Pacifica City Council
July 11, 2022

To: City of Pacifica Planning Commission
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 still 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. Pacifica has completed an exhaustive Beach Boulevard Infrastructure Resiliency Project Study (BBIRP). This BBIRP plan concludes a robust seawall is the best comprehensive and simple solution to the future effects of potential sea level rise in Sharp Park. 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 … will never happen. Why would investors build a hotel, restaurant, offices or affordable homes envisioned in the SPSP… without Pacifica’s commitment to pursue a robust seawall? Not a rhetorical question. Why would they make such a large investment? This single flaw in the SPSP is easy to fix though. The Sharp Park Specific Plan requires 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

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Packet Pg. 3938 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7699 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 22 recreation are at stake. As well as future projects like a hotel, with vital tax income critical to Pacifica’s economic survival!
Hundreds of millions of dollars of public infrastructure are at risk, without a robust seawall. This critical essential public Infrastructure must be protected from potential sea level rise. Without the existing standing sewer pump station alone, which would be lost to sea level rise, 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, key environmental and economic justice issues.

Candidly, 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 robust seawall happen.

Page two here includes a 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.

Tom Thompson
Sharp Park property owner and taxpayer for 35 years.

June 6,
2022

Sharp Park Specific Plan Public Comments
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 and Cable lines
10) Water Service Lines
11) Golf Course
12) Fishing Pier
13) 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.

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Packet Pg. 3939 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7700 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 23 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. 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.

From: Murdock, Christian <[email protected]>
Sent: Monday, June 6, 2022 4:24 PM
To: Tom Thompson < >
Subject: RE: Public Comment before 6-6-2022 Pacifica Planning Commission Meeting Item #2 General Plan Update and New Sharp Park Specific Plan and recommendations to city council Tom, thanks for resending. I’m still unable to open the PDF. My apologies for the inconvenience.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]
From: Tom Thompson < >
Sent: Monday, June 6, 2022 4:11 PM
To: Public Comment <[email protected]>

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Packet Pg. 3940 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7701 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 24 Cc: Murdock, Christian <[email protected]>
Subject: RE: Public Comment before 6-6-2022 Pacifica Planning Commission Meeting Item #2 General Plan Update and New Sharp Park Specific Plan and recommendations to city council [CAUTION: External Email]

Hi Christian:

Here again is the PDF for today’s 6-6-2022 Pacifica Planning Commission Meeting Item #2 General Plan Update and New Sharp Park Specific Plan and recommendations to city council. I verified the PDF is working fine.

Tom Thompson
From: Public Comment <[email protected]>
Sent: Monday, June 6, 2022 3:57 PM
To: Tom Thompson < >
Subject: RE: Public Comment before 6-6-2022 Pacifica Planning Commission Meeting Item #2 General Plan Update and New Sharp Park Specific Plan and recommendations to city council Hi Tom,
There appears to be a problem with the PDF you attached to your comment email. Can you resend, please? Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]
From: Tom Thompson < >
Sent: Monday, June 6, 2022 8:14 AM
To: Public Comment <[email protected]>
Cc: ; Murdock, Christian <[email protected]>
Subject: Public Comment before 6-6-2022 Pacifica Planning Commission Meeting Item #2 General Plan Update and New Sharp Park Specific Plan and recommendations to city council [CAUTION: External Email]

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Packet Pg. 3941 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7702 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 25 Honorable Planning Commissioners, City Council and city staff:

The Sharp Park Specific Plan is spot-on, with one major flaw we can fix.

It goes into detail about potential Sea Level Rise… yet is virtually silent about a commitment to seek a solution for Pacifica and Sharp Park… A RUBUST SEAWALL north of the pier. Pacifica completed an exhaustive Beach Boulevard Infrastructure Resiliency Project Study… which concludes a robust seawall is the best comprehensive and simple solution to future effects of potential sea level rise in Sharp Park.

Without a commitment to pursue a robust seawall…. investment in Sharp Park … will never happen. Why would investors build a hotel, restaurant, offices or affordable housing without Pacifica’s commitment to pursue a robust seawall? Not a rhetorical question. Why?
The Sharp Park Specific Plan requires 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. As well as future projects like a hotel and the tax revenues we desperately need!
Pacifica families invested their life savings, and built their nest eggs, never thinking they should fear their government might abandon them and effectively condemn their homes and businesses by not protecting public infrastructure and places to live… with a robust seawall. Billions
Hundreds of millions of dollars of public infrastructure alone are potentially at risk. Without the existing sewer pump station alone, 40% of ALL Pacificans will lose their sewer service. The golf course, pier and access to coastal trails provide affordable recreation that need the protection of a robust seawall. A robust seawall north of the pier are both huge environmental justice and economic justice issues.

Let’s fix the Sharp Park Specific Plan, with a clear policy statement added… Pacifica will work to make a robust seawall north of the pier happen.

I also submitted into the public record by email, a 2-page detail (attached to this email) of what is at stake, unless we make a commitment to pursue a robust seawall north of the pier… within the Sharp Park Specific Plan itself.

Thanks for listening,
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.

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

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

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Packet Pg. 3942 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7703 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3943 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7704 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3944 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7705 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 26 Murdock, Christian
From: Madhu Mathew < >
Sent: Monday, June 6, 2022 5:56 PM
To: Murdock, Christian
Cc: Public Comment
Subject: Public Comment - Pacifica Planning Commission Item 2, 2009-001 2020-007 [CAUTION: External Email]

Dear Christian Murdock,
I am writing to request more time to fully read and understand the document regarding Consideration of Environmental Impact Report and California Environmental Quality Act Findings, General Plan Update and New Sharp Park Specific Plan. The document is close 5000 pages long and it takes time for an average lay person like me to fully comprehend. I have to do so after our day jobs are done. Please do consider extending the timeline by a few weeks for us to read through and participate in the process.

Please also consider breaking these into three separate documents and have us public comment on it separately. It would allow us to have the time to understand each one and provide meaningful comments.

With climate change we are now faced with extreme weather events. Heavy precipitation events like bomb cyclones cause landslide risks and extended drought conditions increase fire risks. All of these require careful considerations in the plan update. As a Pacifica resident, I humbly request an extension for the citizens like me to participate meaningfully.

Thank you,
Madhu Mathew

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

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Packet Pg. 3945 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7706 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 27 Murdock, Christian
From: Richard Harris Jr.

Sent: Monday, June 6, 2022 4:11 PM
To: Murdock, Christian; Pacifica Permit Tech; Coffey, Sarah; City Manager; [email protected]; [email protected]; 'Potter, Spencer (REC)'; 'HELEN DUFFY'; 'Leslie Davis'; [email protected]; Bob Downing; Bo Links Cc: O'Connor, Bonny
Subject: SF Public Golf Alliance Comment re Pacifica Gen Plan, EIR,6.6.22 / Planning Commission Meeting, June 6, 2022, Agenda Item #2
Attachments: SFPGA.Ltr.Pacif.Pln.Comm.comment.Gen.Pln.,EIR,6.6.22.pdf [CAUTION: External Email]

SF Public Golf Alliance Comment re Pacifica Gen Plan, EIR,6.6.22 / Planning Commission Meeting, June 6, 2022, Agenda Item #2
Dear Pacifica Planning Commission and Department, et al Enclosed please find the Comment of San Francisco Public Golf Alliance re the Pacifica General Plan and EIR (May 2022 Draft), set for discussion at the Commission’s June 6 meeting.

Please confirm receipt.

Planning Staff and Ms. Coffey, please distribute to the Planning Commissioners prior to tonight’s meeting, and to City Council members, respectively.

Mid-afternoon today, in the course of final proofreading, I found that the Planning Commission’s url link to the Agenda Packet for the June 6 meeting became inoperable.

Don’t know whether this was a problem local to my computer or whether the problem is at the City’s end. There are several citations in the above-attached letter to
Page numbers in the Agenda Packet. So I request leave, at such time that the Agenda Packet becomes operable again, to make any necessary corrections in the event
You are unable to track my citations to those page numbers.

Thanks all around for your diligence and hard work.

Richard Harris, President
San Francisco Public Golf Alliance
San Francisco, CA 94117-4012
Phone:

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

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Packet Pg. 3946 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7707 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 1 San Francisco, CA 94117 • • [email protected]
June 6, 2022
By e-mail
[email protected]
[email protected]
Pacifica Planning Commission
Pacifica Planning Department
Attn: Christian Murdock, Acting Director
540 Crespi Dr.

Pacifica, CA. 94044
Re: Pacifica Planning Commission Meeting, June 6, 2022
2022 Pacifica Public Review Draft General Plan, and Final EIR San Francisco Public Golf Alliance comment:

In the response to comments section of the Final EIR (responding to comment letter C128-1, at Packet Page 1507), the Planning Department admits an “accidental omission” of Sharp Park Golf Course from the text, tables, and figures of the General Plan and EIR. But the error has not yet been completely corrected in the Final EIR or in the May 2022 Draft General Plan now being considered by the Planning Commission at its June 6 meeting.

The “accidental omission” should be corrected as follows:
(1) in the Final EIR, Figure 3.8.1, the “Historic and Cultural Resources” map (at 559/1125), the label should read: “Sharp Park Golf Course and Clubhouse”; (2) in the May 2022 Draft General Plan, at page 7-42 (Packet Page 237) the text should be amended to add the word “and” between “Golf Course” and “club house”, and Table 7-5 (also at page 7-42) and Figure 7-4 “Historic and Cultural Resources” (at Packet Page 238) should both be revised to designate “Sharp Park Golf Course and Club House”

Dear Pacifica Planning Commission and Planning Department, The purpose of this letter is to correct old and stubborn mistakes in the Draft General Plan and Environmental Impact Report – both of which designated in their 2022 drafts the Sharp Park Golf Course Clubhouse as a Pacifica historical resource but failed to so designate the Sharp Park Golf Course itself. This has been a repeated subject of our correspondence to the Pacifica Planning Department and Commission -- on three prior occasions, in 2014-15, 2020, and again in March 2022. Each time, City of Pacifica Planning Department formally acknowledged our

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Packet Pg. 3947 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7708 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 2 comment that both the golf course and the clubhouse are Pacifica historical resources and said that the new General Plan would be corrected to formally recognize the historical resource status of both the golf course and clubhouse. Yet the error persists in the current versions of the City’s draft documents. Now is the time to finally get this right.

By our 11-page, heavily annotated and documented letter dated July 9, 2014 to the Pacifica Planning Department, commenting on the then-draft Pacifica General Plan and EIR, we set out at length the architectural history of the golf course and its world-famous architect Dr. Alister MacKenzie, including official resolutions from the Pacifica City Council1 and San Mateo County Board of Supervisors2
recognizing the historic significanceof both the golf course and the club house, together with the resolution from the Pacifica Historical Society and the “historic resource property” designation under CEQA by the City and County of San Francisco. A copy of that letter is attached hereto by electronic link as Exhibit A, and is incorporated herein by this reference.3 Responding to our comment, the Pacifica Planning Department’s formal Response to Comments to the Draft General Plan, dated April 2015,4 stated:

Recommendation: Identify Sharp Park Golf Course as a historic resource. Sharp Park Golf Course is identified as a historic resource in the text, table and map on pages 7-44 and 7-45 of the Draft General Plan. Please see Chapter 3: Recommended Plan Modifications.

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

Table 7-5: Historic Sites in Pacifica . . . .Sharp Park Golf Course and Clubhouse”

Figure 7-6: Historic and Cultural Resources Map will be revised to show Sharp Park Golf Course and Clubhouse as a historic resource.”
When the current iteration of the Pacifica General Plan / EIR updating process recommenced in or about 2020, by e-mail exchange in August- September 2020 with Pacific Planning Department, we resubmitted our July 9, 2014 General Plan/EIR comment (Exhibit A), and 1 Pacifica City Council, Resolution No. 63-2007, Dec. 10, 2007, at page 1 https://drive.google.com/file/d/1EC6KmukbSSxSdIFvX9aDahcmfz46B1f4/view?usp=sharing 2 San Mateo County Board of Supervisors, Resolution No.069145, Dec. 18, 2007, at page 1 https://drive.google.com/file/d/12287bypq7f1cFy3c8fNZYjAMVnVvbEk6/view?usp=sharing 3 SF Public Golf Alliance Comment Letter to Pacifica Planning Department, re Draft General Plan and Environmental Impact Report, Jy. 9, 2014: https://drive.google.com/file/d/1JHtusyzIS4xo12EFIAdpy7fbDiPZEYlx/view?usp=sharing (EXHIBIT A).
4 Responses to Comments on the Draft Pacifica General Plan, April 2015, at pg. 2-50 (58/120) Prepared by City Staff (Dyett and Bhatia stamp appears at page 120/120). https://www.cityofpacifica.org/civicax/filebank/blobdload.aspx?blobid=7443

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Packet Pg. 3948 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7709 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 3 were assured by then-Chief Deputy Planner Mr. Murdock of the Planning Department’s “intent to rely on any environmental analysis which was completed in the earlier EIR process.”5 But the January 2022 Draft versions of the General Plan and EIR continued to fail to identify Sharp Park Golf Course and Clubhouse as Pacifica historical resource properties, so we again by letter dated March 7, 2022 (a copy of which is part of the Record at Packet Page 2893 ff, and is incorporated herein by this reference), urged the Planning Department that the Final General Plan and EIR should, in their respective texts, tables of Historic Sites, and figures of “Historic and Cultural Resources,” identify both the Sharp Park Golf Course and Clubhouse as Pacifica historic properties. And we reminded the Planning Department of its prior commitments – not yet realized – to make the necessary changes to the General Plan and EIR.6 Rinse. Repeat. In the Response to Comments section of the Final EIR, the Pacifica Planning Department acknowledged our March 7, 2022 letter (Letter C128-1, at Packet Page 1507), by admitting the Department’s mistake: “The comment accurately describes the accidental omission of the entire Sharp Park Golf Course as a historic resource, and is noted and appreciated.. . . The comment stated that the Sharp Park Golf Course itself—and not only the Clubhouse—should be identified in the General Plan and EIR as an historic resource. , , the Draft EIR has been updated to reflect this change.”
7 (emphasis added) See Packet Pg. 1507.

But this has still not been done in the Final EIR and the General Plan May 2022 Draft that are before the Planning Commission for consideration at its June 6, 2022 public meeting. And by this letter we request that the changes be made.

THE TEXT AND HISTORIC RESOURCES TABLE IN THE FINAL ENVIRONMENTAL IMPACT REPORT (FEIR) BOTH LIST “SHARP PARK GOLF COURSE AND CLUBHOUSE” AMONG PACIFICA’S HISTORIC RESOURCES,
BUT FIGURE 3.8-1, THE “HISTORIC AND CULTURAL RESOURCES” MAP, NOW IDENTIFIES THE GOLF COURSE BUT NOT THE CLUBHOUSE.

THIS DETAIL NEEDS TO BE CORRECTED, AND BOTH SHOULD BE IDENTIFIED.

The Final EIR to the Pacifica General Plan Update and Sharp Park Specific plan, dated May 25, 2022, appears at Packet Page 3566 of the Planning Commission’s June 6, 2022 meeting Packet as a URL link: https://cityofpacifica.egnyte.com/dl/mccqSGSmU7. 8 This linked document,
entitled “City of Pacifica General Plan Update and Sharp Park Specific Plan Final Environmental Impact Report, SCH: 2012022046, Appendix B / May 25, 2022,” is a redline version, showing changes from previous version of the Draft EIR.9
5 E-mail, Aug. 6, 2020 from Pacifica Deputy Planning Director Murdock, in response to Aug. 6, 2020 e-mail from Richard Harris: https://drive.google.com/file/d/1P8LIUmmkWBFACu1R4FWFo wqRrwqeaQy/view 6 Letter, San Francisco Public Golf Alliance to Pacifica Planning Dept., Mar. 7, 2022, at pp. 2-4 https://drive.google.com/file/d/1Se6duX6FtVR1k0McnXz2AUzNMKZ7xVde/view?usp=sharing 7 Attachment F – Final EIR (FEIR) Chapters 1-3, etc., LetterC128-1, at Packet Pages 1507-08 https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1414&Inline=True 8 Copies of pages 3.8-4 through 3.8-4 of the FEIR redline can be found here:
https://drive.google.com/file/d/1bv-gwnuN0Mh X1ge69GPdATrxXA13DNh/view?usp=sharing

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Packet Pg. 3949 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7710 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 4 In Section 3.8, “Cultural Resources and Tribal Cultural Resources,” under the subheading “Historic Resources,” the text of the Final EIR at page 3.8-4 (558/1125) has been corrected (redline showing) to list “the Sharp Park Golf Course and Clubhouse” among Pacifica’s “Locally Listed [Historic] Resources,”10 as follows:

The Final EIR’s Table 3.8.1, “Historic Resources in the Planning Area,” at Page 3.8-8 (562/1125),11 has also been corrected to designate “Sharp Park Golf Course and Clubhouse:

10 See copies of the relevant pages at footnote 8, supra. 11 See copies of the relevant pages at footnote 8, supra.

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Packet Pg. 3950 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7711 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 5 But the correction has not correctly been made to the Final EIR’s Figure 3.8-1,12 “Historic and Cultural Resources,” which now names the Golf Course but omits the Club House:

This omission in the Final EIR should be corrected by simply adding the words “and Clubhouse” after “Sharp Park Golf Course,” to make Figure 3.8-1 consistent with Table 3.8-1 and the text of Section 3.8, “Cultural Resources and Tribal Cultural Resources”.13

THERE ARE JUMBLED REFERENCES TO THE SHARP PARK GOLF COURSE AND CLUBHOUSE IN THE TEXT AND AT TABLE 7-5 AND THE MAP AT FIGURE 7-4 IN THE “HISTORIC RESOURCES” SUBSECTION OF THE MAY 2022 DRAFT GENERAL PLAN.

THESE REFERENCES SHOULD BE CORRECTED TO UNIFORMLY DENOTE “SHARP PARK GOLF COURSE AND CLUBHOUSE” AS PACIFICA HISTORIC RESOURCES.

Section 7, “Conservation,” of the Draft General Plan (May 2022), at Page 7-42 (Packet Page 352), under the heading “Historic Resources,” third paragraph, states: “The City has identified nine historical landmarks . . . the Sharp Park Golf Course club house”. This is error because it omits the “and” between “Golf Course” and “club house,” and is inconsistent with the Final EIR text, as discussed above at Footnote 2, and is inconsistent with the Final EIR Table 3.8-1, also discussed above. Likewise, the May 2022 Draft General Plan’s Table 7-5 at Page 7-42 (Packet Page 352) and Figure 7-4 Historic and Cultural Resources are in error because they now identify only Sharp Park Golf Course as a Pacifica Historical Resource, rather than the correct designation of “Sharp Park Golf Course and Club House”. See the discussion above. 12 See copies of the relevant pages at footnote 8, supra. 13 See copies of the relevant pages at footnote 8, supra.

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Packet Pg. 3951 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7712 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 6 CONCLUSION: The Sharp Park Golf Course is the eponym of Pacifica’s Sharp Park District. The golf course, which opened for play in 1932, is the work of world-renowned master architect Alister MacKenzie, and has been designated Historic Resource Property under CEQA by the San Francisco Planning Department and by the Pacifica Historical Society. The current (1980) Pacifica General Plan and Unanimous resolutions of the Pacifica City Council and San Mateo County Board of Supervisors recognize both the golf course and its clubhouse as historically significant properties. The General Plan and EIR should be revised – as discussed above and as provided in the April 2015 Responses to Comments on the Draft General Plan – to show and determine Sharp Park Golf Course and its clubhouse to be Pacifica Historic Sites and Resources.

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

Pacifica City Council and Councilmembers
Pacifica City Manager Kevin Woodhouse
Pacifica Historical Society
Spencer Potter, SF Recreation and Park Department
Leslie Davis, Helen Duffy, Lisa Villasenor, Sharp Park Business Women’s Golf Club Bob Downing, Sharp Park Golf Club
Bo Links, Esq.

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Packet Pg. 3952 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7713 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 28 Murdock, Christian
From: dawn zidonis
Sent: Monday, June 6, 2022 4:09 PM
To: Public Comment; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg; Murdock, Christian; Murdock, Christian Subject: Public Meeting 6/6
[CAUTION: External Email]

Hello,
I first want to thank you all for the energy you've put into the general plan and EIR. It's a massive project and I'm grateful to everyone working towards making a positive impact on the future of Pacifica.

1. My first comment is to share disappointment about not receiving notifications of tonight's meeting. I had June 1st on my calendar and was not notified it had been rescheduled. (I had to ask a neighbor when I was getting ready to attend why I could no longer find the info on the website). I emailed the city manager to inquire about being added to a notification list, but I never received a response. We have a right to be informed of meetings in a more efficient and timely manner. Releasing information over holiday weekends, which has happened multiple times, is not acceptable.

With projects such as this, schedules and timelines should be published far in advance.

2. My second comment is about the lack of transparency, communication and engagement with the public about the General Plan and EIR. When residents speak up, there is little to no engagement or response in return from leadership. It feels very one-sided and doesn't feel collaborative or as if leadership has our best interests in mind (possibly because we're not being asked, as a community, what do we want? How do we envision the future of Pacifica?) I know our city staff and council members are working hard with limited resources, and I'm hoping that they are doing so by having our best interest in mind. I've never been asked by leadership about how I envision the future of Pacifica. We have an opportunity to plan for the future and should have had surveys, community workshops, presentations and more opportunities for engagement.

It is my hope that we can find a way to engage and collaborate better together in planning for the future to resolve the disconnect between leadership and residents and taxpayers who call Pacifica home. --
Dawn Zidonis
(she/her/hers)
m
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Packet Pg. 3953 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7714 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 1 Murdock, Christian
From: William Bradford >
Sent: Monday, June 6, 2022 5:58 PM
To: Public Comment
Cc: Bier, Mary; Phil and Sharron Lindsey
Subject: Oral Communications
[CAUTION: External Email]

My name is William Bradford living at 580 Ridgeway Drive, Pacifica.

Regarding the Safe Parking Program for over sized vehicles I respectfully request that a full environmental impact report be prepared prior to finalizing this program. I have been told by a city official that the only consideration given at this point was traffic safety ignoring all other impacts to our city. An environmental impact report will provide the needed analysis of all impacts so informed decisions can be made. And, besides, I think it is the law.

Sincerely,
William Bradford
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Packet Pg. 3954 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7715 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 2 Murdock, Christian
From: David Whitney
Sent: Monday, June 6, 2022 6:57 PM
To: Public Comment
Subject: Sharp Park Specific Plan, Planning Commission, 6/5/2022 [CAUTION: External Email]

It seems Pacifica’s is in financial denial when it is dependent on sales tax increase passing in November 2022, just to keep operating expenses covered, and nothing left over for this plan. Does Pacifica imagine it has Biotech industry to pay for such expansive ideas. Who accounts for plans that will not get approved and then waste money to redo plans. Pacifica lost2 million years ago in bad accounting, David Whitney
Pacifica, Ca 94044
Sent from Mail for Windows
2 million
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Packet Pg. 3955 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7716 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 3 Murdock, Christian
From: Erin Farrell
Sent: Monday, June 6, 2022 10:12 PM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: Did you vote yet? Gen Plan / EIR Comment
[CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,

I am writing to urge you not to adopt the current GPU and EIR that are being presented for your consideration at the upcoming June 6 public hearing, which proposes to change the Land Use Designation of the five-acre Pedro Point Field, a recognized wetlands and Environmentally-Sensitive Habitat Area (ESHA) and a center of our community, from Commercial-Recreational Use to Commercial Residential Mixed Use.

In addition to the environmental ramifications for this wetland area and habitat, I have seen the adverse effect of sea rise in Pacifica and other cities. Building on this plot of land would be irresponsible for Pacifica to pursue on multiple levels--budget to continue down a path that will not be approved, damage to the environment, consequences of sea rise-- physical, insurance, etc Is Pacifica going to buy this property from owners later when we need to cede to the ocean? Who will gain? Developers, not Pacifica's government or residents.

I fully support comments previously submitted by PPCA President Allison West on March 7, 2022 and related letters submitted by the PPCA’s CEQA consultant Richard Grassetti, attorney Brian Gaffney, and consulting Coastal Ecologist, Dr. Peter Baye, and am disturbed that this testimony was rejected without adequate analysis. Their comments documented known DEIR deficiencies and reasonably foreseeable adverse impacts of the proposed GPU that are in violation of CEQA and Coastal Act policies. Please do not dismiss these expert opinions and instead take steps to address the noted deficiencies and violations before adopting these important guiding documents for our city.

Sincerely,
Erin Farrell
Belfast Ave
Pacifica, CA
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Packet Pg. 3956 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7717 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 4 Murdock, Christian
From: Samuel Casillas < >
Sent: Monday, June 6, 2022 10:48 PM
To: Public Comment
Subject: Comments for Special Planning Commission meeting to consider approval of the GPU, FEIR and SPSP
Attachments: GPU DEIR and SPSP Casillas comments 6 6 22.docx [CAUTION: External Email]

Please include my comments from tonight for the public record. thanks,
Sam
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Packet Pg. 3957 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7718 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Mr. Christian Murdock
Deputy Planning Director
Planning Department
1800 Francisco Boulevard
Pacifica, CA 94044
[email protected]
[email protected]
CC: California Coastal Commission
Date: June 6, 2022
Subject: Consideration of Environmental Impact Report and California Environmental Quality Act Findings, General Plan Update and New Sharp Park Specific Plan, and Recommendation to City Council.

Dear Planning Commission:

Over the past decade the community of Pedro Point has attempted to act as a partner in the update to Pacifica’s General Plan, including neighborhood meetings with the input and participation of the city manager’s office. The community even requested the city work with us to develop a neighborhood specific plan which the city also dismissed.

I personally have tried to be a conduit for community input as a past member of both the Pacifica Sea Level Rise Adaptation Planning Committee and the Pacifica GPU Community Outreach Committee and I can once again state that the majority of our concerns about this plan have consistently been ignored. The DEIR even states in chapter 4.2 that “the alternatives were selected to, “bracket the range of choices that have the broadest support from the community”, yet that city has disregarded over 99% of what the Pedro Point Community has repeatedly recommended for the property known as the Pedro Point Field in order to please only the investor property owner.

We have been forced to hire biologists, CEQA experts, environmental attorneys and submitted irrefutable evidence of special species and ESHA along with documented CEQA and Coastal Act violations and yet the city continues to work against its own citizens.

Under the current draft of the 2022 GPU states implementation policies to Expanded low-intensity outdoor Commercial Recreation on sites near Pacifica State Beach (ES-I-34), Preserve the Experience of the Natural Environment that do not disrupt view corridors (ES-I-35), be a center for recreation and community (CD-I-1), Improve pedestrian routes along corridors (CD-I-24), Open Space Conservation and Habitat Protection that support critical wildlife habitat and special status species (LU-G-7) and to not increase the density or intensity of land use designations beyond those indicated in the LCLUP for sites located within Coastal Vulnerability Zones (LU-G-8), not to mention the violations of SB379, yet these policies are exactly what the City chose to ignore by recommending residential at this site.

Further, with the city being fully aware of the denial of the CDP at 505 San Pedro due to the multiple hazards including flooding, shallow water table, identified multiple protected species, wetlands and an ESHA designation the city has still ignored this data. As far as the CRLF is concerned the CCC biology report states that the frog needs a minimum of a 300 ft foraging corridor. Again, the City has chosen to ignore this data. The city does recognize the existence of the CRLF in the DEIR “Special Status Species” figure 3.7-4 but omits the USFWS guidance of a minimum of 300 feet of foraging corridor for the special status species. Additionally, because the species is not able to forage in any other direction because of the existing developing to the south and east the whole west of the Site is needed for foraging habitat which can end up covering the whole field. In addition, the city has cherry picked a low SLR range that the CCC says is mandating at 6.9 feet which is based on the best available science.

If these egregious denials were not enough the California Coastal Commission has continually requested this same data to certify the LCLUP that they handed to you and that we have made available to you all, which included that denial of the CDP application 2-19-0026 at 505 San Pedro Ave where the Coastal Commission’s biologist and the Department of State Fish and Wildlife concluded the presence of ESHA and the California Red Leg Frog in the adjacent waterway AND

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Packet Pg. 3958 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7719 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve also surmised that the Pedro Point Field was most likely wetlands, yet the city has chosen to ignore the coastal commission and F&W.

Specific to violations of CEQA the city master responses state erroneously that it can defer a site specific EIR until another project is proposed in this area and basically ignore any data presented by the agencies that will need to certify the City’s General Plan because there is a “conflict of experts”. CEQA does not allow this deferral for two reasons:

1. The city is required to make the determination now as to which data it will use to justify their recommendation

2. The city is proposing substantial changes from the current zoning of Commercial recreational to residential and also ignoring the on-site conditions of zero current structures; they can not hypothetically state a fast food joint can be built there now so the housing will be less impact NOTE: many of the responses to our questions are that the comments are “noted” or “comments received”; this response is inappropriate at best and also insulting.

The city also states that the FEIR also reviewed hydrology hazards throughout the city, yet there is no data specific to the water table rising due to SLR in the Pedro Point Field. Just by walking through the southwest corner of the field there is water percolating to the surface all year around as well as the before-mentioned analysis of the CCC that the field is most likely a wetland.

The general plan actually has a Conservation (C) designation that states that it also applies to privately-owned open areas where the land is physically unsuitable for development due to geotechnical hazards, excessive steepness, wetlands, Environmentally Sensitive Habitat Areas (ESHA) or other environmental constraints or lies within stream channels; this site meets all these criteria so why is it not designated as Conservation? This site should result instead as a density transfer to another area of Pacifica if needed. The ideal transfer would be to add housing as a policy overlay to strip malls throughout Pacifica where very little environmental damage will occur due to hazards or ESHA.

The city is also stating that it can defer review of wildlife corridors because it doesn’t have the data. All that the city has to do is look on NextDoor or ask any agency like F&W who has given the city the data that mountain lions are all over Pacifica which is also an improper deferral of analysis under CEQA.

The city is also not addressing the issue of water resources and availability to residents in this era of the climate crisis so how can there be a determination of the increase of housing without appropriate water resources.

The city is also proposing to get rid of the height limitations throughout the city including the coastal zone and currently specific to the SPSP which is also in violation of the CEQA. Additionally, stating the designated number of units per acre is moot without taking state regulations like SB9, SB10 and affordable housing credits into consideration also makes this FEIR fatally flawed.

Under separate cover Richard Grassetti, Principal of Grassetti Environmental Consulting has provided a multitude of areas with the DEIR violates CEQA and is therefore fatally flawed. Mr. Grassetti also recognizes the reasonable argument that this Site should be designated Conservation.

In summary the Undeveloped San Pedro Avenue Field Site has a multitude of encumbrances including environmental designations and hazards the City has chosen to willfully ignore and places the adoption of the LCLUP by the California Coastal Commission (CCC) in jeopardy. At this time because of the City’s consistent inability to integrate undeniable scientific data as far back as 2005 if would be prudent to have the CCC assume responsibility of the LCLUP process in order to reconcile the required GPU alignment so that we do not continue to rely on a GP that is over 43(!!!) years old and a City that is negligent and unwilling to listen to its citizens or sound data.

Sincerely,
Samuel Casillas
Board member, PPCA
Past Vice-Chair, Pacifica Economic Development Committee Past Member, Pacifica Sea Level Rise Adaptation Planning Committee

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Packet Pg. 3959 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7720 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Past Co
-Chair GGNRA Board Liaison Committee
Past Member, Pacifica GPU Community Outreach Committee

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Packet Pg. 3960 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7721 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 5 Murdock, Christian
From: Inna Gorsky
Sent: Tuesday, June 7, 2022 12:06 PM
To: Public Comment
Subject: Pacifica Beach boulevard
[CAUTION: External Email]

Hello,
In light of discussion of Pacifica General Plan, I would like to express my concerns pertaining to view and look of Beach Boulevard: this place obviously fell into disrepair (both car road and pedestrian walk). Many Pacifica residents consider Beach boulevard as “face” of Pacifica as it is mostly visited place in our town. But awful condition of street pavement, lack of appealing benches, constant sand on pedestrian walk don’t allow to enjoy of this beautiful rest area.

So, Beach Boulevard improvement has to be a highest priority - before any other major investment and constriction .

Regards
Inna Gorsky

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

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Packet Pg. 3961 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7722 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 6 Murdock, Christian
From: Vicki Sundstrom
Sent: Wednesday, June 8, 2022 10:53 AM
To: Berman, Lauren; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg; Domurat, George; Hauser, Samantha
Cc: Public Comment
Subject: Traffic and Transportation Analysis in Pacifica General Plan Update and EIR Attachments: Planning Commissioners - GPFEIR transportation issues.pdf; Pacifica DEIR rev.pdf [CAUTION: External Email]

June 8, 2022
Planning Commissioners -
Following up on my comment, from the 6/6/22 Planning Meeting, regarding the inadequacies of the transportation/traffic analysis in the Pacifica General Plan/EIR updates. It’s irresponsible and a disservice to everyone in Pacifica, and coming to Pacifica, to proceed with these plans without adequately addressing the traffic and transportation issues.

Before I dive into the nuts and bolts of all things transportation - I looked up the purpose of the planning commission and the City’s website says:
“ The Planning Commission shall also advise the Council on private development plans for the City in accordance with the State Planning Law and the City's established development review standards and processes.”
I am confused by why the Planning Commission is being asked to look at documents that do not comply with state law. Pacifica and its planning commission do not have the authority to disregard requirements set forth by the California Coastal Commission (page 263) nor the Air District (VMT mitigation). And no one should ask you to disregard the law/regulations and incur risk on behalf of the residents of Pacifica. What is the liability associated with these decisions and what is the cost of non compliance? Now onto transportation and traffic. You have a lot on your plate and this isn’t meant to inundate you. Only to inform you that the analysis for transportation/traffic is lacking, the GP docs have changed from what was posted and in the last three months with respect to traffic/transportation. And also, it’s going to take a lot of work to get the transportation portion right.

I’ve spent a great deal of time looking through these and other development project documents, in the last two years, with respect to traffic and transportation impacts. It’s clear to me that the City of Pacifica has not adopted standard/required practices with transportation analysis.

Given their general lack of transportation planning understanding, traffic grows unnoticed, mitigation is not addressed and important transportation improvements opportunities are missed. Cities are required by state law to develop and maintain transportation demand management programs, as well as congestion management plans. Pacifica has neither.

The question isn’t whether or not the General Plan or EIR requires the detailed traffic and transportation analysis nor is it about what methodology. The General Plan is about where we are as a community and

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Packet Pg. 3962 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7723 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 7 where we want to be - and if traffic and transportation need to be a part of the discussion, include it and use the methodology needed to speak to the problem. VMT is required but others may be included. Budget for the work accordingly. Traffic data is easy to obtain for free and relatively inexpensive to collect new data if needed. See attachment A.

We have seen a great deal of organic growth over the years and the growth associated with all the projects under the General Plan will also generate traffic. Sharp Park, The Quarry, Pedro Point, “a robust city center”, “a tourist location” will all generate traffic. Where will they park, what will the traffic congestion look like for any one of the projects and what will it look like across town? The analysis is lacking, to say the least, and to throw our hands up in the air and claim it’s unavoidable is irresponsible and keeps us from actually understanding what the fixes are, how we should proceed and where to fund fixes.

With respect to the General Plan Update and related documents. I’ve attached the comments I submitted in March. And also offer the following -

1. There are references to “existing conditions” but no clarity on what specifically the conditions were and whether they included traffic counts.

2. Traffic counts, in order to understand commute patterns, are done during the week, when schools are in session on Tuesdays/Wednesdays/Thursdays. Given our weekend “tourism” traffic, traffic should be counted on the weekend as well. The traffic counts done are not consistent in that they weren’t done on the same days, some were done on a Tuesday/Wednesday/Thursday and at least one was done Thursday/Friday/Saturday.

3. There is no information on how study intersections were selected - there was no community input on the matter and no transparency on counts, complaints or the like.

4. There are a number of different dates floating around in the document - 2010, 2014, 2018, 2019 etc. Again no clarity on what they specifically relate to and how that impacted the data or analysis.

5. The documents posted online prior to 2022 are not consistent with the documents released this year with respect to transportation/traffic. The horizon year in the prior documents was 2035, the General Plan released in 2022 changed the horizon year to 2040 - this matters with respect to traffic, locally and regionally. At least one study intersection was removed (with no explanation) - a problematic intersection that should have been addressed some time ago and still needs attention.

6. There is some difference between the draft released earlier in the year and the May documents - I noticed discrepancies in table numbering but never explored beyond the fact that something was different.

7. None of the analysis speaks to Pacifica’s ability to address evacuations during a fire nor how first responders from other cities’ can respond in an evacuation. For example, if Linda Mar Woods is to become a reality, should it have a secondary access route. What should evacuation look like from Pedro Point? What supporting/enabling projects are required to support evacuations?

8. If we are to proceed with the development as proposed in the general plan, what are the transportation impacts (avoidable or not) and what are the mitigation measures? Can Pacifica afford to implement the mitigation? Should it be on the developers to fund? This ultimately is what needs to be addressed and is lacking.

9. I’ve explained in the March comments about the vagueness of the mitigation measures provided in the documents. Mitigation needs to be measurable, monitored and reported.

Feel free to reach out should you have any questions.

Regards
Vicki Sundstrom
Appendix A

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Packet Pg. 3963 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7724 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 8 Based on traffic counts from Caltrans - traffic volume growth through Pacifica ranges from 13%-57% CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3964 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7725 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve June 8, 2022
Planning Commissioners -
Following up on my comment, from the 6/6/22 Planning Meeting, regarding the inadequacies of the transportation/traffic analysis in the Pacifica General Plan/EIR updates. It’s irresponsible and a disservice to every one in Pacifica, and coming to Pacifica, to proceed with these plans without adequately addressing the traffic and transportation issues.

Before I dive into the nuts and bolts of all things transportation - I looked up the purpose of the planning commission and the City’s website says:
“ The Planning Commission shall also advise the Council on private development plans for the City in accordance with the State Planning Law and the City's established development review standards and processes.”
I am confused by why the Planning Commission is being asked to look at documents that do not comply with state law. Pacifica and its’ planning commission do not have the authority to disregard requirements set forth by the California Coastal Commission (page 263) nor the Air District (VMT mitigation). And no one should ask you to disregard the law/regulations and incur risk on behalf of the residents of Pacifica. What is the liability associated with these decisions and what is the cost of non compliance?
Now onto transportation and traffic. You have a lot on your plate and this isn’t meant to inundate you. Only to inform you that the analysis for transportation/traffic is lacking, the GP docs have changed from what was posted and in the last three months with respect to traffic/ transportation. And also, it’s going to take a lot of work to get the transportation portion right.

I’ve spent a great deal of time looking through these and other development project documents, in the last two years, with respect to traffic and transportation impacts. It’s clear to me that the City of Pacifica has not adopted standard/required practices with transportation analysis.

Given their general lack of transportation planning understanding, traffic grows unnoticed, mitigation is not addressed and important transportation improvements opportunities are missed. Cities’ are required by state law to develop and maintain transportation demand management programs, as well as congestion management plans. Pacifica has neither.

The question isn’t whether or not the General Plan or EIR requires the detailed raffic and transportation analysis nor is it about what methodology. The General Plan is about where we are as a community and where we want to be - and if traffic and transportation need to be a part of the discussion, include it and use the methodology needed to speak to the problem.

VMT is required but others may be included. Budget for the work accordingly. Traffic data is easy to obtain for free and relatively inexpensive to collect new data if needed. See attachment A.

We have seen a great deal of organic growth over the years and the growth associated with all the projects under the General Plan will also generate traffic. Sharp Park, The Quarry, Pedro Point, “a robust city center”, “a tourist location” will all generate traffic. Where will they park, what will the traffic congestion look like for any one of the projects and what will it look like across town? The analysis is lacking, to say the least, and to throw our hands up in the air and claim it’s unavoidable is irresponsible and keeps us from actually understanding what the fixes are, how we should proceed and where to fund fixes.

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Packet Pg. 3965 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7726 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve With respect to the General Plan Update and related documents. I’ve attached the comments I submitted in March. And also offer the following -

1. There are references to “existing conditions” but no clarity on what specifically the conditions were and whether they included traffic counts.

2. Traffic counts, in order to understand commute patterns, are done during the week, when schools is in session on Tuesdays/Wednesdays/Thursdays. Given our weekend “tourism” traffic, traffic should be counted on the weekend as well. The traffic counts done are not consistent in that they weren’t done on the same days, some were done on a Tuesday/ Wednesday/Thursday and at least one was done Thursday/Friday/Saturday.

3. There is no information on how study intersections were selected - there was no community input on the matter and no transparency on counts, complaints or the like.

4. There are a number of different dates floating around in the document - 2010, 2014, 2018, 2019 etc. Again no clarity on what they specifically relate to and how that impacted the data or analysis.

5. The documents posted online prior to 2022 are not consistent with the documents released this year with respect to transportation/traffic. The horizon year in the prior documents was 2035, the General Plan released in 2022 changed the horizon year to 2040 - this matters with respect to traffic, locally and regionally. At least one study intersection was removed (with no explanation) - a problematic intersections that should have been addressed some time ago and still needs attention.

6. There is some difference between the draft released earlier in the year and the May documents - I noticed discrepancies in table numbering but never explored beyond the fact that something was different.

7. None of the analysis speaks to Pacifica’s ability to address evacuations during a fire nor how first responders from other cities’ can respond in an evacuation. For example, if Linda Mar Woods is to become a reality, should it have a secondary access route. What should evacuation look like from Pedro Point? What supporting/enabling projects are required to support evacuations?

8. If we are to proceed with the development as proposed in the general plan, what are thetransportation impacts (avoidable or not) and what are the mitigation measures? Can Pacifica afford to implement the mitigation? Should it be on the developers to fund? This ultimately is what needs to be addressed and is lacking.

9. I’ve explained in the March comments about the vagueness of the mitigation measures provided in the documents. Mitigation needs to be measurable, monitored and reported.

Feel free to reach out should you have any questions. In the interest of time, I’ve forgone supporting links to state laws and citing actual pages/screenshots - happy to share if you should require the assistance.

Regards

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Packet Pg. 3966 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7727 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Appendix A
Based on traffic counts from Caltrans - traffic volume growth through Pacifica ranges from 13%-57%

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Packet Pg. 3967 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7728 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3968 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7729 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3969 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7730 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3970 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7731 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3971 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7732 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve - Free parking is the biggest deterrent to Transportation Demand Management Programs and parking charges should be considered as an option both for Congestion Management and Economic Development.
- Stated TDMs options read like a textbook of available strategies rather than targeted policy to meet objectives. Please provide targeted strategies appropriate to our community and identify programs based on type of property (residential, commercial, etc)

13. Circulation element – How does the city plan to reduce congestion on roadways before reducing roadway capacity to implement complete streets?

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

15. Given that the Sharp Park Specific Plan related community meetings were limited to Sharp Park, the items stated below should be addressed with the greater Pacifica as it relates to all of Pacifica.

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Packet Pg. 3972 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7733 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3973 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7734 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3974 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7735 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3975 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7736 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Please let me know you’d like to discuss any of these comments further.

Regards,
Vicki Sundstrom

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Packet Pg. 3976 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7737 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve Appendix
A

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Packet Pg. 3977 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7738 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3978 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7739 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3979 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7740 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve San Luis Obispo
– TDM policy and monitoring program
Belmont– Residential TDM

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Packet Pg. 3980 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7741 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 9 Murdock, Christian
From: David Whitney <
Sent: Thursday, June 9, 2022 3:44 PM
To: Public Comment
Subject: General Plan, Pacifica Planning Commission Hearing, 6 June 2022 [CAUTION: External Email]

In previous General Plan in Fairmont at Hickey & Gateway, signalizing the intersection was proposed on page 5-13 {in the circulation element}:

At Hickey Blvd & Gateway Dr signalizing the intersection will result in LOS C for AM peak hour and LOS D for PM peak hour. An additional reference is on page 5-14. The intersections at Hickey Blvd and SR35 {a CMP intersection} and Hickey Blvd and Gateway Drive {non-CMP} would operate at LOS F at Plan buildout at both peak hours. Improvements proposed in the Plan would allow these intersections to operate at LOS E and C, respectively at peak hours.

In proposed General Plan, this carries no weight, and should be reinstated. as Hickey Blvd is entry to Pacifica and Gateway Drive is feeder from Daly City.

Also, SI high school from SF has purchased Fairmont school property and appears to have plans to expand generating more traffic at Hickey and Gateway. Issue needs to be pushed so we can require traffic mitigation for that property.

David L, Whitney
Pacifica, Ca 94044
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Packet Pg. 3981 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7742 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 10 Murdock, Christian
From: Mike Vernazza < >
Sent: Friday, June 10, 2022 1:07 PM
To: Public Comment
Subject: GP comments
[CAUTION: External Email]
It is very frustrating to see a fire map absent of fire danger that is clearly mapped in cal fire docs.

It’s obviously there is a financial or political reason for this given what Portola Valley is currently doing and how Woodside has decided to operate. How does fire danger end at city limits? Mike vernazza
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Packet Pg. 3982 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7743 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 11 Murdock, Christian
From: Remi Tan < >
Sent: Saturday, June 11, 2022 1:19 AM
To: Public Comment; Murdock, Christian; _City Council Group; Woodhouse, Kevin; Berman, Lauren; Hauser, Samantha; Nibbelin, John; Leal, David; Godwin, James; Domurat, George; Ferguson, Alex; O'Connor, Bonny
Subject: Pacifica General Plan - break into elements
[CAUTION: External Email]

Dear Planning Dept, Commission and City Council -
Many of the commentors on June 6 and at other meetings commented the document is too unwieldy to review all at once. They are probably correct as many other cities such as San Francisco and Oakland update their GP in sections tackling only one or at most a few sections at a time and prioritizing based on cities changing needs or state mandates For example SF and Oakland were addressing their housing element recently due to RHNA requirements from the state. Maybe Pacifica should consider breaking the GP into separate elements.

Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment Pacific Manor
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Packet Pg. 3983 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7744 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 1 Murdock, Christian
From: peter k
Sent: Sunday, June 19, 2022 1:36 PM
To: Public Comment
Cc: _City Council Group; City Manager; Murdock, Christian; O'Connor, Bonny; Christine Boles
Subject: Pacifica General Plan & Sharp Park Specific Plan [CAUTION: External Email]
Do not approve the GP or SPSP
0) Neither the GP nor the SPSP adequately address climate change. 1) The fact that Pacifica's LCP is inadequate means that the SPSP will not get approved by the CCC. It is a waste of Pacifica's time and money to be submitting this seriously inadequate plan. 2) The fact that the proposed seawall will make erosion worse on the north end of the wall opens Pacifica to lawsuits from private property owners.
3) The fact that the Planning commission has been approving developments while missing or ignoring fire hazard and geological instability is bordering on criminal negligence. 4) The General Plan does not adequate address the fact that Pacifica is literally falling into the Ocean, after decades and millions of dollars of loss, you'd think the current plan would have a substantive plan. 5) Pacifica owes the county 1800+ units of housing. There's no real plan in the GP for this. Further development west of Highway 1 should be curtailed, except in more stable areas like the quarry. 6) The fact that plans were not made to move the sewer line by the shore, instead of spending millions on a seawall that will not last 50 years is arguably in violation of tax laws about the fair share of residents paying to protect private property.
7) Pacifica really needs to get SF to help with fact that the golf course floods after every major storm, and in violation of clean water laws pumps water straight into the ocean.
8) Because of sea level rise there are many houses by Linda Mar Beach and Shelter Cove and north of Beach Blvd that are in danger in the next decade of needing to be demolished at city cost.

Peter Key
Linda Mar
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Packet Pg. 3984 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7745 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 2 Murdock, Christian
From: Suzanne Moore < >
Sent: Sunday, June 19, 2022 3:12 PM
To: Berman, Lauren; Hauser, Samantha; Domurat, George; Godwin, James; Ferguson, Alex; Leal, David; Wright, Greg; Public Comment
Cc: Suzanne Moore
Subject: Sharp park Specific Plan
[CAUTION: External Email]

Hello Commissioners and Staff:

Again, thank you for the work done on this document to date.

I first want to address goals expressed for supportive housing and preservation of affordability, goals 3 - I -34 and 3-I-35. I appreciate that the SPSP addresses the community need for affordable housing at all income levels and resident abilities. As mentioned in the document, our community suffers when housing is not available for all its residents. While I think the stated goals are laudable, I do not detect the particulars needed for their success - specifically dedicated Pacifica housing funds to collaborate with non-profit builders and established housing preservation specialists. It is imperative for Pacifica to dedicate funds which can be accomplished through a vacancy fee and title transfer fee.

I also want to address anti-displacement goals. As this document states, 70% of Sharp Park residents are tenants. Current data is not provided since 2019, but housing costs have increased. There is not Pacifica data collection on displacement, but our school districts report difficulty with staff retention due to cost of living. Goal 3-I-36 discusses displacement indicators - and perhaps Concord could provide a model (with an estimated cost of $5-15/unit) which would provide data on rents and rent increases, vacancy rates, evictions, condo and Air B&B conversions - data which could be used to monitor compliance.

Anti-displacement efforts and tenant protection should be incorporated into the development plan, especially when 70% of Sharp Park residents are tenants. - Eviction without cause is financially and emotionally devastating because it is unplanned. In this time of a housing crisis and the economic downturn from COVID, tenants should be evicted only with just cause. - If a tenant is displaced through no fault of their own, they should be supplied with relocation benefits equivalent to three months of market-rate rent.
- Sadly, some landlords have been known to harass tenants, and communities, like Richmond, have adopted anti-harassment ordinances.
- To reduce loss of housing stock to short-term rentals, communities like Half Moon Bay have restricted short-term rental limits.
- When tenants are asked to leave for substantial renovation, along with relocation benefits, a tenant should be supplied evidence that renovation permits have been pulled, given an estimate of when the refurbished unit will be available, and offered first right of return.

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Packet Pg. 3985 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7746 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 3 I feel this language should be incorporated into the SPSP as evidence of the intent to reduce displacement as plans for future development unfold.

Thank you
--
Suzanne Moore
Home
Cell
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Packet Pg. 3986 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7747 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 4 Murdock, Christian
From: Peter Loeb < >
Sent: Sunday, June 19, 2022 3:23 PM
To: Public Comment
Cc: Berman, Lauren; Hauser, Samantha; Domurat, George; Godwin, James; Ferguson, Alex; Leal, David; Wright, Greg; Murdock, Christian
Subject: 6-20-22, Item 2, Continued Public Hearing, Consideration of Sharp Park Specific Plan and Recommendation to City Council.
[CAUTION: External Email]

Recommended CEQA Action: Find adoption of the Sharp Park Specific Plan substantially consistent with the General Plan Update and Sharp Park Specific Plan Final Environmental Impact Report, State Clearinghouse No. 2012022046.

Recommended Action: Adopt the attached resolution to recommend City Council approval of the Sharp Park Specific Plan.

The Sharp Park Specific Plan cannot be approved because it is inconsistent with the current certified Local Coastal Plan.

The Sharp Park Specific Plan cannot be approved until there is a new certified Local Coastal Land Use Plan.

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Packet Pg. 3987 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7748 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 5 Murdock, Christian
From: Clif Lawrence < >
Sent: Monday, June 20, 2022 9:15 AM
To: Public Comment
Cc: Coffey, Sarah; Clif Lawrence
Subject: Item 2 of Planning Commission Agenda - 20 June 2022 [CAUTION: External Email]

RE: Consideration of Sharp Park Specific Plan and Recommendation to City Council.

Honorable Commissioners,
Is it a fact (i.e. correct) that ultimately the SPSP needs the City Council's APPROVAL, but it is only the California Coastal Commission (CCC) which can grant it CERTIFICATION?
What exactly is the current working relationship between the City and the CCC?
The City's approved LCLUP lingers at the CCC a year and a half so far waiting for CERTIFICATION.

Has the CCC been clear as to what they would require before providing Certification?
What is the City's plan? Do we plan to get Certification of the SPSP before the LCLUP?
Or will the SPSP join our LCLUP in "Limbo" at the CCC?
Pardon the analogy, but to an outsider, it looks like a game of "Chicken".

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Packet Pg. 3988 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7749 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 6 How then is not the current consideration of the SPSP not a moot exercise?
Thank you,
Clifford (Clif) Lawrence
(resident Pacifica "greybeard")

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

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Packet Pg. 3989 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7750 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 7 Murdock, Christian
From: Christine Boles < >
Sent: Monday, June 20, 2022 11:46 AM
To: Murdock, Christian; _City Council Group; Berman, Lauren; Godwin, James; Michelle Kenyon [BWS Law]; Public Comment; Woodhouse, Kevin; Leal, David; Hauser, Samantha; Wright, Greg; Domurat, George; Ferguson, Alex
Subject: Major GP/LCLUP Fire Map discrepancy
[CAUTION: External Email]

Good morning Christian, Planning Commissioners and Council members, I met with Oceane of the Coastal Commission last week and asked her about fire hazards in Pedro Point in relation to the current GP and DEIR. She pointed me to the LCLUP "Certified" Draft that includes fire hazards. Sure enough Figure 5.4 on page 152 seems to be using the same fire map as was in the 2014 draft General Plan. This shows high fire risk in Pedro Point, and even hatched areas of Very High Fire Hazard Severity Zones, which is in direct conflict with the General Plan the Planning Commission just approved that specifically says there are no VHFHSZ in areas within city limits and LRA with existing structures.

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Packet Pg. 3990 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7751 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 8 I am appalled that the fire map in the GP the Planning Commission approved last weekend is still blank. CEQA law for General Plans requires using BEST AVAILABLE DATA. Leaving the maps blank and saying we will update them with new maps once Cal Fire has finished their update process seems to be a clear CEQA violation to me. There is older data available, as is shown here and in the 2014 draft GP.

I would also like to ask about the legality of the process of the GP and EIR being reviewed by the City Council this coming Saturday, June 25th as announced.

The Planning Commission has not reviewed the minutes of the 6/11/22 meeting nor the changes they requested to the documents to see if they are complete. They have also not reviewed the two landslide maps Mr. Murdock said were being revised in coordination with the Department of Conservation. The agenda for tonight's meeting does not include these minutes. It therefore seems premature to have the City Council review and possibly approve these documents in a public hearing without the Commission's sign off.

Also, I would again like to raise my objection to the lack of notification in the Pacifica Tribune for the upcoming City Council meeting.

I also knocked on doors of residents and businesses in Sharp Park this weekend as part of my city council campaign for District 2. NOT ONE PERSON was aware of tonight's Planning Commission meeting.

The Council's goals of an engaged community are apparently being ignored.

Christine Boles, Architect
Beausoleil Architects
478 Monterey Road
Pacifica, CA 94044

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Packet Pg. 3991 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7752 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 9 415.587.2004
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.

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Packet Pg. 3992 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7753 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 10 Murdock, Christian
From: Christine Boles < >
Sent: Monday, June 20, 2022 12:00 PM
To: Murdock, Christian; _City Council Group; Berman, Lauren; Godwin, James; Michelle Kenyon [BWS Law]; Public Comment; Woodhouse, Kevin; Leal, David; Hauser, Samantha; Wright, Greg; Domurat, George; Ferguson, Alex
Subject: Sharp Park Specific Plan
Attachments: AirBnB.PNG; Christine Boles Comment Letter #A 6.6.22 PC Hearing.pdf; Christine Boles Comment Letter #5.pdf
[CAUTION: External Email]

Dear Commissioners and staff,
In addition to the two comment letters I previously sent in about the SPSP(attached for reference), I have the following comments.
1) Land Use Plan Figure 3-3 fails to identify the Pacifica Resource Center as Public and Semi-Public facilities. It is identified as such under Parks, Public and Community Uses, see image below. 2) There is no discussion of moving infrastructure out of harm's way as a potential strategy of Climate change adaptation.

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Packet Pg. 3993 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7754 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 11 3) There is no discussion of loss of existing housing, and especially affordable units in section 3.6, in relation to the short term rentals. Sharp Park is one of the communities most affected. See attached image. 4) Parking studies were done pre-pandemic in 2019 and are no longer accurate given Pacifica's "COVID" discovery. 5) As previously commented on the GP and DEIR, the Coastal Resilience section has not been updated with current documents, including the Coastal Regional Sediment Management Plan. It also fails to note that the 2018 ESA Sea Level Rise Vulnerability Assessment is a draft and has not been finalized and approved.

Christine Boles, Architect
Beausoleil Architects
478 Monterey Road
Pacifica, CA 94044
415.587.2004
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.

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Packet Pg. 3994 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7755 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3995 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7756 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve General Plan Update/EIR) 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com DATE: June 5, 2022
TO: Christian Murdock, AICP
Deputy Director of Planning
City of Pacifica Planning Department
540 Crespi Drive, Pacifica, CA 94044

RE: City of Pacifica General Plan, Sharp Park Specific Plan (SPSP) and EIR Comments, letter A Dear Mr. Murdock and Planning Commissioners:

I want to first raise my objections to this flawed process that limits public and agency engagement on critical environmental and life safety issues that will define Pacifica for the next 20-40 years. Given the ridiculously short time frame allowed (12 calendar days which include a major holiday) to review this new set of documents, totaling 4,795 pages including the FEIR, I have not had time to read, much less research and respond to many items of concern.

I will focus my comments on a few items I noticed that feel are substantial deficiencies in the documents and underlying data that will require edits and recirculation. This letter will focus on issues in the Coastal Zone. 1) There are many references through the FEIR, General Plan and SPSP documents to the 2018 Sea Level Rise Vulnerability Assessment prepared by ESA. Thank you for the clarification based on my comment C49-1 that this document is only a draft and has not been finalized nor officially adopted or certified by the City of Pacifica. Please clarify how this document can legally be used to fully evaluate environmental and safety issues and write policy, much less certify the FEIR. 2) The FEIR has been modified to include new references to this ESA study without labeling it as draft.

See highlighted section in green.
3) The response to my comment C49-11 regarding the accuracy of the dune shoreline erosion numbers of 115-116 meters by 2025 was not answered and the information remains grossly in error. See screenshot from above from redlined DEIR. If our dunes are eroding 115 meters (over 377 feet) by 2025, we are in deep trouble losing our major arterial road, SR1, and these documents are seriously deficient.

Note that there is also confusing duplicated text in the newly added redlined text.

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Packet Pg. 3996 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7757 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com 4) The FEIR (COI-44) and the General Plan both refer to the Regional Sediment Management Plan. From the GP page 732, “Pacifica participates in the Coastal Regional Sediment Management Plan (CRSMP) process for the San Francisco Littoral Cell (the stretch of coastline in which Pacifica is included). The CRSMP will establish policies for management of coastal sediment resources in the area, addressing:
• Shoreline erosion and coastal storm damage reduction; • Environmental restoration and protection, including beach nourishment, sediment transportation, and natural sediment supply to the coast;
• Sea level rise;
• Coastal access and recreation;
• Water quality along beaches; and
• Identification of beneficial uses for dredged sediment.” Note the highlighted section above. The San Francisco Littoral Cell Coastal Regional Sediment Management Plan was actually completed in 2017. It has already established policies for the management of coastal sediment resources, and yet there is no mention of this final document, and it is missing from the bibliography. The FEIR identifies coastal erosion as Pacifica’s greatest environmental hazard and I fear that key analysis, policies and mitigation measures are missing from the FEIR, GP and SPSP. Please update accordingly, include this current and readily available data as required by CEQA.

The final CRSMP document can be accessed through the California Department of Boating and Waterways website: https://dbw.parks.ca.gov/?page id=29337
5) Please explain why COI-46 was deleted. I see there was a duplicate item with the same reference number in the DEIR, but I cannot find this text with a new number. Deletion of this important mitigation measure constitutes a significant change that must be re-reviewed by agencies including the CCC. 6) The FEIR, General Plan and SPSP documents also include multiple references to Pacifica’s Draft LCLUP, which has not been certified by the California Coastal Commission (CCC) and which still contains major points of disagreement regarding sea level rise and coastal erosion adaption planning.

The CCC has made it very clear that until our LCLUP is certified, we must use the actual certified 1980 Local Costal Plan.1 The documents therefore need to be revised to comply with the Coastal Act and the 1980 LCP, or this update process paused until the draft LCLUP is certified. 7) Detailed maps of projected coastal erosion and sea level rise are still missing from both the FEIR and General Plan. The responses to my comments refer to ESA’s 2018 Draft Sea Level Rise Vulnerability Assessment as the latest best information on the subject, and this document provides very detailed maps with coastal erosion and sea level rise projections. These maps should be added to the FEIR and GP Safety Element so that decision makers have the visual data to be able to analyze potential projects, including the SPSP. I have copied below ESA’s map of Sharp Park, with my annotations of the proposed redevelopment areas identified in the SPSP to assist the Planning Commission in their deliberations in relation to existing and projected hazards. Remember that all development in the Coastal Zone must be designed with a 100-year life, which will necessitate mitigation measures such as elevating 1 5.24.22 email from Oceane Ringuette of the CCC to Christian Murdock

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Packet Pg. 3997 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7758 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com structures above projected water levels. This analysis is missing from the FEIR, GP and SPSP and therefore the documents are inadequate and in violation of CEQA law.

Sincerely,
Christine Boles, Architect
Principal
Cc: Honorable Mayor Mary Bier
Pacifica Planning Commissioners Berman, Domorat, Ferguson, Godwin, Hauser, Leal, White [email protected]
California Coastal Commission staff:

[email protected]
[email protected]
[email protected]

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Packet Pg. 3998 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7759 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 3999 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7760 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com DATE: March 8, 2022
TO: Christian Murdock, AICP
Deputy Director of Planning
City of Pacifica Planning Department
540 Crespi Drive, Pacifica, CA 94044

RE: City of Pacifica General Plan and DEIR Comments, letter #5, DEIR questions related to Sharp Park Specific Plan and other miscellaneous items
Dear Mr. Murdock,
Please accept my preemptive apology that these comments are not well organized or complete, but my time is limited due to today’s deadline. I have a number of concerns and questions about the City’s focus on Sharp Park as the preferred project for concentrating development increases. The Sharp Park areas is heavily burdened due to environmental, climate change and safety factors, and I wonder if it is really the best place to put all of the city’s energy into redevelopment. Below are my concerns, not in any particular order of importance.

1. As mentioned previously in my Comment Letter #2, detailed maps of projected coastal erosion and sea level rise are missing from both the DEIR and General Plan. In fact, the city’s own Existing Conditions Report from July 2010 showed much better maps to help decision makers and developers analyze these conditions, in that they are more complete. Using less complete information in subsequent updates leaves the City vulnerable to confusion and lititgation by artificially adding perceived value by rezoning to higher allowed densities.

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Packet Pg. 4000 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7761 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com

2. In addition, the City’s hired consultant, ESA, in the 2018 Sea Level Rise Vulnerability Assessment provides even more detailed information about coastal erosion and sea level rise projections. There is no link to this document in the DEIR and it is not listed in the Bibliography. Please add the references to ensure we are working on the same information. The copy I have of this report is dated January 2018 and is labeled DRAFT. Has this report been finalized with the consultant and approved by the City Council? Why were these maps not incorporated into the DEIR and GP Safety Element when sea level rise and coastal erosion are some of our greatest hazards, and have already cost the city greatly in lost housing and fees to tear down inappropriately built structures?

3. I spoke with one of the report authors at ESA about a year ago to try to understand the map in Sharp Park in particular. I was confused because there is no storm flood area shown in the diagram when I have personally observed major flooding along Beach Boulevard and the properties across the street from the ocean in winter storms and king tide events. I was told that flooding was not analyzed due to the presence of the sea wall. I would suggest that this issue needs further scientific study and mapping to understand the real hazards in this area and this information needs to be added to the DEIR.

4. In addition, new development cannot be permitted in the Coastal Zone that relies on a sea wall or other armoring, which makes it imperative to redo this modeling without a sea wall in place. In previous letters I have documented that this is actually a state requirement for General Plan Safety Elements for flood areas. As these properties in the Coastal Zone must be designed for 100-year life, which is 50 years beyond the design life of the sea wall currently being proposed, this modeling is essential to understanding how building design life criteria can be met.

Specifically, Section 30253 prohibits new development if it would require a coastal armoring structure:

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.

5. Below is the map of the Sharp Park Area from this ESA study, showing considerable threat. I have roughly overlaid the map with the areas indicated on Figure 4-3 Land Use Diagram, to be the highest density allowed, where height is increased to 55’ or more (there was one reference to more than 55’ somewhere that I can’t find now) with the provision of low-income housing. Note that several of these overlap these high hazard zones. I believe the General Plan Safety Element calls for avoidance of building in high hazard areas.

Please remember that the Coastal Commission needed to assert jurisdiction over the Coastal Zone, and overturned the City of Pacifica’s questionable approval of Coastal Development Permit Application Number CDP-395-18, which had been previously green-lighted by the City, despite numerous objections and appeals by local residents who had pointed out the obvious hazards at 1567 Beach Blvd Pacifica. Failing to provide current information to the public further endangers Pacificans, misleads developers who wish to build sustainably in good-faith, and wastes staff and the public’s time and taxpayer funds. So, I would question the validity and wisdom of the current proposed land use maps for this area.

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Packet Pg. 4001 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7762 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com

6. I am pretty certain there are restrictions about placing--or concentrating--vulnerable low-income population in areas of high hazards. If not, there are moral issues with placing vulnerable residents in the highest-risk areas. Please confirm and add appropriate conditions in the Land Use Element to comply with applicable laws, and explain how these could possibly be in conformance with the State’s Environmental Justice goals.

7. Please also note that Palmetto Avenue is threatened by sea level rise on the southern end. I have seen no discussion of the possible need to move the road and infrastructure inland. This should be discussed now before new high-density construction is allowed on the inland side of Palmetto.

8. As previously mentioned in Comment Letter #4, our sewage infrastructure will eventually need to be moved inland. Our sea wall consultant GHD specifically said that the sea wall would not protect us long term, it is only being designed with a 50-year life to buy us time for more wholistic and long-range resiliency planning. An alternate site for the Sharp Park Sewage Pump Station that serves the entire northern section of Pacifica must be identified now as part of this General Plan. Perhaps the city’s Salada parking lot would be a good location, but that is also zoned Mixed Use Center. This property has also recently been approved as part of the Civic Center Remodel as required parking for those buildings, so perhaps we need to find an alternate site?

9. SA-I-26 Tsunami Evacuation Zone. For new development in the tsunami evacuation zone, require use of low impact engineering techniques, such as elevating structures above projected water levels, to mitigate impacts to people and structures.

My understanding from my limited experience with the Coastal Act is that new development is not strictly prohibited in Tsunami Evacuation zones or areas with or projected flooding from sea level rise or seasonal rains, but that the structures and roads must be adaptable and allow the water to pass through. Their ground floor levels also need to be raised above projected sea level rise. These requirements and basic protections are missing in the DEIR, and are also conspicuously absent from the consultant’s pretty renderings of what Sharp Park development might look like under this General Plan.

These basic requirements will completely change the relationship of the buildings to the street and

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Packet Pg. 4002 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7763 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com require long handicapped ramps that require considerable space (1 foot of length for every inch of rise) and will therefore limit the amount of buildable space. This seems negligent on behalf of our planning consultant to not have raised this issue in the planning process.

10. SA-G-3 Sea Level Rise Adaptation. Establish policies to minimize the risk to persons and property posed by potential sea level rise.

Please confirm what measures this General Plan establishes to minimize risk. These measures that affect basic life safety cannot be deferred under CEQA.

11. Chapter 3.9 of the DEIR discusses visual resources. As a licensed architect, I am considered as a professional expert in commenting on these issues. Visual Resources Figure 3.9-1 from the DEIR is copied below for reference.

Please note the area circled in red, the coastal view corridors identified in Sharp Park. As you are well aware, the current design for the new Sharp Park sea wall recently approved by the City Council as a hybrid option of hard armoring with sand nourishment will entail an approximately 5’ high sea wall above the existing road. Please clarify how this will protect these scenic resources which will no longer be able to be seen from the sidewalk or the surrounding roads by the majority of the population.

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Packet Pg. 4003 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7764 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com Without expensive and regular sand nourishment the city’s consultant, GHD, said the sea wall would need to be 8’ high. I believe GHD also said that even with these heights the proposed hard armoring will not protect the area from future projected storm surge and wave overtopping, so flooding will still be an issue. Please confirm. Is there additional drainage planned for the area? I’m anxiously waiting for Public Work’s drainage study due to be completed later this year.

12. Highway One is also identified on the map as a scenic route. I have seen no analysis or visual simulations in the DEIR that show how the views from Highway One may be impacted by the rezoning of tall structures in Sharp Park along Palmetto and Francisco. Please provide these simulations so that the impacts of the rezoning to Mixed Use Center can be properly evaluated.

13. The importance of Highway One View Corridors is also written in the DEIR on page 3.9.21.

As essential parts to Pacifica’s identity, I would expect to see a real analysis of visual impacts with simulations from multiple viewpoints. The increased height limits and new zoning right up next to the freeway at Manor Plaza should also be evaluated with visual simulations. This is the first view that most visitors get of Pacifica coming down the hill and is particularly important to the city’s image.

14. Furthermore, on page 3.9-22 somehow without any visual analysis, the impact on visual corridors has been declared to be less than significant. Please explain in detail how this conclusion was reached.

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Packet Pg. 4004 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7765 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com

15. Page 3.9-5 of the DEIR states
There are no renderings provided in the Sharp Park Specific Plan of the relationship between these tall new buildings along Francisco and Palmetto to all the one- and two-story existing homes in the area.

Please provide this analysis and renderings so the visual impacts can be understood. I remember Mayor Mary Bier commenting at a Council Meeting when the renderings were presented that she would want to see those as well as they directly affect her constituents.

16. Page 3.9-6 of the DEIR states

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Packet Pg. 4005 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7766 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com Again these important view corridors may be lost due to both the sea wall and the more bulky and tall strucutres proposed under this General Plan Land Use Element. Can you confirm that this is in compliance with CEQA for Visual Resources, and with the Coastal Act, see pae 3.9-10 of the DEIR?

17. Would there not be some lost economic benefits in Sharp Park if the ocean, which is one of the major draws of the area, was no longer visible? Has this financial analyis been done as part of the GP update or sea wall project? I have not seen this information.

18. Under Impacts and Mitigation Measures on page 3.9-14 somehow, without this detailed visual analysis, it has been determined that impacts are less than significant. Please provide actual information to back up this statement to avoid a CEQA challenge.

19. Further down on page 3.9-14 it talks about landscape screeing as a method to protect visual resources.

I believe there are other General Plan and Municipal Code regulations that prohibit the use of landscaping to hide an otherwise unacceptable structure. I don’t have time to find references, but this was discussed in my letters regarding the Vista Mar Project. Landscaping obviously does nothing to help blocked ocean vistas from buildings so this line of argument is flawed.

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Packet Pg. 4006 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7767 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com

20. There is one image in the DEIR on page 3.9-17 that shows ocean views being blocked by buildings even 35’ in height at the city’s property at 2212 Beach Boulevard. Does this indicate that at this site the height must even be reduced beyond current zoning limitations? Please clarify. Note that this image and the others after it in the DEIR, were taken from a higher elevation, not street level on Palmetto, so they should be redone.

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Packet Pg. 4007 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7768 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com

21. Page 3.9-22
Doesn’t this mitigation measure contradict the basic concept in the Land Use Diagram to allow heights up to 55’ in this area. I am very confused.

22. The Coastal Commission also brought up their concerns about visual impacts of increased heights in their comment letter to the NOP sent on September 9, 2020. I have copied the letter here below. Please provide a response to their comments.

23. In this letter, the Coastal Commission also asked for a thorough geotechnical analysis of the area in this letter. I also asked for that information in a public hearing about the Sharp Park Specific Plan in 2021.

Do we know that the area’s soils and ground water table can even support a 55’ high building? Please add this analysis to the DEIR to ensure this proposed project even feasible.

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Packet Pg. 4008 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7769 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com

24. From page 3.9-22 of the DEIR
This statement is in error. The Little Brown Church is visible from Highway One, as is the adjacent Salada lot. This is why the Pacifica Historical Society has chosen the Salada lot facing Francisco as the ideal location for the refurbished Ocean Shore Railroad Car. Please revise this section as required per actual analysis of what is visible from Highway One.

25. I also asked previously in my comment letter #4 whether NCCWD currently has the fire capacity to serve 5 story buildings in this area as they will require different equipment than needed for 3 story buildings. Please confirm. If new equipment is needed, please confirm the city has the financial resources to make these basic infrastructure improvements before this General Plan and Sharp Park Specific Plan are adopted.

26. I have not had a chance to review the Historical Preservation section of the GP or DEIR, but I would like to see some explanation of how these important resources are protected in the Sharp Park Specific Plan. Several sites along Palmetto that are being rezoned to Mixed Use Center currently house these vibrant buildings and gardens that are important to the community and that are well used, and that speak to our history as a town. Here are three for example. Wouldn’t the economic value added by increasing density to 5 stories entice developers to tear down these treasures that contribute to this unique and desirable shopping area now?

27. Traffic and Parking Exceptions
Many residents complain that parking is very difficult in this area now, especially on sunny days, which are more numerous now with climate change and reduction in coastal fog.

real study that was done. Please confirm.

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Packet Pg. 4009 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7770 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com Dyett and Bhatia’s contract, it seems a parking study of the area was an optional service. Was the option taken and the additional fees for this important study approved? I have not seen that study in the DEIR documents.

Please provide it so we can understand these impacts under CEQA.

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Packet Pg. 4010 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7771 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com

28. Page 3.4.31 of the DEIR under Energy and Greenhouse Gases says that reduced parking requirements in Sharp Park are being used to actively discourage cars in the area. While I applaud the goal, the fact is that we do not currently have any reasonable public transportation in the area. Please show where this proposed policy was discussed at community meetings to get input on the SPSP. I have informally polled community members on the subject on Facebook and local residents are livid that reduced parking requirements are even being considered. Be prepared for pushback from the community on these assumptions.

At this point, with all these unanswered questions about the Sharp Park Specific Plan, I would really question whether this is the best location to focus most of the the city’s attention and funding for redevelopment as part of the General Plan. The new sea wall for this area also has major hurdles to clear before it can even be considered, and even if it somehow clears the environmental and technical review by the Coastal Commission, funding sources for such an expensive project are uncertain at best. I strongly suggest that the city expand its focus for this General Plan for redevelopment and increased density to include other areas of town that are less burdened.

For example, I am really puzzled why the Fairmont Area has not been included in this plan for increased density as it is on a high value transit corridor on Highway 35 which does not impact already burdened traffic in the rest of town. This area has already been identified in Plan Bay Area 2050 as a Priority Development Area, which I understand means that local and state funding grant opportunities are available for redevelopment. See below.

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Packet Pg. 4011 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7772 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 478 Monterey Road ♦ Pacifica, CA 94044 ♦ Tel 415.587.2004 ♦ www.beausoleil-architects.com In my opinion, the very first step needed now in this process is to update our DEIR sections about safety, including landslides, sea level rise, coastal erosion, fire, flooding, greenhouse gases, etc. so we understand our hazards. Vulnerability assessments as required by SB379 must also be prepared for the entire city, not just the coast, to understand our changing environment with climate change. Then we need to update the DEIR for the actual scale of the Proposed Project under this General Plan, which must consider the 1892 units allocated to us under RHNA at a minimum. We can simultaneously begin work on the Housing Element update which is due by January 2023 so we can get to work to find appropriate sites for these units, about half of which need to be affordable and out of harms way. Then we can have a General Plan that can comprehensively guide us for the next 20-30 years.

I hope that through this process of collecting public comments you will see the value of engaging the public, who basically works for free to help create the vision of Pacifica we all want to see for the next 20-40 years.

There are so many amazing people here; I’m so fortunate to have met so many recently, people with PhD’s in their respective fields like biology and oceanography, as well as trained and experienced professionals, architects, civil, structural and traffic engineers, EPA professionals, attorneys, historians, as well as general members of the public that have a passion for a particular issue like open space or a passion for particular creature like mountain lions or red legged frogs. Next to our beautiful mountains and ocean, we the people are your greatest resource.

Please use us and treat us as such.

Sincerely,
Christine Boles, Architect License #C-024448
Principal
Cc: Honorable Mayor Mary Bier
Tina Wehrmeister, Planning Director
Kevin Woodhouse, City Manager
Pacifica Planning Commissioners Berman, Domorat, Ferguson, Godwin, Hauser, Leal, Nibbelin [email protected]
California Coastal Commission staff:

[email protected], [email protected]

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Packet Pg. 4012 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7773 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 12 Murdock, Christian
From: Richard Harris Jr.

Sent: Monday, June 20, 2022 1:10 PM
To: Murdock, Christian; Public Comment; O'Connor, Bonny; Pacifica Permit Tech; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; [email protected]; Leal, David; [email protected] Cc: Coffey, Sarah; _City Council Group; Woodhouse, Kevin; 'Potter, Spencer (REC)'; lisav744 @gmail.com; 'Lisa Villasenor'; 'HELEN DUFFY'; 'Leslie Davis'; 'Bob Downing'; [email protected]; [email protected]; 'Bo Links'; 'Kathleen Manning' Subject: Pacifica Sharp Park Specific Plan / San Francisco Public Golf Alliance Comment / Plan.

Comm. Mtg. Jn.20
Attachments: SFPGA.Ltr.Pac.Plng.re.Sh.Pk.Specif.Pln.6.19.22.pdf [CAUTION: External Email]

Please find attached above, for the record, a pdf of San Francisco Public Golf Alliance comment re Pacifica’ Sharp Park Specific Plan (May 2022 Draft). Please include this in the record, and distribute to Individual Planning Commissioners in advance of the June 20 7 p.m. Special Meeting re hearing on the Sharp Park Specific Plan. Please acknowledge receipt.

Thank you.
 Richard Harris
 San Francisco Public Golf Alliance
 1370 Masonic Ave.
 San Francisco, CA. 94117
 415-290-5718
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 4013 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7774 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 1 1370 Masonic Ave., San Francisco, CA 94117 • 415-290-5718 • [email protected] June 19, 2022
By e-mail
[email protected]
[email protected]
Pacifica Planning Commission
Pacifica Planning Department
Attn: Christian Murdock, Acting Director
540 Crespi Dr.

Pacifica, CA. 94044
Re: Pacifica Planning Commission Meeting, June 20, 2022 Comment of San Francisco Public Golf Alliance
Request correction of two errors in the Sharp Park Specific Plan (at Chapter 1.1, page 1-3 (Packet Page 360),
Regarding history of the Sharp Park Golf Course:
(1) the golf course was not used as an internment camp in WW II; rather the internment camp was located in the canyon to the east of the golf course, on San Francisco-owned land which is now the site of the Archery Range; (2) the Sharp Park Golf Course architect was Alister MacKenzie; John McLaren was San Francisco’s Superintendent of Parks.

Dear Pacifica Planning Commission and Planning Department, The non-profit San Francisco Public Golf Alliance, whose 6,500-plus mostly San Francisco and Peninsula public course golfer members include substantial numbers of Pacifica residents, respectfully requests correction of two errors in the “Sharp Park’s Past” subchapter (Ch. 1.1) of the Sharp Park Specific Plan (May 2022 revision), regarding the history of the Sharp Park Golf Course.

The errors appear Chapter 1.1, page 1-3 (at Packet Page 360 for the Commission’s June 20 meeting), which paragraph reads as follows (with problematic language highlighted in yellow):

To the south of the current Sharp Park Specific Plan Area, Sharp Park’s namesake, George F. Sharp, established a 400-acre estate in 1849, part of which became the current Sharp Park Golf Course. Sharp’s widow, Honora Sharp, bequeathed the estate to the City of San Francisco with specific instructions that the property be used for recreational functions.

Noted golf architect Alister Mackenzie and landscape architect John McLaren designed the course in the 1920s. Back in 1932 when the course opened, games cost 70¢ on weekdays and $1 on weekends. During the 1930s, the Sharp Park recreation area served as a state relief camp that provided shelter, food, medical services, and employment for Bay Area residents struggling during the Depression. During World War II, the Golf Course also

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Packet Pg. 4014 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7775 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 2 served as internment camp for Japanese Americans roughly where the San Francisco Archers range stands now along the east boundary of the Sharp Park recreation area.

1. The Golf Course was not used as an Internment Camp; rather, the Internment Camp was located on land to the east of the golf course, in the vicinity of the Archery Range
The above-quoted paragraph’s references to the “Sharp Park recreation area” and “the Golf Course” should be corrected to make clear that the Golf Course occupies only the westernmost approximately 120 acres of the approximately 400 acre Sharp Estate parcel that was bequeathed to the City and County of San Francisco, and that the Golf Course did not serve as Relief Camp or Internment Camp. A portion of the land lying to the east of the golf course, further uphill into the canyon – which area is currently occupied by the Archery Range – served as a Relief Camp during the Depression, and subsequently as a World War II Internment Camp. But the Golf Course itself did not serve as a Relief Camp or as an Internment Camp. This is clear from a contemporaneous news report in the March 31, 1943 San Francisco News, captioned: “193 Aliens, Chiefly Japanese, Moved to Sharp Park Camp to East Immigration Station”:
“Formerly an [one word missing] shelter, the Sharp Park camp, located in a canyon back of the Sharp Park Golf Course, is surrounded by a strong wire fence . . .”1 To the same effect is this excerpt from the Densho Encyclopedia:
“The Sharp Park Internment Camp is now the home of the San Francisco Archery Club. The former enemy alien site is located near Sharp Park Road off Highway 1 and is located in a canyon next to the Sharp Park Golf Course in the City of Pacifica, California, which is located south of the City and County of San Francisco along the Pacific Ocean.”2

2. Alister MacKenzie was the architect of the Golf Course; John McLaren was San Francisco’s Superintendent of Parks
The architect of Sharp Park Golf Course was Alister MacKenzie, who was commissioned by the City and County of San Francisco to design the course.3 John McLaren was San Francisco’s legendary Superintendent of Parks at the time.4 1 Museum of the City of San Francisco, reprinting article from San Francisco News, March 31, 1942, “193 Aliens, Chiefly Japanese, Moved to Sharp Park Camp to East Immigration Station”:
http://www.sfmuseum.org/hist8/sharppark.html
2 Densho Encyclopedia, Sharp Park (detention facility)
https://encyclopedia.densho.org/Sharp Park (detention facility)/ 3 State of California Resources Agency, Form DPR 523, compiled by Julia Mates, Mar. 4, 2010, at pp. 4-5:
https://drive.google.com/file/d/1gBazm3mAc EhFLoHmu7cSU15bFImfY0L/view?usp=sharing 4 Wikipedia, John McLaren: https://en.wikipedia.org/wiki/John McLaren (horticulturist)

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Packet Pg. 4015 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7776 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve 3 3. Suggested Revision of the Paragraph in Question at page 1-3 of Chapter 1.1 Accordingly, we respectfully suggest the following revised language of the paragraph in question, found at the Sharp Park Specific Plan (May 2022 revision), Chapter 1.1, at page 1-3 with deletions in [bracketed and bolded red] typeface, and additions in boldface black:

To the south of the current Sharp Park Specific Plan Area, Sharp Park’s namesake, George F. Sharp, established a 400-acre estate in 1849 [part] of which the westernmost approximately 100 acres became the current Sharp Park Golf Course. Sharp’s widow, Honora Sharp, bequeathed the estate to the City of San Francisco with specific instructions that the property be used for recreational functions. Noted golf architect Alister Mackenzie [and landscape architect John McLaren] designed the course in the late 1920s for San Francisco, whose Superintendent of Parks at the time was [landscape architect] John McLaren. Back in 1932 when the course opened, games cost 70¢ on weekdays and $1 on weekends. During the 1930s, a portion of the Sharp Park recreation area to the east of the current golf course, roughly where the San Francisco Archers range now stands, served as a state relief camp that provided shelter, food, medical services, and employment for Bay Area residents struggling during the Depression. During World War II, the [Golf Course] relief camp area also served as an internment camp for Japanese Americans. [along the east boundary of the Sharp Park recreation area.] Respectfully submitted,
San Francisco Public Golf Alliance
Richard Harris
Richard Harris, President
cc:

Pacifica City Council and Councilmembers
Pacifica City Manager Kevin Woodhouse
Pacifica Historical Society
Spencer Potter, SF Recreation and Park Department
Leslie Davis, Helen Duffy, Lisa Villasenor, Sharp Park Business Women’s Golf Club Bob Downing, Sharp Park Golf Club
Bo Links, Esq.

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Packet Pg. 4016 Attachment: Attachment K - Combined Public Comments (Non-EIR) (5035 : Consideration of Adoption of General Plan Update)

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Packet Pg. 7777 Attachment: Attachment C - City Council Agenda Packet - June 25, 2022 (5049 : Appeal of Planning Commission Recommendation to Approve

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Packet Pg. 7778 Attachment: Attachment D - Appeal Form (5049 : Appeal of Planning Commission Recommendation to Approve General Plan Update/EIR) 6/30/22, 2:52 PM View Document - California Code of Regulations https://govt.westlaw.com/calregs/Document/I6D0AE2CFEF5F43F798E6F34719A7FA7D?viewType=FullText&originationContext=documenttoc&transiti… 1/2 Home Table of Contents
§ 15168. Program EIR.
14 CA ADC § 15168

BARCLAYS OFFICIAL CALIFORNIA CODE OF REGULATIONS
(a) General. A program EIR is an EIR which may be prepared on a series of actions that can be characterized as one large project and are related either:
(1) Geographically,
(2) As logical parts in the chain of contemplated actions, (3) In connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program, or
(4) As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways. (b) Advantages. Use of a program EIR can provide the following advantages. The program EIR can:
(1) Provide an occasion for a more exhaustive consideration of effects and alternatives than would be practical in an EIR on an individual action,
(2) Ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis, (3) Avoid duplicative reconsideration of basic policy considerations, (4) Allow the lead agency to consider broad policy alternatives and program wide mitigation measures at an early time when the agency has greater flexibility to deal with basic problems or cumulative impacts, (5) Allow reduction in paperwork.
(c) Use With Later Activities. Later activities in the program must be examined in the light of the program EIR to determine whether an additional environmental document must be prepared.
(1) If a later activity would have effects that were not examined in the program EIR, a new initial study would need to be prepared leading to either an EIR or a negative declaration. That later analysis may tier from the program EIR as provided in Section 15152.
(2) If the agency finds that pursuant to Section 15162, no subsequent EIR would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document would be required. Whether a later activity is within the scope of a program EIR is a factual question that the lead agency determines based on substantial evidence in the record. Factors that an agency may consider in making that determination include, but are not limited to, consistency of the later activity with the type of allowable land use, overall planned density and building intensity, geographic area analyzed for environmental impacts, and covered infrastructure, as described in the program EIR. (3) An agency shall incorporate feasible mitigation measures and alternatives developed in the program EIR into later activities in the program.
(4) Where the later activities involve site specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the scope of the program EIR.

California Code of Regulations
Barclays Official California Code of Regulations Currentness Title 14. Natural Resources
Division 6. Resources Agency
Chapter 3. Guidelines for Implementation of the California Environmental Quality Act Article 11. Types of EIRs
14 CCR § 15168
§ 15168. Program EIR.

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Packet Pg. 7779 Attachment: Attachment E - CEQA Guidelines Section 15168 (5049 : Appeal of Planning Commission Recommendation to Approve General 6/30/22, 2:52 PM View Document - California Code of Regulations https://govt.westlaw.com/calregs/Document/I6D0AE2CFEF5F43F798E6F34719A7FA7D?viewType=FullText&originationContext=documenttoc&transiti… 2/2 (5) A program EIR will be most helpful in dealing with later activities if it provides a description of planned activities that would implement the program and deals with the effects of the program as specifically and comprehensively as possible. With a good and detailed project description and analysis of the program, many later activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required. (d) Use With Subsequent EIRS and Negative Declarations. A program EIR can be used to simplify the task of preparing environmental documents on later activities in the program. The program EIR can:
(1) Provide the basis in an initial study for determining whether the later activity may have any significant effects. (2) Be incorporated by reference to deal with regional influences, secondary effects, cumulative impacts, broad alternatives, and other factors that apply to the program as a whole.
(3) Focus an EIR on a later activity to permit discussion solely of new effects which had not been considered before. (e) Notice With Later Activities. When a law other than CEQA requires public notice when the agency later proposes to carry out or approve an activity within the program and to rely on the program EIR for CEQA compliance, the notice for the activity shall include a statement that:
(1) This activity is within the scope of the program approved earlier, and (2) The program EIR adequately describes the activity for the purposes of CEQA.

Note: Authority cited: Section 21083, Public Resources Code. Reference: Section 21003, Public Resources Code; Citizens for Responsible Equitable Environmental Development v. City of San Diego Redevelopment Agency (2005) 134 Cal. App. 4th 598; Santa Teresa Citizen Action Group v. City of San Jose (2003) 114 Cal. App. 4th 689; and County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795.

HISTORY

1. Change without regulatory effect amending Note filed 10-6-2005 pursuant to section 100, title 1, California Code of Regulations (Register 2005, No. 40).

2. Amendment of subsections (c)-(d) and (d)(3) and amendment of Note filed 12-28-2018; operative 12-28-2018 pursuant to Government Code section 11343.4(b)(3) (Register 2018, No. 52).

This database is current through 6/17/22 Register 2022, No. 24 14 CCR § 15168, 14 CA ADC § 15168

END OF DOCUMENT

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Packet Pg. 7780 Attachment: Attachment E - CEQA Guidelines Section 15168 (5049 : Appeal of Planning Commission Recommendation to Approve General Mr. Christian Murdock
Deputy Planning Director
Planning Department
1800 Francisco Boulevard
Pacifica, CA 94044
[email protected]
[email protected]
CC: California Coastal Commission
Date: July 1, 2022
Subject: Appeal of Planning Commission Recommendation to Approve the General Plan Update and EIR Certification (City of Pacifica) on Monday, July 11, 2022.

Dear City Council:

In the previous Planning Commission meeting on 6/6/22 my concerns for the deficiencies and document contradictions were not considered and need to be addressed by the City Council prior to the potential appeal to the California Coastal Commission.

To reiterate:

Over the past decade the community of Pedro Point has attempted to act as a partner in the update to Pacifica’s General Plan, including neighborhood meetings with the input and participation of the city manager’s office. The community even requested the city work with us to develop a neighborhood specific plan which the city also dismissed.

I personally have tried to be a conduit for community input as a past member of both the Pacifica Sea Level Rise Adaptation Planning Committee and the Pacifica GPU Community Outreach Committee and I can once again state that the majority of our concerns about this plan have consistently been ignored. The DEIR even states in chapter 4.2 that “the alternatives were selected to, “the range of choices that have the broadest support from the community”, yet that city has disregarded over 99% of what the Pedro Point Community has repeatedly recommended for the property known as the Pedro Point Field in order to please only the investor property owner.

We have been forced to hire biologists, CEQA experts, environmental attorneys and submitted irrefutable evidence of special species and ESHA along with documented CEQA and Coastal Act violations and yet the city continues to work against its own citizens.

Under the current draft of the 2022 GPU states implementation policies to Expanded low-intensity outdoor Commercial Recreation on sites near Pacifica State Beach (ES-I-34), Preserve the Experience of the Natural Environment that do not disrupt view corridors (ES-I-35), be a center for recreation and community (CD-I-1), Improve pedestrian routes along corridors (CD-I-24), Open Space Conservation and Habitat Protection that support critical wildlife habitat and special status species (LU-G-7) and to not increase the density or intensity of land use designations beyond those indicated in the LCLUP for sites located within Coastal Vulnerability Zones (LU-G-8), not to mention the violations of SB379, yet these policies are exactly what the City chose to ignore by recommending residential at this site.

Further, with the city being fully aware of the denial of the CDP at 505 San Pedro due to the multiple hazards including flooding, shallow water table, identified multiple protected species, wetlands and an ESHA designation the city has still ignored this data. As far as the CRLF is concerned the CCC biology report states that the frog needs a minimum of a 300 ft foraging corridor. Again, the City has chosen to ignore this data. The city does recognize the existence of the CRLF in the DEIR “Special Status Species” figure 3.7-4 but omits the USFWS guidance of a minimum of 300 feet of foraging corridor for the special status species. Additionally, because the species is not able to forage in any other direction because of the existing developing to the south and east the whole west of the Site is needed for foraging habitat which can end up covering the whole field. In addition, the city has cherry picked a low SLR range that the CCC says is mandating at 6.9 feet which is based on the best available science.

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Packet Pg. 7781 Attachment: Attachment F - Public Comments Received Prior to Agenda Publication (5049 : Appeal of Planning Commission Recommendation If these egregious denials were not enough the California Coastal Commission has continually requested this same data to certify the LCLUP that they handed to you and that we have made available to you all, which included that denial of the CDP application 2-19-0026 at 505 San Pedro Ave where the Coastal Commission’s biologist and the Department of State Fish and Wildlife concluded the presence of ESHA and the California Red Leg Frog in the adjacent waterway AND also surmised that the Pedro Point Field was most likely wetlands, yet the city has chosen to ignore the coastal commission and F&W.

Specific to violations of CEQA the city master responses state erroneously that it can defer a site specific EIR until another project is proposed in this area and basically ignore any data presented by the agencies that will need to certify the City’s General Plan because there is a “conflict of experts”. CEQA does not allow this deferral for two reasons:

1. The city is required to make the determination now as to which data it will use to justify their recommendation

2. The city is proposing substantial changes from the current zoning of Commercial recreational to residential and also ignoring the on-site conditions of zero current structures; they can not hypothetically state a fast food joint can be built there now so the housing will be less impact NOTE: many of the responses to our questions are that the comments are “noted” or “comments received”; this response is inappropriate at best and also insulting.

The city also states that the FEIR also reviewed hydrology hazards throughout the city, yet there is no data specific to the water table rising due to SLR in the Pedro Point Field. Just by walking through the southwest corner of the field there is water percolating to the surface all year around as well as the before-mentioned analysis of the CCC that the field is most likely a wetland.

The general plan actually has a Conservation (C) designation that states that it also applies to privately-owned open areas where the land is physically unsuitable for development due to geotechnical hazards, excessive steepness, wetlands, Environmentally Sensitive Habitat Areas (ESHA) or other environmental constraints or lies within stream channels; this site meets all these criteria so why is it not designated as Conservation? This site should result instead as a density transfer to another area of Pacifica if needed. The ideal transfer would be to add housing as a policy overlay to strip malls throughout Pacifica where very little environmental damage will occur due to hazards or ESHA.

The city is also stating that it can defer review of wildlife corridors because it doesn’t have the data. All that the city has to do is look on NextDoor or ask any agency like F&W who has given the city the data that mountain lions are all over Pacifica which is also an improper deferral of analysis under CEQA.

The city is also not addressing the issue of water resources and availability to residents in this era of the climate crisis so how can there be a determination of the increase of housing without appropriate water resources.

The city is also proposing to get rid of the height limitations throughout the city including the coastal zone and currently specific to the SPSP which is also in violation of the CEQA. Additionally, stating the designated number of units per acre is moot without taking state regulations like SB9, SB10 and affordable housing credits into consideration also makes this FEIR fatally flawed.

Under separate cover Richard Grassetti, Principal of Grassetti Environmental Consulting has provided a multitude of areas with the DEIR violates CEQA and is therefore fatally flawed. Mr. Grassetti also recognizes the reasonable argument that this Site should be designated Conservation.

Additionally, the city fails to document prior landslide activity throughout Pedro Point and fire hazard at Grand Ave and Olympian Way.

Also, the Rockaway Headlands GPU land use designation changes fails to consider erosion hazards and the FEIR ignores the potential for wildlife habitat including wildlife corridors potential. The Land Use Designation for this area should be Conservation.

In summary the Undeveloped San Pedro Avenue Field Site, Pedro Point in general and the Rockaway Headlands have a multitude of encumbrances including environmental designations and hazards the City has chosen to willfully ignore and

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Packet Pg. 7782 Attachment: Attachment F - Public Comments Received Prior to Agenda Publication (5049 : Appeal of Planning Commission Recommendation places the adoption of the LCLUP by the California Coastal Commission (CCC) in jeopardy. At this time because of the City’s consistent inability to integrate undeniable scientific data as far back as 2005 if would be prudent to have the CCC assume responsibility of the LCLUP process in order to reconcile the required GPU alignment so that we do not continue to rely on a GP that is over 43 years old and a City that is negligent and unwilling to listen to its citizens or sound data.

Sincerely,
Samuel Casillas
Board member, PPCA
Past Vice-Chair, Pacifica Economic Development Committee Past Member, Pacifica Sea Level Rise Adaptation Planning Committee Past Co-Chair GGNRA Board Liaison Committee
Past Member, Pacifica GPU Community Outreach Committee

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Packet Pg. 7783 Attachment: Attachment F - Public Comments Received Prior to Agenda Publication (5049 : Appeal of Planning Commission Recommendation