Pacifica City Council
July 11, 2022

1.g
Packet Pg. 3132 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6893 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 3

2. SETTING

2.1 SITE DESCRIPTION
The study area encompasses approximately 1.6 acres of land located at 505 San Pedro Avenue (project site) and the drainage channel adjacent to the property in Pacifica, California. The applicant (Shawn Rhodes) is proposing to develop the parcel at 505 San Pedro Avenue, which is

0.86 acres. The adjacent drainage channel is 0.74 acres. The drainage channel is located to the west of the property within an unaccepted city right of way. This delineation was conducted to provide additional information on the drainage channel, in response to California Coastal Commission letter dated July 2, 2019 regarding Coastal Development Permit (CDP) Application Number 2-19-0026 (construction of a mixed-use scheme, including three buildings, a skate park, and a parking lot in Pacifica.

The site is bordered by the Pedro Point Shopping Center to the East, San Pedro Avenue to the south, and residential properties to the north. The area is highly developed, and the property is surrounded by residential and commercial developments on all sides. The Pacific Ocean is located approximately 210 feet to the northwest. Topography on the project site is variable, as is located on an elevated berm-like feature. The top of the berm runs southwest-northeast through the approximate center of the property, and slopes downwards towards the drainage channel on the west side and the shopping center on the east side. Elevations at the study area range from approximately 14 to 23 feet. Figure 1 shows the project boundaries and location. Photographs of the project site can be found in Appendix B.

The drainage channel was created most likely as an irrigation ditch for farming prior to the 1950’s. The City of Pacifica constructed a sewer line below the channel, with sewer manholes in two locations within the channel, at some point later (in the 1960’s possibly). The channel bed and banks are categorized as ‘urban’ soil type due the history of disturbance to the channel and its location adjacent to a 5-acre commercial shopping center and parking lot. Urban runoff from the local community of Pedro Point flows into the channel which then empties through a culvert and into San Pedro Creek on the north side of the 505 San Pedro Avenue property.

2.2 PROJECT DESCRIPTION
The property (APN 023-72-010) is located on San Pedro Avenue in Pacifica, California. The property is 0.86 acres in size (37,273 ft.2) and is located on the west side of Highway 1 in the Pedro Point area. The site is located within the coastal zone and is subject to the City of 2-19-0026
Exhibit 5

1.g
Packet Pg. 3133 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6894 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 4 Pacifica’s Local Coastal Land Use Plan. The property is zoned as commercial and is within the Pedro Point – Shelter Cove Land Use Plan Area, and is outside of any special areas delineated in the Local Coastal Land Use Plan (City of Pacifica, 1992). The site is a narrow, rectangular strip of land (755 feet long x 55 feet wide) and is bounded by San Pedro Road on the south, a drainage channel and open field on the west, a strip mall/shopping area to the east and a parking lot on the north. San Pedro Creek and the Pacific Ocean are located further to the north, and northwest of the parking lot. The surrounding area is single family residential homes and small businesses.

The project intends to develop a currently vacant lot into commercial and residential buildings.

The development will consist of a 2-story surf shop building with storage basement (3,500 ft2 ), a
skatepark enclosed within chain-link fencing and a roof (4,730 ft2), a 2-story storage building for the surf shop (1,540 ft2), 2 parking lot areas (16,513 ft2), a 2-story building with retail space at the lower level and 2 residential units above (2,516 ft2 ), and various areas of landscaping (7,302
ft2). The project would be constructed within an upland area that is behind an existing shopping center, and would include a public access easement (pedestrian trail) that would extend along the western boundary of the site, along the top of bank of an adjacent drainage channel. The project area and adjacent drainage channel have been heavily disturbed by grading activities in the past.

The adjacent drainage channel would not be directly impacted by the proposed project.

This wetland delineation was conducted on the adjacent drainage channel, which is designated as an unaccepted right of way (identified as ‘Chester Way’) on the most current San Mateo County Assessor’s parcel map.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3134 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6895 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 5 2-19-0026
Exhibit 5

1.g
Packet Pg. 3135 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6896 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 6

2.3 VEGETATION
Vegetation at the study site (drainage channel) can be categorized into several different natural communities based upon plant species composition. The boundaries between communities can be distinct, or can change gradually over an area. Due to the semi-developed nature of the project site, vegetation types in this analysis are based upon, but do not strictly follow, species alliances described by the California Native Plant Society (CNPS) Manual of California Vegetation. Natural communities on the site include arroyo willow thicket, coastal brambles, eucalyptus grove, kikuyu grass sward, Monterey cypress stand, perennial rye grass fields, smallfruited bulrush marsh, smartweed patch, upland mustards/ruderal and ornamental.

2.3.1 Arroyo Willow Thicket
The arroyo willow thicket community is dominated by arroyo willow (Salix lasiolepis). This plant community is found within the drainage at the northeast terminus of the drainage. It is comprised of dense arroyo willow trees. Arroyo willows are a facultative wetland (FACW) plant, found more frequently in wetlands than outside of them.

2.3.2 Coastal Brambles
The coastal brambles plant community is characterized as being heavily dominated by brambles (Rubus sp.). Within the study area, this plant community is primarily made up of dense California blackberry (Rubus ursinus) vines, with the ornamental species multiflora rose (Rosa multiflora) and California privet (Ligustrum ovalifolium) occasionally present at lower densities.

The coastal brambles plant community is found along the banks of the drainage channel, sometimes extending into the channel itself. California blackberry is a Facultative plant (FAC), found equally often in wetland and upland habitats. Multiflora rose and California privet are considered upland species (UPL). Due to the prevalence of dominant upland species within this habitat, it is not considered a wetland.

2.3.3 Eucalyptus Grove
Two groves of mature blue gum (Eucalyptus globulus) trees are present at the western and southwestern portions of the study area. Large blue gum trees make up the overstory of this community, while the understory is primarily composed of eucalyptus duff and English ivy (Hedera helix). Blue gum is an upland (UPL) species, and English ivy is considered a Facultative Upland (FACU) species more likely to be found in upland habitats. 2-19-0026
Exhibit 5

1.g
Packet Pg. 3136 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6897 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 7

2.3.4 Kikuyu Grass Sward
Swards of the invasive Kikuyu grass (Pennisetum clandestinum) are present within the bottom of the drainage channel. These areas are completely dominated by Kikuyu grass with no other vegetation present. This species is considered a Facultative Upland (FACU) plant, being found more often in upland habitats. The presence of Kikuyu grass indicates that there is unlikely to be significant soil inundation (and thus wetland habitat) in this portion of the drainage channel.

2.3.5 Monterey Cypress Stand
One stand of Monterey cypress (Hesperocyperus macrocarpa) is present within the study area along the western bank of the channel. Vegetative cover within this stand is entirely made up of Monterey cypress, as the density of the trees prevents any understory vegetation from growing beneath them. Monterey cypress is ranked UPL.

2.3.6 Ornamental
The ornamental vegetation community is made up of non-native ornamental plant species that are not widespread enough in natural areas to possess a community designation. Within the study site, areas of ornamental vegetation are dominated by garden nasturtium (Tropaeolum majus), English ivy (Hedera helix), or cape ivy (Delairea odorata). Where present, each species provides nearly 100 percent of the vegetative cover. These areas heavily dominated by non-native vegetation are primarily found along the eastern bank of the drainage channel. All of these plants are considered upland species.

2.3.7 Perennial Rye Grass Fields
This plant community is dominated by perennial rye grass (Festuca perennis). Individual curly and green dock (Rumex crispus/Rumex conglomeratus) plants are also present at lower densities.

Perennial fescue is a Facultative wetland plant (FAC), equally likely to be found inside or outside of wetland habitats. Curly dock is also a FAC plant, while green dock is considered a FACW plant.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3137 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6898 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 8

2.3.8 Small-fruited Bulrush Marsh
This plant community is dominated by small-fruited bulrush (Scripus microcarpus). One small patch of these plants is present within the drainage channel, where they make up 100 percent of the vegetative cover. Small-fruited bulrush is an Obligate wetland species (OBL), only being found within wetland habitats.

2.3.9 Smartweed Patch
This plant community is primarily dominated by smartweed (Persicaria sp.). Within the study area, this community is dominated by water smartweed (Persicaria amphibia), a wetland obligate species (OBL). Other plant species observed growing beneath and around the smartweed include silverweed cinquefoil (Potentilla anserina), dock (Rumex sp.), and California blackberry (Rubus ursinus). These plants are only found within the wetter portions of the drainage channel.

2.3.10 Upland Mustards and Ruderal Forbs
This plant community is dominated by non-native mustards and other invasive species. Within the study area, this habitat is heavily dominated by wild radish (Raphanus sativus), which dominates the vegetative cover along the eastern bank/berm and upland portions of the site.

Small patches of fennel (Foeniculum vulgare) can also be found within this community. These plants are designated as upland (UPL) species.

2.4 SOILS
Only one soil type is present within the study area: Urban land. Urban land is defined by the USDA NRCS as areas where 85% or more of the ground surface is covered by asphalt, concrete, buildings, and other structures (USDA SCS 1991). Appendix C provides a soils map of the study area.

2.5 HYDROLOGY
The project site consists of a vacant lot and does not contain any watercourses or wetland habitats. Aquatic features within a 100-meter radius of the project site include the Pacific Ocean, San Pedro Creek (approximately 75 meters northeast of the site), and an intermittent drainage channel on the west side of the project site
2-19-0026
Exhibit 5

1.g
Packet Pg. 3138 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6899 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 9 The drainage channel was created most likely as an irrigation ditch for farming prior to the 1950’s. At some point later (in the 1960’s possibly), the City of Pacifica constructed a sewer pipe that runs below the open channel for most of the channel’s length. Two sewer manholes are located in the channel bottom. During rain events, urban stormwater runoff from the local community of Pedro Point flows into the channel which then empties through a culvert into San Pedro Creek to the north side of the property.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3139 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6900 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 10

3. METHODOLOGY
This wetland delineation was conducted in accordance with the USACE 1987 Corps of Engineers Wetlands Delineation Manual along with the USACE 2008 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region. A Level 3 Determination (i.e., a combination of onsite inspection and aerial review) was conducted as defined in the Wetland Delineation Manual.

The location of the project site is within the boundary zone between the Arid West Region and the Western Mountains, Valleys, and Coast Region. The climatic conditions and vegetation in Pacifica overlaps with what is described in both supplements. Both regional supplements include coastal areas, and a reasonable justification could be made to support the use of either supplement. The Western Mountains regional supplement was chosen as the appropriate manual based on vegetation and climate; including the following:

Arid West: Generally hot and dry with long summer dry season. Average annual precipitation mostly <15”, except along the coast. Most precipitation falls as rain.

Western Mountains, Valleys and Coast: Cooler and more humid with a shorter dry season.

Average annual precipitation mostly >20” except near the coast. Much of the annual precipitation falls as snow, particularly at higher elevations.

Average annual precipitation in Pacifica is approximately 32”1. Due to heavy fog during the summertime especially, the amount of water available to vegetation is much greater due to fog drip.

3.1 DEFINITION OF TERMS
The following section provides key definitions of terms used in this report that are relevant to the delineation of wetlands and other waters of the US.

Waters of the United States: Title 33, Chapter II, Part 328.3 of the Code of Federal Regulations defines waters of the United States as:
(1) All waters which are currently used, were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide;
(2) All interstate waters including interstate wetlands; 1 https://www.ncdc.noaa.gov/cdo-web/datatools/normals
2-19-0026
Exhibit 5

1.g
Packet Pg. 3140 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6901 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 11 (3) All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mud flats, sand flats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation, or destruction of which could affect interstate or foreign commerce including any such waters:
a. which are or could be used by interstate or foreign travelers for recreational or other purposes;
b. or from which fish or shellfish are or could be taken and sold in interstate or foreign commerce;
c. or which are used or could be used for industrial purposes by industries in interstate commerce;
(4) All impoundments of waters otherwise defined as waters of the United States under the definition;
(5) Tributaries of waters identified in paragraphs (1) through (4); (6) Territorial seas; and
(7) Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraphs (1) through (6).

Federal Definition of Wetlands: In Title 33, Chapter II, Part 328.4 of the Code of Federal Regulations, wetlands are defined as: “Those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” For the purposes of a USACE wetland delineation, an area must meet three diagnostic environmental characteristics in order to be considered a wetland. These three characteristics include the presence of hydrophytic vegetation, hydric soils, and wetland hydrology.

Hydrophytic Vegetation: The USACE 1987 Wetland Delineation Manual describes hydrophytic vegetation as “sum total of macrophytic plant life that occurs in areas where the frequency and duration of inundation or soil saturation produce permanently or periodically saturated soils of sufficient duration to exert a controlling influence on the plant species present. The vegetation occurring in a wetland may consist of more than one plant community (species association). Emphasis is placed on the assemblage of plant species that exert a controlling influence on the character of the plant community, rather than on indicator species.”
Hydric Soil: Defined by the USACE Western Mountains Supplement as “a soil that formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part. Most hydric soils exhibit characteristic morphologies that result from repeated periods of saturation or inundation for more than a few days…These processes result in distinctive characteristics that persist in the soil during both wet and dry periods.” 2-19-0026
Exhibit 5

1.g
Packet Pg. 3141 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6902 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 12 Wetland Hydrology: The USACE 1987 Wetland Delineation Manual describes wetland hydrology as “all hydrologic characteristics of areas that are periodically inundated or have soils saturated to the surface at some time during the growing season. Areas with evident characteristics of wetland hydrology are those where the presence of water has an overriding influence on characteristics of vegetation and soils due to anaerobic and reducing conditions, respectively.”
Navigable Waters of the United States: Title 33, Chapter II, Part 329.4 of the Code of Federal Regulations defines navigable waters of the U.S. as “those waters subject to the ebb and flow of the tide and/or are presently used, or have been used in the past, or may be susceptible for us to transport interstate or foreign commerce. A determination of navigability, once made, applies laterally over the entire surface of the waterbody, and is not extinguished by later actions or events which impede or destroy navigable capacity.” For the purposes of a USACE jurisdictional determination, navigable waters of the United States are considered Traditionally Navigable Waters.

Ordinary High Water Mark (OHWM): Title 33, Chapter II, Part 328.3 of the Code of Federal Regulations defines the OHWM as “that line on the shore established by the fluctuations of water and indicated by physical characteristics, such as a clear, natural line impressed on the bank, shelving, changes in the character of the soil, destruction of terrestrial vegetation, the presence of litter or debris, or other appropriate means that consider the characteristics of the surrounding area.”
Mean High Water (MHW): Section 10 of the Rivers and Harbors Act (RHA), which regulates certain activities in navigable waters of the U.S., defines the landward limit of Section 10 jurisdiction as the Mean High Water (MHW) mark. The MHW mark, with respect to ocean and coastal waters, is defined as: “The line on the shore established by the average of all high tides. It is established by survey based on available tidal data (preferably averaged over a period of 18.6 years because of the variations in tide). In the absence of such data, less precise methods to determine the mean high water mark are used, such as physical markings, lines of vegetation or comparison of the area in question with an area having similar physical characteristics for which tidal data are readily available.”
In the case of non-tidal waters regulated by the RHA, the MHW is defined as the OHWM.

State Definition of Wetlands: The State defines wetlands more broadly than the federal wetlands program by recognizing that wetlands may have evidence of only one of the three federal parameters. The State definition also conforms to the USFWS definition:
"Wetlands are lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water. For purposes of this classification, wetlands must have one or more of the following three attributes: (1) at least periodically, the land supports hydrophytes, (2) the substrate is 2-19-0026
Exhibit 5

1.g
Packet Pg. 3142 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6903 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 13 predominantly undrained hydric soil; and (3) the substrate is non-soil and is saturated with water or covered by shallow water at some time during the growing season of each year" (Cowardin, 1979).

Additionally, for the purposes of identifying Environmentally Sensitive Habitat Areas (ESHA) regulated by the California Coastal Commission, the California Coastal Act of 1976 further specifies that wetlands are:
“Land where the water table is at, near, or above the land surface long enough to promote the formation of hydric soils or to support the growth of hydrophytes, and shall also include those types of wetlands where vegetation is lacking and soil is poorly developed or absent as a result of frequent and drastic fluctuations of surface water levels, wave action, water flow, turbidity or high concentrations of salts or other substances in the substrate. Such wetlands can be recognized by the presence of surface water or saturated substrate at some time during each year and their location within, or adjacent to, vegetated wetlands or deep-water habitats” (CCR Title 14, Section 13577).

Although the State definition may require only a single parameter to establish the presence of wetlands (and ESHA), in practice, such decisions are based on a case-by-case interpretation of data that either support or disprove the presumption of whether wetlands are indicated by a single parameter.

3.2 REGULATORY SETTING

3.2.1 U.S Army Corps of Engineers
The US Army Corps of Engineers (USACE) regulates activities that result in the discharge of dredged or fill materials into waters of the U.S. including wetlands, under Section 404 of the Clean Water Act. USACE also regulates dredging, filling, and construction activities in navigable waters under Section 10 of the Rivers and Harbors Act. Activities involving dredged or filled materials require a Section 404 permit, and/or a Section 10 permit, issued by the USACE. Section 404 projects may be authorized under general permits, also known as nationwide permits, or may require individual permits in the case of more complex projects that exceed the threshold for impacts under the nationwide permits.

3.2.2 California Coastal Commission
The California Coastal Commission (CCC) exercises jurisdiction over development activities within the coastal zone. In the city of Pacifica, construction projects within the coastal zone are regulated through the City’s Local Coastal Land Use Plan (LCLUP). The City regulates construction projects through the LCLUP, to bring projects into conformance with the California Coastal Act of 1976.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3143 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6904 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 14 The project site is within the Pedro Point/ Shelter Cove Land Use Plan area, and is not located within a designated environmentally sensitive wetland area (LCLUP 1992). However, in the Plan Conclusions section, under Development Near Wetlands and Creeks; the LCLUP states:
“Riparian vegetation along all intermittent and year-round creeks shall be protected, enhanced and restored where feasible, and buffer zones required.”; And; “As a general rule, a buffer of at least 100 feet measured from the outward edge of riparian vegetation would be appropriate unless such a width is determined to be unnecessary for protecting the resources of the habitat area”

3.2.3 California Department of Fish and Wildlife
The California Department of Fish and Wildlife (CDFW) regulates projects that will:
(1) substantially divert or obstruct the natural flow of any river, stream or lake; (2) substantially change or use any material from the bed, channel, or bank of, any river, stream, or lake; or
(3) deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake. (Section 1602, California Fish and Game Code)
To complete projects which will affect these characteristics of any river, stream, or lake, within the state of California, projects must apply for a Lake or Streambed Alteration Agreement (Section 1600 Series Permit). The jurisdictional boundary of the CDFW typically follows the top-of-bank or the outermost edge of riparian vegetation adjacent to the regulated stream, river, or lake.

3.2.4 Regional Water Quality Control Board
The Regional Water Quality Control Board (RWQCB) has authority over projects that could result in negative impacts to waters of the State and wetlands. The RWQCB, defines “waters of the State” as any surface water or groundwater, including saline waters within the boundaries of the State of California (Cal. Water Quality Control, Division 7, January 2011). In addition, it defines “water quality control” as the regulation of any activity that may affect the quality of the waters of the State, and includes the prevention and correction of water pollution and nuisance.

Under the Porter-Cologne Water Quality Control Act, the RWQCB is authorized to regulate the discharge of waste that could affect the quality of State waters. Regulated discharges include any substances associated with human habitation that are harmful to the aquatic environment, including stormwater runoff associated with construction projects and other activities that could discharge soil, pollutants, or other materials into waters of the State. Projects that could produce pollutants or discharge into waters of the state must apply for a Section 401 Certification from 2-19-0026
Exhibit 5

1.g
Packet Pg. 3144 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6905 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 15 the California Regional Water Quality Control Board to ensure that any discharges will be in compliance with California’s water quality standards.

3.3 DELINEATION METHODS
This wetland delineation was conducted through the analysis of aerial photography, historical records, and other relevant data sources, as well as an onsite survey to characterize vegetation, soils, and hydrology.

3.4 LITERATURE REVIEW
Prior to the field survey, aerial photographs were reviewed for current and historical data on lake levels and vegetation. Soil types were assessed using the online USDA Natural Resource Conservation Science Web Soil Survey (NRCS 2019). Historical and current land use data was accessed from various sources, including historical aerial photographs (UCSB 2019).

3.5 FIELD SURVEY
The field delineation for the study area was conducted by Patrick Kobernus of Coast Ridge Ecology on October 21, 2019. Wetland vegetation was mapped by P. Kobernus and CRE Biologist Greg Pfau on September 18, 2019. Weather conditions at the time of the field visits included clear skies, temperatures in the 70’s (ºF), and no wind. The onsite inspection evaluated the three parameters that identify and delineate the boundaries of jurisdictional wetlands, including (1) the dominance of wetland vegetation; (2) the presence of hydric soils; and (3) hydrologic conditions that result in periods of inundation or saturation on the surface from flooding or ponding.

Survey methods follow the protocol outlined in the 1987 USACE Wetland Delineation Manual for Areas Less Than Five Acres in Size. GPS coordinates of each sample location were recorded in the field with a Trimble GeoExplorer 6000 series unit. Vegetation, soils and hydrology data were taken at each of these points. The completed Wetland Determination Data Forms for the Western Mountains Region are located in Appendix A.

3.5.1 Vegetation Data Collection
Vegetation data was collected at each sample point taken during the field survey. As per the 1987 Wetland Delineation Manual and the 2010 Western Mountains, Valleys and Coast Regional Supplement, plants in the tree stratum are defined as woody plants with a diameter three inches or more at breast height (DBH). Saplings/shrubs are defined as woody plants with a diameter of less than three inches DBH, and herbs are defined as non-woody plants regardless of size. Species type and percent dominance of each species was recording at each sample point.

The USACE National Wetland Plant List was used to determine the wetland indicator status of 2-19-0026
Exhibit 5

1.g
Packet Pg. 3145 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6906 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 16 plants observed in the study area. Wetland indicator status refers to the probability that a plant will occur within a wetland or upland area. The indicator status categories are defined as follows:
• Obligate (OBL): almost always occurs in wetlands
• Facultative wetland (FACW): usually occurs in wetlands, sometimes may occur in uplands
• Facultative (FAC): equally likely to occur in wetlands or nonwetlands • Facultative upland (FACU): usually occurs in uplands but may occasionally occur in wetlands
• Obligate upland (UPL): almost never occurs in wetlands • No indicator (NI)/ No status (NS): no indicator or status assigned due to lack of information
The presence of hydrophytic vegetation data was then determined using the dominance test and prevalence index described in the USACE Wetland Delineation Manual and Western Mountains Regional Supplement.

3.5.2 Soils
Soil pits were taken at each of the eight sample point sites. Soil pits were excavated to the maximum depth possible and soil color and texture was assessed and recorded onto the Western Mountains data sheets. Soil color was determined by matching samples to Munsell Soils Color Charts (Munsell Colors 2000). Soils were then assessed for hydric features described in the Western Mountains Regional Supplement, such as the presence of redoxomorphic concentrations, mucky soils or hydrogen sulfide odor.

3.5.3 Hydrology
Hydrology at each of the sample points was assessed based upon the USACE Western Mountains, Valleys, And Coast Region hydrology guidelines. Positive hydrological indicators include the presence of a visible water table, saturation and/or muck, water marks or drift deposits.

3.6 FEDERAL WETLAND BOUNDARY DETERMINATION
A preliminary wetland boundary line, based on the 3-parameter wetland definition was determined based on data points and vegetation mapping. Based upon the location of wetland versus non-wetland sample points, the wetland boundary was determined to correspond to specific discrete locations within the channel bottom (Figure 2). 2-19-0026
Exhibit 5

1.g
Packet Pg. 3146 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6907 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 17

3.6.1 Acreage Calculations
The area for each individual vegetation polygon within the wetland boundary was calculated in ArcMAP 10.2. All vegetation areas were then added to obtain a total area for wetlands within the study area.

3.7 STATE WETLAND BOUNDARY DETERMINATION
The state definition of wetlands requires only a single parameter to be met in order to indicate the presence of wetlands. Hydrophytic vegetation, hydric soils, or wetland hydrology were used to determine the state upland wetland boundary.

Areas of wetland vegetation were identified and mapped using a Trimble GeoExplorer 6000 unit.

Vegetation units were mapped based upon the dominant species.

Areas of hydric vegetation were defined using the dominance test, and by assessing the indicator status of the dominant species. Vegetation defined as obligate or facultative wetland by the USACE National Plant List was mapped as wetland vegetation.

Wetland acreage was determined using the methods described in Section 3.6.1 Acreage Calculation.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3147 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6908 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 18

4. RESULTS

4.1 FEDERAL WETLANDS
A total of 0.088 acres of potential federally jurisdictional wetlands occur within the delineation study area. Table 1 provides the calculations for the total acreage for wetland areas within the study area. Jurisdictional areas lie within the vegetated central portions of the drainage channel.

These areas are within the primary flow of the channel, where the soil remains saturated even after water is no longer visible at the surface. Wetland areas are represented by sample points A2 and A4 within the study area. Figure 2 provides an illustration of potentially jurisdictional wetlands within the study area. Appendix B provides representative photographs of the sample points and study area.

TABLE 1: TOTAL ACREAGE OF WETLAND AREAS WITHIN STUDY AREA Wetland Type Federal State
Area (acres) Area (sq ft) Area (acres) Area (sq ft)
Arroyo Willow Wetland
AW-1
Perennial Rye Grass Wetland
PR-1 0.010 437.146 0.001 35.026
Small-fruited Bulrush Marsh
BM-1 0.003 116.769 0.003 120.651
Smartweed Wetland
SW-1 0.012 508.292 0.004 161.820
SW-2 0.019 833.803
SW-3 0.019 844.048 0.022 963.699
subtotal
Ephemeral Channel
FC-1
Wetted Channel
WC-1 0.017 722.949
Total 0.248 10803.370
2-19-0026
Exhibit 5

1.g
Packet Pg. 3148 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6909 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve FC-1
A1
A2
A4A3
AW-1
SW-3
SW-2
SW-1
WC-1
PR-1
BM-1
Figure 2: Federal and State Wetlands
Legend
Site Parcel Boundary
Delineation Point
Waters of the State/State Wetland
Wetted Channel
Federal Wetlands
Arroyo Willow Thicket
Perennial Rye Grass Fields
Small-fruited Bulrush Marsh
Smartweed Patch
State Wetlands
Arroyo Willow Thicket
Perennial Rye Grass Fields
Small-fruited Bulrush Marsh
Smartweed Patch
Flow Channel
Service Layer Credits: Source: Esri,
DigitalGlobe, GeoEye, Earthstar Geographics,
CNES/Airbus DS, USDA, USGS, AeroGRID,
IGN, and the GIS User Community
505 San Pedro Avenue, Pacifica, CA
0 20 40 80 120 160
Feet
±
2-19-0026
Exhibit 5

1.g
Packet Pg. 3149 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6910 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 20

4.1.1 Vegetation
Freshwater wetlands on the study site are composed of a variety of plant species. Areas with the greatest water availability, at the northern end of the drainage, are dominated by arroyo willow and small-fruited bulrush. Wetlands within the primary flow of the channel are dominated by water smartweed and perennial rye grass, with curly and green dock also present at lower densities. Silver weed cinquefoil (Potentilla anserina) (OBL) can also be found here beneath the smartweed.

4.1.2 Soils
Within the wetland sample points, soils tended to be dark brown and homogenous with a color matrix of 10YR 3/1 at sample points A2 and A4; and 5YR 3/2 at sample point A1; and 5YR 3/3 at sample point A3. Soil texture ranged from sandy loam at sample points A1, A3, and A4 to sandy clay loam at sample point A2. Several unusual soil compositions were noted at the study site within the channel, due to the site being graded in the past, and the site used as an illegal dumping area. Within each of the sample point areas, concrete rubble, brick, plastic and metal refuse were present on the soil surface and/or within the soil. Soils determined to be wetland soils were based on one indicator (redox dark surface), likely due to a lack of ponding in the channel during most times of year. In addition, dark parent materials and the fact that the drainage feature has only been in existence for a few to several decades likely limits the formation of more hydric soil indicators.

4.1.3 Hydrology
Wetland hydrology indicators at sample points A2 and A4 included mud cracks at the surface of the channel bottom (Photo 9 in Appendix B). No other hydrology indicators were present. No ordinary high water mark was visible in the channel, likely due to a lack of flow through the channel at most times of year.

4.2 STATE WETLANDS
A total of 0.248 acres of potential state jurisdictional wetlands occur within the delineation study area. The acreage of state wetlands exceeds that of the federal wetlands since determination state wetlands is based upon only one parameter (hydrophytic vegetation or hydric soils or wetland hydrology) rather than the presence of all three required by the federal wetland definition. Table 1 provides the calculations for the total acreage for state and federal wetland areas within the study area.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3150 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6911 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 21 The entire portion of the channel exhibiting hydrology features was mapped and designated as FC-1. This area qualifies as a state wetland due to hydrology and soil indicators, but vegetation is either lacking or composed of upland plant species in many places. Areas where the hydrophytic vegetation is dominant within the channel satisfy the criteria for federal wetlands.

4.3 ENVIRONMENTALLY SENSITIVE HABITAT AREAS (ESHA)
The CCC defines an ESHA as an 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.” (California Coastal Act §30107.5).

The CCC Guidelines contain definitions for specific types of ESHAs, including: wetlands, estuaries, streams and rivers, lakes, open coastal waters and coastal waters, riparian habitats, other resource areas, and special-status species and their habitats. For the purposes of this report, ESHAs include any areas that may meet the definition of any ESHA defined by the CCC guidelines or the City of Pacifica LCLUP. A “special-status natural community” is a natural habitat community that is unique in its constituent components, restricted in distribution, supported by distinctive soil conditions, considered locally rare, potentially supporting specialstatus plant or wildlife species, and/or that receives regulatory recognition from municipal, county, state, and/or federal entities such as the California Natural Diversity Database (CNDDB). Within the study area, the arroyo willow stand is consistent with the description of Arroyo willow thickets (61.201.01 – Salix lasiolepis), which is listed by CDFW as sensitive plant community. This species is common in coastal California and does not have a rarity ranking. However, based on this classification and that it is often associated with riparian habitat, the arroyo willow stand, would be considered an ESHA. Discrete portions of the drainage channel where one or more wetland parameters are present would also be considered an ESHA.

RECOMMENDATIONS
The proposed project would not result in direct or indirect, temporary or permanent impacts to wetlands, other waters, or any ESHA’s. The drainage channel feature adjacent to the property at 505 San Pedro Avenue appears to be a man-made constructed feature, that is highly degraded due to construction and ongoing maintenance of a City of Pacifica sewer line that runs underneath the feature. The channel has been used as an illegal dumping area for decades and refuse such as gas cans, mattresses, appliances, plastic garbage, concrete rubble, bricks, and other refuse are present within the channel and buried within the soil. 2-19-0026
Exhibit 5

1.g
Packet Pg. 3151 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6912 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 22 The project as proposed would create a retaining wall and public access easement (pedestrian trail) along the western property boundary, and the following setbacks from the wetlands are shown in Table 2.

TABLE 2. STATE AND FEDERAL WETLANDS AND SETBACK DISTANCES FROM PROPOSED PROJECT AT 505 SAN PEDRO AVENUE, PACIFICA, CA
From Retaining Wall/Trail From Structures (approximate) Name Wetland Type
Distance to
closest point(ft)
Distance (ft) max
to near edge
Distance to closest
point (ft)
Distance (ft) max to
near edge
AW-1 Federal Wetland 4.10 13.34 32.9 84.7
AW-1 State Wetlands 0.00 0 29.31 63
BM-1 Federal Wetland 12.47 13.7 26.9 33.67
BM-1 State Wetland 6.16 10.5 23.17 31.5
FC-1 State Wetland 6.35 18.45 19.4 26.3
PR-1 State Wetland 10.86 12.8 23.46 26.19
PR-1 Federal Wetland 12.79 15.7 26.36 28.18
SW-1 State Wetland 2.31 7 15.31 19.95
SW-1 Federal Wetland 5.52 10.4 17.85 25.59
SW-2 Federal Wetland 8.51 21.4 20.61 33.4
SW-3 State Wetlands 0.00 6.13 8.67 18.64
SW-3 Federal Wetland 7.66 12.3 20.9 24.5
WC-1 State Wetland 0.00 5.5 10.06 22
The LCLUP states that “As a general rule, a buffer of at least 100 feet measured from the outward edge of riparian vegetation would be appropriate unless such a width is determined to be unnecessary for protecting the resources of the habitat area”. The California Coastal Commission has required buffers of 100 feet from the edge of riparian vegetation in areas where such buffers are feasible. However, it is not unusual for the Commission to allow smaller buffers in urbanized areas where the existing land use patterns do not allow for increased riparian buffer areas.

Based on the existing condition of the drainage channel, and the setback distances, the proposed project would not present a source of physical, chemical or biological disturbance to the wetland habitats including the arroyo willow stand (AW-1). Additional measures to ensure the channel is not impacted by construction activities would include planting of native plant species suitable for the boundary area adjacent to the channel, and installation of appropriate erosion/ sediment controls such as silt fencing, fiber rolls, and erosion control blankets along the top of the bank.

These measures would be suitable to protect the resource and improve the quality of this resource.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3152 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6913 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 23 Any economic use of the subject property would result in a reduction of the recommended 100- foot buffer because of the proximity of any development on the property to wetland habitat. The CCC has permitted more intensive uses that resulted in direct impacts to sensitive coastal resources, consistent with the mandate of Coastal Act § 30010 that prevents taking of private property without compensation (see CCC Appeal Numbers A-2-SMC-11-040 & A-2-SMC-11- 041)2 concerning a controversial project near Half Moon Bay that was ultimately approved). 2 https://documents.coastal.ca.gov/reports/2013/12/W18a-12-2013.pdf 2-19-0026
Exhibit 5

1.g
Packet Pg. 3153 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6914 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 24

5. REPORT PREPARATION AND REFERENCES

5.1 REPORT PREPARATION
Coast Ridge Ecology, LLC
1410 31st Ave
San Francisco, CA 94122
Field work and report preparation were completed by Patrick Kobernus (Senior Biologist) and Greg Pfau (Associate Biologist).

5.2 REFERENCES
Commercial Development for Norcal Surf Shop 505 San Pedro Ave., A.P.N. -23-072-010, Pacifica. Project Plans dated: 01/20/2016.

Baldwin, B. G., D. H. Goldman, D. J. Keil, R. Patterson, T. J. Rosatti, and D. H. Wilken, editors. 2012. The Jepson manual: vascular plants of California, second edition. University of California Press, Berkeley.

US Army Corps of Engineers, Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report Y-87-1, U.S. Army Engineer Waterways Experiment Station. Vicksburg, Miss.

US Army Corps of Engineers, Environmental Laboratory. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys and Coast Region (Version 2.0). U.S. Army Engineer Research and Development Center, Vicksburg, MS.

ERDC/EL TR-10-03. May 2010.

CNPS. 2019. A Manual of California Vegetation, Online
Edition. http://www.cnps.org/cnps/vegetation/; searched on October 21, 2019. California Native Plant Society, Sacramento, CA.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3154 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6915 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation – November 2019 Page 25 Lichvar, R.W, D. L. Banks, W. N. Kirchner and N. C. Melvin. 2016. The National Wetland Plant List: 2016 wetland ratings. Phytoneuron 2016-30: 1-17. Available online at http://rsgisias.crrel.usace.army.mil/NWPL/# . Accessed on September 17, 2019.

Munsell Soil Color Charts Year 2000 Revised Washable Edition. 2000. Munsell Color. Grand Rapids, MI.

Sawyer, John; Keeler-Wolf, T.; and Evans, J., 2009. A Manual of California Vegetation, second edition. California Native Plant Society, Sacramento.

Natural Resources Conservation Service, United States Department of Agriculture. Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/. Accessed October 21, 2019.

United States Department of Agriculture. Soil Conservation Science (USDA SCS). 1991. Soil Survey of San Mateo County, Eastern Part, and San Francisco County, California. Available online at http://soildatamart.nrcs.usda.gov . October 21, 2019.

UCSB, 2019. University California Santa Barbara, California Aerial Photography by County (On-Line Library). Accessed October 25, 2019.
https://www.library.ucsb.edu/src/airphotos/california-aerial-photography-county Wood Biological Consulting. 2019. One-Parameter Wetland Delineation for the Proposed Norcal Surf Shop Mixed-use Development, San Mateo County, California. 2-19-0026
Exhibit 5

1.g
Packet Pg. 3155 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6916 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation Page A-1

APPENDIX A
Wetland determination data forms
2-19-0026
Exhibit 5

1.g
Packet Pg. 3156 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6917 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region Project/Site: NorCal Surf Shop City/County: Pacifica, SMC Sampling Date: 10/21/2019 Applicant/Owner: Shawn Rhodes State: CA Sampling Point: A1 Investigator(s): Patrick Kobernus Section, Township, Range:

Landform (hillslope, terrace, etc.): Channel bank Local relief (concave, convex, none): Convex Slope (%): 50 Subregion (LRR): California Lat: 37.595406 Long: -122.506549 Datum: NAD83 Soil Map Unit Name: Urban NWI classification: None
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes x No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No x
Hydric Soil Present? Yes No x Is the Sampled Area within a Wetland? Yes No x Wetland Hydrology Present? Yes No x
Remarks:

Delineation is being done at request of CA Coastal Commission and potential wetland area is adjacent to, but not on, applicant’s property.

VEGETATION – Use scientific names of plants.

Tree Stratum (Plot size: )
Absolute
% Cover
Dominant
Species?
Indicator
Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: 2m r )

1. Ligustrum ovilifolium 20 Y -NS2.

3. 4.

5. 20 = Total Cover
Herb Stratum (Plot size: 2m r )

1. Delairea odorata 15 N -NS2. Persicaria amphibia 10 N OBL

3. Urtica dioica 5 N FAC

4. 5.

6. 7.

8. 9.

10. 11.
30 = Total Cover
Woody Vine Stratum (Plot size: 2m r )

1. Rubus ursinus 50 Y FACU

2. 50 = Total Cover
% Bare Ground in Herb Stratum
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: 0 (A)
Total Number of Dominant
Species Across All Strata: 2 (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: 0 (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:
1 - Rapid Test for Hydrophytic Vegetation
2 - Dominance Test is >50%
3 - Prevalence Index is ≤3.01
4 - Morphological Adaptations1 (Provide supporting
data in Remarks or on a separate sheet)
5 - Wetland Non-Vascular Plants1
Problematic Hydrophytic Vegetation1 (Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present? Yes No x
Remarks:
2-19-0026
Exhibit 5

1.g
Packet Pg. 3157 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6918 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: A1
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth
(inches)
Matrix Redox Features
Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 5YR 3/2 100 Sandy loam
1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)
Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3)
Thick Dark Surface (A12) Redox Dark Surface (F6) 3
Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic
Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)
Sandy Gleyed Matrix (S4) Redox Depressions (F8)
Restrictive Layer (if present):

Type: Hydric Soil Present? Yes No x
Depth (inches):

Remarks:

Uniform color to soil, combined with urban fill (concrete, brick, and other refuse)

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1)
Water-Stained Leaves (B9) (except
MLRA 1, 2, 4A, and 4B)
Water-Stained Leaves (B9) (MLRA 1, 2,
4A, and 4B)
High Water Table (A2) Salt Crust (B11) Drainage Patterns (B10) Saturation (A3) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Water Marks (B1) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Sediment Deposits (B2)
Oxidized Rhizospheres along Living
Roots (C3) Geomorphic Position (D2)
Drift Deposits (B3) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Algal Mat or Crust (B4)
Recent Iron Reduction in Tilled
Soils (C6) FAC-Neutral Test (D5)
Iron Deposits (B5)
Stunted or Stressed Plants (D1)
(LRR A) Raised Ant Mounds (D6) (LRR A)
Surface Soil Cracks (B6) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Inundation Visible on Aerial Imagery (B7)
Sparsely Vegetated Concave Surface (B8)
Field Observations:

Surface Water Present? Yes No x Depth (inches):

Water Table Present? Yes No x Depth (inches): Wetland Hydrology Present? Yes No x Saturation Present?
(includes capillary fringe) Yes No x Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

No hydrologic indicators present.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3158 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6919 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region Project/Site: NorCal Surf Shop City/County: Pacifica, SMC Sampling Date: 10/21/2019 Applicant/Owner: Shawn Rhodes State: CA Sampling Point: A2 Investigator(s): Patrick Kobernus Section, Township, Range:

Landform (hillslope, terrace, etc.): Channel bed Local relief (concave, convex, none): Concave Slope (%): 0 Subregion (LRR): California Lat: 37.595406 Long: -122.506549 Datum: NAD83 Soil Map Unit Name: Urban NWI classification: None
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes x No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes x No
Hydric Soil Present? Yes x No Is the Sampled Area within a Wetland? Yes x No Wetland Hydrology Present? Yes x No
Remarks:

Delineation is being done at request of CA Coastal Commission and potential wetland area is adjacent to, but not on, applicant’s property.

VEGETATION – Use scientific names of plants.

Tree Stratum (Plot size: )
Absolute
% Cover
Dominant
Species?
Indicator
Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. 20 = Total Cover
Herb Stratum (Plot size: 2m r )

1. Persicaria amphibia 35 Y OBL

2. Rubus crispus 55 Y FAC

3. Scirpus microcarpus 5 N OBL

4. Potentilla anserina 5 N OBL

5. 6.

7. 8.

9. 10.

11. 100 = Total Cover
Woody Vine Stratum (Plot size: )

1. 2.
= Total Cover
% Bare Ground in Herb Stratum
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: 2 (A)
Total Number of Dominant
Species Across All Strata: 2 (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: 100 (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:
1 - Rapid Test for Hydrophytic Vegetation
x 2 - Dominance Test is >50%
3 - Prevalence Index is ≤3.01
4 - Morphological Adaptations1 (Provide supporting
data in Remarks or on a separate sheet)
5 - Wetland Non-Vascular Plants1
Problematic Hydrophytic Vegetation1 (Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present? Yes x No
Remarks:
2-19-0026
Exhibit 5

1.g
Packet Pg. 3159 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6920 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: A2
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth
(inches)
Matrix Redox Features
Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 10YR 3/1 100
Sandy clay
loam
1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)
Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3)
Thick Dark Surface (A12) x Redox Dark Surface (F6) 3
Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic
Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)
Sandy Gleyed Matrix (S4) Redox Depressions (F8)
Restrictive Layer (if present):

Type: Hydric Soil Present? Yes x No
Depth (inches):

Remarks:

Uniform color to soil, combined with urban fill (concrete, brick, and other refuse)

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1)
Water-Stained Leaves (B9) (except
MLRA 1, 2, 4A, and 4B)
Water-Stained Leaves (B9) (MLRA 1, 2,
4A, and 4B)
High Water Table (A2) Salt Crust (B11) Drainage Patterns (B10) Saturation (A3) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Water Marks (B1) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Sediment Deposits (B2)
Oxidized Rhizospheres along Living
Roots (C3) Geomorphic Position (D2)
Drift Deposits (B3) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Algal Mat or Crust (B4)
Recent Iron Reduction in Tilled
Soils (C6) FAC-Neutral Test (D5)
Iron Deposits (B5)
Stunted or Stressed Plants (D1)
(LRR A) Raised Ant Mounds (D6) (LRR A)
x Surface Soil Cracks (B6) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Inundation Visible on Aerial Imagery (B7)
Sparsely Vegetated Concave Surface (B8)
Field Observations:

Surface Water Present? Yes x No Depth (inches):

Water Table Present? Yes x No Depth (inches): Wetland Hydrology Present? Yes x No Saturation Present?
(includes capillary fringe) Yes x No Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:
2-19-0026
Exhibit 5

1.g
Packet Pg. 3160 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6921 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region Project/Site: NorCal Surf Shop City/County: Pacifica, SMC Sampling Date: 10/21/2019 Applicant/Owner: Shawn Rhodes State: CA Sampling Point: A3 Investigator(s): Patrick Kobernus Section, Township, Range:

Landform (hillslope, terrace, etc.): Channel bank Local relief (concave, convex, none): Convex Slope (%): 100 Subregion (LRR): California Lat: 37.594600 Long: -122.507276 Datum: NAD83 Soil Map Unit Name: Urban NWI classification: None
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes x No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No x
Hydric Soil Present? Yes No x Is the Sampled Area within a Wetland? Yes No x Wetland Hydrology Present? Yes No x
Remarks:

Delineation is being done at request of CA Coastal Commission and potential wetland area is adjacent to, but not on, applicant’s property.

VEGETATION – Use scientific names of plants.

Tree Stratum (Plot size:
10 m r )
Absolute
% Cover
Dominant
Species?
Indicator
Status

1. Eucalyptus globulus 60 Y -NS2.

3. 4.
60 = Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. = Total Cover
Herb Stratum (Plot size: 2m r )

1. Tropaeolum majus 65 Y UPL

2. Conium maculatum 5 N FAC

3. Zantedeschia aethiopica 5 N -NS4. Solanum nigrum 15 N FACU

5. 6.

7. 8.

9. 10.

11. 90 = Total Cover
Woody Vine Stratum (Plot size: 2m r )

1. Rubus ursinus 10 N FACU

2. 10 = Total Cover
% Bare Ground in Herb Stratum
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: 0 (A)
Total Number of Dominant
Species Across All Strata: 2 (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: 0 (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:
1 - Rapid Test for Hydrophytic Vegetation
2 - Dominance Test is >50%
3 - Prevalence Index is ≤3.01
4 - Morphological Adaptations1 (Provide supporting
data in Remarks or on a separate sheet)
5 - Wetland Non-Vascular Plants1
Problematic Hydrophytic Vegetation1 (Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present? Yes No x
Remarks:
2-19-0026
Exhibit 5

1.g
Packet Pg. 3161 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6922 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: A3
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth
(inches)
Matrix Redox Features
Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 5YR 3/3 100 Sandy loam
1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)
Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3)
Thick Dark Surface (A12) Redox Dark Surface (F6) 3
Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic
Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)
Sandy Gleyed Matrix (S4) Redox Depressions (F8)
Restrictive Layer (if present):

Type: Hydric Soil Present? Yes No x
Depth (inches):

Remarks:

Uniform color to soil, combined with urban fill (concrete, brick, and other refuse)

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1)
Water-Stained Leaves (B9) (except
MLRA 1, 2, 4A, and 4B)
Water-Stained Leaves (B9) (MLRA 1, 2,
4A, and 4B)
High Water Table (A2) Salt Crust (B11) Drainage Patterns (B10) Saturation (A3) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Water Marks (B1) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Sediment Deposits (B2)
Oxidized Rhizospheres along Living
Roots (C3) Geomorphic Position (D2)
Drift Deposits (B3) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Algal Mat or Crust (B4)
Recent Iron Reduction in Tilled
Soils (C6) FAC-Neutral Test (D5)
Iron Deposits (B5)
Stunted or Stressed Plants (D1)
(LRR A) Raised Ant Mounds (D6) (LRR A)
Surface Soil Cracks (B6) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Inundation Visible on Aerial Imagery (B7)
Sparsely Vegetated Concave Surface (B8)
Field Observations:

Surface Water Present? Yes No X Depth (inches):

Water Table Present? Yes No X Depth (inches): Wetland Hydrology Present? Yes No x Saturation Present?
(includes capillary fringe) Yes No x Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

No wetland hydrology indicators present
2-19-0026
Exhibit 5

1.g
Packet Pg. 3162 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6923 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region Project/Site: NorCal Surf Shop City/County: Pacifica, SMC Sampling Date: 10/21/2019 Applicant/Owner: Shawn Rhodes State: CA Sampling Point: A4 Investigator(s): Patrick Kobernus Section, Township, Range:

Landform (hillslope, terrace, etc.): Channel bed Local relief (concave, convex, none): Concave Slope (%): 0 Subregion (LRR): California Lat: 37.594600 Long: -122.507276 Datum: NAD83 Soil Map Unit Name: Urban NWI classification: None
Are climatic / hydrologic conditions on the site typical for this time of year? Yes x No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes x No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes X No
Hydric Soil Present? Yes X No Is the Sampled Area within a Wetland? Yes x No Wetland Hydrology Present? Yes x No
Remarks:

Delineation is being done at request of CA Coastal Commission and potential wetland area is adjacent to, but not on, applicant’s property.

VEGETATION – Use scientific names of plants.

Tree Stratum (Plot size: )
Absolute
% Cover
Dominant
Species?
Indicator
Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. = Total Cover
Herb Stratum (Plot size: 2m r )

1. Persicaria amphibia 40 Y OBL

2. Plantago major 5 N FAC

3. Sonchus asper 5 N FACU

4. Raphanus sativus 5 N -NS5.

6. 7.

8. 9.

10. 11.
55 = Total Cover
Woody Vine Stratum (Plot size: )

1. 2.
= Total Cover
% Bare Ground in Herb Stratum
Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: 1 (A)
Total Number of Dominant
Species Across All Strata: 1 (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: 100 (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:
1 - Rapid Test for Hydrophytic Vegetation
x 2 - Dominance Test is >50%
3 - Prevalence Index is ≤3.01
4 - Morphological Adaptations1 (Provide supporting
data in Remarks or on a separate sheet)
5 - Wetland Non-Vascular Plants1
Problematic Hydrophytic Vegetation1 (Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Hydrophytic
Vegetation
Present? Yes x No
Remarks:
2-19-0026
Exhibit 5

1.g
Packet Pg. 3163 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6924 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: A4
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth
(inches)
Matrix Redox Features
Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 10YR 3/1 100 Sandy loam
1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)
Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3)
Thick Dark Surface (A12) x Redox Dark Surface (F6) 3
Indicators of hydrophytic vegetation and
wetland hydrology must be present,
unless disturbed or problematic
Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)
Sandy Gleyed Matrix (S4) Redox Depressions (F8)
Restrictive Layer (if present):

Type: Hydric Soil Present? Yes x No
Depth (inches):

Remarks:

Uniform color to soil, combined with urban fill (concrete, brick, and other refuse)

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1)
Water-Stained Leaves (B9) (except
MLRA 1, 2, 4A, and 4B)
Water-Stained Leaves (B9) (MLRA 1, 2,
4A, and 4B)
High Water Table (A2) Salt Crust (B11) Drainage Patterns (B10) Saturation (A3) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Water Marks (B1) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Sediment Deposits (B2)
Oxidized Rhizospheres along Living
Roots (C3) Geomorphic Position (D2)
Drift Deposits (B3) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Algal Mat or Crust (B4)
Recent Iron Reduction in Tilled
Soils (C6) FAC-Neutral Test (D5)
Iron Deposits (B5)
Stunted or Stressed Plants (D1)
(LRR A) Raised Ant Mounds (D6) (LRR A)
x Surface Soil Cracks (B6) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Inundation Visible on Aerial Imagery (B7)
Sparsely Vegetated Concave Surface (B8)
Field Observations:

Surface Water Present? Yes No X Depth (inches):

Water Table Present? Yes No X Depth (inches): Wetland Hydrology Present? Yes x No Saturation Present?
(includes capillary fringe) Yes No x Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

Electrical cable under channel, bricks, concrete rubble in soil. 2-19-0026
Exhibit 5

1.g
Packet Pg. 3164 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6925 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation Page B-1

APPENDIX B
Representative Photographs
Figure 1. Drainage channel, with Eucalyptus trees. Photo date: 09/18/2019.

Figure 2. Drainage channel with brambles, north end. Photo date: 09/18/2019. 2-19-0026 Exhibit 5

1.g
Packet Pg. 3165 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6926 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation Page B-2
Figure 3. Drainage channel and bank with Eucalyptus, Rumex, Kikuyu grass and Tropaeolum plants. Photo date: 09/18/2019.

Figure 4. Drainage channel with blackberry and grass vegetation. Photo date: 09/18/2019. 2-19-0026
Exhibit 5

1.g
Packet Pg. 3166 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6927 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation Page B-3
Figure 5. Top of berm, (505 San Pedro Ave. property) looking north. Photo date: 09/18/2019.

Figure 6. Top of berm, (505 San Pedro Ave. property) looking south. Photo date: 09/18/2019. 2-19-0026
Exhibit 5

1.g
Packet Pg. 3167 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6928 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation Page B-4
Figure 7. Wetted channel on south end. Photo date: 09/18/2019.

Figure 8. Drainage channel (data point A4 and sewer line manhole). Photo date: 10/21/2019. 2-19-0026 Exhibit 5

1.g
Packet Pg. 3168 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6929 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation Page B-5
Figure 9. Channel bottom near data point A2 showing mud cracks. Photo date: 10/21/2019.

Figure 10. Channel bottom. Data point A2. Photo date: 10/21/2109. 2-19-0026
Exhibit 5

1.g
Packet Pg. 3169 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6930 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve NorCal Surf Shop Project Wetland Delineation Page C-1 APPENDIX C Soil Survey Map
2-19-0026
Exhibit 5

1.g
Packet Pg. 3170 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6931 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Soil Map—San Mateo County, Eastern Part, and San Francisco County, California (Drainage Channel adjacent to 505 San Pedro Avenue)
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
11/19/2019

4160830 4160860 4160890 4160920 4160950 4160980 4161010 4161040 4161070 4161100 4161130 4160830 4160860 4160890 4160920 4160950 4160980 4161010 4161040 4161070 4161100 4161130 543420 543450 543480 543510 543540 543570 543600 543630 543420 543450 543480 543510 543540 543570 543600 543630 37° 35' 46'' N
122° 30' 29'' W
37° 35' 46'' N
122° 30' 20'' W
37° 35' 36'' N
122° 30' 29'' W
37° 35' 36'' N
122° 30' 20'' W
N
Map projection: Web Mercator Corner coordinates: WGS84 Edge tics: UTM Zone 10N WGS84 0 50 100 200 300
Feet
020 40 80 120
Meters
Map Scale: 1:1,530 if printed on A portrait (8.5" x 11") sheet.

Soil Map may not be valid at this scale.
2-19-0026
Exhibit 5

1.g
Packet Pg. 3171 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6932 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

MAP LEGEND MAP INFORMATION
Area of Interest (AOI)
Area of Interest (AOI)
Soils
Soil Map Unit Polygons
Soil Map Unit Lines
Soil Map Unit Points
Special Point Features
Blowout
Borrow Pit
Clay Spot
Closed Depression
Gravel Pit
Gravelly Spot
Landfill
Lava Flow
Marsh or swamp
Mine or Quarry
Miscellaneous Water
Perennial Water
Rock Outcrop
Saline Spot
Sandy Spot
Severely Eroded Spot
Sinkhole
Slide or Slip
Sodic Spot
Spoil Area
Stony Spot
Very Stony Spot
Wet Spot
Other
Special Line Features
Water Features
Streams and Canals
Transportation
Rails
Interstate Highways
US Routes
Major Roads
Local Roads
Background
Aerial Photography
The soil surveys that comprise your AOI were mapped at
1:24,000.

Warning: Soil Map may not be valid at this scale.

Enlargement of maps beyond the scale of mapping can cause misunderstanding of the detail of mapping and accuracy of soil line placement. The maps do not show the small areas of contrasting soils that could have been shown at a more detailed scale.

Please rely on the bar scale on each map sheet for map
measurements.

Source of Map: Natural Resources Conservation Service
Web Soil Survey URL:

Coordinate System: Web Mercator (EPSG:3857)
Maps from the Web Soil Survey are based on the Web Mercator projection, which preserves direction and shape but distorts distance and area. A projection that preserves area, such as the Albers equal-area conic projection, should be used if more accurate calculations of distance or area are required.

This product is generated from the USDA-NRCS certified data as of the version date(s) listed below.

Soil Survey Area: San Mateo County, Eastern Part, and San Francisco County, California
Survey Area Data: Version 15, Sep 16, 2019
Soil map units are labeled (as space allows) for map scales 1:50,000 or larger.

Date(s) aerial images were photographed: Apr 29, 2019—Jun 5, 2019
The orthophoto or other base map on which the soil lines were compiled and digitized probably differs from the background imagery displayed on these maps. As a result, some minor shifting of map unit boundaries may be evident.

Soil Map—San Mateo County, Eastern Part, and San Francisco County, California (Drainage Channel adjacent to 505 San Pedro Avenue)
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
11/19/2019

2-19-0026
Exhibit 5

1.g
Packet Pg. 3172
Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6933
Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Map Unit Legend
Map Unit Symbol Map Unit Name Acres in AOI Percent of AOI 121 Orthents, cut and fill, 0 to 15
percent slopes

5.1 43.0%
124 Orthents, cut and fill-Urban
land complex, 5 to 75
percent slopes

0.2 2.0%
131 Urban land 6.3 54.0%
138 Beaches 0.1 1.0%
Totals for Area of Interest 11.7 100.0%
Soil Map—San Mateo County, Eastern Part, and San Francisco County, California Drainage Channel adjacent to 505 San Pedro Avenue
Natural Resources
Conservation Service
Web Soil Survey
National Cooperative Soil Survey
11/19/2019
2-19-0026 Page 3 of 3
Exhibit 5

1.g
Packet Pg. 3173 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6934 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve f
Page I of 1
Horrisberger, Christina
From: Renee Anahda [rana/
Sent: Wednesday, May 19, 2010 1:14 PM
To: Horrisberger, Christina·
Cc: y onguines, Raymond
Subject FW: APN 023--072-010 Study Session
Christlna,
It appears you didn't receive my comments (originally sent on May 13th). Please see the forwarded message below. Sorry for any inconveniences. Thank you.

From: Renee Ananda
Sent: Thursday, May 13, 2010 2:49 PM
To: '
Cc: Renee Ananda
Subject: APN 023-072-010 Study Session
Hello Christina,
This is a follow-up to our conversation (on Monday 5110) re, the applicant's (Shawn Rhodes') preliminary proposal to construct a·z-story commercial-residential unit, a surf shop, and storage shop (a total of 3 structures) and a skate board park on a vacant tot west of San Pedro Point Shoppfng Center. The plans we received are preliminary and serve for early discussions of what would be required for the potential development project.

Please note my preliminary comments below:

The site is located within the Coastal Zone. ft appears that a majority of the site is in an area under the retained jurisdiction the Coastal Commission. The applicant w1fl need to obtain a Coastal Development Permit from the Coastal Commissic>n.

The Commission is concernecvabout the development's consistency with the Coastal Act (particularly Chapter 3, Article 6., Developmen!),JhJ_fefore potential imi:,,mt~.lo b. lological resourcesJcoaslaf views, public access to_the coast (1.e., public beaches), and its visuaf·compat1b11ity With the character ot"the surrounding area. /l"he applicant should include an analysis of traffic that would be generated by the development and assocfated impacts to vehicular public access to the coastJ
The design of the proposed project should consider measures to avoid or reduce potential impacts to the adjacent wetlands and drainage area, as these most likely nneet the definition of a wetlands under the Coastal Act. The applioant should provide an evaluation. of the proposed/potential development's impact on biological resources localed on and adjacent to the site.

These comments do not preclude additional comments Commission staff may have on the proposal, as planning and permitting processes progress.

Thank you for the opportunity to provide you with comments. RTA , ,5/19/2010
2-19-0026
Exhibit 6

1.g
Packet Pg. 3174 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6935 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 2-19-0026
Exhibit 6

1.g
Packet Pg. 3175 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6936 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

STATE OF CALIFORNIA-NATURAL RESOURCES AGENCY

CALIFORNIA COASTAL COMMISSION NORTH CENTRAL COAST DISTRICT OFFICE 45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415)
FAX: (415)
WEB: WWW.COASTAL.CA.GOV
Kathryn F arb stein
Assistant Planner
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA
94044
EDMUND G. BROWN JR., GOVERNOR
May 8, 2015
Subject: Commission Staff Comments on Development Review Coordination for Proposed Project at 505 San Pedro Avenue, Pacifica, CA
Dear Ms. Farbstein:

Thank you for the opportunity to comment on the Development Review Coordination materials for the proposed development of a 2 story retail building plus basement, covered skate park, 2 story storage building, parking lol am12 story mixed use building with 2 residential units at 505 San Pedro Avenue, Pacifica, CA. The proposed development will cover approximately 13,000 square feet on the 37,000 square feet lot with the surf shop totaling 3,500 square feet, the storage building totaling 1,540 square feet and the retail/residential building totaling 2,516 square feet.

The development also proposes a total of26 parking spaces-24 uncovered spots and 2 covered spots.

Coastal Commission Staff has previously sent comments on this development proposal (see attached May 13,2010 email from Renee Ananda and my email from October 30, 2014) citing concerns regarding the proposed development's potential impacts to biological resources, public views, access to the coast, compatibility with surrounding development, and to traffic.

Specifically, our concerns consist of the proposed project's potential impacts to the sensitive biological resources present and associated with the intermittent stream that bmmds the western edge of the subject parcel, potential flooding and geotechnical issues, hardscape protection concerns regardingform of the proposed installation of rip rap on the banks of the intermittent stream, the appropriateness of residential use on this parcel and finally, future parking and access conflicts with the adjacent shopping center use. In addition, Commission Staff raised jurisdictional issues in our previous comments because it appears the subject parcel is located within a split jurisdiction between the City and Coastal Commission coastal permit jurisdiction, either requiring the applicant to apply for two separate coastal development permits or a consolidated permit handled by the Commission (with permission from the applicant and the City).

With regard to biological resources, the 2005 biological report prepared for the subject property found that given the parcel's close proximity to San Pedro Creek, California red-legged frogs 1 2-19-0026
Exhibit 6

1.g
Packet Pg. 3176 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6937 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve (CRLF) are likely to be "present and breeding within the immediate area of the surrmmding property," along the high quality habitat of the creek. The subject site is constrained by the presence of the drainage, on the western edge of the parcel that the 2005 biological report by Thomas Reid Associates determined was likely to provide a dispersal corridor for CRLF, especially given the drainage's proximity to San Pedro Creek. This drainage was deemed an "intermittent stream" in the biological report. Because of the presence of this drainage, it is also likely that the adjacent upland habitats may provide refugia for CRLF and upland areas to aestivate. Because of the parcel's constrained shape, it is unlikely the development could be adequately buffered from the drainage in order to avoid sensitive habitat impacts. LCP Policies protect intermittent streams, requiring that such streams shall be "protected, enhanced and restored where feasible"; also requiring that adequate buffer zones be identified to protect habitat areas associated with the stream. LCP Policy C-99 requires that in general, a buffer of at least I 00 feet measured from the outward edge of the vegetation would be appropriate, unless such a buffer is deemed uunecessary. Because the proposed development will immediately abut the drainage edge, and the upland habitats are proposed to be removed for future development or paved over, this proposed project does not confonn to the LCP policies protecting sensitive habitats.

With regard to geotechnical issues, plans dated October 7, 2014 proposed rip rap be installed along the ban1c of the drainage per the recommendation of the geotechnical engineer. The current plans appear to remove this aspect of the development but still propose to install a concrete curb wall with wood railing at the drainage edge. LCP Policies found on page C-1 05 state that since erosion is a problem in Pacifica, a report by the United States Army Corps of Engineers found that in many cases shoreline [protection] structures are not economically justified and would be allowable to protect on1y "major beach access or highly sensitive habitat." Further, if such protections are allowed as part of any development LCP Policy C-1 05 requires that a qualified expert should analyze and propose mitigation for such structures. Further, LCP Policy C-1 01 requires that development in habitat support areas, such as on the banks of this stream, carmot disrupt habitat and must minimize erosion. Given these limitations and the development's proximity to the drainage which provides flood storage capacity for the surrounding areas, it is unclear how the proposed development will be protected from flooding and erosion. Commission Staff has seen no analysis of flooding impacts to the proposed development including without the use of streambank alteration, but such an analysis would be required given the development's proximity to the drainage at the western edge of the parcel and its association with San Pedro Creek.

Finally, with regard to the development's, size, scope, intensity and type of use, Conunission Staff has concerns that locating new residential and other mixed-use/retail development so close to the already existing shopping center may have traffic impacts on the already-impacted Highway I in this area, and subsequent impacts to public access to the coast. No traffic analysis has been shared with Coastal Commission staff. In addition, the parcel is zoned C-2 "Conununity Conunercial District," which conditionally allows residential uses only when they are located entirely above the ground floor. Residential development in C-2 zones is further controlled by a minimum lot area per dwelling unit of 2,000 square feet. Further, development in the C-2 zones located in the Coastal Zone that propose a new use other than visitor-serving commercial use, require a Use Permit determination that demands "an analysis of the balance of visitor-serving commercial uses with other commercial uses, and consistency with the individual neighborhood narratives and the plan conclusions and other relevant policies of the ... Land Use 2 2-19-0026
Exhibit 6

1.g
Packet Pg. 3177 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6938 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Plan" (per Implementation Plan Sec. 9-4.1 002). The proposed development, if allowable at all given the biological and potential flood resource concerns, would need to be designed to fit the individual narrative of the neighborhood and other requiremeots of the LUP that are specific to the Pedro Point neighborhood.

If you have any questions regarding these comments or wish to discuss the project further, please contact me at
Sincerely,
Stephanie Rexing, Coastal Planner
Encl. May 13,2010 Email
October 30,2014 Email
3 2-19-0026
Exhibit 6

1.g
Packet Pg. 3178 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6939 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Response to Comments
505 San Pedro Avenue Project
June 2018
6 Letter 2
2-2
2-1
2-5
2-3
2-7
2-6
2-8
2-4
2-19-0026
Exhibit 6

1.g
Packet Pg. 3179 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6940 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Response to Comments
505 San Pedro Avenue Project
June 2018
7 2-8
Cont’d
Letter 2
Cont’d
2-9
2-19-0026
Exhibit 6

1.g
Packet Pg. 3180 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6941 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

ANNAPOLIS FIELD STATION
Coastal Plant Observatory
Plant Ecology Serving Conservation
33660 Annapolis Road
Annapolis, California 95412

1 MEMORANDUM
To: Jim Browning, U.S. Fish and Wildlife Service, SFWO, Sacramento From: Peter Baye, Ph.D., coastal plant ecologist
Date: 4 May 2005
SUBJECT: Documentation of California red-legged frog occurrence at Pedro Point, Pacifica, San Mateo County
Jim, I am reporting to USFWS directly the attached documentation of a California redlegged frog population at Pedro Point. The site is a drainage ditch in an historic floodplain of Pedro Creek, recently proposed for residential development. The site is somewhat isolated from Pedro Creek by Highway 1, a road, buildings, and parking lots, but has drainage connections to the mouth of the creek.

LOCATION: Pedro Point Road opposite Grand Avenue, Pedro Point, Pacifica, San Mateo County. Southeast corner of Calson/”Archdiocese” Pedro Point Field.

SETTING: Drainage ditch through blue gum windbreak between commercial shopping plaza and mown grassy field with seasonal wetlands, approximately 0.25 mi from Pedro Creek. See photo attached.

HABITAT CONDITIONS: Road drainage ditch and culvert fed by seasonal to perennial seeps in hillslopes of developed residential area and historic blue gum/Monterey pine plantation. Blue gum-shaded pool less than 3 m diameter, up to 25 cm deep currently, minimal vegetation; mostly flood-deposited sand and silt; abundant non-native wetland vegetation downstream, but no perennial ponds or cattail/tule marsh.

OBSERVED OCCURRENCE: 3 Adult CRLF observed; one within culvert, one at pool edge of concrete culvert support, one submerged at depth of 10 cm. No tree frogs present in pool, but present in downstream portions of ditch system. Photos attached of two CRLF, one highly visible, one obscure (submerged silhouette). Visual observation and photos 5/3/05. Multiple aural detections of diving frogs April; no visual detections in turbid water.

No egg masses observed within visible upper 10 cm of water column.

NEARBY OCCURRENCES: Other confirmed CRLF observations in last 2 years at mouth of Calera Creek (Quarry), with San Francisco garter snake, approx 1.5 mile north. Likely 2-19-0026
Exhibit 7

1.g
Packet Pg. 3181 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6942 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

ANNAPOLIS FIELD STATION
Coastal Plant Observatory
Plant Ecology Serving Conservation
33660 Annapolis Road
Annapolis, California 95412

2 occurrence in Pedro Creek floodplain wetlands, perennial freshwater marsh. Garter snakes (likely San Francisco ssp.) also present in residential area gardens, yards.

POTENTIAL THREATS: Residential development proposed for adjacent field; likely to require improved drainage. Drainage problems of adjacent Pedro Road may require repair work; some recently implemented.
(a) (b)
Figure 1: (a) Culvert and scour pool with lobe of flood sediment. (b) Detail of pool and sack-concrete dam. Adult CRLF head emergent at edge of sack-concrete, next to woody debris (sticks) at extreme left. 5/3/05.
2-19-0026
Exhibit 7

1.g
Packet Pg. 3182 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6943 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

ANNAPOLIS FIELD STATION
Coastal Plant Observatory
Plant Ecology Serving Conservation
33660 Annapolis Road
Annapolis, California 95412

3 Figure 2. Adult California red-legged frog at edge of sack-concrete dam of culvert. 5/3/05 2-19-0026
Exhibit 7

1.g
Packet Pg. 3183 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6944 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

ANNAPOLIS FIELD STATION
Coastal Plant Observatory
Plant Ecology Serving Conservation
33660 Annapolis Road
Annapolis, California 95412

4 Figure 3. Submerged silhouette of second CRLF in pool. 2-19-0026
Exhibit 7

1.g
Packet Pg. 3184 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6945 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412
Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 1 Lee Diaz July 7, 2014
Associate Planner
City of Pacifica
Planning Department
1800 Francisco Boulevard
Pacifica, CA 94044

SUBJECT: Draft Environmental Impact Report for The Pacifica General Plan Update Project – SCH No. No. #2012022046
Dear Mr. Diaz,
The comments below regarding the Draft Environmental Impact Report for the Pacifica General Plan Update Project (DEIR) are submitted on behalf of the Pedro Point Community Association, but represent my independent, best professional judgment.

I have reviewed the DEIR sections relevant to assessment of biological resources, land use policies, and selected relevant portions covering hydrology and geology for CEQA compliance and for LCP amendment compliance with the Coastal Act. I have also conducted site visits of the Pedro Point field (also “undeveloped San Pedro Ave site” and described as “vacant” in the DEIR, General Plan and Local Coastal Plan documents) in all seasons since 2000.

My qualifications to provide expert comments are based on nearly 35 years of professional work in coastal wetland and terrestrial ecology, with over 20 years in San Francisco Estuary wetlands, including long-term direct knowledge of the estuarine wetlands, special-status species, and diked baylands in the project area. A statement of my qualifications is attached hereto as Attachment A.

My comments focus on the potentially adverse environmental impacts of proposed changes in the land use designation of the Pedro Point neighborhood. 2-19-0026
Exhibit 8

1.g
Packet Pg. 3185 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6946 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 2 Summary of Comments

1. Environmental Baseline: The DEIR provides contradictory information about the vegetation of the Pedro Point field, asserting that it supports “northern coastal scrub”, an upland vegetation type absent in the grassy field, and that it supports wetlands. The field supports seasonal wetlands. The DEIR fails to disclose the importance of these wetlands in terms of the environmental setting of San Pedro Creek mouth wetlands in the Coastal Zone (the field is the last remaining historical floodplain of the lower San Pedro Creek Valley that has not been developed in the Coastal Zone) and the local distribution of ESHA (Environmentally Sensitive Habitat Areas) supporting California red-legged frogs.

2. Biological Impacts to Wetlands and Special-status Species: The DEIR fails to analyze any biological impacts caused by conversion of the existing Pedro Point field to a land use designation of “Coastal Residential Mixed Use development”. The DEIR fails to programmatically assess impacts at a neighborhood-specific level as it did in the 1980 General Plan, and it fails to consider general impacts of residential development on extensive seasonal wetlands and ESHA in and around the field. The proposed land use change for the field is likely to cause significant impacts to wetlands, wildlife, and special-status species for which no feasible mitigation has been identified, and for which no feasible mitigation probably exists.

3. Land Use Impacts. The DEIR fails to analyze land use impacts caused by changing the land use of the field from a general “Commercial” use (1980 General Plan) to a more specific and different “Coastal Residential Mixed Use” designation. This change for the field’s designated land use causes significant impacts (conflicts with) to the City’s own land use policies and numerous Coastal Commission land use policies that cannot be mitigated, and are not mitigated by the vague, programmatic mitigation measures cited in the DEIR.

4. Conclusion. The DEIR fails to disclose important biological resources, and their distribution and relationship to other biological resources and communities in the environmental setting of lower San Pedro Creek. This precludes meaningful public comment and DEIR analysis of significant impacts to biological resources and land use policies that are likely to occur. The DEIR should be recirculated to correct the flawed environmental baseline and defective impact analysis, and should identify reasonable alternatives that either lessen significant impacts, or are otherwise environmentally preferable.

1. Environmental Baseline
The DEIR presents inconsistent and erroneous biological baseline description of the existing conditions of the Pedro Point field and its vicinity. The errors, omissions, and contradictory environmental baseline description results in erroneous conclusions that the project (General Plan) will have no significant biological impacts. Neighborhood-specific assessments of proposed General Plan land use changes are lacking for Pedro Point, its field, and for the DEIR in general. 2-19-0026
Exhibit 8

1.g
Packet Pg. 3186 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6947 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 3 Assessment of biological and land use impacts to the Pedro Point neighborhood requires reference to existing physical and biological environmental conditions (2014; approximately the time of the EIR’s notice of preparation), and the existing land use designations from the 1980 General Plan. The existing biological conditions of the Pedro Point field – the last undeveloped lowland open space within the historical floodplain of San Pedro Creek – is inaccurately and inconsistently represented in the DEIR’s figures and text. These errors result in underestimation of significant biological impacts, as discussed below.

1.1 Mapped DEIR Wetlands, Vegetation and Habitats – physical and biological baseline The DEIR provides contradictory and confused (and confusing) information about the existing biological conditions of the Pedro Point field. Figure 3.7-1 (Vegetation; DEIR p. 3.7-3) maps most of the field in the color-code (pale olive green) corresponding with “Northern Coastal Scrub” (an upland vegetation type associated with coastal hillslopes and bluffs), and part of the field color-coded gray as “urban” land use but overlapping with the “wetlands” symbol. This is contradictory and erroneous environmental baseline information. There are in fact no stands of northern coastal scrub vegetation at all within or around the Pedro Point field. The shrubs on the railroad berm are ornamental non-native plantings. No part of the field is “urban” cover type, as misrepresented in the figure; no paved or developed areas with structures exist in the field. Figure 3.1-1 shows the “Existing land use” color-coded gray as “Vacant/Undeveloped”, which is also inconsistent with “urban” land use, but consistent with “wetlands”. The map also misrepresents mixed ornamental, non-native, and native coastal bluff scrub vegetation northwest of the field as “beach/intertidal” habitat. The two major color-coded map units for the Pedro Point field, “urban” and “northern coastal scrub” are incorrect.
2-19-0026
Exhibit 8

1.g
Packet Pg. 3187 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6948 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 4 Excerpted section of Figure 3.7-1 of the DEIR “Vegetation” map (above) showing Pedro Point field with paper streets between Dannman and San Pedro Ave. The setting within the Draft Local Coastal Plan (2014) as represented as “Undeveloped San Pedro Ave Site”, is shown in a portion of Figure 4.8 (left).

Only one map symbol (pattern) for the vacant/undeveloped Pedro Point field in Figure 3.7-1 is accurate: “wetlands” classified by the U.S. Fish and Wildlife Service National Wetlands Inventory at coarse scale, as shown also in DEIR figure 3.7-2. The Pedro Point field itself is dominated by non-native grasses and herbaceous broadleaf plants, including seasonal wetland and non-wetland vegetation. Both maps omit the distinct seasonal and perennial wetlands of the drainage swale at the east end of the field, which drain to San Pedro Creek through a series of culverts. The drainage swale wetlands, the wetland connectivity to San Pedro Creek mouth, and the extensive perennial wetlands (Freshwater Marsh) of San Pedro Creek are entirely missing from the vegetation map of Figure 3.7-1.

Other errors describing habitat and vegetation are evident in the DEIR’s descriptions of existing conditions in the coastal zone. For example, the DEIR confuses coastal strand (beaches and dunes) with coastal bluff scrub, and states that the plant sea-rocket (Cakile maritima) is a dominant species of “coastal bluff scrub”. Sea-rocket is a non-native species common on sand beaches and low foredunes (like those 2-19-0026
Exhibit 8

1.g
Packet Pg. 3188 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6949 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 5 of Pacifica State Beach), but does not occur at all in coastal bluff scrub in Pacifica or elsewhere, let alone as a dominant species. The description of coastal bluff scrub combines species that simply do not occur together in natural or disturbed environments of Pacifica.

1.2. Wetland classification of the Pedro Point field and vicinity: existing conditions Based on my recent and past site visits, I know that the existing vegetation of the Pedro Point field consists of predominantly annual and perennial, herbaceous, non-native seasonal wetland and upland grassland vegetation. Seasonal wetland grassland occupies a mosaic of depressions, ditches, and swales.

Mesic grassland (seasonally wet but lacking a prevalence of wetland indicator plants) occupies portions of the higher elevation zones of the site, primarily to the southwest corner. The wetland depressions are indicated by seasonally high density of toad rush (Juncus bufonius, FACW, facultative-wet indicator in arid west), co-occuring with European ryegrass (Festuca perenne; syn. Lolium perenne; FAC, facultative wetland indicator in arid west) and buck’s-horn plaintain (Plantago coronopus; FACW, facultative-wet indicator in arid west). Some of the wettest depressions support populations of Lilaea scilloides (flowering quillwort). Flowering quillwort is evident only in the wettest years when pools stay flooded for many weeks or months. Accurate wetland plant identification and measurement of the seasonal wetland patches at this site are possible only during winter to spring months. Desiccation, disturbance (trampling, mowing, discing) eliminates or degrades wetland vegetation and precludes accurate identification in fall and summer. Similarly, accurate assessment of wetland hydrology is feasible only during the rainy season, during and within two weeks following major rainfall events.

The USFWS classification of Pedro Point Field wetlands shows wetlands distributed over approximately all of the site, as shown in DEIR Figures 3.7-1 and 3.7-2. Past and current National Wetland Inventory (“NWI”) maps consistently apply wetland classifications to approximately all of the field. Two current classifications of the field’s wetlands include the codes “PEMah” and “PUSCh”, both “palustrine” (freshwater emergent, non-tidal) seasonal, and consistent with the seasonally flooded hydrology associated with surrounding berms. The “U” (unconsolidated shore) probably is associated with intermittent unvegetated (disced, vegetation disturbed) conditions. The NWI wetland mapping of the field broad-brush treatment of prevailing past wetland distribution, but the precision of the NWI wetland type boundaries is not precise enough for the DEIR to represent as “existing conditions” in 2014 CEQA assessment. In my professional opinion, “wetlands” meeting the jurisdictional criteria for Coastal Commission (“Commission”) policies, and classification as “wetland” under the Cowardin (U.S. Fish and Wildlife Service, USFWS) system, are in fact present and widely distributed over the Pedro Point field today, despite past unauthorized ditching and drainage activities (see wetland history, below).

Despite DEIR’s inclusion of NWI mapped wetlands in some figures, the DEIR fails to apply the NWI wetland mapping and classification (as well any current field reconnaissance observations to update or verify them) to any meaningful biological assessment of potential wetland impacts of land use 2-19-0026
Exhibit 8

1.g
Packet Pg. 3189 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6950 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 6 designation changes to the field, and assessment of alternatives. The DEIR fails to assess the extent and distribution of the field’s seasonal wetlands (meeting Cowardin/California Coastal Commission wetland criteria) in relation to land use changes proposed. The DEIR does not consider the accuracy or distribution of the (old) NWI wetland maps based on existing field conditions. Specifically, the DEIR does not analyze whether the field’s wetlands are localized or extensively distributed in the field, so it cannot analyze whether it is even feasible to designate a coastal residential mixed-use development without committing the City’s General Plan to significant wetland impacts, in conflict with its own land use policies and Coastal Act policies.

Further, because of the DEIR’s omissions about wetland impacts, comparison of alternatives will lack relevant information about feasible land use alternatives that may avoid or minimize wetland impacts, and which may be environmentally preferable. Examples of environmentally preferable alternatives consistent with City and Coastal Act policies include existing “Commercial” land use (with and without “Commercial-Recreation” zoning) compatible with low-intensity visitor-serving commercial recreation/tourism-promoting uses; or “Conservation” - all of which are consistent with City policies for tourism destination, avoidance of natural hazards, wetland conservation, and consistency with recreational, scenic values that Coastal Act policies give priority over residential development.

1.3. Wetland jurisdiction and CEQA
The DEIR cites multiple state and federal wetland jurisdictions. With respect to assessment of biological impacts to wetlands, USFWS (NWI, Cowardin wetland classification), California Coastal Act, and California Department of Fish and Wildlife wetland policy definitions are applicable because these are fundamentally based on habitat, hydrogeomorphic features, and ecological functions. In contrast the narrowest federal definition (U.S. Army Corps of Engineers and Environmental Protection Agency; USACE/EPA) under the Clean Water Act is specifically limited to legal wetland definition for jurisdiction over authorization of discharges of earthen fill regulated under Section 404 of the Clean Water Act. The USACE/EPA wetland definition contains federal exemptions and policy disclaimers that are not relevant to biological impact assessment under CEQA, and it is a narrower and more exclusive definition that is likely to underestimate the extent of habitat-based or hydrogeomorphic definitions appropriate for impact assessment.

The California Coastal Act Section 30231 defines a wetland as:
…lands within the coastal zone which may be covered periodically or permanently with shallow water and include saltwater marshes, freshwater marshes, open or closed brackish water marshes, swamps, mudflats, and fens.
2-19-0026
Exhibit 8

1.g
Packet Pg. 3190 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6951 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 7 Similarly, the Cowardin (USFWS, NWI) wetland classification uses a general broad definition of wetlands:

Wetlands are lands transitional between terrestrial and aquatic systems where the water table is usually at or near the surface or the land is covered by shallow water.

California Coastal Act jurisdictional wetlands criteria in the California Code of Regulations at 14 14 CCR Section 13577 establish a “one-parameter definition” that only requires evidence of a single wetland parameter to establish wetland conditions, in contrast with federal wetlands criteria under the Clean Water Act:

Wetland shall be defined as land where the water table is at, near, or above the land surface long enough to promote the formation of hydric soils or to support the growth of hydrophytes, and shall also include those types of wetlands where vegetation is lacking and soil is poorly developed or absent as a result of frequent and drastic fluctuations of surface water levels, wave action, water flow, turbidity or high concentrations of salts…
The Commission’s one-parameter definition is similar to the USFWS wetlands criteria, which state that wetlands must have one or more of the following three attributes:
(1) at least periodically the land supports predominantly hydrophytes; (2) the substrate is predominantly undrained hydric soil; and (3) the substrate is nonsoil and is saturated with water or covered by shallow water at some time during the growing season of each year.

In contrast, the U.S. Army Corps of Engineers (USACE) and the Environmental Protection Agency use a three parameter definition for delineating wetlands under Clean Water Act jurisdiction, which is relevant only in context of USACE permit authorization for discharges of fill in jurisdictional waters of the United States. The USACE definition is narrower than those of the Coastal Commission (relevant to LCP) and USFWS (relevant to wetland impact assessment under CEQA, not limited to fill discharges and subject to federal exemptions irrelevant to CEQA).

The City’s wetland policies (Land Use; DEIR p. 3.1-21) cite both USACE/EPA and Coastal Commission wetland definitions. CO-I-5, CO-I-6 cites both, and CO-I-8 cites State (CDFW/CCC) wetlands only. The narrower USACE/EPA definition is relevant only to those land use policy elements that specifically cite it in context of wetland fill permits. The USACE/EPA jurisdictional wetlands are not the proper standard for determining consistency of GPU consistency with Coastal Act wetlands policies, or wetland impacts under CEQA. This should be corrected in the EIR, or else the EIR will not provide accurate conclusions about Pedro Point field land use impacts regarding wetlands in context of CEQA or Coastal Act policies.

1.4. Special-status species and Environmentally Sensitive Habitat Areas (ESHA): California red-legged frogs (Rana draytonii) environmental baseline 2-19-0026
Exhibit 8

1.g
Packet Pg. 3191 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6952 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 8 California red-legged frogs (Rana draytonii; CRLF) occur in the freshwater marsh drainage swale bordering the Pedro Point Field along its eastern edge. I reported their presence to the U.S. Fish and Wildlife Service Sacramento Fish and Wildlife Office, Endangered Species Program in 2005. If the DEIR preparers had consulted properly with state and federal wildlife agencies, or local residents, about the local distribution of special-status or other wildlife species, this information would have been available to include in the DEIR. The DEIR, however, failed to disclose the local sub-population of CRLF in the drainage swale bordering the field, and its relationship with the population of the lower San Pedro Creek wetland complex.

I have observed adult red-legged frogs are most often observable basking along muddy or prostrate grass banks near the culverts draining San Pedro Avenue at the southeast corner of the field. The perennial moisture in this swale provides year-round hydration habitat for CRLF, as well as foraging and potential breeding habitat. CRLF breeding is indicated by intermittent local population increases in redlegged frogs here, most notably in 2010. Foraging activities of CRLF likely extend to adjacent nonwetland flats (rich in invertebrate prey) in the field during moist, foggy nighttime and early morning conditions. I am not aware of protocol nighttime surveys for California red-legged frog conducted either in the freshwater marsh swale adjacent to the field, or in the field itself. The vicinity of the freshwater marsh swale and field are a complex of foraging, basking, dispersal, and breeding wetland and upland habitat for California red-legged frogs. It thus also meets criteria for Environmentally Sensitive Habitat Areas (ESHA) under California Coastal Commission regulations. The DEIR fails to include this information about CRLF at and in proximity to the field.

In addition, the DEIR fails to analyze the potential adverse, significant impacts to CRLF from the proposed land use changes. Land use designations that would foreseeably increase the intensity of land use, such as the proposed redesignation to allow residential development or other substantial increases in the built environment, may have significant direct and indirect impacts on CRLF. The proposed residential mixed-use development of the field would likely (a) substantially reduce available nocturnal foraging habitat for CRLF (food and prey base impacts to growth and survival; (b) increase contaminant loads in the drainage swale due to runoff from driveways, roads, and backyard sources of pesticides, petroleum hydrocarbons, solvents, and detergents (reproductive impacts); (c) increase peak flow velocities in the swale during major storm runoff events (juvenile mortality impacts).

Not only has the DEIR not assessed such impacts, it has not identified feasible programmatic mitigation measures. Feasible mitigation for ESHA/California red-legged frog habitat and frog populations must include measures to (a) avoid and minimize “take” of individual frogs, (b) avoid and minimize impacts to CRLF habitat; and (c) provide adequate buffer zones to minimize adverse effects of incompatible adjacent land uses. The spatial structure of CRLF mitigation aligned with the freshwater marsh swale bordering the field may substantially constrain the feasibility of some incompatible land use designations, especially any that increase runoff, contaminants or pesticides, predator pressure on CRLF, 2-19-0026
Exhibit 8

1.g
Packet Pg. 3192 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6953 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 9 or reduce the extent or quality of potential productive nighttime foraging habitat. The Bolsa Chica court decision [Bolsa Chica Land Trust v. Superior Court 71 Cal. Ap.4th 493, 507] confirmed that the Coastal Act requires that ESHA be avoided and buffered from development impacts and that providing compensatory mitigation alone is insufficient as ESHA mitigation.

Intermittent breeding habitat of California red-legged frogs in freshwater marsh swale bordering the southeast corner of the field, near roadside culverts. An adult CRLF is shown at the concrete base of foundation culvert on August 20, 2006, after the field ditch connections were breached to the swale north of this pool. CRLF frequently bask in the western muddy or grassy banks of this pool in wet (non-drought) years.

1.5. Wetland context and cumulative impacts: environmental setting of Pedro Point The DEIR also omisrepresents the existing environmental setting and context of the wetlands of the Pedro Point field. The field’s wetlands are represented as completely isolated from any other significant wetlands or potential wetland-dependent endangered species habitats. See Figures 3.1-1, 3.7-1, 3.7-2, and

3.7-3, all of which fail to show the San Pedro Creek mouth wetlands and their riparian wetland habitat, vegetation and hydrological connections with Pedro Point field and its wetlands. The San Pedro Creek stream mouth wetlands, however, are shown as red-legged frog habitat (marsh, creek, and riparian vegetation) in Figure 3.7-1, but without their wetland connections to the Pedro Point field and drainage swale wetlands. The omission of the San Pedro Creek mouth wetlands in the Coastal Zone is either arbitrarily selective or at least inconsistent in the DEIR: the riparian corridor and wetlands upstream of Highway 1, outside the coastal zone, are represented in Figure 3.7-1 and 3.7-4, but not in Figure 3.7-2.

This error of selective omission of wetlands in the project vicinity appears to be due to the DEIR’s failure to critically interpret and update National Wetlands Inventory map with even cursory examination of readily available current aerial or satellite imagery of San Pedro Creek mouth (e.g., Google Earth), or field reconnaissance surveys of the conspicuous restored freshwater marsh there. 2-19-0026
Exhibit 8

1.g
Packet Pg. 3193 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6954 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 10 Figure 3.7-2, “National Wetlands Inventory Wetlands”, completely fails to represent the perennial freshwater emergent marsh and freshwater streams of San Pedro Creek mouth as they existed at the time of the DEIR’s notice of preparation, and as they have existed for about a decade. The DEIR cannot uncritically transfer NWI map data without checking for errors of omission due to outdated data layers.

The NWI wetland classification (Cowardin USFWS classification system) provides sufficient clear wetland criteria to identify the obvious wetlands (cattail and tule marsh vegetation 6 to over 10 feet tall with standing water) at the mouth of San Pedro Creek. This marsh is clearly known to the City of Pacifica, which was the local partner in the project that restored it.

The adjacent San Pedro Creek mouth freshwater marsh is very significant as an environmental setting of the seasonal wetlands of the Pedro Point field. Ecological connectivity (wildlife corridors for wetland-dependent wildlife) exists between the creek mouth marsh and the field, provided by the drainage swale wetlands (not currently channelized; infilled with sediment and wetland vegetation) consisting of willow swamp (riparian scrub) and freshwater marsh dominated by broadleaf wetland forbs and grasses.

The environmental setting and potential Project and cumulative impacts to wetlands at the Pedro Point field are related to their hydrogeomorphic setting and historical origins and development. The preagricultural “natural” condition of the field was freshwater nontidal marsh within the floodplain of San Pedro Creek (San Pedro Valley lowlands). The modern field was part of complex of freshwater marsh and swamp (alder-willow) surrounding Lake Mathilda (the freshwater lagoon outlet of San Pedro Creek prior to channelization), behind the barrier beach (San Pedro Beach). The rich organic fine-grained alluvial soils were converted to agricultural cropland (artichoke fields) by draining and ditching in the late 19th century. The field apparently persisted with either low-intensity agricultural use (grazing, haying) into the 1950s or early 1960s when Linda Mar was extensively developed. Some fill was placed on at least portions of the field in recent decades, but differential subsidence in the flat to very gently sloping (<2%) field maintained depressional microtopography (shallow swales, pools) to the present day.

I have observed the Pedro Point field since the year 2000 in all seasons. Wet (saturated to seasonally flooded) depressions in the field persisted for weeks to months, supporting typical seasonal wetlands grasslands dominated by ryegrss, toad rush, buck’s-horn plaintain in winter-spring months. In addition, a regionally rare vernal pool/pond plant, the flowering quillwort (Lilaea scilloides) occurred in local abundance in several pools. In January, 2006, the current landowner and assistants manually excavated diagonal ditches and side-cast fill (ditch spoils) across the field, apparently with the intent of draining the field. In August 2006, mechanical equipment breached wide gaps in the berm between the field and the adjacent drainage swale marsh. These drainage activities were apparently completed without benefit of a Coastal Development Permit or authorization from the U.S. Army Corps of Engineers.

Despite the 2006 drainage ditching and subsequent maintenance and repeated discing of the field, depressional wetlands have persisted and re-emerged (due in part to differential settlement and choking of 2-19-0026
Exhibit 8

1.g
Packet Pg. 3194 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6955 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 11 ditches) in the field. The ditching appears to have reduced the duration and extent of wetland hydrology, but significant wetland areas remain widely distributed across most of the field, including the original seasonal wetland plant community.

Excerpt of U.S. Coast Survey map of San Francisco Peninsula, 1869, based on 1850s topography: San Pedro Creek Valley and beach, now Linda Mar. Approximate location of San Pedro Field (Calson/former Archdiocese property) in red shows the relationship of the modern field wetlands to the historical valley floodplain wetland complex.

Parallel horizontal hatched lines indicate freshwater marsh. Stippled shoreline area indicates sandy beach, dune, washover. Fine horizontal hatching is open freshwater (Lake Mathilda; historical Pedro Creek Lagoon, drained for agriculture 19th century). Irregular circles/dots within marsh = wooded freshwater swamp (alder, willow). No scale.

Extensive seasonal flooding of
the Pedro Point Field during the
transition between the historical
agricultural era (derelict or lowintensity agricultural use) and suburban development of Linda
Mar in San Pedro Valley
lowlands (background), likely
1950s-early 1960s. View to
E/SE. The eucalyptus and
Monterey cypress trees at the
fenceline correspond the mature
trees present today along the
drainage swale at the east end of
Approximate
location modern
San Pedro Field flats

SAN PEDRO
VALLEY

FRESHWATER
MARSH

FRESHWATER MARSH
(horizontal hatching)

FRESHWATER SWAMP
2-19-0026
Exhibit 8

1.g
Packet Pg. 3195 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6956 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 12 the field. The extensive seasonal pond likely represents flooding patterns prior to partial filling of the wetlands.

Flooding patterns delineate undrained depressions of shallow open water in a matrix of saturated soils in San Pedro Field following heavy rainfall. December 26, 2005. View to N.

Shorebirds (likely sanderlings) forage in the seasonally saturated and flooded field during high tide and storm wave conditions that restrict foraging habitat availability on the adjacent San Pedro (Pacifica State) Beach. December 27, 2005, prior to unauthorized ditching of the field. Red-necked phalaropes also forage in the saturated to flooded field during winter storms.
2-19-0026
Exhibit 8

1.g
Packet Pg. 3196 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6957 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 13 January 19, 2006. Manual excavation of drainage ditches in flooded field at the east end of the field. Grass grows above water surface. Water in bare spots can be seen as reflected sunlight on the field; emergent unvegetated mud is dark brown.

2-19-0026
Exhibit 8

1.g
Packet Pg. 3197 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6958 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 14 During discing of the field in summer, the berm along the east end of the field was mechanically breached at multiple locations to connect new drainage ditches (excavated in seasonal wetlands of the field) to the large drainage swale occupied by California red-legged frogs, draining to San Pedro Creek through culverts at the northwest end.

August 20, 2006.

Despite new unauthorized ditching and drainage connections of the field, ditches merely reduce the extent and duration of soil saturation and flooding; they do not eliminate wetland conditions in the winter following ditching.

December 27, 2006
Today, wildlife in the seasonal wetlands of the Pedro Point field includes shorebirds, meadowlarks, black-tail deer, tree frogs, small mammals, and raptors, all of which move between the field wetlands, the adjacent drainage swale wetlands, uplands, and the mouth of San Pedro Creek. Sanderlings and red-necked phalaropes occur intermittently in the flooded to saturated fields, particularly during high tides and storm wave conditions that flood the beach.. In summer, meadowlarks inhabit the field some years, particularly when grass and forb vegetation cover is thick. Small mammals, including mice, pocket gophers, and voles, occur frequently in the field (indicated by burrows, runs) and provide a prey base for raptors, including great horned owls (roosting in eucalyptus trees near the field), and red-tail hawks. Deer browse in the field at night, and at times in the morning as well. The marsh swale bordering the east end 2-19-0026
Exhibit 8

1.g
Packet Pg. 3198 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6959 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 15 of the field has supported a breeding population of tree frogs (Pseudacris sierra) and a population of federally listed threatened California red-legged frogs (Rana draytonii) most years at least since 2000 (see special-status species, below). The DEIR fails to disclose intermittent red-legged frog populations in the vicinity (and sometimes directly bordering) the field, and the existence of probably nocturnal foraging habitat (for this species spring-fall non-breeding adults) within in the field itself. The DEIR failed to identify these significant wildlife movement and habitat connections between the field and habitats in its wetland setting. The DEIR fails to analyze potentially significant impacts to red-legged frogs using the field that would be affected by proposed conversion to coastal residential mixed use development.

The DEIR’s failure to correctly characterize the wetland environmental setting (the wetland complex comprising the San Pedro Creek mouth wetlands, the drainage swale wetlands, and the historical and existing condition of the Pedro Point field wetlands) prevents the DEIR from accurately analyzing potentially significant cumulative impacts caused by wetland habitat loss, degradation or fragmentation in the lower San Pedro Creek corridor, and the Pedro Point neighborhood.

Given the outstanding biological significance of the field as the only open, level (flatland) space left in the Pedro Point neighborhood, and despite years of being the focus of substantial public concern and comment in scoping and other public meetings, the DEIR’s failure to provide even minimally accurate, consistent baseline environmental description of the field is a very serious defect in the DEIR.

It precludes accurate assessment of potentially significant impacts that are not mitigated at the policy or site-specific level.

1.6. Biological Resource Impact Assessment and Mitigation in the DEIR Despite identifying wetlands occurring potentially throughout the field, the DEIR fails to assess potential adverse, significant impacts to Coastal Act wetlands from the proposed land use designation changes at the Pedro Point Field. The DEIR provides no explanation why converting existing wetlands of the Pedro Point field to residential mixed use development would have no significant biological or land use policy impacts. The DEIR omits any specific reference at all to the Pedro Point field wetlands in discussion of biological impacts.

Further, the DEIR’s cumulative impact analysis must consider that the extent of Coastal Act wetlands in the field was modified by ditching and drainage activities conducted by the landowner and assistants on January 19, 2006, during conditions of saturation and widespread flooding of the field. As far as I am aware, ditching and draining activities of these wetlands occurred without issuance of a Coastal Development Permit or analysis of environmental impacts. The apparently unauthorized drainage of the field probably results in underestimation of the actual extent of proper Coastal Commission jurisdictional wetlands in the field. See wetland history, below. The errors in the DEIR’s environmental baseline, described above, contribute to basic errors in assessment of significant biological impacts and mitigation to wetlands and special-status species.
2-19-0026
Exhibit 8

1.g
Packet Pg. 3199 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6960 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 16 The DEIR identifies only two potential general city-wide biological impacts, without areaspecific reference to Pedro Point neighborhood and the specific land use changes proposed in the revised General Plan. Both of these impacts are incorrectly assessed with respect to Pedro Point biological resources, and their proposed programmatic (policy-level) mitigation is infeasible applied to Pedro Point field.

Figure 3.1-2 of the DEIR (p. 3.1-9; “Existing General Plan Land Use”) shows the majority of the Pedro Point field mapped in red (“Commercial”), and apparently one small lot in the northwest corner of the field mapped in light yellow-orange (“low density residential”). The biological impacts of this proposed land use change must be assessed at a programmatic level, commensurate with the level of detail of land use designation change in the programmatic EIR at neighborhood-scale. The DEIR, however, fails to assess biological impacts at this geographic scale even at a programmatic level. It merely assesses biological impacts at a sweeping, vague, city-wide, policy level, omitting neighborhoodlevel biological impacts of specific land use changes proposed (DEIR p. 3.7-48 Impact 3.7-1; p. 3.7-57, Impact 3.7-3). The DEIR also provides only vague, policy-level “mitigation” (pseudo-mitigation; purely speculative policy without reference to physical or biological conditions) for land use change impacts in the aggregate, city-wide:

Impact 3.7-1 Implementation of the proposed General Plan would not have a substantial adverse effect, either directly or through habitat modifications, on candidate, sensitive, or special status species identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service. (Less than Significant)
Impact 3.7-3 Implementation of the proposed General Plan would not have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. (Less than Significant)
The DEIR provides no substantial evidence and no arguments for either impact findings or their level of significance. It is inconsistent with proposed land use changes (coastal residiential mixed-use development) for the field, and the presence of extensive seasonal wetlands and adjacent special-status species populations.

Although the DEIR does not need to assess impacts of land use change at a project-specific level (i.e., it cannot speculate about the design of specific project proposals or their impacts in site-specific detail), it must address biological impacts that are reasonably foreseeable for the type of land uses proposed in the environmental setting under existing conditions. There is only one major land use change proposed in Pedro Point, and the DEIR provides no biological impact or mitigation discussion about it at 2-19-0026
Exhibit 8

1.g
Packet Pg. 3200 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6961 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 17 all – not even the cursory programmatic wetland discussion presented in the Draft Land Use plan itself (LUI-30, p. 4-36, Pacifica Draft Land Use Plan, March 2014). The boilerplate, standard wetland permit discussion in the DEIR at p. 3.7-42 has no substantial bearing on impact or mitigation analysis for wetlands at Pedro Point.

Potentially significant biological impacts of proposed residential land use (development) at the Pedro Point Field and adjacent habitats are enumerated below. These are based on a more adequate characterization of the Pedro Point field wetlands, their relationship to San Pedro Creek wetlands, and their wildlife and hydrological attributes described above. None of these potentially significant biological impacts were analyzed in the DEIR.

Coastal Zone Wetland impacts
o Direct filling (loss) of the last coastal zone seasonal wetlands in Pedro Point watershed due to residential development. Lack of available off-site compensatory mitigation area within the coastal zone of the San Pedro Creek watershed (no feasible compensatory mitigation).
o Degradation of remaining coastal zone wetlands (wetland swale east of field) the San Pedro Creek watershed due to hydrological changes; increased impermeable surfaced area, decreased groundwater infiltration, increased storm runoff from drained residential lots within basin (historic floodplain).
o Degradation of remaining wetlands (wetland swale east of field) due to increased contaminant loading from adjacent residential development: pesticides (residential pesticide use and pesticide loading from runoff and drainage), increased petroleum hydrocarbon contaminant loads from street and driveway runoff; increased surfactant runoff to the drainage swale from residential car washing.

Wildlife and Special-status species impacts
o Loss of storm high tide refuge habitat for shorebirds o Loss of meadowlark foraging habitat
o Loss of nocturnal deer browsing habitat
o Loss of raptor foraging habitat (Great Horned Owl, red-tail hawk, kestrel) o Loss of terrestrial foraging habitat for California red-legged frogs o Loss of flood refuge habitat for California red-legged frogs during peak flood events of San Pedro Creek.
2-19-0026
Exhibit 8

1.g
Packet Pg. 3201 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6962 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 18 2.0 Land Use Impacts – Coastal Zone
The DEIR proposes to change the land use designation of the Pedro Point field from “Commercial” (Pacifica General Plan, pp. 86 and 90; DEIR Figure 3.1-2) to “Coastal Residential Mixed Use“ (CRMU; DEIR Figure 2.2-1). The DEIR inaccurately states that the new proposed CRMU designation corresponds with an existing “Mixed Use” land use category (Table 3.1-3), but no such independent or category or subcategory of “mixed use” exists in the 1980 General Plan; “mixed use” is simply described as a contingent allowable use of “commercial” land use in the original General Plan (1980 General Plan p. 32-33). The project description is inconsistent, incorrect, and confusing in terms of existing and proposed land uses.

The 2014 Draft General Plan Land Use element states the following with regard to the CRMU designation on p. 4-24: “The Plan retains flexibility for any future development on the vacant site west of the shopping center, which could have residential and small-scale commercial and visitor-oriented uses.

Future development should include a small park and access to the berm and the beach beyond”. Table 4.1 of the Draft General Plan states that residential density with CRMU designation may range between 10- 15 gross units per acre.

The DEIR, in contrast with the original 1980 General Plan, fails to assess even at a programmatic level the area-specific effects of proposed land use designations for the Pedro Point neighborhood, and specifically for the vacant Pedro Point field, in terms of land use impacts (cf. 1980 General Plan, pp. 84- 89). The DEIR gives no reason why the level of specificity for impact assessment should be broader and more programmatic than the level of specificity for individual parcel land use designations like the Pedro Point field, or why the level of neighborhood-specific assessment should be significantly less than that of the 1980 General Plan’s treatment of Pedro Point, especially in the Coastal Zone.

The existing land use designation of the field, “commercial” is compatible with low-intensity, visitorserving commercial recreational land uses that support coastal-dependent (beach and coastal scenic) recreation and associated economic uses, which matches the existing zoning (commercial-recreation) of the field. Low-intensity commercial land uses that do not involve ditching, draining, filling, paving, or construction in the field (open-space and recreational uses, special events, coastal agriculture) are potentially compatible with conservation of wetlands, environmentally sensitive habitat areas, and special-status species, and relevant Coastal Act policies. Proposed Coastal Residential Mixed Use land uses, however, are likely to have significant impacts on Coastal Act land use policies (cited in Draft Pacifica Local Coastal Land Use Plan, March 2014, Appendix A) and Pacifica General Plan policies involving these elements, as discussed below.

The extensive distribution of Coastal Act jurisdictional wetlands in the Pedro Point field, and the presence of California red-legged frog habitat and population in the adjacent freshwater marsh swale, 2-19-0026
Exhibit 8

1.g
Packet Pg. 3202 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6963 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 19 both indicate that land use designations for the field must be compatible with ESHA policies of the Coastal Commission. According to the Coastal Commission’s LCP Update Guide: Sensitive Habitats and Natural Resources (April 3, 2007 update), the DEIR and LCP should clearly state that only “resource dependent” development, such as restoration or nature study, is allowed in ESHA, consistent with Coastal Act §30240. No ESHA assessment for the proposed changes in land use designation of the Pedro Point field has been provided in the DEIR, which is likely related to the DEIR’s failure to accurately identify wetlands and special-status species at the site. The DEIR must be revised to include this analysis of potentially significant environmental impacts even at a programmatic level.

The 1980 Pacifica General Plan provided a programmatic analysis of consistency between proposed (commercial) land use designation of the Pedro Point Field and specific Coastal Act policies (1980 General Plan p. 86), including assessment of unimproved coastal access through foot trails (p. 88).

The DEIR for the General Plan update has provided no such analysis for proposed changed land use designation of the field or coastal access impacts. It merely included the Coastal Act policies as an appendix, without analysis of proposed land use designation change impacts. The changed land use designation has potential significant land use policy conflicts (impacts) with Coastal Act land use policies, each of which affects ESHA (wetlands and special-status wetland-dependent wildlife). Some examples are provided below. The DEIR should fully assess at a programmatic level all such potential significant land use impacts, and compare the compatibility (conflict) of existing, proposed and alternative land use designations for the field in terms of Coastal Act policies.

Section 30212 New development projects
(a) Public access from the nearest public roadway to the shoreline and along the coast shall be provided in new development projects except where:
(1) it is inconsistent with public safety, military security needs, or the protection of fragile coastal resources,
(2) adequate access exists nearby, or,
(3) agriculture would be adversely affected.

Pedro Point field has three well-established and persistent foot trails that lead from San Pedro Avenue (the nearest public roadway to the shoreline) to a private beach with long-established open public access.

The foot trails are visible in aerial photographs dating back to at least 1993 (Google Earth images) and reemerge after being temporarily erased by discing, ditching, or mowing. The foot trails are formed by trampling patterns established between physical points of access from the roadway to a stairway from the beach to the historic railroad berm, and to a public path to the beach at the mouth of San Pedro Creek.

Foot trails are frequently used by beach visitors and surfers seeking minimal travel distances to the beach.

The foot trails evidently established long before the current ownership of the property. The foot trails are the most efficient short cuts from San Pedro Avenue to the public shore; alternative routes along public 2-19-0026
Exhibit 8

1.g
Packet Pg. 3203 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6964 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 20 roads would nearly double foot trail distance from the public roads to the shore from established access points.

Pedro Point field in relation to public and private ocean shores, and freshwater marsh and stream habitat of San Pedro Creek mouth. 2013 Google Earth image.

Pedro Pt
Field
Private beach
with public
shore access
Pacifica
State
Beach
Freshwater
marsh
2-19-0026
Exhibit 8

1.g
Packet Pg. 3204 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6965 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 21 Foot trail network (2013) of Pedro Point Field, showing connections to levee trail access to private shore with long-established public access. Freshwater wetland drainage swale connecting to San Pedro Creek mouth is shown in dashed blue line. 2013 Google Earth image.

Pedro Pt
Field
2-19-0026
Exhibit 8

1.g
Packet Pg. 3205 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6966 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 22 Detail of Pedro Point field foot trail connection to the public access walkway to privately owned beach (with public access) across the historic railroad berm. 2013 Google Earth image.

Proposed coastal residential mixed-use development may potentially eliminate or significantly impair existing long-established public access from San Pedro Avenue to the public shore. This could be mitigated by requirements to provide public access easements along existing trails or equivalent efficient alignments (similar travel distance, slopes, road access points), but the DEIR proposed no mitigation or policy that would ensure such mitigation. The impact and mitigation for this Coastal Act policy were not assessed in the DEIR. There are no military needs, fragile coastal resources, or existing agriculture to provide exemptions for this policy.

Section 30221 Oceanfront land; protection for recreational use and Development Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area.

PEDRO POINT FIELD
stairs
2-19-0026
Exhibit 8

1.g
Packet Pg. 3206 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6967 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 23 The Pedro Point field is separated from the ocean only by the railroad berm, and in its original condition (backbarrier floodplain marsh) it was “oceanfront”, with line of sight to the ocean over the low barrier beach. According to Pedro Point long-term residents, the field has been used for recreation for years prior to and during the current land ownership. Recent recreational uses include children’s games, domestic animal feeding and observation (former llama and emu enclosure along the toe of the railroad berm), ball sports, playground activities extending from the adjacent Pedro Point firehouse playground, and dog walking. The field is suitable for these established recreational uses, and is suitable for other recreational uses as well.

Proposed Coastal Mixed Use Residential land use changes could eliminate, reduce, or substantially interfere with long-established recreational uses of the oceanfront land. This impact is not assessed in the DEIR. The feasibility of mitigation for this impact is not assessed, and no mitigation is proposed.

Recreational uses that depend on extensive area or open scenic views may not be feasible to mitigate with small parks enclosed by development.

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

The proposed change in land use from an open field (compatible with public access, coastal views, and recreation) to a mixed-use private residential development would conflict with this coastal act policy.

This would be a significant impact that, by definition, could not be mitigated. General industrial or commercial development of the field would also conflict with this policy. Commercial development by agriculture including public access and visitor-serving commerce (such as a coastal berry farm, pumpkin farm with visitor-serving amenities), in contrast, would not conflict with this policy. No mitigation is feasible for this conflict, by definition of “priority” of land uses cited in the policy.

Section 30240 Environmentally sensitive habitat areas (ESHA); adjacent developments (a) Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on those resources shall be allowed within those areas.
(b) Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade those areas, and shall be compatible with the continuance of those habitat and recreation areas.
2-19-0026
Exhibit 8

1.g
Packet Pg. 3207 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6968 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 24 The field contains extensive seasonal wetlands (winter-saturated and temporarily flooded depressional wetlands and drainage swales, ditches). The perennial wetlands of the drainage swale at the east end of the field supports California red-legged frog habitat and is typically occupied by a population (see comments in this letter, above). The seasonal wetlands and the zone bordering the frog habitat of the swale meet the definition of ESHA. Residential and mixed use commercial development would likely eliminate, significantly reduce, or degrade existing wetlands and ESHA on the site. Since the field is the last undeveloped lowland floodplain of San Pedro Creek within the Coastal Zone that is available for wetland restoration and enhancement, it is infeasible to mitigate impacts to these wetlands off-site; compensatory mitigation is not available for the red-legged frog populations in lower San Pedro Creek in the coastal zone. The DEIR failed to assess impacts to this Coastal Act policy or propose any feasible mitigation for it. The only feasible mitigation for this policy impact would be avoidance of impacts by not applying the residential mixed use land use designation.

Section 30242. Lands suitable for agricultural use; conversion All other lands suitable for agricultural use shall not be converted to nonagricultural uses unless (l) continued or renewed agricultural use is not feasible, or (2) such conversion would preserve prime agricultural land or concentrate development consistent with Section 30250. Any such permitted conversion shall be compatible with continued agricultural use on surrounding lands. (emphasis added)
The Pedro Point field was historically prime agricultural land, but was abandoned. Nonetheless, renewal of prime agricultural use of the field is potentially feasible (physically and economically) and could be integrated with visitor-serving recreational and economic development aligned with the new coastal trail to Devil’s Slide. The original prime agricultural soils are present beneath shallow fill. The site is suitable for coastal commercial visitor-oriented berry farm or produce farm and related recreational or visitorserving uses (viz. Half Moon Bay to Davenport). Renewed agricultural use combined with tourism, some recreational uses, or eco-tourism may be compatible with conservation of seasonal wetlands and specialstatus wildlife if properly designed. The DEIR failed to consider feasible alternatives compatible with this section.

Section 30243 Productivity of soils and timberlands; conversions The long-term productivity of soils and timberlands shall be protected, and conversions of coastal commercial timberlands in units of commercial size to other uses or their division into units of noncommercial size shall be limited to providing for necessary timber processing and related facilities.

The Pedro Point field is former prime agricultural land (historic artichoke farm) on rich alluvial soils (drained marshland). The soils have been degraded by placement of fill, but may be remediated by either 2-19-0026
Exhibit 8

1.g
Packet Pg. 3208 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6969 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 25 removal of fill or addition of soil amendments to restore agricultural productivity similar to farms on the marine terraces and valleys along the San Mateo Coast south of Pacifica. There are no other potential highly productive historic farmland soils left in the Coastal Zone of Pacifica. Residential development of the field would conflict with this policy that requires the protection of long-term soil productivity. This impact was not assessed or mitigated in the DEIR.

Section 30251 Scenic and visual qualities
The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas. New development in highly scenic areas such as those designated in the California Coastline Preservation and Recreation Plan prepared by the Department of Parks and Recreation and by local government shall be subordinate to the character of its setting.

The Pedro Point field is the last undeveloped lowland (floodplain) in the Coastal Zone of San Pedro Creek’s watershed that retains the original overall floodplain topography and visual character of the historic farms that dominated the valley. All other valley lowlands have been developed in the Coastal Zone of Pacifica, including the Salada Valley (the historical Salada Valley farmland has been developed, drained and filled, with only the deepest lagoon bed remaining as a wetland). The visual character of the adjacent historic railroad berm is dependent on the contrast between the steep relief of the berm and the adjacent lowland flats of the field. Residential development (with or without “pocket parks”) would not protect the scenic and visual qualities of the field and adjacent historic berm. Residential development of the field would fully fill the lowland open space visual character of Pedro Point. This would conflict with the policy.

Section 30253 Minimization of adverse impacts
New development shall do all of the following:
(a) Minimize risks to life and property in areas of high geologic, flood, and fire hazard. (b) Assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs. […]
Most of the Pedro Point field lies approximately 15-17 feet in elevation above Mean Sea Level (MSL), only about 3-5 feet above the marsh and high tide beach at the mouth of San Pedro Creek. In addition, the 2-19-0026
Exhibit 8

1.g
Packet Pg. 3209 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6970 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 26 alluvial soils (historical wetland) of the field have the same relative liquefaction (earthquake shaking) potential as diked bay muds and marshes in San Francisco Bay, like those that underlie filled San Francisco peninsula baylands. (Witter, Robert C., Keith L. Knudsen, Janet M. Sowers, Carl M.

Wentworth, Richard D. Koehler, and Carolyn E. Randolph. 2006. Maps of Quaternary deposits and liquefaction susceptibility, nine-county San Francisco Bay Area. U.S. Geological Survey Open-File Report 2006-1037 Version 1.1; shown in Draft Pacifica Coastal Land Use Plan 2014, Figure 5.1). This condition contrasts with relatively low risk of liquefaction affecting residential and commercial development in adjacent lands built over bedrock. Structural (residential or commercial) development of the field may cause significant conflicts (impacts) with this section. In contrast, this section would be potentially compatible with recreational or other low-intensity commercial development or agricultural redevelopment of the field. The DEIR failed to analyze alternative land use designations compatible with this section.

Similarly, placing additional residential development in the last undeveloped floodplain area within the coastal zone of San Pedro Valley – currently able to function as a flood detention and storage basin when San Pedro Creek is at extreme high flood stage during extreme high tides – would conflict with this land use policy (Draft Pacifica Coastal Land Use Plan 2014 p. 5-19). The intensity, frequency, and significance of this land use policy conflict would likely increase as sea level rises, and as intense storm frequency increases with climate change. In addition, the field lies within a Tsunami evacuation area of the Coastal Zone (Draft Pacifica Coastal Land Use Plan 2014, Figure 5.3). Flooding, liquefaction, sea level rise impacts, increasing over time as indicated by the draft Pacifica Coastal Land Use plan (2014) demonstrate the conflict between this Coastal Act policy and the proposed land use change for Pedro Point field.

Section 30255 Priority of coastal-dependent developments Coastal-dependent developments shall have priority over other developments on or near the shoreline. Except as provided elsewhere in this division, coastal-dependent developments shall not be sited in a wetland. When appropriate, coastal-related developments should be accommodated within reasonable proximity to the coastal-dependent uses they support.

Residential development itself is not fundamentally “coastal dependent”, even if the land use designation nomenclature is “Coastal Residential Mixed Use”. “Coastal” as a modifier does not denote any essential distinction in the nature of residential development, but merely describes its location in the coastal zone.

Other types of commercial development based on recreational access to the shoreline or the distinctive coastal climate (e.g., surfer recreational events, coastal agritourism like berry farm stands with berry farming) would have priority over residential development at this location. Residential development would conflict with this policy. In addition, development within wetlands as defined in the Coastal Act 2-19-0026
Exhibit 8

1.g
Packet Pg. 3210 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6971 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 27 (whether or not they meet federal wetland criteria for fill authorization under the Clean Water Act) would conflict with this policy.

City of Pacifica Land Use Policy Impacts
The DEIR’s proposed change in land use for the Pedro Point field also conflicts (and thus causes a significant land use policy impact) with the City’s own policy on Wetlands Conservation:
p. 3.1-22 CO-I-8 Maintain Functional Capacity of Wetlands. Ensure that any diking, filling, or dredging in existing wetlands maintains or enhances their functional capacity. Any alteration of coastal wetlands identified by the Department of Fish and Game must be limited to very minor incidental public facilities, restorative measures, or nature study, according to the California Coastal Act.

The “functional capacity” of the existing wetlands at the Pedro Point field and adjacent to them are dependent on their geographic setting and landscape position – their relationship to San Pedro Creek (offchannel flood velocity refuge; population buffer for California red-legged frogs; infiltration and groundwater recharge potential; flood detention and flood peak attenuation) and other hydrogeomorphic and ecological functions (red-legged frog nocturnal foraging habitat potential; shorebird storm refuge and roost sites). There are no other undeveloped historic floodplain locations within the lower San Pedro Creek valley, let alone the Coastal Zone, where loss or degradation of these functions could be compensated by wetland restoration Residential development of the field would likely have a significant impact on existing wetlands of the site and its vicinity, and without any feasible mitigation identified.

This City policy is also vague and unenforceable as mitigation for wetland impacts because: (a) it does not cite or define the scope or meaning of the jargon of wetland “functional capacity”; (b) it does not identify any geographic setting within Pacifica for ‘functional capacity” (on-site or off-site/withinwatershed) and (c) it fails to cite or provide any meaningful criteria for what constitutes maintenance or enhancement of “functional capacity”. Furthermore, the California Department of Fish and Wildlife does not delineate or identify coastal wetlands as a service to local governments. The Department and the Coastal Commission use approximately the same wetland indicator criteria for determination of wetlands, but the agencies themselves generally do not conduct wetland delineations. The policy is also misleading as proposed policy-level mitigation in the DEIR because potential wetland fill in context of proposed land use designation changes in the DEIR do not involve restoration, nature study, or public facilities. The DEIR identifies wetlands at the Pedro Point field exactly where it proposes private mixed use residential and commercial development as the new land use designation. This “alteration” does not meet the criteria cited in the policy, and does not involve “enhancement” of functional capacity if the wetlands must be filled or drained for residential or commercial development. The land use designation proposed basically conflicts with this policy, and appears to be an unmitigated significant impact, since no feasible 2-19-0026
Exhibit 8

1.g
Packet Pg. 3211 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6972 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 28 mitigation is identified. Furthermore, the DEIR alleges that no mitigation is even required because it wrongly asserts that there is no impact.

3.0 Conclusions
The DEIR fails to provide adequate analysis of potential impacts and feasible mitigation measures for the proposed land use changes at the Pedro Point field, compared with (a) existing conditions; (b) existing land use designations under the General Plan/LCP, and (c) alternatives that are environmentally superior and compatible with Coastal Act policies. Because the DEIR is fundamentally inadequate, after such revisions, the DEIR should be recirculated for further public review.

Thank you for considering these comments. Please contact me if you have any questions.

Peter Baye
Cc: Pedro Point Community Association
Law Offices of Brian Gaffney APC
Richard Grassetti
California Coastal Commission

2-19-0026
Exhibit 8

1.g
Packet Pg. 3212 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6973 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 29 ATTACHMENT A – STATEMENT OF QUALIFICATIONS - Peter R. Baye, Ph.D.

I am a coastal ecologist and botanist with over 30 years of professional and academic experience. My Ph.D. research in coastal ecology (University of Western Ontario, Canada, Department of Plant Sciences, 1990) was followed by a career in applied ecology in California. I worked for the U.S. Army Corps of Engineers, San Francisco District, where I served as a senior environmental scientist and regulatory project manager conducting endangered species consultation, wetland jurisdictional determinations, wetland assessments, preparing Environmental Assessments and managing joint NEPA/CEQA Environmental Impact Statements/Reports. My Corps regulatory projects included sites adjacent to Port Sonoma (Sonoma Baylands, Carl’s Marsh). Subsequently I worked for the U.S. Fish and Wildlife Service, where I prepared endangered species recovery plans (including comprehensive plans covering all of Marin Baylands and tidal marshes) and endangered species biological opinions. I was a contributing author and participant in the Baylands Ecosystem Habitat Goals Report (Goals Project 1999), its companion volume on Bayland species and community profiles (2000), and its 2014 update (in preparation), for which I developed many Marin bayland recommendations. I have developed or substantially contributed to estuarine wetland restoration and management plans for many Marin coastal wetland sites, including some adjacent to the plan area: Corte Madera Baylands Conceptual Sea Level Rise Adaptation Strategy, prepared by The San Francisco Bay Conservation and Development Commission and ESA PWA (specific focal area: Corte Madera Ecological Reserve marshes); Aramburu Island, Richardson Bay (with Wetlands and Water Resources) and wetland restoration projects at Bahia, Novato (with ESA-PWA) and Bolinas Lagoon (Kent Island, with William Carmen & Associates).
2-19-0026
Exhibit 8

1.g
Packet Pg. 3213 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6974 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 


 















 
! 
#$
$"$"



 

  
  











2-19-0026
Exhibit 9

1.g
Packet Pg. 3214 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6975 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 2-19-0026
Exhibit 9

1.g
Packet Pg. 3215 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6976 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 2-19-0026
Exhibit 9

1.g
Packet Pg. 3216 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6977 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 2-19-0026
Exhibit 9

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

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






!

!!

&
"%
"&



 




 



$




"%

'



 

#$


.,$
.,.,

5%/1%04











!



 
$
 )




.,.,,1-5(-225&
$
.,.,,1-5(-243&
$
.,.,,1-5(-24/&.&
$
.,.,,1-5(-231&.&
$
.,.,,1-5(-253&.&
$
.,-5,.,.(13/2&0&

%9Ā'C;91
$0& Ā1Ā=1BC@1;9ABĀ6@95=4ĀB>>:ĀB85Ā?93BC@5AĀ25;>EĀ>D5@Ā>=Ā*54@>Ā *>9=BĀ;1ABĀ'1=C1@GĀ16B5@Ā>C@Ā.,$/, E9=B5@Ā?;>D5@ĀAC@D5GĀ1BĀ(9=41Ā)1@ !Ā-85Ā;1ABĀ?8>B>ĀE9B8ĀB85Ā3G?@ 5AAĀB@55Ā9AĀ>=ĀB85ĀA<1;;Ā3@55:Ā2589= AB@9?Ā<1;;ĀB81BĀ4@19=AĀB85Ā5=B9@5Ā1@51!ĀĀ-85Ā#+($AĀ6>@175ĀE5ABĀ C?Ā>=B>ĀB85Ā#1;A>=Ā?@>?5@BGĀ1BĀ=978B %>?9=7Ā6>@ĀA><5Ā?5135Ā1=4Ā@5;1F1B9>=Ā6>@ĀG>CĀ>D5@ĀB85Ā8>;941GA! Ā"=4Ā%1??GĀA>;AB935 ĀB>>Ȁ )1@71@5B
----- Forwarded Message -----
Subject: Red-legged Frogs
May 19, 2020
2-19-0026
Exhibit 9

1.g
Packet Pg. 3218 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6979 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve  

!

$
2-19-0026
Exhibit 9

1.g
Packet Pg. 3219 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6980 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve  

"

$
2-19-0026
Exhibit 9

1.g
Packet Pg. 3220 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6981 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve  

#

$
36D>Ā2#Ā1A@6<D9
artist - naturalist - photographer
-)-Ā/@F6Ā1B=E9
2-19-0026
Exhibit 9
Pa
ge 8 of 8

1.g
Packet Pg. 3221 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6982 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve California Natural Diversity Database
Department of Fish and Wildlife
1416 9th Street, Suite 1266
Sacramento, CA 95814
Fax:

CNDDB Online Field Survey Form Report
www.dfg.ca.gov/biogeodata/cnddb/
Source code_____________________
Quad code______________________
Occ. no. ________________________
EO index no._____________________
Map index no.____________________
This data has been reported to the CNDDB, but may not have been evaluated by the CNDDB staff VAS20F0001
3712254
Scientific name: Rana draytonii
Common name: California red-legged frog
Date of field work (mm-dd-yyyy): 04-12-2020
Comment about field work date(s): Field observation in a drainage channel along road near my home on San Pedro Road
Observer: Michael C. Vasey
Affiliation: San Francisco State University
Address: 368 San Pedro Avenue , Pacifica, CA 94044
Email:

Phone: (650)
Other observers: Sheila Harman and Jon Harman

DETERMINATION
Keyed in: Visually and from close up photograph
Compared w/ specimen at:

Compared w/ image in: https://www.nps.gov/rlc/pacificcoast/california-red-legged-frogs.htm By another person:

Other:

Identification explanation: The individual frog was in drainage channel along road. Observation was about 3' away.

Close-up photo taken by Jon Harman (my neighbor) is attached Identification confidence: Confident
Species found: Yes If not found, why not?
Total number of individuals: 1
Collection? No Collection number:

Museum/Herbarium:

ANIMAL INFORMATION
How was the detection made? Seen
Number detected in each age class:

Age class comment: Appears to be juvenile (relatively small) but I'm not an expert adults juveniles larvae egg mass unknown
1 Level of survey effort: Low. Drainage channel along road. Drainage known to harbor CRLF in the past (a few years ago) but they have not been present recently.

OBSERVER INFORMATION
Submitted: 04/20/2020 VAS20F0001 Page 1 of 3
2-19-0026
Exhibit 10

1.g
Packet Pg. 3222 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6983 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Site use description: Drainage channel that drains water from Pedro Point down, across San Pedro Road, and then along east side of Calson field into a willow swale and then into San Pedro Creek near its entry into the ocean.

What was the observed behavior? Resting on floating vegetation half submerged.

Describe any evidence of reproduction: None observed.

SITE INFORMATION
Habitat description: Drainage channel along roadway
Slope: 0 Land owner/manager: City of Pacifica
Site condition + population viability: Fair
Aspect: standing water
Immediate & surrounding land use: 5 acre vacant field known to have been filled during mid 1900's, drainage channel flows east down to 'dogleg' bend and then along eastern boundary of the field until going under some culverts and a swale before entering San Pedro Creek near ocean
Visible disturbances: Recent tree trimming near site but frog observed to persist after this activity. Human and dog traffic into the field but frog about 2-3 feet below banks of channel so reasonably well protected.

Threats: Water could dry up but persisting due to run-off from neighborhood. Non-point source run-off could be polluted. Possible disturbance by people and dogs passing by.

General comments: First sighting of CRLF in around five years. Used to be a larger population, apparently breeding, in the dogleg portion of the channel near the road. So far, only one individual observed.

The mapped feature is accurate within: 5 m
Source of mapped feature: CNDDB Field survey form
ID
County
San Mateo
1 24K Quadrangle Elev. (ft) Latitude
NAD83
Longitude
NAD83
UTM E
NAD83
UTM
Zone
Montara Mountain 18 37.59432 -122.50808 543426 4160920 10 Public Land Survey
M T04S R06W 10
Feature Comment
Drainage channel in 2 feet of standing water
UTM N
NAD83

MAP INFORMATION
Submitted: 04/20/2020 VAS20F0001 Page 2 of 3
2-19-0026
Exhibit 10

1.g
Packet Pg. 3223 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6984 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Attachment(s): CRLF in drainage channel Pedro Point, Pacifica.pdf Mapping notes: Drainage channel along north side of San Pedro Road near junction with Grand Ave in floating algae but clearly visible. Frog has been there persistently since first observed.

Location/directions comments: Take turn off from Hwy 1 and San Pedro Road, cross creek by shopping center, take big curve by Ace Hardware, just past Grand Ave is the drainage channel on north side of road.

Submitted: 04/20/2020 VAS20F0001 Page 3 of 3
2-19-0026
Exhibit 10

1.g
Packet Pg. 3224 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6985 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Presumed California red-legged frog in drainage channel along San Pedro Road – Observed by Sheila Harman, Jon Harman, and Michael Vasey on April 12, 2020. Photo by Jon Harman. 2-19-0026 Exhibit 10

1.g
Packet Pg. 3225
Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6986
Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve STATE OF CALIFORNIA – CALIFORNIA NATURAL RESOURCES AGENCY GAVIN NEWSOM,

GOVERNOR

CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105
VOICE (415) 904- 5200
FAX
WWW.COASTAL.CA.GOV

MEMORANDUM
FROM: Lauren Garske-Garcia, Ph.D. – Senior Ecologist
TO: Julia Koppman Norton – North Central Coast District Analyst Jeannine Manna – North Central Coast District Manager
Dan Carl – North Central Coast District Deputy Director Jessica Reed – North Central Coast Legal Counsel
SUBJECT: 505 San Pedro, Pacifica (APN 023-72-010): Ecological Resources DATE: January 25, 2021
Documents Reviewed:
• California Natural Diversity Database (CNDDB), latest query: January 10, 2021. • Coast Ridge Ecology. Biological Resources Assessment for APN 023-72-010. Prepared for Shawn Rhodes/NorCal Surf Shop, Pacifica, California 94044; March 2015. • Coast Ridge Ecology. 505 San Pedro Avenue, Pacifica Wetland Delineation. Prepared for Shawn Rhodes/NorCal Surf Shop, Pacifica, California 94044; November 2019. • Coast Ridge Ecology. Letter to Shawn Rhodes RE: Observed Change of Flow Conditions of Drainage Channel Adjacent to the Pedro Point Shopping Area and the Proposed NorCal Surf Shop Mixed-Use Development Project, San Mateo County, California. CDP Application 2-19-0026; June 13, 2020. • Live Oak Associates, Inc. Letter to Nick Pappani RE: Biological Resources Assessment Peer Review for the Shawn Rhodes/NorCal Surf Shop project, located in the City of Pacifica, San Mateo County, California (PN 2110-01); January 19, 2017.
• Thomas Reid Associates. 2005a. Biological Assessment Report. APN (023-72-10) Pacifica, CA 94044. For Compliance with San Mateo County Local Coastal Program Policies. Prepared for Rick D Lee and Richard Lee. August 2005.
• Thomas Reid Associates. 2005b. Site Assessment for California Red-Legged Frog. APN (023-72-10) Pacifica, CA 94044. For US Fish and Wildlife Service, Sacramento Field Office. Prepared for Rick D Lee and Richard Lee. August 2005.
2-19-0026
Exhibit 11

1.g
Packet Pg. 3226 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6987 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 2 • Wood Biological Consulting. One-Parameter Wetland Delineation for the Proposed NorCal Surf Shop Mixed-Use Development, San Mateo County, California (CDP Application 2-19-0026). Prepared for Shawn Rhodes, 5460 Pacific Coast Highway, Pacifica, CA 94044; May 14, 2019.

The North Central Coast District has requested a technical analysis of the ecological resources that could be adversely impacted by proposed development at 505 San Pedro Avenue in Pacifica, California (APN 023-72-010).

The project would almost entirely cover the approximately 600-ft long by less than 60 ft-wide parcel with several buildings, a skate park, parking, and pedestrian pathways. The parcel is bounded by Halling Way and a strip mall to the east, San Pedro Avenue to the south, a drainage and an open field to the west, and to the north, a footpath leading to the southern reach of Pacifica State Beach (Figure 1). The adjacent drainage intermittently conveys water, including from westward San Pedro Avenue to a culvert at the northern end of the subject parcel, which connects to the mouth of San Pedro Creek on the opposite side of a shopping center parking lot, approximately 270 feet to the east. Importantly, the parcel is divided between jurisdictions, with approximately one third nearest the sea occurring within the Commission’s retained jurisdiction and the remainder nearest San Pedro Avenue within the City’s jurisdiction – the applicant did not elect to pursue a consolidated permit and the City approved a permit for the portion of the project in its jurisdiction in 2018. The following analysis addresses the Coastal Development Permit (CDP) application submitted to the Commission and my conclusion is summarized on page 12.

History
Since May 2010, when the applicant preliminarily sought consultation with Commission staff, staff has consistently identified concerns regarding wetlands and other biological resources both on and adjacent to the project site. In a letter dated May 8, 2015 to the City of Pacifica concerning review coordination for the proposed project, staff cited a 2005 biological report that characterized the drainage as an intermittent stream, that California red-legged frogs (CRLF) were likely present and breeding in the area surrounding the property, and that the drainage likely served as a dispersal corridor from nearby San Pedro Creek. In the 2015 letter, staff concluded that the proposed project would not conform to Local Coastal Plan (LCP) policies protecting sensitive habitats. In May 2018, staff commented on the project’s Initial Study/Minimum Negative Declaration (IS/MND)1 and again
reiterated concern for both wetlands and sensitive species that may be affected, specifically citing concern for CRLF use of the drainage as a corridor and its movement across adjacent areas including the subject parcel. The City’s response largely dismissed these concerns2
and since that time, staff has continued to reiterate them to the applicant.

Following review of several submitted documents, initial desktop research, and having made an informal roadside visit to the site in March 2019, I and several District staff met with the applicant and their representatives on-site on October 3, 2019. During this visit, ecological concerns were again discussed at length. 1 Email from Patrick Foster, Coastal Commission Analyst, to Christian Murdock, Senior Planner at City of Pacifica RE: 505 San Pedro CEQA Document. May 1, 2018.
2 City of Pacifica. 2018. Response to Comments: 505 San Pedro Avenue Project Initial Study/Mitigated Negative Declaration, Public Review Draft – Agency Comments. June 2018.
2-19-0026
Exhibit 11

1.g
Packet Pg. 3227 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6988 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 3 Wetlands
The 2005 biological report referenced in the Commission staff 2015 letter regarded the drainage adjacent to the subject parcel as an intermittent stream and the California Aquatic Resources Inventory (CARI) maps it as part of a natural fluvial drainage sourcing from across San Pedro Avenue and the forested area behind existing development (Figure 2). The drainage receives flows from the Pedro Point neighborhood, which primarily enter through a culvert directly east of the subject parcel and flow northward until meeting San Pedro Creek. A scour pool has formed at the mouth of the culvert, next to the roadside, and water generally ponds for some distance thereafter, even well after seasonal flows cease (Figure 3). During larger flows, surface water continues along the full length of the drainage paralleling the subject parcel and exits through a culvert largely obscured by the willow thickets at its north end, which daylights within a restoration area on City land for a short distance, enters another culvert, and then flows into San Pedro Creek on the other side of the San Pedro Shopping Center. Aerial imagery shows that throughout the year, the drainage remains largely green with vegetation even when surrounding areas dry out (Figure 4).

Despite suggestions that the drainage be characterized as a stream, I believe it is more accurately treated as wetlands for several reasons. First, while there may be intermittent seasonal surface flows along the length of the drainage between San Pedro Avenue and the northern willow thickets, the scour pool near San Pedro Ave appears to remain a largely wetted feature year-round, while mid-way ponding and flow beyond this is more seasonal, and in the area furthest north, limited to the largest flows. Second, apart from the planted windbreak along the western side of the drainage, which is above the banks and/or normal extent of flows, the drainage largely lacks the multi-strata structure of a typical riparian corridor; instead, the vegetation is primarily composed of an herbaceous layer with some vines and brambles along the eastern bank. Third, the presence of emergent vegetation typical of wetlands (e.g., willows and bulrush) has reportedly increased over time despite the drainage’s relatively degraded state, suggesting the persistence of subsurface water.3 Fourth, a previous biological
assessment report references delineated three-parameter wetlands within the drainage totaling approximately

0.02 ac (Thomas Reid Associates 2005a). Fifth, as detailed in a 2014 comment letter provided by Dr. Peter Baye to the City regarding the Draft Environmental Impact Report for the Pacifica General Plan Update Project, this area was historically a complex of freshwater marsh and alder-willow swamp surrounding what was once Lake Mathilda, a freshwater lagoon outlet of San Pedro Creek prior to its channelization and infill to support the development observed today.4
Finally, the project’s 2018 IS/MND regarded the drainage as a man-made intermittently flowing swale that would be exempt from creek protections under the Local Coastal Land Use Plan (LCLUP) and asserted that the proposed project would have a less-than-significant impact on sensitive resources even though it acknowledged that the drainage would meet the Coastal Commission definition of a wetland (and despite the lack of a proper delineation at that time).5 Wetlands are protected under the Coastal Act by several policies including §30231, which emphasizes the importance of protecting and enhancing water quality and states:

Biological productivity; water quality
The biological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes 3 Baye, P. 2014. Letter to City of Pacifica RE: Draft Environmental Impact Report for the Pacifica General Plan Update Project – SCH #2012022046. 29pp
4 Baye, P. 2014. Ibid.
5 City of Pacifica. 2018. 505 San Pedro Avenue Project Initial Study/Mitigated Negative Declaration, Public Review Draft. April 2018. 2-19-0026
Exhibit 11

1.g
Packet Pg. 3228 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6989 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 4 appropriate to maintain optimum populations of marine organisms and for the protection of human health shall be maintained and, where feasible, restored through, among other means, minimizing adverse effects of waste water discharges and entrainment, controlling runoff, preventing depletion of ground water supplies and substantial interference with surface waterflow, encouraging waste water reclamation, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing alteration of natural streams.

Another key policy is §30233, which limits the allowance of direct impacts to wetlands to specified situations, requires that such action would constitute the least environmentally damaging feasible alternative, and that the impact is minimized and mitigated for:

Diking, filling or dredging; continued movement of sediment and nutrients (a) The diking, filling, or dredging of open coastal waters, wetlands, estuaries, and lakes shall be permitted in accordance with other applicable provisions of this division, where there is no feasible less environmentally damaging alternative, and where feasible mitigation measures have been provided to minimize adverse environmental effects, and shall be limited to the following:
(l) New or expanded port, energy, and coastal-dependent industrial facilities, including commercial fishing facilities.
(2) Maintaining existing, or restoring previously dredged, depths in existing navigational channels, turning basins, vessel berthing and mooring areas, and boat launching ramps. (3) In open coastal waters, other than wetlands, including streams, estuaries, and lakes, new or expanded boating facilities and the placement of structural pilings for public recreational piers that provide public access and recreational opportunities. (4) Incidental public service purposes, including but not limited to, burying cables and pipes or inspection of piers and maintenance of existing intake and outfall lines. (5) Mineral extraction, including sand for restoring beaches, except in environmentally sensitive areas.
(6) Restoration purposes.
(7) Nature study, aquaculture, or similar resource dependent activities… Wetland Delineations
In May 2019, the applicant submitted a wetland delineation to inform the proposed project’s potential to impose adverse impacts on wetland resources, both on the subject parcel and in the adjacent drainage. This delineation had several issues and shortly following our site visit in October 2019, a second delineation was completed; the delineation dated November 2019 has since been used as a basis for technical analysis. Despite having been completed outside of the wet season when wetlands are best detected and delineated, all three wetland parameters were present in at least some areas6
and six different wetland types were identified within the drainage channel, characterized as: arroyo willow thicket, perennial rye grass, small-fruited bulrush marsh, smartweed, ephemeral channel, and wetted channel. Two of these have been mapped on the subject parcel itself (a small area of smartweed within the City’s jurisdiction and a large portion of the arroyo willow wetlands at the

6 United States Army Corp of Engineers jurisdictional wetlands, based upon the presence of all three parameters (hydrology, vegetation and soils), totaled 0.088 ac; Coastal Commission wetlands, based upon the presence of at least a single parameter, totaled 0.248 ac. 2-19-0026
Exhibit 11

1.g
Packet Pg. 3229 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6990 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 5 northern end, in the Commission’s jurisdiction). Of note is that the increase in area delineated in 2019 relative to what was reported from 2005 (Thomas Reid Associates 2005a) supports observations also made by Dr. Baye that wetland areas have expanded at this location.7
According to estimates provided in the analysis of the November 2019 wetland delineation, the proposed development would occur inside the wetland boundary at the arroyo willow thickets where a retaining wall to support an existing earthen berm and proposed pedestrian pathway along the full length of the subject parcel would be constructed. Figure 5 illustrates that the retaining wall would in fact encroach roughly 20 ft into the willows and directly remove wetland habitat; however, the project fails to qualify as an allowable use under Coastal Act §30233 and moreover, the willow stand also qualifies as ESHA (see next section). Elsewhere along the length of the drainage, the retaining wall would be sited no more than 11 ft from the delineated Commission wetlands while the buildings and other development features would sit between 9 and 30 ft of the wetland boundaries at their nearest points.

Wetland Buffers
Typically, staff recommends at minimum 100-ft buffers surrounding wetland habitats to adequately protect them from the many impacts that they may experience due to adjacent development. Such impacts can include altered drainage patterns and runoff, noise, debris, visual disturbance to wildlife, and inadvertent trampling. In some situations, reduced buffers have been recommended after taking into consideration wetland quality, the surrounding landscape, habitat functions, and the wetland’s susceptibility to various impacts; however, buffers sufficient to provide meaningful protection are still generally required.8 Here, based on the information available
to us prior to April 2020, including a lack of records affirming concerns for sensitive species use, I have advised that with the proposed BMPs and additional project modifications to avoid direct impacts to wetlands and to protect water quality, that wetland buffers might be reduced to no less than 25 ft along most of the drainage except where delineated by willow thickets and bulrush marsh. Around the willow thickets and bulrush marsh, which constitute arguably robust features providing relatively more habitat value and support for other species (e.g., complex shelter, refuge, foraging), my recommendation was a minimum 50-ft wetland buffer. Further informing my recommendation is that the willow thickets and bulrush marsh are characterized by the California Department of Fish and Wildlife (CDFW) as sensitive natural communities that qualify as ESHA (see discussion below). These recommended wetland buffers are reflected in Figure 5 except around a small patch of smallfruited bulrush marsh, which would extend further onto the subject parcel than as depicted.

Environmentally Sensitive Habitat Areas
Coastal Act §30107.5 defines environmentally sensitive [habitat] areas 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.

Rarity determinations for habitats and species are made by CDFW, the United States Fish and Wildlife Service (USFWS), and California Native Plant Society (CNPS), and are used to support Coastal Commission ESHA

7 Baye, P. 2014. Ibid.
8 For example, see: Blackman and O’Connell (A-2-PAC-15-0046) where wetland buffers surrounding a willow stand were reduced to 50 ft, or Trask (A-1-DNC-07-036) where wetland buffers surrounding emergent vegetation were reduced to a minimum 68 ft. 2-19-0026
Exhibit 11

1.g
Packet Pg. 3230 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6991 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 6 determinations.9 An ESHA determination may also be made on the basis of an area constituting ‘especially valuable habitat’ where it is of a special nature and/or serves a special role in the ecosystem, such as providing a pristine example of a habitat type or supporting important ecological linkages.

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

This is notably more restrictive than the preceding wetland policies, as it limits uses of ESHA to those dependent upon it and requires protection from not only direct impacts, but also indirect impacts that may result from adjacent development.

Sensitive Natural Communities
Arroyo Willow Thickets
The arroyo willow thickets located at the northern end of the subject parcel and continuing into the adjacent drainage are classified by CDFW as a natural vegetation community. Although the broader alliance Arroyo Willow as a whole is not considered rare, the more specific association characterized by stands exclusively composed of the namesake species, arroyo willow (Salix lasiolepis), is represented at this site and is considered sensitive.10 While this association does not presently have a rarity ranking, CDFW guidance is to treat communities designated as sensitive, whether or not they are ranked, with comparable protections. Under the Coastal Act, the arroyo willow thickets delineate as a wetland on the basis of their facultative wetland indicator status and therefore, must be treated as wetlands under Coastal Act §30233 rather than as ESHA under §3024011; however, the sensitive natural community status gives weight to the ecological significance of the thickets and is reflected in my more protective buffer recommendation of 50 ft relative to that for other wetlands at this site (except smallfruited bulrush marsh), as detailed above. Though not documented at this location, sensitive species such as the saltmarsh common yellowthroat (Geothlypis trichas sinuosa; CA Species of Special Concern) are known to use willow thickets as breeding habitat and many birds and smaller animals use them more generally.

Small-fruited Bulrush Marsh
Similar to the arroyo willow thickets, the small-fruited bulrush marsh identified in the wetland delineation is characterized by CDFW as a sensitive natural community. Specifically, the alliance Small-Fruited Bulrush has a state rarity ranking of S2 indicating that is considered imperiled within the state and at high risk of extirpation.

The association characterized by stands exclusively composed of the namesake species, small-fruited bulrush

9 CDFW defines natural communities, animals, and plants with a global or state ranking of 1, 2, or 3 as rare and the CCC typically finds these to be ESHA. CCC also typically considers plant and animal species listed by the federal and state endangered species acts (ESA and CESA, respectively) and/or identified under other special status categories (e.g., California Species of Special Concern), and/or identified by the California Native Plant Society (CNPS) as ‘1B’ and ‘2’ plant species as constituting ESHA. 10 Explanation of alliance vs. association; see Arroyo Willow Thickets alliance (CaCode: 61.201.00) and Salix lasiolepis association (CaCode:

61.201.01) in California Sensitive Natural Communities list (version: September 9, 2020) – accessible online at https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153609&inline. 11 Bolsa Chica Land Trust v. Superior Court (1999) 71 Cal.App.4th 493 2-19-0026
Exhibit 11

1.g
Packet Pg. 3231 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6992 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 7 (Scirpus microcarpus), is represented at this site and though unranked, is considered sensitive.12 The species is an obligate wetland indicator and like the arroyo willow, is necessarily treated under wetland policies but warrants the protection of a 50-ft buffer due to its ecological significance. Species such as the California red-legged frog (see below) frequently use bulrush habitat for breeding.

Sensitive Wildlife
California Red-Legged Frog
The California red-legged frog (Rana draytonii) is federally-listed as threatened and recognized by the state as a Species of Special Concern, is state-ranked as S3 indicating that it is considered vulnerable, and is the official state amphibian.13 It is the largest native frog in the western United States and is frequently associated with freshwater emergent wetlands, marshes, and riparian corridors throughout the central California coast but can also inhabit lagoons, ephemeral water bodies, stock ponds, and man-made drainages as well as drier habitat types within the wetter and cooler coastal fogbelt. CRLF uses both aquatic and upland habitat, the former for refuge and breeding, and the latter for foraging, dispersal, and aestivation. Breeding habitat is often characterized by perennial bodies of water with emergent vegetation providing structural complexity such as cattails, bulrush (see above), or dense riparian cover; however, sub-optimal habitats with little to no emergent vegetation and/or that periodically dry out are also known to be used.14 Dispersal habitat is generally considered to be areas within 1-2 miles of breeding areas, and can include forests, grasslands, coastal scrub, root masses formed by brambles or thickets, and oak woodlands in addition to those already named above.15 CRLF movement across habitat tends to peak during rainy periods and can vary widely among individuals.

CRLF breeding occurs from November to April. Reproduction rates tend to be highly variable and responsive to climate conditions (e.g., drought vs. wet years). Individuals may remain at breeding sites year-round or disperse to neighboring areas. Along the central coast, the species is particularly mobile and has been documented traversing areas that would not otherwise be expected, especially during wet conditions.16 CRLF has a diverse diet, which changes throughout its life cycle. Early in its life, it is believed to primarily consume algae, diatoms and detritus.17 As it matures, terrestrial and aquatic insects tend to make up the largest fraction of its diet, although larger frogs have been documented as consuming smaller invertebrates, including the smaller Pacific chorus frog (Pseudacris sierra), which is also common throughout this region.18 CRLF are considered diurnal but primarily forage at night.

12 See Small-fruited Bulrush Marsh alliance (CaCode: 52.113.00) and Scirpus microcarpus association (CaCode: 52.113.01) 13 California Assembly Bill 2364, approved June 28, 2014 - http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201320140AB2364 14 USFWS. 2004. Federal Register: Endangered and Threatened Wildlife and Plants; Proposed Designation of Critical Habitat for the California Red-legged Frog (Rana aurora draytonii); Proposed Rule. 50 CFR. Part 17. Vol 69. No. 71: 19620-19642. 15 Fellers, G. 2005. Rana draytonii Baird and Girard, 1852b California red-legged frog. Pages 552-554 in M. Lannoo (editor). Amphibian declines: the conservation status of United States species. University of California Press. Berkeley, California; CWHA database 16 Bulger, JB, NJ Scott Jr. & RB Seymour. 2003. Terrestrial activity and conservation of adult California red-legged frogs Rana aurora draytonii in coastal forests and grasslands. Biological Conservation 110(1): 85-95. 17 Fellers, G. 2005. Ibid. 18 Hayes, MP & MR Tennant. 1985. Diet and feeding behavior of the California red-legged frog, Rana aurora draytonii (Ranidae). The Southwestern Naturalist 30(4): 601-605; Fellers, G. 2005. Ibid. 2-19-0026
Exhibit 11

1.g
Packet Pg. 3232 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6993 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 8 Key threats to CRLF are recognized as habitat loss, urban encroachment, and the introduction of non-native species such American bullfrogs that can compete with CRLF for habitat as well as prey upon them. Several introduced freshwater fish species are also known prey on CRLF. Herbicide and pesticide use as well as disease may be other significant threats to CRLF, as has been documented for many amphibians around the globe.19 Prior to April 2020, we were unaware of any records affirming the presence of California red-legged frogs (Rana draytonii) at the subject parcel or its immediate surroundings although it has been well-documented at nearby San Pedro Creek.20 While I and the consulting reports I had initially reviewed for this project considered the species to have at least a moderate potential to occur given records from the nearby creek, there has also been recognition of the degraded state of the subject parcel and adjacent drainage as relatively unfavorable when compared to nearby habitat opportunities. No published record had appeared in the California Natural Diversity Database (CNDDB) beyond the creek’s main channel, the project’s IS/MND, or the other known reports for the location that staff generally relies upon. In addition, recent neighboring developments within the City’s jurisdiction along San Pedro Avenue had truncated the drainage’s corridor extension to more forested areas in the south and potential foraging, aestivation, and dispersal areas to the east (Figure 2). As such, my recommendations had focused on the wetlands and ensuring that appropriate measures would be taken during construction, in the off chance a frog was encountered.

On April 18, 2020, Commission staff received a report and accompanying photo from Pedro Point resident and San Francisco State University ecologist, Michael Vasey, documenting the presence of CRLF in ponded water at the drainage adjacent to the subject parcel six days prior.21 I was able to validate that the animal in the photo (Figure 6a) was a CRLF based upon diagnostic markings that were clearly visible and advised Dr. Vasey to submit his documentation to CDFW for further validation and inclusion to the CNDDB; District staff informed the applicant of this new finding. On April 24, another Pedro Point resident, Sheila Harman, contacted staff on behalf of herself and Jon Harman, with additional reports of having observed as many as four CRLF at the same location at one time and provided both time-stamped photos and a video also showing the surrounding location in relation to San Pedro Avenue to confirm this (Figure 6b-c)

22. She also commented that this was the first time in the past seven years that they had observed CRLF at the site, indicating previous but undocumented observations. On April 28, Dr. Vasey communicated with staff again, indicating that he and the Harman’s had now seen as many as five CRLF at a time in the drainage ditch along San Pedro Avenue and the pool just past the culverts feeding into the drainage adjacent to the subject parcel at 505 San Pedro Avenue.23 He also relayed a 2014 comment letter he had discovered through conversation with Peter Baye, another ecologist working along the central coast. This letter is referenced above in the discussion on wetlands.24
Dr. Baye’s 2014 letter provides important insights specific to CRLF, the surrounding area, and the drainage itself.

19 Davidson, EW, M Parris, JP Collins, JE Longcore, AP Pessier, & J Brunner. 2003. Pathogenicity and transmission of chytridiomycosis in tiger salamanders (Ambystoma tigrinum). Copeia 2003(3): 601-607. 20 CNDDB records for Occurrence Number 652 cover the lower half-mile of San Pedro Creek since 2002, when a total of 5 frogs were recorded from approximately 0.2 mi north of the subject parcel; reports since 2014 have more frequently detailed occurrences, including as many as 129 frogs caught in June-October in 2014 and notes that that adults were observed year-round in 2015. Egg masses were documented in 2014 and 2015.
21 Vasey, M. (personal communication, April 18, 2020)
22 Harman, S. (personal communication, April 24-29, 2020) 23 Vasey, M. (personal communication, April 29, 2020)
24 Baye, P. 2014. Ibid.
2-19-0026
Exhibit 11

1.g
Packet Pg. 3233 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6994 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 9 He presents information on CRLF not found in the research various parties had conducted, including reporting having observed CRLF at the drainage over different seasons since at least 2005 and having submitted an official report to USFWS in 2005.25 Dr. Baye specifies that his observations have occurred regularly at the drainage and that CRLF have been most frequently found in the ponded, perennially wet area [scour pool] nearest San Pedro Avenue, the location neighborhood residents made reports from in April 2020. He hypothesizes that these animals may represent a local sub-population with a relationship to the lower San Pedro Creek wetland complex and that this perennially wet area may be breeding habitat given his observations of intermittent local population fluctuations and observation of other habitat requirements being immediately proximate, including the large field just west of the drainage. He also states that he believes this area would qualify as ESHA. Dr. Baye’s report goes on to note that CRLF was apparently absent throughout the drought period beginning in 2012 through the time of his report in 2014. As the drought ended in the winter of 2017, it is not all the surprising that the applicant’s consultants would not have observed CRLF at the site when conducting the biological assessments in 2015 (Coast Ridge Ecology) or January 2017 (Live Oak Associates) as the area was just coming out of drought status.26 I reached out to colleagues at CDFW and the USFWS in May 2020 to further investigate whether there was any other unpublished CRLF occurrence information, either from the drainage or otherwise nearby apart from San Pedro Creek. CDFW staff at the Biogeographic Branch were able to confirm that Dr. Vasey’s April 2020 CNDDB submission appeared to be valid, including the species identification; since then, his record has been processed and officially incorporated to the state database (Figure 2). USFWS staff from the Bay-Delta Regional Office indicated that while they did not have the 2005 record submitted by Dr. Baye available digitally, it was likely that it has been held as a paper file that cannot be accessed readily due to constraints imposed by the current pandemic. Nonetheless, they were not surprised by the contemporaneous observations and were able to provide comments on recent observations from nearby San Pedro Creek27 as well as advise that ESA Section 10 permitting may be necessary and that recommended habitat corridors for CRLF are typically 300 ft, which is consistent with Commission decisions elsewhere along this part of the coast.28 In response to the discovery of CRLF in April 2020 at the drainage channel, the applicant’s consultant at Coast Ridge Ecology (2020) has observed that significantly more water appears to be flowing through the drainage now than during their initial assessment in 2015. Notably, 2015 would have been several years into a drought (stage 3:
extreme drought) whereas conditions were less severe in 2020 (stage 1: moderate drought), so this might be reasonably expected.
29 The consultant speculates that the differences could be a result of supplemental water inputs from nearby residential properties but does not provide any evidence thereof or consider alternative explanations (including relative drought conditions). They also express doubt concerning CRLF’s ability to have moved from San Pedro Creek into the drainage and suggest that they may have been “assisted by humans (i.e. planted in the drainage)”. They consider the area “isolated” without acknowledging the dispersal range and known movement patterns of the species, particularly in the coastal fogbelt, where culverts connect the drainage channel directly to a City restoration area and ultimately, San Pedro Creek only 300 ft away from the north end of

25 Baye, P. 2005. Letter to United States Fish and Wildlife Service RE: Documentation of California red-legged frog occurrence at Pedro Point, Pacifica, San Mateo County. May 4, 2005.
26 https://www.drought.gov/historical-information for January 2017 27 For example: United States Fish and Wildlife Service. Consultation Letter to United States Army Corps of Engineers RE: Formal Consultation on the San Pedro Terrace Project in San Mateo County, California. Reference #08ESMF00-2017-F-1370. April 5, 2018. 28 UC Santa Cruz Marine Science Campus - Coastal Long Range Development Plan. January 2017. 344pp. 29 https://www.drought.gov/historical-information for March 2015 and April 2020 2-19-0026
Exhibit 11

1.g
Packet Pg. 3234 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6995 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 10 the subject parcel. Though these avenues of dispersal are perhaps not the most idyllic, the species is capable of having used any variety of these. Finally, the consultant argues that the location is unlikely to provide “consistent, stable long-term habitat for [CRLF] over time” and that it would likely be considered a population sink. However, CRLF is known to use (and require) a mosaic of habitat types across the landscape and we cannot ignore that the species has been documented using this location intermittently for decades, even in the absence of focused study.

Moreover, it is not necessary for CRLF to carry out its full life cycle in the drainage for the area to have ecological value for this sensitive species.

In August 2020, I reached out to Dr. Baye to inquire whether he had a copy of his 2005 report to the USFWS, which had been referenced in his 2014 letter. He was able to forward this report to staff, including photos of CRLF, thus providing additional information that had not been otherwise available through standard data searches or inquiries during the pandemic. On May 4, 2005, Dr. Baye reported to USFWS having observed three adult CRLF at the [scour] pool adjacent to San Pedro Avenue on the previous day, at the southern end of the drainage ditch directly adjacent to the subject parcel. He also states that he had observed “multiple aural detections of diving frogs in April” and indicates that water turbidity limited visual detections but “no egg masses were observed within the visible upper 10 cm of water column.” Figure 7 is excerpted from Dr. Baye’s report and also appears in his 2014 letter to the City.

In the course of my research, I also sought out the biological assessment report from 2005, which had been referenced in the May 8, 2015 staff letter to the City regarding review coordination for the proposed project.

Although such reports are generally considered outdated after five years for the purposes of evaluating current conditions at a site, they can be informative in the context of habitat change as well as documenting patterns of use (or likely use). Where data is limited and/or species may not be readily detected, historical reports can be especially helpful. In this situation, I located not only the biological assessment report (Thomas Reid Associates 2005a) but also discovered a site assessment specifically for CRLF (Thomas Reid Associates 2005b). Both 2005 reports had been intended to inform a different project at the same location, which would have restored habitat over approximately 60% of the subject parcel including the willow thickets and upland areas to be contiguous with the then-planned wetland restoration at San Pedro Creek. Concerning CRLF, while the species was not explicitly confirmed on-site by these two reports, it was regarded that “there is a high potential for them to be present within proximal aquatic habitats… [including] the drainage ditch adjacent to the property as a traveling corridor or nearby upland areas for aestivation” and the consultants recommended “that this report be submitted to the [USFWS]” for further consultation, though it remains unclear whether it ever was. The proposed restoration was apparently anticipated to benefit CRLF among other species.

The recent repeated daytime observations of multiple CRLF at the roadside end of the drainage indicates that even in the absence of formal surveys, the area has been functioning as habitat for more than an individual transient CRLF. Consideration of this, the multiple reported occurrences of CRLF at the drainage since at least 2005, and the concurrence of information from colleagues at partner resource agencies informs my revised opinion that CRLF occurrence here is not a moderately hypothetical possibility but in fact, a demonstrated pattern of use. Given the connection to San Pedro Creek, including by way of the underground culvert, the observations of CRLF near San Pedro Avenue, wetlands, and evidence of the drainage’s role as a green corridor year-round, the full length of the drainage adjacent to the subject parcel should be considered habitat. In addition, because CRLF requires not only wetted areas but also makes use of upland habitats for foraging, dispersal, and estivation, this habitat is very likely extends to adjacent upland areas on either side of the drainage. Though we cannot presently delineate the full extent of CRLF use in these areas without protocol-level surveys, we can interpret that at a 2-19-0026
Exhibit 11

1.g
Packet Pg. 3235 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6996 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 11 minimum, the drainage itself constitutes ESHA and is likely functioning as a habitat corridor for this species between San Pedro Creek and upland areas.

Habitat Corridors
The drainage running adjacent to the subject parcel arguably constitutes a habitat corridor for CRLF but additionally, likely supports several other species moving across the landscape as well. As evident from the timeseries of aerial imagery (Figure 4), the drainage remains relatively green throughout the seasons and as compared to adjacent parcels. It also connects to San Pedro Creek (through culverts), the shore, and the Pacific Ocean in the north; a large open space to the west; historically, to spaces in the east beyond the subject parcel (i.e. the parcel due east of Halling Way, along San Pedro Avenue); and to a major forested area to the south, which again connects to San Pedro Creek, though this connection was somewhat fragmented by recent development.

Despite the more recent encroachments of development, it remains that the drainage provides a connection across the landscape capable of supporting many species including birds and small mammals that may be less affected by some of these interruptions. For example, birds move primarily by line of sight rather than on-theground conditions and while raptor nests have not been observed in the trees immediately along the drainage, the forested area to the south is better-suited for such and the large open space just west of the drainage provides excellent conditions for foraging on fossorial rodents and small reptiles; raptors have been regularly observed using the area.30 These same small animals (and others) are likely to find refuge within the drainage relative to sun, wind, and predator exposure where surrounding areas are paved, mowed, or otherwise devoid of vegetation. During my brief roadside visit in March 2019, I observed a duck resting among ponded waters of the drainage (Figure 3e) indicating that waterfowl also use the shaded and wetted area at least occasionally. Small mammals such as skunks, raccoons, and coyote would all be likely to make use of the drainage area as well.

In addition, the California Essential Habitat Connectivity Project identifies a major natural landscape block beginning in Pacifica and extending south through the San Mateo and Santa Cruz Counties coast and mountains (Figure 8).31 It also recognizes “small” natural areas (defined as < 2000 ac), with one of approximately 140 ac occurring some 800 ft south of the project site, in the forested area that has already been discussed (Figure 9). All of this emphasizes the especially valuable role of the drainage in facilitating connections across a semi-developed landscape, from the shore and creek mouth to forested areas inland, as well as open spaces that can function as upland habitat and foraging grounds, and I recognize it as a habitat corridor rising to the level of ESHA.

ESHA Delineation & Buffers
The sensitive natural communities of Arroyo Willow Thickets and Small-fruited Bulrush Marsh both constitute ESHA in addition to wetlands, as delineated in the November 2019 wetland delineation report. As stated above in the wetlands section, buffers of 50 ft should be applied to these two areas.

As a federally-threatened and California Species of Special Concern, the California red-legged frog qualifies for Coastal Act protection under ESHA policies. Thus, the revelation that CRLF does, and has, in fact occurred at this location necessitates consideration of habitat beyond that of the wetlands. With the limited documentation available, it is not possible to precisely delineate boundaries for CRLF habitat but we can observe that there is no

30 eBird records for the area include white-tailed kites, golden eagles, sharp-shinned hawks, red-shouldered hawks, and red-tailed hawks – www.ebird.org
31 Spencer, WD, P Beier, K Penrod, K Winters, C Paulmann, H Rustigian-Romsos, J Strittholt, M Parisi and A Pettler. 2010. California Essential Habitat Connectivity Project: A Strategy for Conserving a Connected California. Prepared for California Department of Transportation and California Department of Fish and Game, and Federal Highways Administration. 313 pp. 2-19-0026
Exhibit 11

1.g
Packet Pg. 3236 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6997 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 12 biological argument that would exclude CRLF from the subject parcel or limit its movement to the narrow drainage immediately adjacent. Provided the species ecology, including dispersal and foraging patterns along the central coast, I expect it will readily use nearby upland areas and move freely with little regard for topography or substrate. Given the USFWS recommendation of providing CRLF with at least a 300-ft dispersal corridor where it is known, we can conclude that even if this width was centered on the drainage, it would extend across and beyond the subject parcel well to the east (Figure 5); therefore, I find that the entire subject parcel constitutes CRLF ESHA and that this extends some yet-to-be-defined distance beyond the parcel. No buffer recommendation is provided since it is irrelevant in the absence of an outer habitat limit from which to apply.

Habitat corridors are increasingly critical to preserve as natural lands are converted and encroached upon by development; however, their delineation can be challenging since each species will use the space differently.

Often, riparian areas are treated as corridors with the outermost extent of riparian vegetation being recognized as the edge, from which buffers are then applied to ensure that wildlife movement in and out of riparian cover is protected for some distance. In this case, it is clear that the drainage adjacent to the subject parcel is part of a larger network connecting different habitats but its boundaries are less well-defined by a canopy than riparian areas and it is likely somewhat more permeable within the landscape mosaic. Because we know that CRLF is almost certainly using the drainage as a corridor but cannot clearly define the bounds of such use with the data available, the same determination must transfer to the EVH-based ESHA – I find that the subject parcel is part of a general habitat corridor ESHA, which extends some yet-to-be-defined distance beyond the parcel. No buffer recommendation is provided since it is irrelevant in the absence of an outer limit from which to apply.

In conclusion, I find that the subject parcel includes wetlands, Arroyo Willow Thicket ESHA, California redlegged frog ESHA, and habitat corridor ESHA. These sensitive habitat resources are continuous with the immediately adjacent drainage, which additionally includes Small-fruited bulrush marsh ESHA. The boundaries of at least some of these sensitive resources extend beyond both the drainage and subject parcel, resulting in the entire subject parcel necessarily being recognized as ESHA in addition to the wetlands that have also been delineated there.
2-19-0026
Exhibit 11

1.g
Packet Pg. 3237 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6998 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 13 Figure 1a: 505 San Pedro Avenue parcel (approximated in yellow) as situated in the broader surrounding landscape, and b: relative to specific features including the adjacent drainage (approximated by dashed white arrow), scour pool (red asterisk), and willow thickets. restored wetlands
forested area,
minor drainages
open field
(grassland, likely
wetlands)
willow
thickets
*
restored wetlands
open field
(grassland, likely
wetlands)
2-19-0026
Exhibit 11

1.g
Packet Pg. 3238 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 6999 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 14 Figure 2: CDFW Biogeographic Information and Observation System (BIOS) Viewer display of the California Aquatic Resources Inventory (CARI) stream layer and California Natural Diversity Database (CNDDB) records surrounding the subject parcel (yellow box). CARI data shown as blue lines, including the drainage immediately west (left) of the parcel and San Pedro Creek (far right). Red thatching represents areas with known occurrences of California Red-Legged Frog.
2-19-0026
Exhibit 11

1.g
Packet Pg. 3239 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7000 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 15 Figure 3: Photos from site visits in March and October 2019, showing seasonal variation in drainage conditions – a-b: culvert running parallel to San Pedro Avenue, immediately west of the drainage and subject parcel; c-d: from San Pedro Avenue, facing north with scour pool in foreground; e-f: from San Pedro Avenue, facing northnorthwest into drainage (note Eucalyptus wind break on left (west) before open field and subject parcel on right (east), and duck (white circle) using drainage as resting area in e); g: from western side of drainage, looking south towards San Pedro Avenue (note continuation of tree canopy into forested area south of San Pedro Avenue). a b
c d
subject parcel
subject parcel
San Pedro Ave
San Pedro Ave
2-19-0026
Exhibit 11

1.g
Packet Pg. 3240 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7001 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 16 z
f
e
g
subject parcel
field
subject parcel
field
subject parcel
field
(forest)
2-19-0026
Exhibit 11

1.g
Packet Pg. 3241 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7002 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 17 Figure 4: Subset of larger aerial time series (2002-2020) of the subject parcel (yellow box) and the surrounding landscape, showing wet versus dry season patterns of vegetation. Note how the drainage immediately adjacent to the subject parcel consistently provides a green corridor and effectively links San Pedro Creek with the open field to the west while providing a valuable secondary connection to the forested habitat south of the site.

May 2003
December 2003
City wetland restoration
not yet completed
City wetland restoration
not yet completed
2-19-0026
Exhibit 11

1.g
Packet Pg. 3242 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7003 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210
125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 18 May 2010
September 2003
2-19-0026
Exhibit 11

1.g
Packet Pg. 3243 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7004 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210
125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 19 April 2020
July 2020
recently developed parcels & interrupted tree canopy
recently developed parcels & interrupted tree canopy
2-19-0026
Exhibit 11

1.g
Packet Pg. 3244 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7005 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 20 Figure 5: Delineated single-parameter wetlands (solid green lines) and approximate wetland buffers (dashed green lines) relative to proposed project. Note that 50-ft buffer was drawn around the willow ESHA but should also extend slightly further south around some small-fruited bulrush marsh ESHA, which would further overlap with the proposed footprint, even as potentially modified (red lines). * small-fruited
bulrush marsh ESHA
2-19-0026
Exhibit 11

1.g
Packet Pg. 3245 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7006 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 21 Figure 6a: CRLF as observed at San Pedro Avenue on April 12, 2020 by Michael Vasey, Sheila Harman and Jon Harman (photo credit: Jon Harman); b-d: CRLF as observed at San Pedro Avenue on April 23, 2020 by Sheila Harman. Individual CRLF circled in white for visibility.

a b
c d
2-19-0026
Exhibit 11

1.g
Packet Pg. 3246 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7007 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 22 Figure 7a: From San Pedro Avenue, looking northeast, view of scour pool in drainage with subject parcel as grassy area immediately behind the fence, and b: CRLF observed in scour pool by Peter Baye. Photos by Peter Baye, as submitted to USFWS in May 4, 2005 letter.
a
b
2-19-0026
Exhibit 11

1.g
Packet Pg. 3247 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7008 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 23 Figure 8: Excerpt from California Essential Habitat Connectivity Project displaying the San Mateo-Santa Cruz Counties coastal corridor (within red box). The project location in Pacifica is approximately located at the black arrow, near the northern edge of the extent. Areas in green represent connected stretches of habitat and the yellow-brown spectrum represents areas that would ideally be added to provide better linkages. The Pedro Point area is among those areas identified as valuable additions to improving connections through this corridor.

Approximate
site location
2-19-0026
Exhibit 11

1.g
Packet Pg. 3248 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7009 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 24 Figure 9: CNDDB display of the Pedro Point area in Pacifica, with CRLF occurrences observed in thatched red areas and finer-scale features identified as particularly valuable by the California Essential Habitat Connectivity Project in solid green. The proposed project site (yellow bar) is largely covered by the upper two CRLF occurrences and is situated to link multiple habitats across the landscape mosaic, including riparian, wetland, forest, and grassland.

GRASSLAND &

WETLANDS

RIPARIAN
FOREST

CEHC FEATURE

CEHC FEATURE
2-19-0026
Exhibit 11

1.g
Packet Pg. 3249 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7010 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Terry Watt [
Sent: Tuesday, March 8, 2022 5:16 PM
To: 'Nick Lusson' [ Public Comment [[email protected]] CC: 'Sydney Sulak' [ 'Cassie Leonardi'
[ 'Xavier Macy' [
Subject: RE: public comment on DEIR
[CAUTION: External Email]
Excellent and nice letterhead!
From: Nick Lusson <
Sent: Tuesday, March 8, 2022 5:07 PM
To: [email protected]
Cc: Sydney Sulak < Cassie Leonardi < Xavier
Macy <
Subject: public comment on DEIR
Please see the attached for our public comment. Thank you! Nick Lusson
Sydney Sulak
Cassie Leonardi
Xavier Macy
(Protect San Pedro Mountain Operations Team & all Pacifica residents) CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3250 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7011 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Woodhouse, Kevin [[email protected]]
Sent: Tuesday, February 1, 2022 10:10 AM
To:

CC: _City Council Group [[email protected]]; Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]] Subject: RE: Traffic Growth in Pacifica
Dear Ms. Sundstrom,
I have forwarded your General Plan comment to Deputy Planning Director Christian Murdock so it can be properly included in the public comments on the General Plan.

Sincerely,
Kevin Woodhouse
City Manager
City of Pacifica
www.cityofpacifica.org
650.738.7409
From:

Sent: Tuesday, February 1, 2022 9:45 AM
To: _City Council Group <[email protected]>; Woodhouse, Kevin <[email protected]> Subject: Traffic Growth in Pacifica
[CAUTION: External Email]
Good morning Pacifica City Council Members & Kevin,
I noticed references in Pacifica's general plan about traffic analysis from 2010...

In trying to understand traffic issues in Pacifica, particularly the congestion on Hwy 1, I went looking for traffic counts. Traffic data for other cities is available online and so are traffic counts from Caltrans. I don't think Pacifica does regular traffic counts like other cities do - I do believe this is a requirement or at

1.g
Packet Pg. 3251 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7012 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve least a best practice in city administration. I took the time to download what Caltrans had available and came up with the table below (an hour and a half tops)
A couple of key points from the data & analysis:

1. All the information is pre-pandemic - people were commuting and kids were in school. Data analysis should not be done in anomalous conditions (school breaks, holidays etc)

2. More data is available online, I picked 3 years to compare.

3. The numbers are "annual average daily traffic" - 365 days - so they account for weekend and weekday activity.

4. The data - numbers - speak to the growth in vehicles. Actual traffic conditions are based on lane geometry, speed, road conditions etc. In other words, a 10% increase on a four lane road isn't really a problem but it may be if it's a one lane road with poor traffic control.

5. Between 2013 & 2019 overall traffic has grown anywhere from 13% to an astounding 57%.

6. Traffic counts from ramps and side streets would actually help us better understand the growth and traffic patterns. What's important to note here is that the population of Pacifica grew by 3% but traffic grew by considerably more.

7. While the traffic heading to the tunnel has grown by 13%, does not mean that all 13% come from the north - this requires further analysis.

8. Overall, Pacifica is generating a fair amount of it's own traffic and we have a lot of analysis to do to understand & solve the problems.

The fact that the general plan is using stale data and analysis, from as far back as 2010, is a grave error and a huge disservice to our city. This is something that impacts the residents as well as any future economic development. I am shocked at the fact that any professional - a consultant or staff member - would even suggest using 12 year old data in a region that has seen so much growth.

If this bad analysis isn't proof that you're rushing the general plan through, I don't know what is. Please, let's get honest about the traffic and actually pay someone to do some proper analysis and fix it.

Regards,
Vicki Sundstrom

1.g
Packet Pg. 3252 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7013 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3253 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7014 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From:

Sent: Saturday, February 26, 2022 9:18 PM
To: Public Comment [[email protected]]
CC:

Subject: Red Legged Frog Pedro Point
Attachments: IMG_3307.jpeg; IMG_1657.jpeg; IMG_0459.jpeg [CAUTION: External Email]
Hello,
I would like to comment on the Pacifica General Plan Draft. On page 189 Figure 7-3 Sensitive Critical Habitat, the riparian habitat on San Pedro Ave. is not listed as critical habitat for the reg legged frog. Attached are images from May of 2020 and April of 2021 of frogs in the riparian habitat at the base of Grand Ave, along San Pedro Ave.

Some may consider it a "drainage ditch" but I claim it is more of a habitat than a ditch. The fact that the frogs have been observed there over two years tells us that it is a viable habitat. Furthermore it may have been a frog habitat before 2020, but 2020 brought us closer to home for longer periods of time. I for one in April of 2020 took more walks around my neighborhood than ever before. This may be why it is only being documented now.

While this area seems like a "drainage ditch" it is in fact supplied with water for longer than surface area drainage would indicate. Please see the photo taken about 50 days after the last rain where water was still rising through the pavement. (February 22, 2022) To me this indicates a water source to the "drainage ditch" that is more perennial than simple runoff. Therefore this "drainage ditch" should be reclassified as a riparian habitat with documented cases of the red legged frog in the habitat.

Thank you for your attention in this matter.

Gwendolyn Holden
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3254 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7015 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

1.g
Packet Pg. 3255 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7016 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

1.g
Packet Pg. 3256 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7017 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

1.g
Packet Pg. 3257 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7018 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From:

January 19, 2022 7:52 PM
To: Murdock, Christian [[email protected]]
Subject: Request of time extension to review General Plan DEIR [CAUTION: External Email]
Hello Christian, Please add me to the list of people asking Pacifica to please consider extending the public comment period for the Draft EIR for the General Plan. Thank you very much! Ellen Natesan CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3258 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7019 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Patton, Arlene [
Sent: Saturday, January 22, 2022 11:32 AM
To: Murdock, Christian [[email protected]]
CC: _Open Space & Parkland Advisory Committee Group
[OpenSpace&[email protected]] Subject: Request to Extend Comment Period another 30 Days for Draft General Plan, Draft EIR and Draft Sharp Park Specific Plan
Dear Mr. Murdock,
Thank you for the opportunity to review the Draft General Plan, Draft EIR for the General Plan and the Draft Sharp Park Specific Plan.

Pursuant to my comment at the OSPAC meeting, I'm formally requesting a 30-day extension to the 45-day comment period.

As you know this is an enormous amount of material to review and even as a retired person, I don't think I'll meet the current 45-day deadline!
From what I've read so far, the General Plan is very good and an enormous improvement from the 1980 version. Thank you and the rest of the planning staff for the good work you do.

Sincerely,
Arlene Patton

1.g
Packet Pg. 3259 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7020 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From:

Sent: Wednesday, March 9, 2022 9:58 AM
To: Public Comment [[email protected]]
Subject: Resending General Plan DEIR Comments
Attachments: GENERAL PLAN DEIR COMMENTS_2.pdf
[CAUTION: External Email]
Good day again!
Realizing that I had forgotten to put my contact information on the document I sent before the deadline yesterday, I've added it here, just in case you wanted to talk to me.

Good day.

Attached is my comments on the General Plan DEIR
Please confirm receipt of this email
Thank you,
Mark
This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3260 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7021 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve PACIFICA GENERAL PLAN AND DEIR COMMENTS – JANUARY 2022
Good day, City Staff and Councilmembers.

First, please accept my sincere appreciation for the monumental amount of effort you’ve obviously dedicated to creating these documents – thank you! After such a long wait, every member of our community should be grateful in having an upto-date General Plan.

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.

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

1.g
Packet Pg. 3261 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7022 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 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. “There’s no precipitation forecast through the remainder of February. And there’s very little precipitation in the long-range 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 Trees-For-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.

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? 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.*

1.g
Packet Pg. 3262 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7023 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Map ‘A’ Map ‘B’
Image ‘D’ Map ‘C’
For the sake of accuracy, here are the actual Cal Fire percentages.

1.g
Packet Pg. 3263 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7024 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve *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 located in the hills above populated areas could burst and inundate areas below due to a seismic event. (Pacifica Planning Dept.) 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 Park 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 good news is that many grant funding programs are 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 Threat Wildfire Areas

1.g
Packet Pg. 3264 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7025 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve FEMA: Fire Service Grants and Funding -- Assist fire prevention programs and support firefighter health and safety research and development.

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?
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 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.”
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?
EVACUATION:

In the event of a wildfire emergency, it would be a very bad idea for hundreds or

1.g
Packet Pg. 3265 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7026 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 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? “Every acre in California can and will burn someday,” he announced, as the massive Dixie Fire continued to spread. “Just make sure that you're ready when it does.” According to Cal Fire Chief Them Porter, who retired last December after leading the agency through record wildfire seasons.” Thanks to all of you on The City Staff for your service.

Best,

1.g
Packet Pg. 3266 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7027 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Mr. Paul Totah [
Sent: Sunday, February 27, 2022 11:55 AM
To: Public Comment [[email protected]]
Subject: Revised comments
[CAUTION: External Email]
Please see below for some changes I made to the comments sent to you a few days ago. -- Paul
As a member of Tree City USA, I have worked to protect and grow our urban forest. Pacifica's urban forest includes all trees, both public and private, within the city limits. The DEIR (and General Plan) have some aspects that reflect this commitment and others that need adjusting. Below you will find some comments, questions and requests.

1. The Guiding Principle CO-G-10 in the DEIR (and General Plan) instructs the City to “Conserve trees and encourage native forestation and planting of appropriate trees and vegetation”. This is an excellent guiding principle and reflects the intent of a Tree City USA. There are a couple of cases on pages 85 and 560 where other guiding principles are mislabeled CO-G-10. Can these be relabeled?

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

3. In Figure 3.7-1 Vegetation in the DEIR (Figure 7-2 in the General Plan) part of the information comes from the Department of Forestry in 2005. Some of this information is either outdated or in error. For example, the North side of Vallemar is labeled as Eucalyptus, but it is primarily Monterey Cypress and

1.g
Packet Pg. 3267 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7028 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Pine, with only a few Eucalyptus trees. Current online resources such as iTree can more accurately assess tree canopy. Please update this map with more accurate information.

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

5. There is no Implementing Principle to correspond with the Guiding Principle CO-G-10. Most Tree City USA cities have Canopy Goals for the urban forest that guide the actions of staff and citizens. Tree City Pacifica is requesting that Pacifica establish a Canopy Goal. Please add an Implementing Principle that states “Adopt an aspirational Canopy Goal to promote the protection and growth of the urban forest”.

6. In the DEIR the Heritage Tree Implementing Principle CO-1-41 states “Protect trees designated by the City Council as having special value, according to the terms on the Heritage Tree Ordinance”. In the General Plan, Heritage Trees are under Principle CO-I-39 which has different wording.

Please reword both of these Implementing Principles to better reflect the purpose of the Heritage Tree Ordinance, such as “Protect essential trees in Pacifica’s Urban Forest by enforcing the Heritage Tree Ordinance".

7. The Sharp Park Specific Plan 5-1-4 promotes the addition of curb bulb outs to plant street trees along Palmetto as well as east west connections. Research shows that trees promote commerce, so this would be a notable addition to this plan. Is this reflected in the DEIR? Thank you for all your hard work on the DEIR and General and Sharp Park Plans. We appreciate you addressing these concerns regarding our urban forest.

Yours,
Paul Totah (124 Nataqua Avenue)

1.g
Packet Pg. 3268 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7029 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve --
Paul Totah
Freelance Writer
c: 650-303-1841
e:
w: www.siprep.org/genesis
t: @ptotah
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3269 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7030 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Stan Zeavin [
Sent: Saturday, March 5, 2022 5:49 PM
To: Public Comment [[email protected]]
CC: Nibbelin, John [[email protected]]; Berman, Lauren [[email protected]]; Domurat, George [[email protected]]; Ferguson, Alex [[email protected]]; Godwin, James [[email protected]]; Hauser, Samantha [[email protected]]; Leal, David [[email protected]]; _City Council Group [[email protected]]; Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]
Subject: Safety element figure 8-3 & DEIR 3.6-3
Attachments: Coastal Zone maps comment .docx .docx
[CAUTION: External Email]
Please consider the following:
“Coastal Zone” Maps and following – Safety element figure 8-3 & DEIR 3.6-3 >> Combining upland and coastal information on one map minimizes the impact of each. Separate maps would serve Pacificans better. “Coastal Erosion” can be anticipated as continuing and accelerating with more frequent extreme events caused by climate change and sea level rise.

Slope failure inland from the coast usually depends on severe precipitation and is aggravated by poor engineering choices or inadequate site investigation.

1. Safety Element
Document page 7
• Figure 8-3 MAP titled Slope Failure and Coastal Erosion (page 7) >> Legend identifies the “Coastal Zone” by a dotted pale blue line which is obscured by “seawall” and “riprap, other revetments” >> To identify the “Coastal Zone” as only the immediate meeting of sea and land ignores the “Coastal Zone” definition used elsewhere to indicate that portion of land to which the 1976

1.g
Packet Pg. 3270 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7031 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Coastal Act applies. To avoid confusion the term “Coastal Zone” must be defined specifically and used uniformly.
>> The Figure 8-3 “Note” ( •Figure 8-3 “Note: Beach and cliff erosion are typical of much of Pacifica coastline.”) requires more detailed consideration. >> “Slope Failure Threat” must recognize and include the threat of bluff failure along nearly all our coast
Document page 10 (8-10)
• “Increased Coastal Erosion from Potential Sea Level Rise” >> Use current information from USGS COSMOS and Pacifica’s 2018 ESA vulnerability study to explain projected increase.
• Photo caption: “New development in the Coastal Zone must not require the construction of riprap or other protective devices that would substantially alter natural landforms (left) New development is required to be set back from coastal bluffs enough to accommodate a 100-year event, whether caused by seismic, geotechnical, or storm conditions (right).” >> Photo caption is consistent with State policy and should be emphasized.

Information elsewhere contradicts this caption.

Document page 11 (8-11) Implementing Policies
>> Identify policies specific to coastal bluffs/cliffs more clearly. cf. SA-I-3 Real Estate Disclosure specifies “suspected seismic or geologic hazards…and…risk of liquefaction, subsidence or landslide.” cf. SA-I-7 Erosion Prevention … “of hillside areas by revegetation…” >> Sea Level Rise and cliff/bluff risk of retreat MUST also be specified and disclosed in Real Estate transactions.
>> Revegetation is inappropriate for cliff/bluff erosion.

Cf. SA-I-8 Geotechnical Studies.

1.g
Packet Pg. 3271 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7032 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve ,,,, Within 50 feet of a coastal bluff
>> Add and Emphasize: “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.”
Document page 12 (8-12)
SA-I-9 Maintain Restrictions on Hazardous Areas.
>> Clearly identify “Hazardous Areas”
Document page 13 (8-13)
SA-I-15 New Development in Coastal Zone.
>> Define new development in accord with the Coastal Act. >> Clarify sentence intent: strike beyond the existing development’s life >> Provisions must align with current State certified LCLUP Document p 18 (8-18)
SA-I-27 Critical Facilities Location. Site criti- cal public facilities including hospital and healthcare facilities, emergency shelters, police and fire stations, and emergency communications facilities outside of the tsunami evacuation zone and 100-year flood plains. >> Add sewer pump stations as a Critical Facility
Document page 21 (8-21)
SA-I-28 Vulnerability Identification and Map- ping. The City’s Coastal Vulnerability zones shall be mapped …
>> Mapped in 2018 LCP draft

2. DEIR
page E-46
Table ES-3 Summary of Impacts and…

1.g
Packet Pg. 3272 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7033 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve S A-I-15 New Development in Coastal Zone.
• 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; • 􏱈 Not accelerate the need for a shoreline structure or increase the likelihood 􏱈􏱈of a future seawall beyond the existing development’s expected life; and 􏱈 􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈
• 􏱈 Not violate required setback provisions.
>> Add BEACHES after bluffs and cliffs.
>> Define “substantially.”
>> Follow State of California Coastal Act guidance and clarify the date for “existing development ” to be consistent with the 1976 date for California voters’ approval of the Coastal Act.
>> Define “expected life.”
>> Add “New development is required to be set back from coastal bluffs enough to accommodate a 100-year event, whether caused by seismic, geotechnical, or storm conditions” according to certified LCP.

3.6-14
>> Placing coastal erosion in SMCMJLHMP under “Landslide/Mass Movements” does not adequately emphasize on-going and increasing erosion with SLR.

Document page 470
Beaches and Coastal Erosion
>> Update erosion history and bluff retreat.

Current data is based on 1998 report.

3.6-15

1.g
Packet Pg. 3273 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7034 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Figure 3.6-3 Slope Failure and Coastal Erosion
Map figure 8-3 is repurposed with legend including red line to indicate general “critical coastal erosion”
>> Map requires better accuracy and precision to be meaningful. > Arrow indicating “Severe Beach and Cliff Erosion” should bracket from north of the pier to the city limit and include “gullies” area. > Beach erosion extends south from the pier to Mori Point. > Arrow indicating “Severe Beach & Cliff Erosion“ on northwest Mori Point should include all area south from SF revetment.
> Beach and Cliff erosion occur on the hidden beach (AKA Smuggler’s Cove
> Serious cliff erosion resumes with marked effect on the porous limestones north of the Rockaway revetment.
> Cliff erosion wraps around all of Aramai Point (Rockaway Headland). > Remove “Wave Surge” at Pacifica State Beach north end.

3.6-17 Effects of Sea Level Rise
Paragraph 1: These general projections for the northern California Coast of dune and bluff erosion by 2025, 2050 and 2100 are inappropriate for Pacifica’s exposed coast north of Mori Point where bluff erosion has already exceeded the 2025 prediction in several places.
>> 2018 LCP vulnerability mapping would give Pacifica citizens a much better idea of the area of potential erosion.

Thank you for your consideration,
Margaret Goodale
Naturalist
Educator
Environmental advocate
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3274 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7035 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve “Coastal Zone” Maps and following – Safety element figure 8-3 & DEIR 3.6-3 >> Combining upland and coastal information on one map minimizes the impact of each. Separate maps would serve Pacificans better. “Coastal Erosion” can be anticipated as continuing and accelerating with more frequent extreme events caused by climate change and sea level rise. Slope failure inland from the coast usually depends on severe precipitation and is aggravated by poor engineering choices or inadequate site investigation.

1. Safety Element
Document page 7
• Figure 8-3 MAP titled Slope Failure and Coastal Erosion (page 7) >> Legend identifies the “Coastal Zone” by a dotted pale blue line which is obscured by “seawall” and “riprap, other revetments”
>> To identify the “Coastal Zone” as only the immediate meeting of sea and land ignores the “Coastal Zone” definition used elsewhere to indicate that portion of land to which the 1976 Coastal Act applies. To avoid confusion the term “Coastal Zone” must be defined specifically and used uniformly.
>> The Figure 8-3 “Note” ( •Figure 8-3 “Note: Beach and cliff erosion are typical of much of Pacifica coastline.”) requires more detailed consideration. >> “Slope Failure Threat” must recognize and include the threat of bluff failure along nearly all our coast
Document page 10 (8-10)
• “Increased Coastal Erosion from Potential Sea Level Rise” >> Use current information from USGS COSMOS and Pacifica’s 2018 ESA vulnerability study to explain projected increase.
• Photo caption: “New development in the Coastal Zone must not require the construction of riprap or other protective devices that would substantially alter natural landforms (left) New development is required to be set back from coastal bluffs enough to accommodate a 100-year event, whether caused by seismic, geotechnical, or storm conditions (right).”

1.g
Packet Pg. 3275 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7036 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve >> Photo caption is consistent with State policy and should be emphasized.

Information elsewhere contradicts this caption.

Document page 11 (8-11) Implementing Policies
>> Identify policies specific to coastal bluffs/cliffs more clearly. cf. SA-I-3 Real Estate Disclosure specifies “suspected seismic or geologic hazards…and…risk of liquefaction, subsidence or landslide.” cf. SA-I-7 Erosion Prevention … “of hillside areas by revegetation…” >> Sea Level Rise and cliff/bluff risk of retreat MUST also be specified and disclosed in Real Estate transactions.
>> Revegetation is inappropriate for cliff/bluff erosion.

Cf. SA-I-8 Geotechnical Studies.
,,,, Within 50 feet of a coastal bluff
>> Add and Emphasize: “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.” Document page 12 (8-12)
SA-I-9 Maintain Restrictions on Hazardous Areas.
>> Clearly identify “Hazardous Areas”
Document page 13 (8-13)
SA-I-15 New Development in Coastal Zone.
>> Define new development in accord with the Coastal Act. >> Clarify sentence intent: strike beyond the existing development’s life >> Provisions must align with current State certified LCLUP Document p 18 (8-18)

1.g
Packet Pg. 3276 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7037 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve SA-I-27 Critical Facilities Location. Site criti- cal public facilities including hospital and healthcare facilities, emergency shelters, police and fire stations, and emergency communications facilities outside of the tsunami evacuation zone and 100-year flood plains. >> Add sewer pump stations as a Critical Facility
Document page 21 (8-21)
SA-I-28 Vulnerability Identification and Map- ping. The City’s Coastal Vulnerability zones shall be mapped …
>> Mapped in 2018 LCP draft

2. DEIR
page E-46
Table ES-3 Summary of Impacts and…
S A-I-15 New Development in Coastal Zone.
• 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; • 􏱈 Not accelerate the need for a shoreline structure or increase the likelihood 􏱈􏱈of a future seawall beyond the existing development’s expected life; and 􏱈 􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈 • 􏱈 Not violate required setback provisions.
>> Add BEACHES after bluffs and cliffs.
>> Define “substantially.”
>> Follow State of California Coastal Act guidance and clarify the date for “existing development ” to be consistent with the 1976 date for California voters’ approval of the Coastal Act.
>> Define “expected life.”
>> Add “New development is required to be set back from coastal bluffs enough to accommodate a 100-year event, whether caused by seismic, geotechnical, or storm conditions” according to certified LCP.

3.6-14
>> Placing coastal erosion in SMCMJLHMP under “Landslide/Mass Movements” does not adequately emphasize on-going and increasing erosion with SLR.

1.g
Packet Pg. 3277 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7038 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Document page 470
Beaches and Coastal Erosion
>> Update erosion history and bluff retreat.

Current data is based on 1998 report.

3.6-15
Figure 3.6-3 Slope Failure and Coastal Erosion
Map figure 8-3 is repurposed with legend including red line to indicate general “critical coastal erosion”
>> Map requires better accuracy and precision to be meaningful. > Arrow indicating “Severe Beach and Cliff Erosion” should bracket from north of the pier to the city limit and include “gullies” area. > Beach erosion extends south from the pier to Mori Point. > Arrow indicating “Severe Beach & Cliff Erosion“ on northwest Mori Point should include all area south from SF revetment.
> Beach and Cliff erosion occur on the hidden beach (AKA Smuggler’s Cove
> Serious cliff erosion resumes with marked effect on the porous limestones north of the Rockaway revetment.
> Cliff erosion wraps around all of Aramai Point (Rockaway Headland). > Remove “Wave Surge” at Pacifica State Beach north end.

3.6-17 Effects of Sea Level Rise
Paragraph 1: These general projections for the northern California Coast of dune and bluff erosion by 2025, 2050 and 2100 are inappropriate for Pacifica’s exposed coast north of Mori Point where bluff erosion has already exceeded the 2025 prediction in several places.
>> 2018 LCP vulnerability mapping would give Pacifica citizens a much better idea of the area of potential erosion.

1.g
Packet Pg. 3278 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7039 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Christine Boles [
Sent: Monday, January 10, 2022 10:16 AM
To: Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Bier, Mary [[email protected]]; Woodhouse, Kevin [[email protected]]; Coffey, Sarah [[email protected]] Subject: Safety Element public meetings?
[CAUTION: External Email]
Could one of you confirm if there were even any public meetings about the Safety Element portion of the General Plan?
Christine Boles, Architect
Beausoleil Architects
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3279 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7040 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From:

Sent: Monday, March 7, 2022 5:15 PM
To: Murdock, Christian [[email protected]]
CC: Public Comment [[email protected]]
Subject: San Pedro field
[CAUTION: External Email]
Dear Christian
This is a letter to object to residential development of the field at San Pedro and Grand Avenues.

Since 2016 we have been subjected to construction up against our house and property lines at 1335 Grand Ave. We now live with an « unmanaged motel The Anchor Inn » directly behind us. We also have behind us a very large house still under construction since 2018. Those windows look directly into our bedrooms from high above. Most construction starts at 7:01am. It has been constant noise since 2016. Now the construction on Olympian Way involves very large loud trunks and cranes going up/down Grand Ave at all hours.

We frequently need to escape the noise. The pictures on our walls are always askew due to the vibrations of vehicles and machinery.

On the weekends we are saturated with traffic and cars trying to park for the beach. I have to call the police due to drunk tailgaters. We now hide inside the house on weekends to avoid the « invasion » and because there are too many people and cars on the streets.

I have emailed the police, telephoned them and spoken to them in person about the speeding cars, stop sign running, illegal parking. No improvements. Our mailbox has been knocked down 3 times by speeding drivers due to the narrow road.

The field is the ONLY safe place to walk. It functions as a « village square » park for all of the Pacifica residents. (It does get swampy in the Winter). It gives breathing room to the over-crowded streets.

San Pedro Ave is the only entrance and exit for a large number of houses and people. It is narrow and frequently obstructed by trucks, surfers, food delivery semitrucks. How can it accommodate MORE traffic and people? Please help Pacifica return to a being a thoughtful city with a concern for its residents.

Pedro Point has enough development going on already.

Sincerely,

1.g
Packet Pg. 3280 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7041 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3281 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7042 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From:

Sent: Sunday, January 16, 2022 2:14 PM
To: Public Comment [[email protected]]
CC: _City Council Group [[email protected]]; City Manager [[email protected]] Subject: Sharp Park plan comments
Attachments: problem no solution.jpg
[CAUTION: External Email]
I notice that Sharp Park plan doesn't actually address sea level rise. It does not that sea level rise is an issue, but has not one plan address issues.

Issues like:
- Spending tons of money to beautify Sharp Park, and do nothing to protect that investment. - The pier has been damaged at least twice in the last decade. This is only going to get worse with sea level rise. How does the plan protect the pier, which the plan notes is a precious resource? - The properties near the end of the sea wall are getting damaged by the water forces being directed there by sea wall. Those residents might have a claim against the city. Sea walls are known for causing damage in adjacent areas:
https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fbeachapedia.org%2fShoreline_Structures&c=E,1,ScSmH7L HE7I3dhdumWCaaCrK99GhGTpEHzPPLV9tRFA_lUclyBLTgZ7zwvjqnPjFIvOUfF84L2WACWvQqIh6DzgyMVLSnmkjhMCg3RRNKj7qTCM5DSgM2zfQYM,&typo=1 What is Pacifica doing to protect these homes in the Sharp Park plan? How is Pacifica protecting itself from the legal liabilities around building a seawall next to private property? - Also, what is Pacifica going to do about the buildings that are literally falling into the ocean, and at risk of doing of falling into the ocean? Not just the Esplanade fiasco, but also the residences just north of the sea wall. - And when there are high sea waves, building facing the ocean get damaged, one place has had it garage door blown in at least twice in my memory. How much taller does the wall need to be, versus how tall the plan is? Which is to ask, why doesn't the Sharp Park Plan include data about how tall the sea wall needs to be? Deciding how tall to making the sea wall without knowing how tall it needs to be seems stupid. - During major storms, the Sharp Park golf course floods, and two things happen that are environmental issues:
-- They pile sand up next to the "illegal" berm protecting the golf course. Is that permitted from an environmental standpoint?
-- The golf course pumps out flood water into the ocean. The water from the golf course is polluted with herbicides and pesticides. Does the Sharp Park have a permit to pollute Pacifica's coast waters like that? This snapshot of the Sharp Park plan shows that they don't even know the scope of the problem of sea level rise.

CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3282 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7043 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

1.g
Packet Pg. 3283 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7044 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Bill [
Sent: Tuesday, January 11, 2022 11:20 AM
To: Public Comment [[email protected]]
Subject: Sharp Park Plan proposal
[CAUTION: External Email]
January 11, 2022
This comment is to a portion of the proposed Sharp Park Plan.

With regard to the library proposal, the public should know that:

1. Libraries have books. The Sanchez "library" would have neither books to browse, nor staff. Will it close for "nonuse" after the bond is approved?

2. How will the thousands of Pacificans who don't drive get to a central library? Pacifica is still car-dependent. The bus system is deficient. Pacifica's decision-makers all drive and only hear from fellow motorists. Kids, seniors, disabled and poor people who don't drive are overlooked in Car-Town, USA, yet they'd be taxed for the library. Will there be a library shuttle? An overbuilt library is nice for library staff (who have asked for private potties, among other perks to be paid by Pacificans) but inconvenient to residents miles away in Forgotten Fairmont or Linda Mar.

City Hall won't tell you this, (the interior design is not disclosed) but the "library" bond we'd be taxed for includes a new City

1.g
Packet Pg. 3284 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7045 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Council chamber (called a "community room") when our
existing community center would do just fine. It's overbuilt.

Two libraries are better than one.

Many Pacificans use the libraries in nearby cities without cost.

For years, City Hall has failed to fund library maintenance, cynically betting that voters can be compelled to vote for a new one.

City Hall promises the central library will be open daily. I don't believe it.

Would a building on the coast withstand the harsh weather?

3. Pacifica has the lowest per capita tax revenue in the county, with no corporations or big malls to share the tax burden. A costly library bond, in addition to the many bonds, parcel taxes, and usual property and sales taxes we already pay, would fall mostly on residents, making living here even less affordable. There's no low-income or senior exemptions.

Including interest payments, the actual cost of the bond is double the stated cost. City Hall won't tell you that, either.

City Hall is always poor-mouthing, but property taxes and city revenues are UP. Why doesn't our City chip in?

4. How much has Pacifica raised for this project from private donors? There's vast wealth nearby, but City Hall can only envision a hefty property tax hike. Another city in San Mateo County is building a new library, privately funded. Has Pacifica even tried? If a donor is willing to donate for naming rights, why not reduce the cost to Pacificans?

1.g
Packet Pg. 3285 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7046 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3286 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7047 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From:

Sent: Monday, February 21, 2022 2:34 PM
To: Murdock, Christian [[email protected]]
Subject: Sharp Park Specific Plan Comments
[CAUTION: External Email]
Hi Christian,
I have reviewed the plans and would like to share my concerns and feedback. While I do think that general development of the area to create a downtown atmosphere would be a good thing for Pacifica, I have concerns over the design as described in Chapter 5 of the plan.

First of all, Chapter 1 states the vision for the downtown becoming" charming and vibrant with a seaside atmosphere" and that the plans are to "enhance Sharp Park as a creative and historic enclave." I really appreciate the motive to honor the area's character, history and coastal locale as worded on 1.6
I would like to state that I am opposed to High Density Residencies (3.10) as it detracts from history and charm. The area will become boxy and lose all of its charm. I believe that Medium Density Residency buildings can become Mixed Use Centers and this will help to sustain our city's charm.

I like all the guiding policies described on 4.18 such as complete streets and improved public realm (in fact, this should be a goal for the entirety of Pacifica). We need safer pedestrian crossings that offer coastal access all over this town.

Now, Chapter 5 promotes an "Attractive Urban Design". The documents don't describe what is envisioned by 'urban design,' yet the photos show boxy and bland buildings that are not consistent with (5.1.19) "employing designs, features, materials, color that are consistent with character of Sharp Park."
The buildings in the 3-D renderings shown are similar to the newly renovated Eureka Square, which is a poorly designed hodge podge of materials and will take away all of our local seaside charm.

I would like to propose that the vision for "urban design" design is removed and instead we look towards other beautiful coastal California towns that are thriving in vibrancy and tourism. The designs should be more along the lines of Carmel, Santa Barbara. We can look for inspiration towards our own Rockaway Beach with the light colored shingled buildings.

1.g
Packet Pg. 3287 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7048 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Please do not use mixed materials such as stucco, wood and tiles as in the design of Eureka Square. Pacifica will end up looking just like Daly City and that does not exemplify a "charming and vibrant seaside atmosphere".

Thank you,
Jackie Rosenheim
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3288 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7049 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: brian o'flynn [
Sent: Wednesday, March 9, 2022 12:17 PM
To: Public Comment [[email protected]]
CC: brian o'flynn [
Subject: Sharp Park Specific Plan public comment
[CAUTION: External Email]
What makes the Sharp Park neighborhood in Pacifica uniquely wonderful is due in great part to its location fronting on the Pacific ocean and the people who are drawn to it . Its embrace of the sea first created and then subsequently has shaped Sharp Park.

The SPSP has highlighted the neighborhood’s being the city’s civic core, it being home to many unique businesses and its great potential for evolving and growing in vibrancy over the next several decades.

Significant opportunity for mixed-use buildings, new housing and higher intensity development that will help the city address issues of housing affordability and create a center of gravity for the broader Pacifica Community as well as visitors. The City owned site at 2212 Beach Blvd one block south of the Pacifica Pier slated for hotel development will bring much needed tax revenue to the City. All of the potential in the plan hinges on continuing the City’s commitment to maintaining the integrity of the neighborhoods relation with the ocean.

Managing potential sea level rise via well established construction methods is a good and important investment in our future. Of all of the great improvements planned for Sharp Park ( the revitalization of Palmetto Avenue, the new hotel on Beach Blvd, etc ) the rebuilding of the sea wall north of the pier is the most critical improvement that needs to completed to ensure the long term wellness of the Sharp Park community and should be the top priority of SPSP.It will protect our neighborhood for future generations to live, work and enjoy as well as ensuring public access to our popular ocean front.

Building a new replacement sea wall north of the Pier in the same location as the existing seawall/revetment is a straightforward and efficient proposition. Years of study by the city with community involvement has resulted in a great plan for doing so . The study recognized the importance of protecting the community, housing , property, structures and infrastructures - both public and private via a new sea wall. The construction of a new sea wall should be made a key part of the Sharp Park Specific Plan and written into the plan as specific public policy and top priority. .Sincerely,
Brian O’Flynn
long time Sharp Park Property owner
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3289 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7050 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Tom Thompson [
Sent: Monday, March 7, 2022 5:44 PM
To: Murdock, Christian [[email protected]]
CC:

Subject: Sharp Park Specific Plan Public Comments
[CAUTION: External Email]
Hi Christian:

I just emailed in my Sharp Park Specific Plan Public Comments to the email address [email protected] with a PDF of signed comments as well.

Please, kindly confirm they were received within the deadline.

Best Regards
Tom Thompson, Sharp Park property owner and taxpayer for 35+ years CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3290 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7051 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve From: Tom Thompson [
Sent: Monday, March 7, 2022 5:35 PM
To: Public Comment [[email protected]]
CC:

Subject: Sharp Park Specific Plan Public Input
Attachments: Sharp Park Specific Plan Comments by Tom Thompson, Sharp Park property owner and taxpayer for 35+ years 3-7-2022.pdf
[CAUTION: External Email]
As a Sharp Park property owner and taxpayer for 35+ years, I am submitting the following public comments regarding the Draft Sharp Park Specific Plan. I have attached a signed PDF copy as well.

Date: March 7, 2022
To: City of Pacifica
Subject: Public Comments on Sharp Park Specific Plan
The Sharp Park Specific Plan (SPSP) has a major flaw. Environmental justice and economic justice issues are at risk.

Let’s fix the SPSP. Now, while we can.

Essentially, the Sharp Park Specific Plan (SPSP) is spot-on. Visionary. Essential. Brilliant. The vision for Palmetto Ave as a vibrant and walkable small “Downtown Pacifica” is just what we need. A new hotel at 2212 Beach Blvd. is key to making this happen. Adding shops, eateries and other businesses will make Pacifica thrive. And the increased tax revenue to our city treasuries is essential to our economic viability as a city.

The SPSP goes into detail about the potential for Sea Level Rise. Yet, the SPSP is virtually silent about a commitment to seek a simple sea level rise solution for Pacifica and Sharp Park… A RUBUST SEAWALL. Is this just a major oversight, or a plan for failure? Unless the SPSP includes a commitment to pursue a robust seawall… within the Sharp Park Specific Plan itself, the SPSP becomes a plan for failure.

Furthermore, without a commitment to pursue a robust seawall…. investment in Sharp Park to make it a robust “Downtown Pacifica”… will never happen.

This single flaw in the SPSP is easy to fix though. The SPSP needs a strong policy commitment statement that Pacifica will pursue the design and funding to build a robust seawall. A plan to guard against the potential for sea level rise. Public infrastructure, family homes, retirement nest eggs, businesses, and affordable recreation are at stake.

Hundreds of millions of dollars of public infrastructure are potentially at risk, without a robust seawall.

This critical essential public Infrastructure must be protected from potential sea level rise. Without the

1.g
Packet Pg. 3291 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7052 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve existing standing sewer pump station alone, 40% of Pacificans will lose their sewer service. Not just lost in Sharp Park, but 40% of all Pacifica! The golf course, pier and access to coastal trails provide affordable recreation that need the protection of a robust seawall. A robust seawall is both an environmental justice issue, and an economic justice issue.

Pacifica family investments in homes & businesses must be protected. Homeowners who invested their life savings never thought they should fear their government might abandon them and effectively condemn their homes by not protecting public infrastructure and places to live… with a robust seawall.

Again, environmental and economic justice issues.

A robust seawall north of the pier is a no brainer. The Sharp Park Specific Plan needs to be clear that we are working to make a robust seawall north of the pier happen. The simple solution is a robust seawall north of the pier. Let’s fix the Sharp Park Specific Plan, with a clear policy statement within the SPSP itself that we will work to make a seawall happen.

Here is more detailed list of what is at stake, unless we make a commitment to pursue a robust seawall… within the Sharp Park Specific Plan itself.

PRIORITY SOLUTION: WE NEED TO COMMIT, WITHIN THE SPSP ITSELF, TO BUILDING A SEAWALL NORTH OF THE PIER, so we can:

A) Protect Public Infrastructure Investment. Economic & Social Justices Issues Involving:
1) Streets & Roads
2) Sidewalks
3) Beach Promenade
4) Storm Drains
5) Access to Coastal Trails
6) Sewer Lines
7) Natural Gas Lines
8) Electrical Service
9) Internet
10) Cable lines
11) Water Service Lines
12) Golf Course
13) Fishing Pier
14) Existing major sewer pumping station at 2212 Beach Blvd. Sewer service for 16,000 people. That’s 40% of all Pacificans. Not just Sharp Park.

B) Protect Private Investment. Economic & Social Justices Issues Involving:
1) 1,000 + of our most affordable existing homes.
2) 100+ existing small businesses.
3) Future Investment to make Palmetto a thriving walkable downtown district.
4) 2212 Beach Blvd Hotel won’t happen without a commitment to a seawall.

Pacifica’s financial future depends upon a new hotel on that site.

1.g
Packet Pg. 3292 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7053 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 5) No commitment to pursuit of a robust seawall. Means no commitment to a hotel. How and why would investors move forward without this assurance?
6) The same holds true for other investors in Sharp Park. Why would any investors come to Sharp Park, if the city is not committed to protecting Sharp Park?
C) Again, Protect Environmental and Economic and Social Equity Justice Issues including:
1) Think of the environmental & economic mess if 40% of Pacifica loses their sewer service because we didn’t protect the sewer pumping station with a robust seawall.
2) Preserving Pacifica’s 1,000+ most affordable homes in Sharp Park. 3) Preserving 100+ small businesses in Sharp Park.
4) Homeowners and small businesses have their nest eggs and retirement invested in Sharp Park.
5) These homeowners and businesses never dreamed their city might abandon them by not making it a policy to protect their homes & investments with a robust seawall.
6) Affordable access to our fishing pier provides affordable food to many families.
7) Access to affordable recreation like fishing, picnicking, golf & hiking trails are at risk.
8) Protecting Sharp Park with a simple robust seawall, north of the pier, is essential to getting the investment we need to make Sharp Park thrive. 9) And the increased tax revenue to our city treasuries from these investments is essential to our economic viability as a city. Economic justice for the city itself.

Tom Thompson
Sharp Park Property Owner and Taxpayer for 35+ Years
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

1.g
Packet Pg. 3293 Attachment: Attachment G - FEIR Appendix A - EIR Comment Letters (5035 : Consideration of Adoption of General Plan Update)

2.C
Packet Pg. 7054 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Date: March 7,2022
To: City of Pacifica
Subject: Public Comments on Sharp Park Specific Plan