described in the regional Basin
Plan." Based on analysis under Impact 3.5-3
starting on page 3.5-29, implementation of
existing local regulations and compliance with
the following proposed General Plan policies,
the impacts of the Proposed Project related to
the alteration of drainage patterns, flood flow,
stormwater runoff, and exceeded capacity of
stormwater drainage systems would be less
than significant. See policies CO-G-1, CO-G-2,
CO-G-3, CO-G-4, CO-G-6, CO-I-1, CO-I-2, CO-I-4,
CO-I-5, CO-I-7,CO-I-9 through CO-I-16, CO-I-23,
CO-I-24, CO-I-25, CO-I-38, CO-I-46, CO-I-47, COI-58, CO-I-63, SA-G-4, SA-G-5, SA-I-11, SA-I-12, SA-I-15, SA-I-17, SA-I-18, SA-I-19, SA-I-20, SA-I1.f
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22, SA-I-23, SA-I-24, SA-I-25, SA-I-28, SA-I-30,
SA-I-79, and SA-I-86.

C123-10 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

Average household size uses updated data
from 2014-2019 American Community Survey.

C123-11 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

Thank you for this comment. The correct
number, 41,050, was used as part of project
analysis. The buildout population is amended
on p. E-4 as follows to reflect the buildout
number: 41,28041,050. This does not change
findings of significance.

C123-12 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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).

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

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

C123-13 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
The environmental baseline information in the
DEIR represents an adequate assessment of
environmental settings for CEQA-required
topics. Each of these topics mentioned does
not relate to required topics of CEQA analysis.

Please also see Master Response 2:

Programmatic EIR for more information about
the scope and requirements of a programmatic
EIR.

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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.

C123-14 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 decisionmakers 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
This background information is noted. Please
see responses to comments 123-15 to 123-40.

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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:

C123-15 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 redlegged frog movement from reasonably foreseeable Project development at the San Pedro Avenue site.

Concerns about impacts to biological resources
are mentioned in Areas of Known Controversy,
Biological Resources, DEIR p. E-8. While
findings from the Coastal Commission were not
a matter of public record until after publication
of this DEIR's NOP, Master Response 6: ESHA
for more information, as well as Master
Response 4: Undeveloped San Pedro Ave Sites,
describes the disagreement among experts
about this site, as well as any policies, coupled
with Coastal Act, FESA, and CESA, would
reduce potential impacts to less than
significant.

C123-16 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

As noted on DEIR p. E-1, "This EIR is a program
EIR that examines the potential effects
resulting from implementing designated land
uses and policies in the proposed General Plan.

The impact assessment evaluates the General
Plan as a whole and identifies the broad,
regional effects that may occur with its
implementation. This EIR presents a citywide
assessment of the potential impacts of the
proposed Pacifica General Plan."
"Implementing designated land uses" includes
CRMU. For all sections of analysis, the DEIR
considers where existing vacant land uses
would change. As described in DEIR p. 2.1-18,
the DEIR "compares the Proposed Project land
use diagram to existing land use conditions to
determine whether implementation of the
Proposed Project would trigger any impacts."
For example, as noted on DEIR p. 3.7-61,
"Development at the undeveloped San Pedro
site could potentially result in indirect impacts
to the wildlife utilizing nearby creek habitat.

This includes the possibility of fuel spills and/or

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leaks which could make their way into the
riparian corridor of San Pedro Creek." Please
see Master Response 4: Undeveloped San
Pedro Avenue Sites for more information
about impacts of CRMU, in addition to how
different land uses on the site were compared
in the Alternatives.

As a program EIR, the preparation of this
document does not relieve the sponsors of
specific projects from the responsibility of
complying with the requirements of CEQA. As
noted, individual projects are required to
prepare a more precise, project-level analysis
to fulfill CEQA requirements. The lead agency
responsible for reviewing these projects shall
determine the level of review needed, and the
scope of that analysis will depend on the
specifics of the particular project. These
projects may, however, use the discussion of
impacts in this EIR as a basis of their
assessment of these regional, citywide, or
cumulative impacts.

C123-17 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
Guiding policies are analyzed to the extent that
they may reduce impacts of required CEQA
topics.

CEQA analysis must occur for any known
improvements; the arrangement of any road
widening is not known at this time, and a
contingency plan for alternative access already
exists as part of the All Hazards and Evacuation
Plan. As a programmatic document, this EIR
presents a citywide assessment of the
potential impacts of the proposed Pacifica
General Plan. It does not assess project-specific
impacts of potential future projects under the
proposed Plan, all of which are required to
comply with CEQA as applicable.

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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.
addresses impacts to VMT, air quality, and
stormwater at the programmatic level.

Description of how Compact Mixed Use
Development (LU-G-6) would not physically
divide an existing community is described on
DEIR p. 3.1-20, "the Proposed Project provides
concentrated and compact development
primarily in already developed areas, with
policies to provide more linkages and
enhanced connectivity within and between
those areas."
Compact, Mixed Use Development is also a
strategy used to reduce greenhouse gas
emission and VMT. As described in DEIR p. 3.4-
57, "Sustainable Communities Strategies
policies include a mix of strategies that
encourage compact growth patterns, mixeduse design, alternative transportation, transit, mobility and access, network expansion,
transportation investment, and environmental
justice." As noted on the same page,
"Consistent with MTC goals, the Proposed
Project would... increase mixed-use
development. The land use design,
transportation
network promotion, and transit facility
enhancements would help reduce vehicle trips
and support alternative transportation."
As noted in the DEIR p. 3.9-14, Policies in the
Proposed General Plan that ensure that new
development achieve a high standards of visual
quality consistent with existing regulations
governing scenic quality include use of the
City’s Design Guidelines in evaluating proposals
(CD-I-4) and providing updated, illustrated
Design Guidelines for multifamily and senior
housing (CD-I-5) and for commercial and
mixed-use building form (CD-I-7).

C123-18 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
The fifth paragraph on page 3.5-21 of the DEIR
states that existing local stormwater
management plans and policies, and State
Water Board regulations, which implement
federal Clean Water Act requirements, would
prevent these potential impacts from rising to
a level of significance under CEQA through
requirements that minimize the creation of
pollution generating surfaces. Clean Water Act
Section 402 NPDES MS4 Permit, which covers
many Bay Area jurisdictions including the City
of Pacifica, requires stormwater management
plans, which in turn require source and
treatment control measures. In many cases, as

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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.
part of the NPDES program to reduce the
severity of impacts, stormwater drainage
control/Low Impact Design (LID) measures may
be required as standard conditions of approval
and building permit application submittals,
along with compliance with RWQCB Municipal
Regional Stormwater Permit Order No. 2011-
0083 Provision C.3 (Provision C.3).

As required by Provision C.3, for new
development that would introduce 10,000
square feet of new impervious surfaces, a
project applicant would incorporate LID
strategies, such as stormwater reuse, onsite
infiltration, and evapotranspiration as initial
stormwater management strategies.

Ultimately, adherence to stormwater control
measures as part of the Municipal Regional
NPDES stormwater permit, a SWPPP prepared
as part of the General Construction Permit, and
improvements under the Proposed Project
would minimize the water quality impact to a
less-than-significant level. The Proposed
Project strengthens these provisions through
policies in the Safety Element requiring grading
and drainage plans for proposed developments
requiring a grading permit, minimizing erosion
risk, and enforcing NPDES permits. In addition,
compliance with the Proposed Project policies
set would ensure the impact to water quality is
less than significant. Please also see Master
Response: Undeveloped San Pedro Avenue
Site.

C123-19 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
See Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro Ave Sites
for more information. On DEIR p. 3.7-50,
presence of special status species near San
Pedro Creek is noted: "This analysis addresses
species that are either known to occur or are
highly likely to occur within the key sites and
Planning Area"; occurrence of California redlegged frog is also shown on Figure 3.7-4.

Regarding potential impacts, the following
clarification is made: "Development at the
undeveloped San Pedro site could potentially
result in indirect adverse impacts to the
wildlife utilizing nearby creek habitat."
Proposed Project policies are not intended to
act as mitigation measures; rather, they are
policy statements indicating actions the City
will take on an ongoing basis as the Proposed
Project is implemented and the DEIR has
correctly considered the effects of

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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.
implementing these policies, including any
beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project.

The General Plan and associated DEIR identifies
areas of city-wide sensitive and Critical Habitat
and general locations of Special Status Species.

The General Plan proposes numerous policies
to reduce habitat loss, as summarized noted in
responses to comments A2-4 and C46-24. The
General Plan establishes policies to protect or
mitigate sensitive species habitat, such as the
California red-legged frog, and impacts to
creek habitats. Therefore, potential impacts to
Sensitive Species or Critical Habitat will be less
than significant with implementation of the
General Plan.

C123-20 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

The comment is noted. It is reasonable to infer
the General Plan Land Use Diagram by its title.

The following clarification is thereby made on
p. 2.3-1: “Figure 2.32-1 shows the General
Plan Land Use Diagram.”
C123-21 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

The comment is noted. The following
clarification is thereby made on DEIR p.E-5:
"the Planning Area would result in a population
of approximately 41,280 41,050 people at
buildout..." The clarification does not change
any findings of significance in the DEIR.

C123-22 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 llowed 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.

The comment is noted. Project buildout under
the Proposed Plan represents an reasonable
projection and adequate yardstick for
determining the significance of CEQA impacts.

At the time of Housing Element preparation,
the City would be required to conduct
additional CEQA analysis. SB9 projects and
ADUs are speculative at this time and are
exempted under CEQA. Please see Master
Response 3: Buildout and RHNA for more
information.

C123-23 Brian Gaffney
(representing
Pedro Point
3/8/22 9) The 2022 Draft EIR references that population growth is necessary in order to meet Pacifica’s
Regional Housing Needs Assessment (RHNA)
The comment is noted. Mitigation measures in
the DEIR already reduce the impact of GHGs
within the City to a less than significant level.

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(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.

Incorporation of the additional measures
would reduce an already less than significant
impact and would, thus, not change any
findings of significance.

C123-24 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

Please see more information about the
adequacy of buildout, planning for RHNA, and
CEQA analysis in Master Response: Buildout
and RHNA
C123-25 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

Please see response to comment C123-22.

C123-26 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

As noted on DEIR p. 3.1-18, "The impact
analysis considered the full buildout of the
Proposed Project, although it is uncertain
when or if this full development would occur.

For the purposes of comparing the different
land use designations between the existing
conditions and the Proposed Project,
generalized land use categories were used."
Put simply, the tables help show where existing
land use categories might be the same (in the
same grouped category, such as 'commercial'
to 'retail commercial') or change into
something different (in a different grouped
category, such as 'commercial' to 'mixed use').

C123-27 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

The section mentioned in this comment was
taken out of context and falsely asserts the
DEIR does not identify steelhead habitat. As
noted on DEIR p. 3.7-50, "is known to spawn
along the main stretch of San Pedro Creek in
the area parallel to Linda Mar Boulevard." On
DEIR p. 3.7-49, it state "future land use
changes proposed under the Proposed Project
could impact biological sources if sensitive
natural communities, critical ahbitat, and
special-status or sensitive species are disturbed
or altered." The General Plan has multiple
policies to protect Species Status species,
which are included in Impact 3.7-1, and the
following policies specifically address the
steelhead trout habitat:

CO-G-9 Creeks and Riparian Areas. Protect

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year-round creeks and their riparian habitats.

San Pedro Creek has been designated an
“impaired waterway” by the Regional Water
Quality Control Board and provides critical
habitat to a federally-listed threatened species,
the California coast population of steelhead.
(CO-I-1) Creek Protection and Restoration.

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

Additional policies to protect Sensitive Species
and Habitat are included in Master Response 3.

The General Plan DEIR provides analysis which

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is sufficient for a programmatic EIR. Therefore,
potential impacts to Sensitive Species or
Critical Habitat will be fully mitigated with
implementation of the General Plan.

C123-28 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.)
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 tonalyze 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
The commenter's assertion of inadequate
analysis is incorrect. The DEIR analyzes impacts
of the Proposed Project, and the DEIR
evaluates the potential of beneficial policies in
the Proposed Project to reduce impacts that
could be significant. As noted on DEIR p. 3.7-
49, ''future land use changes proposed under
the Proposed Project could impact biological
resources if sensitive natural communities,
critical habitat, and special-status or sensitive
species are disturbed or altered. Potential
impacts to species are described, followed by
descriptions how land uses change in those
areas: "Red-legged frog and garter snake both
occur in Sharp Park, which would remain a
public open space managed for both public
access and natural conservation under the
Proposed Project. Both of these special status
species also occur at Mori Point, which is a
known breeding location for red-legged frog,
and which is managed for conservation with
limited public access....there are several
specific areas where proposed buildout could
adversely affect this species and its habitat.

While the great majority of Planning Area land
where special status species occur is
designated as park land or for conservation,
the Proposed Project calls for the development
of new trails. The Sharp Park Trail and an
unnamed trail that would run parallel to the
west side of Highway 1 in the southern
Planning Area near Devil’s Slide Trail, would
both occur within critical red-legged frog
habitat." The DEIR then describes how
compliance with federal, state, and local
regulations, as well as Proposed Plan policies,
reduce these potential adverse impacts to less
than significant.

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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.

C123-29 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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);
The level of detail of analysis and
programmatic nature of the DEIR is outlined in
Master Response 2. The General Plan
proposes numerous policies to reduce
potential impacts to habitat and biological
resources; at the time of a development
application, the environmental conditions will
be analyzed in coordination with applicable
habitat conservation policies as outlined in
response to comment C123-30. Thus, potential
impacts to biological will be reduced to less
than significant with implementation of the
General Plan.

The following clarifying language will be added
under Impact 3.7-2 on page 3.7-56. This does
not change the findings of significance of the
DEIR.
"Proposed Project policies ensure that
implementation would preserve and restore
steep and sensitve terrain (LU-I-14), coastal
environments and special status communities
(CO-G-8), creeks and riparian areas as habitat
(CO-G-9), wetlands (CO-I-4), and water quality
through best management practices (CO-I-11).

Therefore, compliance with the provisions of
the California Coastal Act in combination with
implementation of the Proposed Project set
forth below would help reduce potential
impacts to riparian habitat or other sensitive
natural communities to a less than significant
level."
Please see also response to comment C123-7
regarding Impact 3.7-4.

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C123-30 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 oise disturbance, increased night
lighting, harassment from pets, increased mortality
from automobiles, and increased fragmentation of
habitat. Pacifica contains habitat or several specialstatus 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.

As noted on DEIR p. 5-5, "the analysis of
cumulative impacts need not provide the level
of detail required of the analysis of impacts
from the project itself, but shall 'reflect the
severity of the impacts in their likelihood of
occurence." To rise to a level of level of
significance, the Proposed Project must result
in both a cumulatively significant impact AND
have a considerable incremental contribution.

The cumulative impacts to biological resources
analysis on page 5-7 in the DEIR takes into
consideration the land use conservation
strategies, in addition to the multiple goals and
policies to protect sensitive species and
habitats as summarized in all impacts in
Biological Resources Ch 3.7, to determine that
implementation of the Proposed Project would
reduce impacts to less than significant level.

Therefore, the Proposed Project's contribution
to this potentially significant cumulative impact
is not cumulatively considerable. The following
clarification is thereby made: "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.

However, due to the policies proposed in the
Proposed Project and Local Coastal Land Use
Plan, any development in these areas would be
required to comply with existing federal, state,
and local regulations as applicable (including
FESA, CESA, the Clean Water Act, and the
Coastal Act). Compliance with policies in the
Proposed Plan related to sensitive species,
preservation of habitat, and coordination with
the CDFW as described in Ch 3.7 reduce
impacts to less than significant; and the
Proposed Project’s contribution to this
potentially significant cumulative impact is not
cumulatively considerable.

C123-31 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 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
As stated on page 3.5-20, adherence to the
Construction General Permit under the NPDES
program would require that a SWPPP with best
management practices (BMPs) be prepared for
construction sites; it would include measures
to protect water quality of stormwater that is
discharged offsite and practices to limit erosion
or unintentional releases of hazardous
materials used during construction.

Additionally, any development that would
occur under the Proposed Project would be
subject to the erosion and runoff control

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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.
provisions described in the regional Basin Plan.

The Construction General Permit authorizes
the discharge of storm water to surface waters
from construction activities. It prohibits the
discharge of materials other than storm water
and authorized non-storm water discharges
and all discharges that contain a hazardous
substance in excess of reportable quantities
established at 40 Code of Federal Regulations
117.3 or 40 Code of Federal Regulations 302.4,
unless a separate NPDES Permit has been
issued to regulate those discharges. Please see
pages 3.5-15 and 3.5-16 for more information
regarding the requirements of the
Construction General Permit. Please see also
response to comment C123-18 regarding
NPDES regulatory requirements.

C123-32 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 Project to avoid or minimize such
impacts.
(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
Contrary to the commentor's assertion, the
DEIR discusses coastal development and
impacts.

Please see comment C69-8 for more
information on where the DEIR addresses
coastal erosion, and how compliance with
federal, state, and local regulations and
Proposed Plan policies reduce impacts to less
than significant. Please see response to
comment 13-3 for more information on sea
level rise analysis and regulations and policies
that reduce the impact, as well as policies in
the LCLUP regarding sea level rise monitoring.

C123-33 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
The commenter's assertion that the DEIR does
not properly analyze growth inducing impacts
is incorrect. As noted on DEIR p. 5-2, rather
than inducing growth, the Proposed Project
intensifies development in target areas in
order to provide its fair share of future housing
to support the Bay Area as a whole. The
environmental impacts associated with a
growth-inducing action are secondary, or
indirect, physical effects of growth. An

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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.
example of inducing unplanned growth would
be providing a large number of new jobs. As
stated on DEIR p. 5-4, "The Proposed Project
seeks to create a balanced community, with
retail uses, parks, and other features to
accommodate population growth, though since
the jobs/employment ratio is still projected to
be weighted towards jobs, any increase in jobs
in the Planning Area has the potential to
induce growth, lead to growth pressure, or
lead to pressure on services in surrounding
communities. Moreover, as discussed in
Chapter 3.1, Land Use, the Proposed Project
includes land use plans that specify allowable
residential development density in specific
locations within the city, such that unplanned
population growth would be unable to occur."
C123-34 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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,
Please see also responses to Comment C34-17
and C46-46. Proposed Project policies are not
intended to act as mitigation measures; rather,
they are policy statements indicating actions
the City will take on an ongoing basis as the
Proposed Project is implemented and the DEIR
has correctly considered the effects of
implementing these policies, including any
beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project. True, adequate mitigation measures
are described in DEIR p. 3.2-42, 3.2-43, 3.4-37,
and 3.4-38. Please also see response to
comment C46-30.

Policies LU-G-7 and LU-G-10 represent guiding
policies. As noted on DEIR p. E-4, "Guiding
policies define an ideal future related to the
public health, safety,
or general welfare of the community; they set
directions for policies. Implementing policies
are specified ends or conditions that are an
intermediate step towards attaining a goal;
they are specific statements to guide decisionmaking." Discretionary projects are required to make findings of general plan consistency, and
ministerial projects are also checked for
consistency.

The following clarifications are made to p. 3.7-
51; they merely serve to amplify and clarify

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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 cryptic 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-I-27, CO-I-33, and CO-I-42.
findings of significance. For specific
development projects under the Proposed
Project, consultation may be required with
USFWS by FESA, and/or with the California
DFW by CESA. Prior to project construction
under the Proposed Project, the applicant
would be required to conduct biological
resource assessments and pre-construction
plant and wildlife surveys at development
sites. Compensatory mitigation would also be
required in order to offset the loss of or
alteration to special status species’ habitat.

Implementation of the following Proposed
Project policies would reduce potential impacts
to special-status species to a less than
significant level. Policy LU-G-7, CO-G-8, and
CO-G-9 sets forth the City’s vision and
commitment to preserving areas that support
critical wildlife habitat and special status
species and communities, including creeks and
hillsides; discretionary projects would be
required to make findings of General Plan
consistency. Policies CO-I-1, CO-I-2, and CO-I40 describe how creeks, waterways, and wetlands will be protected and impaired
waterways to reduce adverse effects, including
through required minimum setbacks,
controlled runoff and wastewater reclamation.

Policies CO-I-43 and CO-I-44 describe how the
City will seek public acquisition of land of
conservation easements to optimize habitat
protection, particularly for the CRLF and SFGS.

Other specific activities to reduce adverse
effects either directly or through habitat
modifications include policies that relate to
construction or new development, including
CO-I-27, CO-I-37, CO-I-28, CO-I-29, CO-I-35, COI-36, and CO-I-37. These policies prohibit development in critical habitat and require
biological resource assessments and surveys.

Together with federal, state, and local
regulations, policies in the Proposed Project
reduce the impacts to special status species to
a less than significant level." This addition only
clarifies how the policies reduce impacts and
does not change findings of significance in the
DEIR.

CO-I-27 (Protection of Biological Resources
with New Development) and CO-I-33 (Habitat
Preservation) require consultation with a
biologist, as well as ongoing monitoring. This is
described in DEIR p. 3.7-51: "Prior to project
construction under the Proposed Project, the
applicant would be required to conduct
biological resource assessments and pre1.f
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construction plant and wildlife surveys at
development sites. Compensatory mitigation
would also be required in order to offset the
loss of or alteration to special status species’
habitat." These requirements are conditions of
project development.

Land use classifications guiding development
under the Proposed Plan are described on DEIR
p. 2-14 to 2-20; each land use classification
describes the maximum density, intensity, and
allowed uses for each category. Zoning is a tool
to implement land use, and as a general law
city, Pacifica must update its zoning code to be
consistent with an adopted General Plan. Thus,
hillside preservation update (LU-I-12), does not
represent a deferred mitigation, as the zoning
code must be updated.

Policy CO-I-42 (Regulations and Incentives to
Preserve Habitat) represent a combination of
required survey and zoning update, both of
which do not constitute deferred mitigation.

Please see responses to comments C123-35,
C123-36, and C123-37.

C123-35 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

This comment contains an error; the DEIR does
not claim that policies reduce impacts to a
level of insignificance. as noted on P. 3-41,
"proposed policies listed below would reduce
potential impacts by supporting TDM measures
and requiring that new developments prepare
transportation impact assessments to
determine project specific impacts of new
development under the proposed General Plan
such that impacts can be appropriately
mitigated. Additionally, City goals and policies
strive to develop a multi-modal transportation
network that would provide transportation
alternatives to the single-occupant vehicle and
encourage complete street design.

The City shall implement all policies identified
in the proposed General Plan Circulation
Element to reduce the demand for vehicle
travel within and through the Planning Area, as
well as work with local, regional, and state
agencies to implement regional transportation
improvements. Additionally, new
developments would be required to evaluate
their project-specific impacts on the
transportation system and fund improvements
to maintain acceptable levels of service, except
where exemptions are identified in the
Circulation Element of the proposed General
Plan. However, even with implementation of
these policies, the impact would remain
significant and unavoidable."

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On 3-42,the DEIR explains: "It is difficult to
quantify the exact reduction potential of these
mitigation measures as MM-TRA-1 applies only
to new non-residential development of a
certain size and MM-TRA-2 is a voluntary
measure. MM-TRA-2 responds to the recent
surge of remote and hybrid work schedules
following the COVID-19 pandemic. While both
measures could reduce VMT metrics, it is
unlikely that either would be sufficient in
reducing these metrics to the proposed
thresholds and the impact would remain
significant and unavoidable. Please see also
response to comment C46-30 for more
information.

C123-36 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

See responses to C123-29 and C123-30.

The following clarifying language will be added
under Impact 3.7-1 on page 3.7-51. This does
not change the findings of significance of the
DEIR.
"Proposed Project policies ensure that
implementation would protect critical wildlife
habitat and special status species and
communities (CO-G-7), creeks and riparian
areas as habitat (CO-G-9), wildlife corridors
(CO-I-31), and other environmentally sensitive
habitat areas (CO-G-11), as well as restore
creeks (CO-I-1), improve impaired waterways
(CO-I-2), and properly manage public land (COI-42). Therefore, compliance with the provisions of the Federal Endangered Species
Act, California Endangered Species Act,
Migratory Bird Treaty Act, and California State
Fish and Game Code in combination with
implementation of the following Proposed
Project would reduce potential impacts to
special-status species to a less than significant
level."
C123-37 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
This comment makes a vague assertion
without referring to specific mitigation
measures or passages in the DEIR. Please see
also responses to Comments C34-17, C46-46,
and C123-34. The DEIR identifies the potential
environmental impacts that could result from
implementation of the Proposed Project and
discusses the effects that existing regulations
and Proposed Project policies would have in
reducing or avoiding those impacts. In cases
where compliance with existing regulations
and implementation of Proposed Project
policies would not reduce a potentially
significant impact to a less than significant
level, the DEIR recommends feasible mitigation

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(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.)
measures and makes a finding of significance
after implementation of mitigation. Proposed
Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take
on an ongoing basis as the Proposed Project is
implemented and the DEIR has correctly
considered the effects of implementing these
policies, including any beneficial impacts
Proposed Projects may have for reducing or
avoiding potential impacts.

C123-38 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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, noncommittal 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,
The DEIR identifies the potential
environmental impacts that could result from
implementation of the Proposed Project and
discusses the effects that existing regulations
and Proposed Project policies would have in
reducing or avoiding those impacts. In cases
where compliance with existing regulations
and implementation of Proposed Project
policies would not reduce a potentially
significant impact to a less than significant
level, the DEIR recommends feasible mitigation
measures and makes a finding of significance
after implementation of mitigation. Proposed
Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take
on an ongoing basis as the Proposed Project is
implemented and the DEIR has correctly
considered the effects of implementing these
policies.

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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. MMGHG-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.

C123-39 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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. “MMTRA-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.

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

C123-40 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.)
The commenter's allegation that reliance on
California and federal agencies represents
deferred mitigation is untrue. California and
federal agencies that impose regulations by
law do not represent deferred mitigation.

C123-41 Brian Gaffney
(representing
Pedro Point
3/8/22 The 2022 Draft EIR Fails To Integrate Other
Required Environmental Analysis With This CEQA
Process.

To the fullest extent possible, the City of Pacifica
This comment is untrue. Although the LCLUP is
a separate planning document, the LCLUP
policies and relevant narratives are included in
the General Plan Update to ensure

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

Discussion of Coastal Act policies and
requirements occur in Chapter 3.1, Land Use
and Housing (DEIR p. 3-12), Chapter 3.5,
Hydrology and Flooding, (DEIR p. 3.5-14),
Chapter 3.6, Geology and Seismic Hazards
(DEIR p. 3.6-31), Chapter 3.7, Biological
Resources (DEIR p. 3.7-44 and 45), and Chapter

3.9-10, Visual Resources (DEIR p. 3.9-10). The
beneficial impacts of these shared policies as
they relate to reduction of potential impacts
required under CEQA, such as impacts related
to geology or hydrology, are analyzed in the
DEIR. All policies in the General Plan and the
LCLUP are indicated with a wave symbol in the
General Plan.

C123-42 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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 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
This comment is untrue. As noted on DEIR p. 2-
7, "The City of Pacifica started an LCLUP update
in 2009 and continued its work through 2014.

Between 2014 and 2018, the update work
paused. Work on the LCLUP update resumed in
2019 with a series of five community meetings
and study sessions with the Planning
Commission and City Council. On February 24,
2020, the City Council considered the PostConsultation Draft LCLUP and approved transmittal of the LCLUP to the California
Coastal Commission for review and
certification. The LCLUP was transmitted to the
Coastal Commission on June 12, 2020.

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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.)
these shared policies as they relate to
reduction of potential impacts required under
CEQA, such as impacts related to geology or
hydrology, are analyzed in the DEIR. The City
has prepared a draft of the LCP Update in
2019, approved by the City in 2020, and which
is currently under review for certification by
the California Coastal Commission.

To the extent the General Plan Update
proposes any policies beyond those which
were sent to the California Coastal Commission
for review and certification, a subsequent LCP
amendment would be necessary to make the
LCP consistent with the General Plan. The DEIR
does include discussion of the Coastal
Commission requirements; please refer to
response to comment C123-42 for more
information.

C123-43 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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).)
The DEIR does identify areas of potential ESHA
in Figure 3.7-3. More information about ESHA
at the site in question can be found in Master
Response 6: ESHA.

The Banning Ranch case represented a project
EIR. This EIR is a program EIR, which conducts a
citywide assessment of the potential impacts
of the proposed Pacifica General Plan. It does
not assess project-specific impacts of potential
future projects under the proposed Plan, all of
which are required to comply with CEQA as
applicable.

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C123-44 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 4) The 2022 Draft EIR does not identify or discuss which LCLUP policies and relevant narratives are
included in the General Plan Update.

The LCLUP Update is not a part of the
Proposed Project and, therefore, need not be
analyzed in the DEIR. However, the General
Plan Update includes all policies that are also
contained in the LCLUP Update. Page 1-15 of
the General Plan Update states that "Policies
that are included in both the General Plan and
the LCLUP are marked with a [wave symbol] in
the General Plan. All policies in the LCLUP are
also in the General Plan." Therefore, because
all LCLUP Update policies are also included in
the General Plan Update, the DEIR analyzed
these policies for potentially significant
environmental impacts.

C123-45 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.)
Please see response to comment C33-1.

C123-46 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

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

C123-47 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

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

C123-48 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 VI. The Draft EIR Will Need to Be Recirculated for Additional Responsible Agency and Public
Comment.

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
The comment alleges that the DEIR will need to
be recirculated, which is false. All additional
information provided in the FEIR merely
clarifies and amplifies existing findings of
significance.

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and comment is precluded. (Mountain Lion
Coalition v. Fish & Game Com. (1989) 214
Cal.App.3d 1043).

C123-49 Brian Gaffney
(representing
Pedro Point
Community
Association)
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 comment is not related to the adequacy of
the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed Plan
and will be shared with decision-makers in that
context. Please see Master Response: EIR
comments for more information about GP- or
SPSP-related responses.

C123-50 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

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

C123-51 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
Please see Master Response: Buildout and
RHNA for more information about the
adequacy of buildout.

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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.

C123-52 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 3) The 2022 GP Update improperly defers standards development to future zoning ordinances,
standards and regulation updates.

Zoning does not represent a deferral. As a
general law city, Pacifica is required by law to
update its zoning code after adoption of a
General Plan; thus, this does not represent
deferred mitigation. This comment is not
related to the adequacy of the FEIR, thus no
further response is required. Please see Master
Response 1 for more information.

C123-53 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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.

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

C123-54 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 5) Land use designations in the 2022 GP Update
conflict with policies, particularly
at the San Pedro Avenue site.

The commenter provides no evidence to
support this statement. This comment is not
related to the adequacy of DEIR analysis, thus
no further response is required
C123-55 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 6) There are vertical and horizontal internal
inconsistences in and between the
General Plan and the LCP updates.

The commenter provides no evidence to
support this claim.

As noted on DEIR p. 2-7, in February 24, 2020,
the City Council considered the PostConsultation Draft LCLUP and approved transmittal of the LCLUP to the California
Coastal Commission for review and
certification. The LCLUP was transmitted to the
Coastal Commission on June 12, 2020.

Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan
Update to ensure coordination between the
two documents. The City has prepared a draft
of the LCP Update in 2019, approved by the
City in 2020, and which is currently under
review for certification by the California
Coastal Commission. To the extent the General
Plan Update proposes any policies beyond
those which were sent to the California Coastal
Commission for review and certification, a

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subsequent LCP amendment would be
necessary to make the LCP consistent with the
General Plan.

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

C123-56 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
Allowable densities and intensities for every
type of land use designation in the Planning
Area are described in Table 2.3-1. As described
in Master Response: Buildout and RHNA, no
parcel develops at maximum capacity, due to
zoning regulations, setbacks, and potential
environmental constraints. Given
environmental factors such as slope and
sensitive species, there are some constraints
on the development potential of these sites.

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

C123-57 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 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
Allowable densities and intensities for every
type of land use designation in the Planning
Area are described in Table 2.3-1. As described
in Master Response: Buildout and RHNA, no
parcel develops at maximum capacity, due to
zoning regulations, setbacks, and potential
environmental constraints. Given
environmental factors such as slope and
sensitive species, there are some constraints
on the development potential of these sites.

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

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C124: Christine Boles, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C124-1 Christine
Boles
2/11/22 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.

EIR comments for more information about GP- or SPSPrelated responses.

C124-2 Christine
Boles
2/11/22 As an example, of the impossibility of making
CEQA required findings, let’s talk about traffic. We
Congestion is not a required topic of CEQA analysis.

The commenter asserts that traffic counts are from

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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, pretunnel. 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.
2010; this is incorrect. Traffic counts from pages 3-12 to 3-21 were conducted in 2018 and 2019, and analysis
from Table 3.2-7 on page 3-41 was conducted in 2020
and 2021, in accordance with the table references in
the DEIR.

C124-3 Christine
Boles
2/11/22 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.

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

See response to comment C13-3 for more information
about coastal flooding and sea level rise. See also
Master Response 9: Emergency Access.

Analysis pertaining to whether the implementation of
the Proposed Project will require or result in the
relocation or construction of new or expanded storm
water drainage facilities as discussed under criterion

3.13-1, specifically on pages 3.13-16 to 3.13-20. In
regard to stormwater, development under the
Proposed Project will incorporate best management
practices from construction and development, meeting
the requirements of the City’s stormwater permit,
regional and state regulations, and Proposed Project
policies. The increasing incorporation of stormwater
management in site planning will further reduce the
need for development of new storm drainage
infrastructure. Such Proposed Project policies to
reduce impact on stormwater facilities include CO-I-9,
CO-I-10, CO-I-11, CO-I-12, CO-I-13, CO-I-14, CO-I-15,
CO-I-16, and CO-I-17. Thus, the stormwater
infrastructure in Pacifica is adequate to provide for the Proposed Project buildout population.

C124-4 Christine
Boles
2/11/22 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
Please see Master Response 5: Wildfire for more
information on data used for mapping. Maps from
2014 do not use the 2008 CAL FIRE Recommended LRA
maps and thus do not represent the latest and best

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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.
available data. Flammability of eucalyptus forest as
vegetation is included as a factor in Fire Hazard
Severity Zones designated by CALFIRE; mapping is
based on factors such as fuel, slope, and weather.

Figure 3.14-1, which shows Fire Threat, a measure of
fuel conditions and fire potential in the ecosystem.

C124-5 Christine
Boles
2/11/22 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.

The MJ-LHMP was adopted and certified by the state
government, and actions related to wildfire and
emergency planning remain applicable. The DEIR does
not solely rely on the MJ-LHMP for its analysis. Please see Master Response: Wildfire for more information on
the adequacy of analysis.

C124-6 Christine
Boles
2/11/22 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.

As the commenter describes, planned development
does not represent induced growth; the DEIR analyzes
potential impacts of lands use changes (planned
growth) in areas where development could reasonably
occur. Congestion is not a required topic for CEQA
analysis. As discussed in Impact 3.2-4, project level
review required by the City includes site access review for emergency vehicles and traffic control plans as
needed that account for emergency vehicles. Thus,
new development would be required to comply with
Municipal Code requirements for emergency access to
the site and LHMP and Emergency Plan
implementation will reduce impacts to the maximum
extent practicable. In addition, new development
would be subjected to policies listed under Impact 3.2- 4 as well as the existing programmatic framework to
reduce impacts of evacuation to less than significant
level. Please see Master Response 7: Evacuation
Routes for more information regarding emergency
access.

C124-7 Christine
Boles
2/11/22 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.

This comment contains an inaccuracy. The DEIR does
not contain an opinion about annexing land. Shamrock
Ranch is outside of the City limit, under the jurisdiction of San Mateo LAFCo. Policy LU-I-45 would have the City
coordinate with San Mateo County to ensure that any
new development at Shamrock Ranch is clustered to
preserve open space. Any subdivision of greater than
ten lots or development of more than ten housing
units or 40,000 square feet of non-residential space
should occur through a master planning process and
may involve annexation into the city. These controls
show that growth would not be unplanned; instead, it
would account for growth that could require additional
services.

1.f
Packet Pg. 1280 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5041 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 616
Letter Commenter Date Comment Combined Response
Individuals (C)
C124-8 Christine
Boles
2/11/22 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.

As noted in Master Response: Buildout and RHNA, the
City is updating its 6th cycle Housing Element update,
which will likely include land use changes to
accommodate the RHNA. The Housing Element update
and development of the required housing sites
inventory will involve an extensive period of
community input and additional CEQA review. This
approach does not constitute “piecemealing”, dividing
a large project into separate parts, each of which might have individually minimal environmental
consequences, because the CEQA document would
analyze the proposed General Plan in addition to any
future changes to the land use diagram.

C124-9 Christine
Boles
2/11/22 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.

This comment is noted. The following edit has been
made for clarity:

DEIR p. 5-2: "The Planning Area is located in an area
that is partially and urban and lacks opportunities for greenfield development, as nearly all of the open,
undeveloped areas are designated for open space."
This is a minor correction made to clarify and does not affect the findings of the DEIR.

C124-10 Christine
Boles
2/11/22 Further down, section 5.3 Significant and
Unavoidable Impacts identifies
transportation/traffic as a major issue that cannot
be itigated. 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?
Please see also response to comment C123-26. This
comment incorrectly asserts that the DEIR identified
policies that would reduce VMT related impacts of the
Proposed Plan to a less than significant level. In fact, as noted on page 3-41of the DEIR found a significant and
unavoidable VMT impact related to increases the
Vehicle Miles Traveled (VMT) per person above the
baseline conditions even after implementation of all
feasible mitigation measures.

C124-11 Christine
Boles
2/11/22 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?
Traffic counts from pages 3-12 to 3-21 were conducted
in 2018 and 2019, and analysis from Table 3.2-7 on
page 3-41 was conducted in 2020 and 2021, in
accordance with the table references in the DEIR.

For this analysis, impacts of the proposed Project on
GHG emissions and energy resources from
construction were assessed qualitatively, while impacts from operations were assessed quantitatively using
standard and accepted software tools, techniques, and
emission factors. The primary assumptions and key
methods used to quantify emissions and estimate
potential impacts are described below. Model inputs
and calculation files are provided in Appendix C: Air
Quality and Greenhouse Gas Data. Thus, GHG analysis
of This reference edit does not change any findings of
significance.

C124-12 Christine
Boles
2/11/22 Current traffic demand also needs to be
understood so that North County Fire can verify
that they can provide the right level of service.

See response to comment C82-21.

1.f
Packet Pg. 1281 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5042 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 617
Letter Commenter Date Comment Combined Response
Individuals (C)
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.

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?

1.f
Packet Pg. 1282 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5043 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 618
C125: Nancy Tierney, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C125-
1 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 Regarding the Proposed
Project, it’s not clear what
this is, or for that matter
how the alternatives
compare (including No
Project).

As noted on p. 4-2 and 4-3, the Proposed Project represents the project analyzed in chapters 3.1-3.15 in the DEIR. Comparative analysis of the Alternatives is presented in section 4.3.

C125-
2 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 Section 1.2 Planning
Process, covering the
period of 2009 – 2019.

Why the 10-year period
and why wasn’t the 2014
update adopted?
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR. However, the comment addresses the content of the Proposed Plan and will be shared with decision-makers in that context. Please see Master Response: EIR comments for more information about GP- or SPSP-related responses.

C125-
3 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 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.

This comment is noted. The following edit has been made for clarity:

DEIR p. E-5: "As shown in Table ES-1, the Planning Area would result in a population of approximately 41,280 41,050 people at buildout, an increase of about 7.1 percent over the current estimated population, or 2,720 new residents."
This is a minor correction made to clarify and does not affect the findings of the DEIR.

C125-
4 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 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.

Projects undergoing approval now are not yet subject to policies in this Proposed Plan, which have not yet been adopted. The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR. However, the comment addresses the content of the Proposed Plan and will be shared with decision-makers in that context. Please see Master Response: EIR comments for more information about GP- or SPSP-related responses.

C125-
5 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 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.

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

1.f
Packet Pg. 1283 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 5044 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 619
C125-
6 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 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.]
The comment is noted. The applicable recommendations are mentioned in Table 3.3-5.

The comment also mentions taking more aggressive steps in relation to the climate crisis. As the recommendations mentioned in Table 3.3-5 would reduce the impact to a less than significant level, no additional policies are required and no further response is required.

C125-
7 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 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.

The CAP has not been updated yet. The latest information about the update can be found in the City's website:
https://www.cityofpacifica.org/depts/planning/climate_action_plan.asp As noted on DEIR p. 3.4-27, it is acknowledged that "implementation of [the existing] CAP does not necessarily guarantee that an updated CAP will be prepared or that all GHG reduction measures included will be capable of meeting an updated, and potentially lower, GHG emissions reduction target." Because impacts and potential reductions could not be quantified, the DEIR concludes that "therefore, on a local scale, implementation of the Proposed Project would generate GHG emissions that could have a significant impact on the environment and this impact would be potentially significant and mitigation measures would be required." These mitigation measures are described on p. 3.4-47, and

3.4-48.

C125-
8 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 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.

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

C125-
9 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 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.

References will be updated to reflect the latest data used in analysis.

This does not change any findings of significance in the DEIR.

1.f
Packet Pg. 1284 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5045 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 620
C126: Lawrence Bothen, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C126-1 Lawrence
Bothen
3/7/22 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.

The comment is noted. Please refer to response to
comment C3-1
C126-2 Lawrence
Bothen
3/7/22 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.

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

RV parking is controlled by City Ordinance,
enforcement of this ordinance is beyond the scope of
the DEIR, thus, no further response is required.

1.f
Packet Pg. 1285 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 5046 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 621
Letter Commenter Date Comment Combined Response
Individuals (C)
C126-3 Lawrence
Bothen
3/7/22 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?
The comment is noted. This DEIR provides a
programmatic analysis of potential environmental
impacts. A program EIR differs from a project EIR,
which is the most common type of EIR and examines
the environmental impacts of a specific development
project. A project EIR “should focus primarily on the
changes in the environment that would result from
the development project [and] examine all phases of
the project including planning, construction, and
operation.” (CEQA Guidelines, Section 15161; In re
Bay Delta etc. (2008) 43 Cal.4th 1143, 1169.)
A program EIR can be used as the basic general
environmental assessment for an overall program of
projects such as the Pacifica General Plan intended to
be developed over a 22-year planning horizon. A
program EIR has several advantages. First, it provides
a basic reference document to avoid unnecessary
repetition of facts or analysis in subsequent projectspecific assessments. Second, it allows the lead agency to look at the broad, regional impacts of a
program of actions before its adoption and
eliminates redundant or contradictory approaches to
the consideration of regional and cumulative effects.

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

As a program EIR, the preparation of this document
does not relieve the sponsors of specific projects
from the responsibility of complying with the
requirements of CEQA. As noted, individual projects
are required to prepare a more precise, project-level
analysis to fulfill CEQA requirements. The lead
agency responsible for reviewing these projects shall
determine the level of review needed, and the scope
of that analysis will depend on the specifics of the
particular project. These projects may, however, use
the discussion of impacts in this EIR as a basis of their assessment of these regional, citywide, or cumulative
impacts.

C126-4 Lawrence
Bothen
3/7/22 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.

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

C126-5 Lawrence
Bothen
3/7/22 CD-I-18, Rockaway Quarry Site, proposes to
rename Mori Pt. special area for visitor serving
development on portion of quarry site, two
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content

1.f
Packet Pg. 1286 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5047 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 622
Letter Commenter Date Comment Combined Response
Individuals (C)
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.
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response: EIR comments for more information about
GP- or SPSP-related responses.

C126-6 Lawrence
Bothen
3/7/22 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.

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

C126-7 Lawrence
Bothen
3/7/22 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.

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

1.f
Packet Pg. 1287 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5048 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 623
C127: Richard Harris, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C127-1 Richard
Harris, San
Francisco
Public Golf
Alliance
3/9/22 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.

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”.

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”.

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 No development is proposed
that would block scenic views to
the hills to the east of the Golf
Course from the Coastal Trail;
the impact is less than
significant. Please see Master
Response 1 for more
information on General Planrelated response to comments.

1.f
Packet Pg. 1288 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5049 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 624
Letter Commenter Date Comment Combined Response
Individuals (C)
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:
“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.)

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.

1.f
Packet Pg. 1289 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5050 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 625
C128: Richard Harris, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C128-1 Richard
Harris, San
Francisco
Public Golf
Alliance
3/7/22 I. The Public Comment Draft Pacifica General Plan (January 2022) and its Supporting Environmental Impact Report 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.

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”.

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.

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.

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).

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. 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.

F. The April 15, 2015 Response to Comments on the Draft Pacifica General Plan, 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 Page 2-50 [“Master Response”]
”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 zoning code, which only recognizes the Sharp Park Golf The comment accurately describes
the accidental omission of the entire
Sharp Park Golf Course as a historic
resource, and is noted and
appreciated.

The comment stated that that Sharp
Park Golf Course itself—and not only
the Clubhouse—should be identified
in the General Plan and EIR as an
historic resource. The Golf Course and
Clubhouse are identified as an historic
site in the 1980 General Plan, and
were identified by Resolution No. 63-
2007 as “historically significant
facilities” by the Pacifica City Council.

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

1.f
Packet Pg. 1290 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 5051 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 626
Letter Commenter Date Comment Combined Response
Individuals (C)
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.”
• 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”

Page 7 ends

Pacifica City CouncilJuly 11, 2022

Pacifica City Council
July 11, 2022