Agenda, special meeting — Pacifica City Council, July 11, 2022 (part 5 of 45)

The survey will be used to determine the exact
location of habitat areas and to recommend
mitigation measures that minimize potential
impacts.
(CO-I-26) Protection of Biological Resources with
New Development. Protect sensitive habitat areas
and special-status species through implementation
of the following measures:
1) Discourage development and/or buildout in
critical habitat of special status species during the
development review process.
2) Pre-construction plant and wildlife surveys:

Project applicants shall engage a qualified biologist
to conduct presence/absence biological surveys for
sensitive plant and wildlife species prior to
construction adjacent to or within identified special
status communities and other sensitive areas
identified in Figure 7-3 of the proposed General
Plan. If special status species are identified, the
qualified biologist shall consult with the California
Department of Fish and Wildlife (CDFW) and
establish no-disturbance buffers around avian nests,
bat roosts, and sensitive plants to avoid disturbance
and direct impacts to these resources during
construction. If no special status species are
detected during surveys, then construction-related
activities may proceed. Nesting birds, in particular,
are protected by two means; they receive
protection under the Migratory Bird Treaty Act, and
nesting raptors (in the order Falconiformes or
Strigiformes) are protected under the State Fish and
Game Code, §3503.5.
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, or other
sensitive habitat areas shown on Figure 7-3 of the
proposed General Plan.
4) Require on-site monitoring of biological
resources by a qualified biologist throughout the
duration of construction activity.
5) Require compensatory mitigation by means of

2.f
Packet Pg. 918 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 824 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 37 Letter Commenter Date Comment Combined Response
Agencies (A)
habitat preservation, restoration, and
enhancement; for the loss of any critical habitat
and/or special status communities.

The City will coordinate with the U.S. Fish and
Wildlife Service, National Marine Fisheries Service,
California Department of Fish and Wildlife, and
Regional Water Quality Control Board in providing
project applicants with the best guidance to avoid
impacts to special status species and habitat areas
including creeks, wetland features, woodlands, or
other sensitive natural features.
(OC-I-17) Sharp Park. Support the continued
operation of golf at Sharp Park Golf Course, and
support development of additional recreational
uses in upland portions of the Park.

The long-term management approach must protect
existing development from hazards; protect and
restore habitat; and maintain public access to and
along the beach.

Compliance with these Proposed Plan policies
combined with the preservation of the Sharp Park
Golf Course as a park would retain the wetlands and
ponds located on-site.

A2-19 CDFW; Will
Kanz,
Environment
al Scientist
3/26/2
2 COMMENT 8: California Red-Legged Frog
Issue: CRLF is known to occur within the Project
range but the DEIR does not identify specific
locations of all known or recorded detections. In
addition, the DEIR does not include sufficient
avoidance, minimization and mitigation measures
to off-set potentially significant effects to CRLF.

Evidence the impact would be significant: CRLF is a
species listed as threatened under the Federal
Endangered Species Act (ESA) and a California
Species of Special Concern (SSC). CRLF require a
variety of habitats, including aquatic breeding
habitats and upland dispersal habitats. Breeding
sites of the species are in aquatic habitats including
pools and backwaters within streams and creeks,
ponds, marshes, springs, sag ponds, dune ponds
and lagoons. Additionally, CRLF frequently breed in
artificial impoundments such as stock ponds
(USFWS 2002). Breeding sites are generally found in
deep, still, or slow-moving water (>2.5 feet) and can
have a wide range of edge and emergent cover
amounts. CRLF can breed at sites with dense
shrubby riparian or emergent vegetation, such as
cattails or overhanging willows, or can proliferate in
ponds devoid of emergent vegetation (i.e., stock
ponds). Habitat includes nearly any area within one
to two miles of a breeding site that stays moist and
cool through the summer; this includes nonbreeding aquatic habitat in pools of slow-moving streams, perennial or ephemeral ponds, and upland
See response for A2-20

2.f
Packet Pg. 919 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 825 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 38 Letter Commenter Date Comment Combined Response
Agencies (A)
sheltering habitat such as rocks, small mammal
burrows, logs, densely vegetated areas, and even
man-made structures (i.e., culverts, livestock
troughs, spring-boxes, and abandoned sheds)
(USFWS 2017). CRLF populations throughout the
State have experienced ongoing and drastic declines
and many have been extirpated (Thomson et al.
2016). Habitat loss from growth of cities and
suburbs, mining, overgrazing by cattle, invasion of
nonnative plants, impoundments, water diversions,
stream maintenance for flood control, degraded
water quality, and introduced predators, such as
bullfrogs are the primary threats to the species
(Thomson et al. 2016, USFWS 2017). Development
could injure or kill CRLF if they occur on-site,
resulting in a substantial reduction of the
population.

A2-20 CDFW; Will
Kanz,
Environment
al Scientist
3/27/2
2 Recommendations: CDFW recommends the EIR
include additional detection information of known
CRLF detections including those from the following
sources: historical and recent survey data, field
reconnaissance, scientific literature and reports,
and findings from “positive occurrence” databases
such as California Natural Diversity Database
(CNDDB) In addition, CDFW recommends the
following measures are incorporated into the EIR
and included in all projects in suitable CRLF habitat:
· A qualified biologist shall complete CRLF habitat
assessments in accordance with the Revised
Guidance on Site Assessments and Field Surveys for
the California red-legged frog (USFWS 2005) (survey
protocol). Results of the habitat assessment shall be
submitted to USFWS and CDFW for review and
written acceptance prior to starting Project
activities. If after review of the results of the habitat assessment, USFWS or CDFW determines that
surveys are warranted, then surveys shall be
conducted in accordance with the USFWS survey
protocol prior to starting project activities. Results
of surveys shall also be submitted to CDFW for
review and approval in writing.
· If a project may impact CRLF based on the results
of the habitat assessment and any surveys, the
project shall obtain authorization from USFWS for
impacts to the species prior to project start.
· If CRLF is discovered during the habitat
assessment, surveys, or during Project construction,
work shall be delayed/ceased immediately and
contact CDFW and USFWS within 24 hours. In this
event, Project work shall not resume/proceed until
the frog, through its own volition, moves out of
harm’s way and CDFW and USFWS have provided
permission in writing to proceed with the Project.

The Program DEIR identifies both specific locations
of all known or recorded detections and critical
habitat locations for the California Red-Legged Frog
(CRLF) in Figure 3.7-3 Sensitive and Critical Habitat
and 3.7-4 Special Status Species. Figure 3.7-3 shows
the Critical Habitat areas for the CLRF, in
coordination with the most up to date information
provided by USFWS. Figure 3.7-4 shows recorded
detections of the CRLF, sourced from the California
Natural Diversity Database. This represents the best
available evidence for a programmatic EIR. As a
special-status species, the CRLF subject to state and
federal protections. As noted on DEIR p. 3.7-51, "For
specific development projects under the Proposed
Project, consultation may be required with USFWS
by FESA, and/or with the California DFW by CESA.

Prior to project construction under the Proposed
Project, the applicant would be required to conduct
biological resource assessments and preconstruction plant and wildlife surveys at development sites. Compensatory mitigation would
also be required in order to offset the loss of or
alteration to special status species’ habitat." Specific goals and policies to address protecting the CRLF
habitat and other sensitive habitat areas include
policies that protect areas tht support critical
wildlife habitat and special status species (LU-G-7
and CO-G-7), protection of biological resources with
new development (CO-I-26), and explicit reference
to protection of the CRLF and SFGS during
construction (CO-I-35), requirement of habitat
survey in any critical habitat, potential ESHA, high
habitat value, and wildlife movement corridor areas
(CO-I-31).

2.f
Packet Pg. 920 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 826 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 39 Letter Commenter Date Comment Combined Response
Agencies (A)
A2-21 CDFW; Will
Kanz,
Environment
al Scientist
3/28/2
2 ENVIRONMENTAL DATA
CEQA requires that information developed in
environmental impact reports and negative
declarations be incorporated into a database which
may be used to make subsequent or supplemental
environmental determinations. (Pub. Resources
Code, §21003, subd. (e)). Accordingly, please report
any special-status species and natural communities
detected during Project surveys to the CNDDB. The
CNNDB field survey DocuSign Envelope ID:

FE837397-619A-404C-ADB9-2F3D70DEF00E form
can be found at the following link:
https://wildlife.ca.gov/Data/CNDDB/SubmittingData#44524420-pdf-field-survey-form. The completed form can be mailed electronically to
CNDDB at the following email address:

[email protected]. The types of information
reported to CNDDB can be found at the following
link:
https://wildlife.ca.gov/Data/CNDDB/Plants-andAnimals.

The comment is noted. Policy CO-I-26 addresses
consultaton with the CDFW if special status species
are detected.

2.f
Packet Pg. 921 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 827 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 40 A3: Dr. Erik Frost, CGS, 2/1/2022
A3-1 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/1/22 Earthquake Hazard Zones Numerous potential
earthquake hazards exist within the planning area:
a) Fault Rupture, Liquefaction and Landslide
Hazards The DEIR includes figures depicting the
most up-to-date Earthquake Zones of Required
Investigation produced under the Alquist-Priolo
Earthquake Fault Zoning Act and the Seismic
Hazards Mapping Act. The City may also wish to
provide in the Safety Element links to CGS websites
that will be updated as maps are published and
revised:
https://maps.conservation.ca.gov/cgs/information
warehouse/regulatorymaps/
https://maps.conservation.ca.gov/cgs/information
warehouse/apreports/
https://maps.conservation.ca.gov/cgs/EQZApp/app
/
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response: EIR comments for more
information about GP- or SPSP-related responses.

A3-2 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/2/22 Tsunami Hazards The DEIR includes the most recent Tsunami Hazard Area maps for evacuation planning,
which were updated in 2020. Within the next
couple years, CGS will be completing new Tsunami
Hazard Zones under the Seismic Hazard Mapping
Act. These new Tsunami Hazard Zones will use the
same area of the 2020 Tsunami Hazard Area maps
to delineate the overall hazard zone but will include
within it an additional Engineering Analysis
Subzone, which will be delineated by probabilistic
tsunami hazard analyses. When these new Tsunami
Hazard Zones are released, the City of Pacifica will
be responsible for requiring site-specific
investigations and reviewing investigation reports
for development projects, in the same manner as
the other Earthquake Hazard Zones. CGS will reach
out to the City of Pacifica close to the time
Preliminary Tsunami Hazard Zones are released.

The comment is noted.

A3-3 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/3/22 Geologic Hazards
a) Landslides
The DEIR currently includes a figure depicting the
relative density of existing landslides (“mostly
landslides,” “few landslides,” and “not landslide
prone”) throughout the planning area. The City
should also consider providing a map of specific
landslides. CGS has compiled an inventory of
landslides in the planning area (as shown in Seismic
Hazard Zone Reports 128 and 133), and we
recommend this inventory be shown in an
appropriate figure. The GIS data for this landslide
inventory will be transmitted separately.

The comment is noted. As noted in the Department
Conservation Seismic Hazard Zones mapping
methodology, available at
https://www.conservation.ca.gov/cgs/Documents/P
ublications/SHZR/SHZR_133_San_Francisco_South_
a11y.pdf: "As a part of the geologic data
compilation, an inventory of existing landslides in
the San Francisco South Quadrangle, San Mateo
County was prepared by analysis of shaded relief
maps (various illumination directions) and contour
data, limited field reconnaissance, and a review of
previously published (Harding-Lawson, 1983;
Bonilla, 1988; Jacobs Associates, 1999; Brabb and
others, 2000; Wentworth and others, 1998) and
unpublished geologic-landslide mapping. Landslides
were reviewed using the lidar shaded-relief map
(USGS, 2005), Google Earth Pro DigitalGlobe and

2.f
Packet Pg. 922 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 828 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 41 Historical Imagery, and stereo-paired aerial photos.

For each landslide included on the map several
characteristics (attributes) were collected and
compiled in a geodatabase. These characteristics
include recency of activity, type, thickness,
associated geologic unit(s), and the confidence of
interpretation (definite, probable, or questionable).

The completed landslide map was digitized, and the
attributes were entered into a database. Landslides
rated as definite or probable were carried into the
landslide zone..." Methodology indicates that these
inventories are included in Seismic Hazard Zone
mapping, thus, the hazard assessment maps are
adequate.

A3-4 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/4/22 Debris Flows Shallow, rainfall-triggered landslides, described in the DEIR as debris flows, are a known
hazard within the City of Pacifica. The DEIR
mentions debris flow hazards but does not provide
much information on where this hazard exists nor
where it has occurred in the past. CGS recommends
that the Final EIR and Safety Element include debris
flow hazard maps and information prepared by the
USGS (USGS OFR 97-745 E; USGS Professional Paper
1434 including Plate 8). In particular, the City should consider using these references to help identify
existing developments subject to debris flow
hazards and determine what new development
areas should have geotechnical site investigations
prepared prior to project approval.

The comment is noted. A map of debris hazards was
included in the General Plan; it will be added to the
DEIR. This does not constitute new information and
does not change the conclusions of significance.

2.f
Packet Pg. 923 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 829 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 42 A4; Adrianne Carr, NCCWD, 3/8/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A4-1 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/8/22 In the Draft EIR, conservation element CO-G-5,
please note that the NCCWD has demonstrated
compliance with the 2020 water use target of 124
gallons per capita per day, having reduced its
potable water use in 2020 to 65 GPCD. There is no
need for the City to work with the District on
meeting this target.

The comment is noted. To further support NCCWD
efforts, including compliance with AB 1660 and SB
606, the following policy is thereby amended:
“Work with the Water District to meet State targets
for reducing per capita urban water use by 10
percent by 2015 and 20 percent by 2020. for
reducing per capita water use by 1annual water use
objectives, consistent with State targets. This does
not change findings of significance.

A4-2 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/9/22 In regards to conservation element CO-I-22, Water Recycling, the District welcomes the continued
support of the City in the implementation and
expansion of NCCWD’s recycled water project. In
addition to expansion of recycled water production,
which will take coordation between the City and the
District, the District seeks coordination with the City to create a commercial recycled water fill station, so
that construction-related dust control activities and
street cleaning activities can be done with recycled
water.

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

A4-3 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/10/2
2 In regards to conservation elelment CO-I-19, Water
Supply, the District would also welcome the City’s
support in the District’s efforts to secure reliable
local water supplies, such as groundwater.

A4-4 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/11/2
2 The District welcomes coordination efforts
proposed by the City in it’s measures CO-I- 20, CO-I21, CO-I-22, CO-I-23, SA-I-13, SA-I-92, and SA-I-108.

A4-5 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/12/2
2 In the dialog under Table 3.13-4 on page 3.13-23,
there are two typos ("mdg" should be "mgd").

The comment is noted. The second and third
sentence of the first paragraph on page 3.13-23 are
hereby amended as follows, "While implementation
of the Proposed Project would
result in a projected population slightly higher than
NCCWD’s projected 2040 population, demand is
estimated to be 2.27 mgd mdg. Water supply in
regular years is expected to be 3.87 mgd mdg,
similar to other years. Based on these calculations,
there will be adequate water supply to provide for
the population under General Plan buildout in a
normal year." This amendment represents a minor
clarification and does not affect the findings of the
DEIR.

A4-6 NCCWD;
Adrianne
Carr, Ph.D.
3/13/2
2 The District supports the City's Sharp Park Specific
Plan policies that reduce impacts 6-I-13, 6-I-14 and
6-1-21 by supporting water conservation and water
recycling.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared

2.f
Packet Pg. 924 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 830 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 43 Letter Commenter Date Comment Combined Response
Agencies (A)
General
Manager
with decision-makers in that context. Please see
Master Response: EIR comments for more
information about GP- or SPSP-related responses.

A4-7 NCCWD;
Adrianne
Carr, Ph.D.

General
Manager
3/14/2
2 Please include the NCCWD in the City's emergency
planning and response coordination activities as
described in SA-I-101 and SA-I-102, as the District
does provide essential services during emergencies
and needs to be part of the City's meetings and
drills.

2.f
Packet Pg. 925 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 831 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 44 A5; Rob Bartoli, San Mateo LAFCO, 3/8/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A5-1 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/8/22 Please clarify the allowed Urban Reserve density.

Policy LU-I-4 in the DEIR states that the City should
“coordinate with San Mateo County to ensure that
new development in unincorporated areas occurs at
a maximum density of five acres per unit.” Policy
LU-I-4 in the Draft General Plan states that the
development in the Urban Reserve is “maximum
density of 10 acres per unit.” DEIR Policy LU-I-6
states that density for the Urban Reserve is a
“minimum lot area of 10 acres per dwelling unit.”
The response is clarified: "coordinate with San
Mateo County to ensure that new development in
unincorporated areas occurs at a maximum density
of five ten acres per unit." It does not change
findings of significance in the DEIR.

A5-2 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/9/22 For Policy LU-I-4, is it the City’s intent to have the County undertake a master plan for a subdivision of
50 acres or more located in the City’s Sphere of
Influence or it is proposed that the master plan
would be part of the City’s annexation process? In
addition to any City process and entitlements
needed for annexations, LAFCo will need to review
and approve any proposed boundary change.

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

A5-3 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/10/2
2

Page 4 ends

Urban Reserve land use. The section states that
“Sites within the Urban Reserve land designation
that are annexed into the City of Pacifica should
receive a land use designation consistent with the
applicable density prior to annexation.” For parcels
that are annexed to the City, would the parcels
retain the Urban Reserve land designation, or would
they receive a different land use designation?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

A5-4 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/11/2
2 Table 4-1 in the Draft General Plan lists Urban
Reserve as a land use, but does not show a density.

However, Table 4-1 shows Urban Reserve as having
a density of 0.1 or less.

The comment is noted. This change will be made in
the GP errata.

A5-5 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/12/2
2 Policy LU-I-6 in the Draft General Plan states that
the minimum lot area is 1010 acres and appears to
be a typo.

The comment is noted. This change will be made in
the GP errata.

A5-6 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/13/2
2 Page G-10 of the Draft General Plan defines a
Sphere of Influence as “The ultimate service area of
an incorporated city, as established by San Mateo
County.” The Sphere of Influence is established by
San Mateo LAFCo not the County.

The comment is noted. This change will be made in
the GP errata.

A5-7 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/14/2
2 The majority of the General Plan planning area is
served by North Coast County Water District for
water service. LAFCo encourages the City to
continue to engage with the district throughout this
update process, particularly if water service is
The comment is noted. As the comment does not
address the adequacy of the environmental analysis
contained in the DEIR, no further response is
required.

2.f
Packet Pg. 926 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 832 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 45 proposed to be expanded beyond the District’s
existing boundaries for potential development.

2.f
Packet Pg. 927 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 833 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 46 A6; Julia Koppman Norton, CCC, 3/1/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A6-1 Coastal
Commission; Julia
Koppman Norton
North Central Coast
District Supervisor
California Coastal
Commission
3/1/22 Thank you for the opportunity to provide comments on the DEIR for the City’s General Plan Update and Sharp Park Specific Plan. I’ve attached our prior correspondence on this matter, all of which we would like to be incorporated into the comment record for the DEIR and project. Broadly, and as indicated prior, the General Plan Update and Sharp Park Specific Plan, as well as this associated DEIR, must be consistent with the certified LCP. As the LUP update has been submitted to the Coastal Commission but has not yet been certified, the originally certified LCP is the standard with which the GP/SPSP must be consistent. Once an updated LUP is certified, the GP/SPSP would have to be updated to then be consistent with the updated LCP. As such, generally, it may make the most sense to coordinate timing of the GP/SPSP for after the LUP is certified, given the outstanding nature of the LUP certification.

The comment is noted. As described
on DEIR p. 2-7, "To the extent the
General Plan Update proposes any
policies beyond those which were
sent to the California Coastal
Commission for review and
certification, a subsequent LCP
amendment would be necessary to
make the LCP consistent with the
General Plan."
A6-2 Coastal
Commission; Julia
Koppman Norton
North Central Coast
District Supervisor
California Coastal
Commission
3/1/22 More specifically, policies proposed in the GP/SPSP that correspond to coastal resources cannot contradict the certified LCP and thus Coastal Act. While we understand that the City boundaries extend beyond those of the Coastal Zone, policies that contradict Coastal Act mandates cannot be applied within the Coastal Zone. However, as we understand it, multiple policies proposed in the LUP update are duplicated in the proposed GP update (as denoted by a wave symbol), despite not being certified policies and numerous concerns regarding inconsistencies with the Coastal Act that have been noted to City staff over the years. Thus, policies in Chapter 6 ‘Open Space and Community Facilities,’ Section 6.3 ‘Coastal Access’; Chapter 7 ‘Conservation,’ Sections 7.1-7.3 ‘Water, Biological, Land and Soil Resources’; and Chapter 8 ‘Safety,’ Sections 8.1-8.3 and 8.5-8.6 ‘Seismic and Geologic Hazards, Flooding and Drainage, Coastal Resilience, Fire Hazards, and Public Safety and Emergency Management’ (and any other relevant policies) need to be made fully consistent with the currently certified LCP, and thus Coastal Act – currently, the policies noted as being included in both GP and LCLUP are not certified and thus not in effect in the Coastal Zone at this time. Further, the General Plan update appears to include policies that would only apply in coastal areas, including those pertaining to coastal access, coastal resilience, shoreline development, and allowances for shoreline armoring; these cannot be applied in the CZ as the LCP currently stands. As such, please include the attached past comment letters regarding Coastal Act inconsistencies of proposed LUP policies in the record for this GP/SPSP DEIR. Please note that all in-line edits previously provided to City staff on iterations of the proposed LUP update should also be incorporated as feedback on the overlapping GP update policies.

The comment is noted. it does not
pertain to the merits of the DEIR.

While the LCLUP is not certified,
policies in the plan represent postconsultation comments and in-line edits provided by the Coastal
Commission. Please see response to
comment A6-1 for more information
on how the General Plan will be
made consistent.

A6-3 Coastal
Commission; Julia
Koppman Norton
North Central Coast
District Supervisor
California Coastal
Commission
3/1/22
[email correspondence attached] The correspondence is received.

2.f
Packet Pg. 928 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 834 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 47 Pacifica Organizations (B)

2.f
Packet Pg. 929 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 835 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 48 B1: Judy Heldberg, Pacifica Historical Society, 2/18/2022 Letter Commenter Date Comment Combined Response
Organizations (B)
B1-1 The Pacifica
Historical
Society
Board of
Directors,
Judy
Heldberg –
President
2/18/22 These comments regarding the Draft Pacifica
General Plan have been approved by the Board of
Directors of The Pacifica Historical Society on
February 8, 2022. In order to be clear with what
changes we propose, we have included here the
entire section of the 2022 Draft Pacifica General
Plan Chapter 7 (Conservation) section 7.6
“CULTURAL RESOURCES AND HISTORIC
PRESERVATION”. Fig. 4. could not be copied, but
comments are included after comments on Table 5.

For clarity, this second copy does not show the
suggested changes and omissions. 7.6 CULTURAL
RESOURCES AND HISTORIC PRESERVATION One
objective of the General Plan is to protect
community assets, including sites with historical and
cultural significance. Cultural resources include
prehistoric or archaeological sites, properties of
cultural or historic significance, or paleontological
sites. Pacifica has a rich history with regional and
statewide significance, as it was home to Native
American villages as well as the first sighting of the
San Francisco Bay by non-indigenous people. The
Sanchez Adobe Historical Site along San Pedro
Creek, which features physical evidence of several
significant periods in California history.

Historic Context
Native Americans had an extensive presence in the
Planning Area. When Europeans arrived, the area
was home to persons speaking the
Costanoan/Ohlone language, and living in and
around two villages: Pruristac, in San Pedro Valley,
and Timigtac, in Calera Valley. In 1769, an
expedition led by Gaspar de Portola, governor of
the Spanish territory covering both Baja and Alta
California, camped in San Pedro Valley and first
sighted San Francisco Bay from a point on Pacifica’s
Sweeney Ridge. Not long after, Mission San
Francisco de Asis (Mission Dolores in present-day
San Francisco) was established, and in 1786 the
Mission developed an outpost in San Pedro Valley,
alongside Pruristac. The Ohlone village was wiped
out by disease in 1791.21 Mexican independence
from Spain was followed by a “secularization”
program, and in 1839 the San Pedro mission
outpost and its rancho, covering the majority of the
Planning Area, was granted to Francisco Sanchez,
who built the adobe house that stands today as the
oldest structure in San Mateo County. Following his
death, the land was divided and the area developed
slowly. In 1905 construction began on the Ocean
Shore Railway, which was to connect San Francisco
with Santa Cruz. The line was never completed, but
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

2.f
Packet Pg. 930 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 836 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 49 Letter Commenter Date Comment Combined Response
Organizations (B)
operated as far south as Half Moon Bay until 1921,
supporting a string of stops in present-day Pacifica
including Edgemar, Salada Beach, Brighton Beach,
Vallemar, Rockaway Beach, and Tobin (San Pedro
Terrance-by-the- Sea. The communities surrounding
the railway stops grew slowly until the building
boom following World War II. Pacifica incorporated
as a City in 1957, as the union of these
unincorporated neighborhoods. Native American
Cultural Resources Five Native American
archaeological resources have been found and
recorded in Pacifica, all classified as habitation sites.

Two additional resources contain both Native
American and historic-era archaeological value. The
Sanchez Adobe, operated by the San Mateo County
Historical Association as an historical site, is listed as a State Historical Landmark and is listed on the
National Register of Historic Places. The Sanchez
Adobe Park, site of the Pruristac village and the
outpost or asistencia San Pedro y San Pablo of the
Mission San Francisco de Asis (Mission Dolores),
also is listed in the National Register of Historic
Places and the California Register of Historical
Resources. The San Mateo County Historical
Association recently dedicated (summer 2021) a
new building in Sanchez Adobe Park featuring the
history and lifeways of the local Aramai-Ohlone who
lived in the village of Pruristac. The facility is
specifically designed to accommodate tours of
school groups. The Planning Area is rich with the
types of environments where Native American
cultural resources have been found: permanent and
intermittent streams, productive coastal
environments, and sheltered locations for
permanent habitations, as well as ridgelines,
terraces, spurs and saddles. The Planning Area also
includes a significant amount of alluvial soil, which
in some cases is overlaid by artificial fill, increasing the probability for buried archaeological deposits.

There is considered to be a high likelihood that
unrecorded Native American cultural resources are
present. Contemporary Native American Resources
As part of the General Plan update process, the
Native American Heritage Commission (NAHC)
conducted a record search of the sacred lands file in
2009. The search did not indicate the presence of
additional Native American cultural resources
within the Planning Area. The NAHC response listed
six tribes that may have historic ties to the Planning
Area, and letters of inquiry were sent to the six
tribal representatives; however, no responses were
received.

In 1769, an expedition led by Gaspar de Portola
sighted San Francisco Bay from a point on Pacifica’s
Sweeney Ridge (upper). The Sanchez Adobe, built in

2.f
Packet Pg. 931 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 837 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 50 Letter Commenter Date Comment Combined Response
Organizations (B)
1842, is the oldest surviving structure in San Mateo
County. The site was once the Ohlone village of
Pruristac (lower). Historic Resources The Portola
Expedition Camp at San Pedro Creek, the Discovery
Site, and the Sanchez Adobe are State Historical
Landmarks. Tobin Station, one of two remaining
structures from the Ocean Shore Railroad, is a State
Point of Historical Interest. A Master Plan for the
Sanchez Adobe Historical Site, completed in 2007
aims to increase visitation and improve visitors’
educational experience while ensuring that the site
is preserved for future generations. The City has
identified nine local historical landmarks: Sanchez
Adobe; the Little Brown Church; the former San
Pedro Schoolhouse (now City Hall); the 1907
Anderson’s Store building on Paloma Avenue; the
Sharp Park Golf Course club house, from 1932;
Vallemar Station; the former Dollaradio Station; and
two private residences (see Table 7-5). In 2005, the
Pacifica Historical Society began restoration of the
Little Brown Church to establish it as into the
Pacifica Coastside Museum, which opened in 2015.

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

B1-2 The Pacifica
Historical
Society
Board of
Directors,
Judy
Heldberg –
President
2/19/22 Revisions to Table 7-5 with correct headings &
listings:

A) National Historic Landmark – change 1st heading,
this applies only to one site:
- San Francisco Bay Discovery Site
B) National Register of Historic Places –new heading
for 2 items
- San Francisco Bay Discovery Site Remove Little
Brown Church as it is
- Sanchez Adobe not in B) National Register
C) California Historical Landmarks – all O.K.
- Discovery Site
- Sanchez Adobe
- Portola Expedition Camp
D) Local Landmarks Identified in Historic
Preservation Ordinance (1985) – all 9 listings O.K.

Age of buildings: Vallemar Station - 1906; 165
Winona - 1908; 185 Carmel Avenue - 1910
Revision to Figure 7-4:

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

2.f
Packet Pg. 932 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 838 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 51 Letter Commenter Date Comment Combined Response
Organizations (B)
• Little Brown Church is not listed on National
Register.
• The line points to the Portola Camp Historic
marker, not the actual campsite (which was on San
Pedro Creek).
• Discovery Site should add “National Historic
Landmark, National Register, and California Historic
Landmark”.
• We think the format of the map is good overall,
but the size of the notations of the sites themselves
is VERY small, so the colors do not show well.

B1-3 The Pacifica
Historical
Society
Board of
Directors,
Judy
Heldberg –
President
2/20/22 Historic Preservation Ordinance
The Historic Preservation Ordinance found at
Chapter 7 of Title 9 of the City’s Municipal Code
protects structures and sites of historic significance
in the City. The ordinance outlines procedures for
designating historic landmarks, describes the permit
process for the alteration, demolition, or relocating
of any historic structure, and includes a section
pertaining specifically to the Little Brown Church. It
also acknowledges the role of the Pacifica Historical
Society in designation of sites and the permit
process.

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

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

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

Integration of Historic and Cultural Resources with
City Identity. Incorporate historic and cultural
resources into the City’s marketing and branding
efforts. Specific initiatives might include:
• Identifying historic sites in the City’s wayfinding
scheme;
• Giving priority to streetscape and public realm
improvements around historic structures that are
visitor destinations;
• Hosting/supporting events and educational
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

2.f
Packet Pg. 933 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 839 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 52 Letter Commenter Date Comment Combined Response
Organizations (B)
programs that feature Pacifica’s history and
promote its relevance; and
• Linking related historical sites through the City’s
open space and trail system.

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

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

CO-I-68
Resource Impact Mitigation.

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

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

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

Native American Sites. Work with local Native
American tribes to protect recorded and
unrecorded cultural and sacred sites, and educate

2.f
Packet Pg. 934 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 840 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 53 Letter Commenter Date Comment Combined Response
Organizations (B)
developers and the community-at-large about the
connections between Native American his- tory and
the environmental features that characterize the
local landscape.

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

B1-4 The Pacifica
Historical
Society
Board of
Directors,
Judy
Heldberg –
President
2/21/22 1. (Section 7.6, p. 7-40, para. 1) The word “sites” is too limiting, as “historical significance” is not limited to buildings and specific locations. For example, the
old trees (many planted more than 100 years ago)
of both Sharp Park and Vallemar are an integral part
of what defines these Districts and makes them
both have “historical significance”.

2. (p. 7-40, para. 2) Many descendants of the
original native people of this region object to the
use of the words “discovered” or “Discovery”, as
thousands of people living in the Bay Area already
knew about The Bay when Portola’s Expedition
arrived. This may be a semantic point to most
people, but is a matter of some sensitivity and
significance to present day Ohlone. 3. (p. 7-41, para.
1) Pacific Manor was built in 1948, long after the
demise of the OSRR. 4. (p. 7-41, para. 3)
Unfortunately “spurs and saddles” sounds like
something found on a rancho. Are these common
enough terms of geography to avoid confusion?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

2.f
Packet Pg. 935 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 841 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 54 Individuals and Affiliations (C)

2.f
Packet Pg. 936 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 842 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 55 C1: Stan Zeavin, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C1-1 Stan Zeavin 3/7/22 Please include the informative Figure 8-5 Fire Hazards and Public Safety Services
document from the 2014 draft. The 2014
mapping is much more realistic and useful
than simply showing fire danger topping at
the city boundary. Pacificans’ safety depends
on accurate information.

The data and information referenced in the DEIR, including the data used to prepare the above referenced maps, was the latest and most current available at the time the NOP was released and remains the most current available as of publication of this FEIR. The 2014 mapping referenced uses data that is out-of-date, and not the adopted SRA CAL FIRE maps, nor the 2008 Recommended LRA Maps. Please see
Master Response 5: Wildfire for more information.

C1-2 Stan Zeavin 3/8/22 Support the above statements by designating and showing Montara and San
Pedro Mountains and foothills on the map as
a designated viewshed from Pacifica State
Beach, Aramai Point and Highway 1.

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

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

C1-3 Stan Zeavin 3/9/22 Conservation Element ADD:

Grassland/Prairie. Conserve and protect
remnant grassland/prairie for its value as a
carbon sink.

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

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

C1-4 Stan Zeavin 3/10/22 ES-I-21 Shopping Center Upgrades. Support upgrading existing centers to include
affordable housing.

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

C1-5 Stan Zeavin 3/11/22 Pacifica Historic Context
>> Change first paragraph: In 1769, an
expedition led by Gaspar de Portola,
governor of the Spanish territory covering
California, followed an Ohlone trail over the
Montara/San Pedro Mountain saddle (later
the Old Coast Road) to San Pedro Valley
where they camped. From the valley, scouts
discovered San Francisco Bay from a atop
Sweeney Ridge.

The comment is noted. The second sentence of the last
paragraph on page 3.8-2 is hereby amended as follows:…
Native Americans once had an extensive presence in the
Planning Area. When Europeans arrived, the area was
home was to people speaking the Costanoan/Ohlone
language, and living in and around two villages: Pruristac, in San Pedro Valley, and Timiigtac, in Calera Valley. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering California, discovered San
Francisco Bay from a point on Pacifica’s Sweeney Ridge, and camped in San Pedro Valley. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering California, followed an Ohlone trail over the
Montara/San Pedro Mountain saddle (later the Old Coast
Road) to San Pedro Valley where they camped. From the
valley, scouts discovered San Francisco Bay from atop
Sweeney Ridge.

This is a minor correction made to clarify and does not affect the findings of the DEIR.

C1-6 Stan Zeavin 3/12/22 >> Update for 2019 completion and opening of new Sanchez Adobe visitors’ center
The comment is noted. The second sentence of the last
paragraph on page 3.8-2 is hereby amended as follows:…
A Master Plan for the Sanchez Adobe Historical Site was

2.f
Packet Pg. 937 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 843 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 56 Letter Commenter Date Comment Combined Response
Individuals (C)
completed in 2007, which aims to increase visitation and improve visitors’ educational experience while ensuring that the site is preserved for future generations. Key
aspects of the Master Plan’s proposed improvements for
the site include educational and interpretive exhibits and activities; expanded public facilities such as picnic areas and restrooms; and improving site characteristics such as signage, security, screening, and interface with San Pedro Creek. The new interpretive center was completed and
opened to the public in October 2019.

C1-7 Stan Zeavin 3/13/22 3.7 Biological Resources
Plant Communities
1990 and 1992 source reports are out-ofdate.
>> Replace “Annual” Grasslands with
“Grassland/Prairie”
CEQA requires analysis of how the project could have
substantial adverse effect on any riparian habitat or other sensitive natural communities identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. As noted on DEIR p. 3.7-1 and 23.7-2, "The basis for the
vegetation classification system utilized in this analysis relies on the currently accepted California Department of Fish andVegetation communities are mapped using the
Wildlife List of Vegetation Alliances and Associations (also known as the Natural Communities List). Plant communities generally correlate with wildlife habitat types, and these typically are classified and evaluated using CDFW’s
California Wildlife Habitat Relationship classification system. Figure 3.7-1 shows this data. "Annual Grassland" is the term used in this dataset. Thus, this represents the best available source of data, and no change is needed.

C1-8 Stan Zeavin 3/14/22 >> Include common native and special species plants
A list of these species are included in Appendix C and are listed on page 3.7-21. This comment does not relate to the adequacy of DEIR analysis, thus, no further response is required.

C1-9 Stan Zeavin 3/15/22 Coastal Bluff Scrub (p. 3.7-6) >> ACKNOWLEDGE 30 YEARS OF DUNE
RESTORATION AT Pacifica State Beach. Nonnative iceplant (Carpobrotus edulis) New Zealand spinach (Tetragonia tetragonioides)
have been virtually eradicated and replaced
with appropriate natives grown and planted
by volunteers.

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

C1-10 Stan Zeavin 3/16/22 >> The brackish water marsh at the north end of Pacifica State Beach was severely
impacted by the widening of State Highway
1 and now contains only willows where
saltmarsh common yellowthroats can be
heard..

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

C1-11 Stan Zeavin 3/17/22 p. 3.7-14 Beach/Intertidal
>>Add Snowy Plovers, Sanderlings, Willits,
Whimbrels
>> ADD: Pacifica State Beach in the 1970s
hosted nesting Western Snowy Plovers, a
Federally listed threatened species. Since
2003 volunteers have regularly surveyed and
monitored the plovers and have seen only
wintering plovers in declining numbers.

Snowy plover is shown on DEIR p. 3.7-21 to have mediumto-high potential to occur in the Planning Area. ESHA is determined through individual site analysis by a qualified biologist. Any proposed development on land designated
on the Sensitive and Critical Habitat map (Figure 3.7-3) as having potential to include an ESHA requires a site-specific evaluation by qualified biologists. The site evaluation will determine the precise location and extent of sensitive
resources, if any, and establish appropriate development

2.f
Packet Pg. 938 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 844 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 57 Letter Commenter Date Comment Combined Response
Individuals (C)
ESHA is required on the north half of the
beach where plovers roost and feed.
setbacks and standards to ensure that resources are
protected. The entirety of the Pacifica State Beach is
designated as Park land use designation as shown in Figure

2.2-1, which precludes it from development. The General Plan includes multiple policies to protect special status species and identifying ESHAs, including:
(LU-G-7) Open Space Conservation and Habitat Protection.

Protect beaches, oceanfront bluffs, wetlands, riparian
corridors, Environmentally Sensitive Habitat Areas (ESHA), ridgelines, hillside areas adjacent to existing open space, and areas that support critical wildlife habitat and special status species.
(CO-G-8) Coastal Environment and Special Status
Communities. Conserve and protect beaches, sand dunes,
coastal bluffs, and special status communities, particularly the Coastal bluff scrub on the northern bluffs.
(LU-I-2) Land Divisions in the Coastal Zone. Continue to require coastal development permits for all land divisions within the Coastal Zone. Land divisions in the Coastal Zone shall be:
• Designed to minimize impacts to public access,
recreation, and coastal resources.
• Designed to minimize site disturbance, landform
alteration, and the removal of native vegetation for
development or fire safety.
• Prohibited on properties that include any areas that are within or adjacent to an Environmentally Sensitive Habitat Area (ESHA) unless the resulting parcels can be developed without building or requiring vegetation clearance in the ESHA or ESHA buffer, or unless the resulting parcels are set aside for conservation.
• Permitted only in areas with adequate public services to serve development on the resulting parcels.
• Any land division that would result in a parcel that could not be developed in accordance with the policies of this LCLUP is not allowed.
(CO-G-11) Other Environmentally Sensitive Areas. Protect other potential ESHAs, high habitat value areas, and wildlife movement corridors from development that would
significantly disrupt habitat values.
(CO-I-27) Verification of ESHA. Prior to any proposed
development in an ESHA or potential ESHA, require that a habitat survey be conducted by a qualified botanist or
biologist. The habitat survey will verify whether the site is an ESHA, and document the extent of the sensitive
resources, document potential negative impacts to the
habitat, and recommend appropriate mitigation measures.

Verification of an ESHA shall be based on the following considerations:
• Presence of natural communities identified as rare by the California Department of Fish and Wildlife (determined by a state rarity ranking of S1 to S3).
• Recorded or potential presence of plant or animal species designated as rare, threatened or endangered under State or federal law.

2.f
Packet Pg. 939 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 845 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 58 Letter Commenter Date Comment Combined Response
Individuals (C)
• Recorded or potential presence of plant or animal species for which there is compelling evidence or rarity, such as a designation of 1B (rare or endangered in California or
elsewhere) or 2 (rare, threatened, or endangered in
California, but more common elsewhere) by the California Native Plant Society.
• Presence of coastal waterways.
• Integrity of the habitat and its connectivity to other natural areas.
(CO-I-28) Management of ESHA. If the area qualifies as an ESHA under the California Coastal Act, the following
regulations apply:
• No new development shall be allowed within primary
habitat areas with the exception of resource-dependent
uses that can be demonstrated to have no significant
adverse impact.
• Buffer areas shall be established around all sensitive resources, providing a minimum of 100 feet, and varying as needed to account for feeding, breeding, nesting, and
other habitat requirements. New buildings in buffer areas shall be allowed only if there are no other feasible
development areas on the parcel. Exceptions to such buffer requirements should be supported by a biological report demonstrating that the adjusted buffer, in combination
with incorporated siting, design or other mitigation
measures, will prevent impacts that significantly degrade the ESHA and will be compatible with the continuance of the ESHA. Buffer adjustments should also be limited to
where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the
buffer would have a greater impact on the ESHA.

Development shall be sited and designed to prevent
impacts that would degrade adjacent habitat areas, taking into account drainage, vegetation, topography, and other considerations.
• Alteration of landforms, removal of vegetation,
impervious surfaces, noise, light, and glare shall be
minimized.
(CO-I-31) Habitat Preservation. Require a habitat survey be prepared by a qualified botanist or biologist for any
development proposed for the following areas, as shown in Figure 7-3.
• Designated Critical Habitat for Endangered or Threatened Species;
• Potential Environmentally Sensitive Habitat Area (ESHA); • High Habitat Value; and
• Wildlife Movement Corridor.

The survey will be used to determine the exact location of habitat areas and to recommend mitigation measures that minimize potential impacts.

C1-12 Stan Zeavin 3/18/22 p. 3.7-18
Environmentally Sensitive Habitat Areas
(ESHA)
Environmentally Sensitive Habitat Areas
(ESHA) are defined by the California Coastal
See response for C1-11

2.f
Packet Pg. 940 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 846 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 59 Letter Commenter Date Comment Combined Response
Individuals (C)
Act[1] as “any area in which plant or animal
life or their habitats are either rare or
especially valuable because of their special
nature or role in an ecosystem and which
could be easily disturbed or degraded by
human activities and developments”
(California Public Resources Code Section
30107.5).

Figure 3.7-3 Potentially Sensitive and Critical
Habitat Area (AND Figure 7-3 Potentially
Sensitive Habitat Area)
>> ESHA is required on the north half of the
beach where plovers roost and feed on
amphipods and kelp flies.

C1-13 Stan Zeavin 3/19/22 >> ADD: Pacifica State Beach, in the 1970s hosted nesting Western Snowy Plovers, a
Federally ESA designated threatened species
and a State of California “species of special
concern.” PSB is identified in the 2007
USWFS Pacific Coast Recovery Plan as
Recovery Unit CA-48. Since 2003, volunteers
have regularly monitored the plovers for
USFWS surveys and have seen only wintering
plovers whose numbers continue to decline.

Snowy plover is shown on DEIR p. 3.7-21 to have mediumto-high potential to occur in the Planning Area. In addition to federal and State (FESA and CESA) regulations, the DEIR presents policies to protect special status species which would pertain to the western snowy plovers habitat once verified by a biologist, including:
(CO-G-7) Wildlife and Critical Habitat. Conserve and protect indigenous threatened, endangered, and other special
status species by preserving critical habitat.

Habitat can be protected by allowing very limited or no development, by identifying habitat areas as top priorities for permanent conservation, and by managing public land to ensure species protection. Critical Habitat in the Coastal Zone is considered Environmentally Sensitive Habitat Area (ESHA).
(CO-I-26) Protection of Biological Resources with New
Development. Protect sensitive habitat areas and specialstatus species through implementation of the following measures:
1) Discourage development and/or buildout in critical
habitat of special status species during the development review process.
2) Pre-construction plant and wildlife surveys: Project applicants shall engage a qualified biologist to conduct presence/absence biological surveys for sensitive plant and wildlife species prior to construction adjacent to or within identified special status communities and other sensitive areas identified in Figure 7-3 of the proposed General Plan.

If special status species are identified, the qualified biologist shall consult with the California Department of Fish and Wildlife (CDFW) and establish no-disturbance
buffers around avian nests, bat roosts, and sensitive plants to avoid disturbance and direct impacts to these resources during construction. If no special status species are
detected during surveys, then construction-related
activities may proceed. Nesting birds, in particular, are protected by two means; they receive protection under the Migratory Bird Treaty Act, and nesting raptors (in the order Falconiformes or Strigiformes) are protected under the
State Fish and Game Code, §3503.5.

2.f
Packet Pg. 941 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 847 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 60 Letter Commenter Date Comment Combined Response
Individuals (C)
3) Require biological resource assessments be conducted prior to approval for any development within 300 feet of creeks, wetlands, or other sensitive habitat areas shown on Figure 7-3 of the proposed General Plan.
4) Require on-site monitoring of biological resources by a qualified biologist throughout the duration of construction activity.
5) Require compensatory mitigation by means of habitat
preservation, restoration, and enhancement; for the loss of any critical habitat and/or special status communities.

This is a minor correction made to clarify and would not affect the findings of the DEIR.

C1-14 Stan Zeavin 3/20/22 p. 3.7-32
>> ADD to Saltmarsh common yellowthroat:

Also reported at small willow marsh at
northern end of Pacifica State Beach and
Lake Mathilde remnant east of Crespi
Community Center.

The DEIR uses data from the CNDDB database for June
2021. This occurrence was not identified at time of release.

C1-15 Stan Zeavin 3/21/22 p. 3.7-35
ADD: Western pond turtle (Actinemys
marmorata). Ca species of special concern
Observed basking at San Pedro Creek –
(Margaret Goodale personal observation ,
spring, 2019) (ALSO reported from Laguna
Salada)
The DEIR uses data from the CNDDB database for June
2021. This occurrence was not identified at time of release.

C1-16 Stan Zeavin 3/22/22 p. 3.7-39
>> With the completion of the tunnels,
Hickman’s cinquefoil is no longer threatened
by the Devil’s Slide Bypass highway project.

Update.

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

C1-17 Stan Zeavin 3/23/22 p. 3.7-53
Impact of the General Plan
ADD: Western Snowy Plover as a special
status wildlife species and identify Pacifica
State Beach as ESHA.

See response for C1-13. Snowy plover is referenced on DEIR p. 3.7-21.

C1-18 Stan Zeavin 3/24/22 CO-I-1 Creek Protection and Restoration • “Enforcing restrictions on the planting of
invasive species near creek areas;
• Requiring minimum setbacks from the top
of creek banks for development proposed
adjacent to creeks, in keeping with City
regulations and Best Management
Practices.”
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

2.f
Packet Pg. 942 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 848 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 61 Letter Commenter Date Comment Combined Response
Individuals (C)
>> Specify “restrictions” and “minimum
seatbacks”
C1-19 Stan Zeavin 3/25/22 p 3.7-59 CO-I-37 Protection of … During Construction
>> ADD Western Pond Turtles
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-20 Stan Zeavin 3/26/22 p. 3.7-6
>> ESTABLISH ROBUST Habitat Conservation
Plans and Natural Community Conservation
Plan
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-21 Stan Zeavin 3/27/22 p. 3.7-61 (Impact of the General Plan) “…and San Pedro Creek is very close to the
San Pedro Site.”
>> Clearly Identify and add DETAIL ABOUT
THE ”SAN PEDRO SITE”
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C1-22 Stan Zeavin 3/28/22 CO-I-28 Protection of Environmentally Sensitive Habitat Area (ESHA). Protect all
sensitive species with defined or potential
habitat…
CO-I-29 Verification of ESHA
>> Most endangered or threatened species
have been listed due to habitat limitations
from human encroachment. We CANNOT
further limit their habitat. Remove the
possibility of mitigation. Loss of habitat
cannot be mitigated.

See response for C1-13 for ESHA and sensitive habitat
protection policies.

C1-23 Stan Zeavin 3/29/22 p. 3.7-64
CO-I-46 Shoreline Protection. Continue to
prohibit new development requiring
shoreline alterations.
>> Specify and clarify date of “existing
structures” to be consistent with Coastal Act.

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

2.f
Packet Pg. 943 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 849 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 62 C2: Maria Martinez-Mont, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C2-1 Maria
MartinezMont
2/11/22 I've lived in Pacifica for the past 20 years and my family has lived here for over 40 years. Please do
NOT ALLOW for the changes proposed on Sharp park.

These will create more traffic and if you want
affordable housing why not do it in places that are
open like Fresno or up north past Eureka???? that
part of the valley? Pacifica doesn't have the
infrastructure to handle the traffic anymore, we are
already on top of each other.

Plus we do not want the pollution and over
population. You will kill the heart of Pacifica if you do this. We are a small town not crowded like the
Peninsula or South Bay.

The comment is noted. Traffic congestion is no
longer a required topic of analysis under CEQA.

Thus, no further response is required.

2.f
Packet Pg. 944 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 850 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 63 C3: Lisa Villasenor-Volosing, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C3-1 Lisa
VillasenorVolosing
3/8/22 As a Pacifica resident since 2005 and long time
lady golfer and supporter of the Sharp Park Golf
Course and its historical clubhouse, I am
expressing my support for and agreement with
Mr. Richard Harris’ letter dated 3/7/22, regarding
Sharp Park Golf Course is a historical site. I have
reviewed Mr. Harris’ 3/7/22 letter on behalf of
San Francisco Public Golf Alliance, and I agree
with its analysis and its call for Sharp Park to be
listed and designated a Pacifica historic site and
historic resource.

Please see Master Response 1 for more information on
GP-related responses. The comment stated that that
Sharp Park Golf Course itself—and not only the
Clubhouse—should be identified in the General Plan
and EIR as an historic resource. The Golf Course and
Clubhouse are identified as an historic site in the 1980 General Plan, and were identified by Resolution No. 63- 2007 as “historically significant facilities” by the Pacifica City Council.

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

2.f
Packet Pg. 945 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 851 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 64 C4: Remi Tan, 2/26/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C4-1 Remi Tan 2/26/22 I was looking at the DEIR exec summary and the housing number is still to low at 900... The DEIR
needs to be completely updated to reflect the
higher RHNA numbers and the increased service
retail that the new housing would support. Also
the DIER needs to be updated to reflect the
increased traffic, pollution, transit, and other
environmental impacts would increase and need
to be accounted for with the higher RHNA
numbers.

Cal Code Regs. Tit. 14§ 15144 recognizes that drafting
an EIR necessarily involves some degree of
forecasting and requires that the lead agency “use its
best efforts to find out and disclose all that it
reasonably can.” Further, the statute allows for the
use of projected future conditions that are supported
by reliable projections based on substantial evidence
in the record.

Consistent with that guidance, DEIR buildout
projections do not use the theoretical buildout of
each parcel to the maximum extent allowed under
zoning because that would not represent a
reasonably foreseeable forecast. Parcel dimensions or
the existence of environmental constraints will likely
preclude many properties from being built out to the
maximum intensity allowed and historical trends in
the city indicated that developments are typically
approved and constructed at densities and intensities
below the maximum. Therefore, it is impossible for
every parcel in the city to be built out the maximum
permitted under zoning. Furthermore, using
maximum theoretical buildout as the basis for the
CEQA analysis would exaggerate impacts and result in
mitigation measures requiring the construction of
road and utility infrastructure in excess of what is
need to support growth resulting from the Proposed
Plan. Therefore, the DEIR correctly used a reasonably
foreseeable forecast of buildout under the Proposed
Plan as the basis for the environmental analysis.

At a joint study session on September 3, 2019, the
City Council reviewed a limited set of land use
changes developed on the basis of community
outreach conducted in 2019 and directed City staff
and consultants to update the 2014 Draft General
Plan accordingly and prepare a Draft EIR.

Subsequently, in May 2021 the Association of Bay
Area Governments (ABAG) released draft RHNA
numbers for Pacifica which identified a need for
housing far beyond the realistic capacity of the
Proposed Plan Land Use Diagram. These Final RHNA
numbers were adopted by the ABAG Board in
December 2021. To accommodate these new RHNA
numbers, it is likely that Pacifica will need to consider additional land use changes; however, such changes
were beyond the scope of the Proposed Project.

Rather than start the General Plan and EIR process
over again and delay adoption by an additional two
years, the City elected to proceed with the Proposed
Plan knowing that additional land use changes,
community engagement and environmental analysis
will be needed for the Housing Element. The updated
General Plan will provide a better basis for the
subsequent Housing Element update, as the existing

2.f
Packet Pg. 946 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 852 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 65 Letter Commenter Date Comment Combined Response
Individuals (C)
General Plan from 1980 is out of date and
inappropriate for that purpose.

Separately, the City is preparing to initiate its 6th
cycle Housing Element update. The Housing Element
update and development of the required housing
sites inventory will involve extensive community input
and be subject to separate CEQA review. The Housing
Element CEQA document will analyze the cumulative
effects of implementing the Housing Element Update
– including associated changes to the land use
diagram - in combination with the Proposed Plan.

Please see Master Response 3: Buildout and RHNA for
more information.

2.f
Packet Pg. 947 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 853 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 66 C5: Remi Tan, 2/2/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C5-1 Remi Tan 2/2/22 The planned housing quantity of 990 units by 2035 is inadequate and does not cover the job creation of
1,470 jobs by 2040 and is also short of the 1,892 RHNA
required housing units to be built by 2031. (See
excerpts from the Jan 2022 Public Comment Draft
General Plan and the ABAG RHNA.) Also given that the
majority of the jobs projected to be created are in the retail and service sectors (which is in line with the
proposed increase in tourism), and these jobs are
typically low paying, we need to add much more
housing and most of this should be affordable
housing.

Please see response to comment C4-1 and Master
Response 3: Buildout and RHNA for more
information on adequacy of buildout projections.

C5-2 Remi Tan 2/2/22 Given the recent astronomical rise in Pacifica real estate values, Pacifica needs to increase housing
quantities beyond the RHNA allocation to stabilize
prices by increase supply to meet demand.. The City
should work with other Bay Area cities and counties
and ABAG to engage a study by an economist that
would analyze job creation and population increase in
the Bay Area and determine the amount of housing
that needs to be built in Pacifica (and the Bay Area)
not only to accommodate the new jobs within
commutable distance and population growth but to
stabilize rising prices by building enough housing so
that demand and supply are equalized.

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

C5-3 Remi Tan 2/2/22 This new housing should be accounted for in the new General Plan and should be located near transit stops
and shopping centers to reduce traffic, and not
located on hillsides and toes of hills subject to
landslide, in erosion vulnerable coastal edges, or in
areas prone to flooding or high tide inundation to
avoid loss of life and property due to more severe
weather and sea level rise caused by global warming.

This may require increase in density and height limits
near the transit and shopping centers to
accommodate the housing.

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

C5-4 Remi Tan 2/2/22 Given the dire rising cost situation with housing, and with all the effort and public input in the new General Plan and subsequent zoning updates, all housing
projects as well as commercial projects should have
as-of-right zoning that minimizes additional public,
planning commission and city council hearings and
meetings to expedite the planning process and the city
should coordinate with the Coastal Commission to
make sure the General Plan and zoning is designed to
make CC approval as of right too
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C5-5 Remi Tan 2/2/22 The city should have an expedited permit process in place and coordinate this expedited permit process
with the Coastal Commission for housing locations in
the Coastal Zone. Housing projects with high
affordability should be top priority in permit
expediting
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see

2.f
Packet Pg. 948 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 854 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 67 Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

2.f
Packet Pg. 949 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 855 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 68 C6: Clif Lawrence, 1/30/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C6-1 Clif
Lawrence
1/30/22 FIRST...WE NEED MORE TIME
The 2015 FEIR references more than 80 days in
that review period. "What's the rush?"
According to 14 CA ADC § 15105, The public review
period for a draft EIR shall not be less than 30 days nor should it be longer than 60 days except in unusual
circumstances. The public comment period was
extended on 2/14/2022 to 3/8/2022.

2.f
Packet Pg. 950 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 856 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 69 C7: Debra Etienne, 2/14/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C7-1 Debra
Etienne
2/14/22 I am concerned about Wildland fires in our town. The EIR does not adequately address this risk.

In Figure 3.11-2 under the Fire Hazards and Public
Safety Services Map, only one area is marked as Very
High Fire danger and one very tiny spot is marked as a
High fire danger area. Come on, folks! We all know
Pacifica is covered in groves of Eucalyptus trees and
pine trees. How in the world can you honestly say this
map represents our town’s risk of Wildland fires?
Under the Fire Hazards section, (page 639) the DIER
states, “Pacifica has a substantial risk of woodland
fires, with many areas of high and very high threat
within the Planning Area.” Well, where are they? How
can this statement be made without a map showing
these areas throughout town? Additionally, this
statement is contradicted later as shown below. Why
don’t they contain the same information?
Please see Master Response 5: Wildfire. The DEIR
characterizes wildfire hazards within the Planning
Area on pages 3.11-4 through 3.11-6 and 3.14-1
through 3.14-4, making use of data and information
from CALFIRE and from the Multi-Jurisdictional Local
Hazard Mitigation Plan (MJ-LHMP) for San Mateo
County. The characterization in the DEIR includes a
description of vegetation in the Planning Area, a
history of wildfire occurrence in the Planning Area,
the probability of a fire occurring in the future, and
identification of Fire Hazard Severity Zones
designated by CALFIRE based on factors such as fuel,
slope, and weather. Two maps are included:

Figure 3.11-2, which shows Very High Fire Hazard
Severity Zones for Local Responsibility Areas (LRAs),
State Responsibility Areas (SRAs), and Federal
Responsibility Areas (FRAs) as designated by CALFIRE
pursuant to Government Code Section 51175. By law
CALFIRE is required to designate these Fire Hazard
Severity Zones, land within which is subject to
various requirements in the California Building Code
for the design and construction of new buildings
intended to reduce the risk of loss of life and
property, including requirements for building
materials, defensible space clearance, and other
wildland fire safety practices; and
Figure 3.14-1, which shows Fire Threat, a measure of
fuel conditions and fire potential in the ecosystem,
representing the relative likelihood of “damaging” or
difficult to control wildfire occurring for a given area.

Fire Threat is not a risk assessment by itself, but can be used to assess the potential for impacts on
various assets and values susceptible to fire. Impacts
are more likely to occur and/or be of increased
severity for the higher threat classes. Please see
Master Response 5: Wildfire for more information.

Both CAL FIRE datasets/maps used for analysis,
including VHFHSZ (Figure 3.11-2) and Fire Threat
(Figure 3.14-1), incorporate measures related to
wildfire fuel conditions and fire potential. Policy SA-I98: addresses Vegetation Management, included in Impact 3.14-1.

Analysis in the 2021 MJ-LHMP and the safety
element of the Proposed Project identifies areas of
the city that have constrained emergency access.

Reliance on Highway 1 as a north-south connection
causes challenges for timely fire response, and the
Vallemar, West and East Fairway Park, Rockaway
Beach, and Rockaway neighborhoods in central
Pacifica are beyond four-minute travel distance from
northern San Mateo County fire stations, meaning

2.f
Packet Pg. 951 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 857 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 70 Letter Commenter Date Comment Combined Response
Individuals (C)
that a new station would be needed if the central
part of Pacifica were to experience substantial new
development.

Potential improvements to the roadway network
could contribute to mitigating the impacts of
additional traffic on emergency response times.

Furthermore, traffic signal preemption devices on
emergency vehicles, as well as emergency sirens, will
improve emergency response times ven in instances
of intersection congestion during peak commute
periods. The Proposed Project provides for improved
emergency access through policies that promote
mobility connections between communities; provide
additional access routes; require new streets and
developments meet adopted emergency access
standards; and ensure adequate fire, police, and
emergency service in line with any new
development, including in Central Pacifica where
service times do not currently meet NCFA’s
standards, and in areas that have less than two
evacuation routes north of the VHFHSZ (Proposed
General Plan Implementing Policy SA-I-104) Future
development would be required to adhere to all
policies, goals, and standards in the MJ-LHMP,
Pacifica Municipal Code, and CBC, including vehicular
access and emergency access. Implementation of the
following Proposed Project policies will ensure that
inadequate emergency access does not occur, and
will result in a less than significant impact.

C7-2 Debra
Etienne
2/15/22 Further, under the Wildland Fires section, the
document states, “As an urbanized community,
wildfire hazard is minimal in most of Pacifica city limits.

However, areas along the southwestern perimeter
within the Sphere of Influence and in San Pedro Valley
County Park are designated as Very High…..” It then
follows up with, “ Land adjacent to these areas that is within city limits is low and very low density residential development.” Not true.

Using the latest and best available data, as shown on
Figure 3.11-2, the DEIR correctly identified that there are no VHFHSZ within the City limit, but that there
are Fire Hazard Severity Zones in the Sphere of
Influence, which are in areas of State responsibility.

Further, using Fire Threat mapping available from
CAL FIRE (Figure 3.14-1), as described on p. 3.14-14
of the DEIR identified that beyond CALFIREdesignated Fire Hazard Severity Zones described on p. 3.14-14 that Pacifica has a substantial risk of
wildland fires beyond identified VHFHSZ, with many
areas of high threat within the Planning Area.

Development However, as noted in the DEIR
development under the Proposed Plan is expected to
occur predominantly in already-urbanized
neighborhoods where risk is minimal as compared to
areas of higher fire threat, but not devoid. Existing
land uses in the area are shown in Figure 3.1-1,
which uses data from the County Assessors office,
shows that areas surrounding Pacifica's Sphere of
Influence are indeed low density residential. Please
see Master Response 5: Wildfire for more
information.

C7-3 Debra
Etienne
2/16/22 These statements do not accurately reflect the amount of potential danger we face with all of our trees. You
all live here. Look around your backyards and hills.

Both CAL FIRE datasets/maps used for analysis,
including VHFHSZ (Figure 3.11-2) and Fire Threat
(Figure 3.14-1), incorporate measures related to

2.f
Packet Pg. 952 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 858 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 71 Letter Commenter Date Comment Combined Response
Individuals (C)
They are covered in Eucalyptus groves and many areas
have Pine trees lining the properties and streets. Have you honestly driven around town and documented all
the thick groves of trees surrounding our homes?
wildfire fuel conditions and fire potential. Thus, they present an adequate means of establishing areas of
fire risk for purposes of DEIR analysis. Please see
Master Response 5: Wildfire for more information.

C7-4 Debra
Etienne
2/17/22 How can we assess our fire danger when we haven’t accurately documented it? Why aren’t these areas
considered in looking at potential fire dangers within
our city limits:
• Oddstad Park where Spindrift Theatre is located off
Crespi — huge groves Hill behind Christian school on
Seville Dr. — huge groves
• Strip of forest behind Park Mall and below Alicante
Drive.
• Hill above/behind Ortega Elementary and downside
of Banyan
• Everglades drive going up the hill, huge grove on
right, below Water tank accessed from Big Sur Dr.
• On hill above Terra Nova HS, long grove.
• Hill above Cabrillo Elementary and below water tanks
off Fassler — lots of trees clustered there
• Corridor between Fassler and Rockaway Beach Ave.
• Hill above Lumber Yard on Hwy One
• South Hill behind Reina Del Mar and between Fassler
• Rifle Range Road has lots of pines lining it and there’s many trees in the Golf Course also
• Hill below Gypsy Hill Road and above Brighton Rd.
• Hill above Good Shepard School
• All the City’s "Green Belt” areas behind homes that
contain many trees. (My elderly neighbor said our City
sold trees for $.01 to residents to encourage planting
in the early days.) Now all those trees are huge.

You get the idea. We are in big trouble if a wildfire
breaks out here where the trees are so close to homes,
business and schools. I can’t find an accurate map that show all these potential fire dangers, even after
contacting Fire Safe San Mateo and writing North
County Fire Authority. Please, think this over and ask
yourself if you or your family members are protected
by this document. I think not. Please take the time to
accurately reflect the Wildland fire hazards in our town before approving this document.

As noted on DEIR p. 3.14-2, fire hazards and threat
are determined using several factors, including fuel
(or vegetation), fire history, topography, and
climactic conditions. Please see response to
comment C7-1 for more information about the maps
assessing fire threat, and Master Response 5:

Wildfire for more information regarding the
adequacy of analysis.

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Packet Pg. 953 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 859 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 72 C8: Richard Grassetti, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C8-1 Richard
Grassetti
3/8/22 Hi- Attached find “Attachment C” to my letter
sent earlier today. It was too large a file to be
sent with the earlier letter. Please include it with
our letter.

This comment contains an attachment to comment C34
and is not a comment on the DEIR.

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Packet Pg. 954 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 860 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 73 C9: Bob Boles, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C9-1 Bob Boles 3/7/22 This DEIR is a mess: the data it is based on varies from recent to decades ago, it both leaves out
important elements and duplicates others while
providing conflicting information; it meanders
around endlessly while providing platitudes
instead of worthwhile information to determine
impacts and appropriate mitigations to reduce
proposed project impacts to a less than significant
level as required by CEQA.

The adequacy of hazards mapping is described in
response to comment C22-10. Please see response to
comment C123-1 for more information on the
adequacy of impact analysis.

C9-2 Bob Boles 3/7/22 My particular concern while reviewing the DEIR and Draft General Plan was the public utilities that
the city provides: storm drainage, sewer system
collection and treatment, water supply and
waste/recycling.

A. General Comments

1. LU-I-13 “Public Service Priorities. Ensure that
needs generated by development or uses
permitted over the planning period are adequately
served by existing and planned public works
facilities. In the event that existing or planned
public works facilities can accommodate only a
limited amount of new development, services to
coastal dependent land use, essential public
services and basic industries vital to the economic
health of the region, state, or nation, public
recreation, commercial recreation, and visitor
serving land uses shall not be precluded by other
development.”
I see no analysis or discussion in any of the utility
sections that confirms existing sewer, drainage,
water, or waste system capacities or plans to
upgrade/expand capacity to serve the projected
buildout of 990 new units in the General Plan,
much less the 1892 new units required under
RHNA by January 2023, or the recent changes to
state laws which allow ADU’s on virtually any
residential lot and lot splits per SB 9 and 10, along
with current developer proposals for high-rise
residential development and proposed zoning
amendments, annexations, and density bonuses.

These growth projections must be presumed to
have a considerably large error factor, which calls
in question the very basis of the DEIR.

Analysis pertaining to whether the implementation of
the Proposed Project will require or result in the
relocation or construction of new or expanded water,
or wastewater treatment, or storm water drainage
facilities is discussed under criterion 3.13-1, specifically on pages 3.13-16 to 3.13-20. Future water demand in
the NCCWD service area was accounted for through
2045 in the District’s 2020 UWMP, including
development associated with the Proposed Project
buildout, and no new or expanded conveyance
infrastructure beyond that which is already planned
would be required to deliver water to the Planning
Area through 2045. In addition, proposed General Plan
Policy CO-I-63 reduces impact by requiring
implementation of the Project to maximize water
system efficiency.

In regard to wastewater, the dry weather capacity of
the Plant is 7.0 mgd, and the estimated flow under
General Plan buildout is only 2.56 mgd. Therefore,
there is adequate capacity to serve the buildout
population. General Plan buildout will not impact any
existing sewers due to the projected growth of Pacifica over time. Proposed General Plan policies that will
continue to reduce impact include CO-G-5, CO-I-19,
CO-I-20, CO-I-21, CO-22, and CO-I-63 which ensures
that the City maintains adequate wastewater
treatment and sanitary sewer capacity while
maximizing efficiency.

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

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Packet Pg. 955 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 861 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 74 Letter Commenter Date Comment Combined Response
Individuals (C)
Cal Code Regs. Tit. 14§ 15144 recognizes that drafting
an EIR necessarily involves some degree of forecasting
and requires that the lead agency “use its best efforts to find out and disclose all that it reasonably can.”
Further, the statute allows for the use of projected
future conditions that are supported by reliable
projections based on substantial evidence in the
record.

Consistent with that guidance, DEIR buildout
projections do not use the theoretical buildout of each parcel to the maximum extent allowed under zoning
because that would not represent a reasonably
foreseeable forecast. Parcel dimensions or the
existence of environmental constraints will likely
preclude many properties from being built out to the
maximum intensity allowed and historical trends in the
city indicated that developments are typically
approved and constructed at densities and intensities
below the maximum. Therefore, it is impossible for
every parcel in the city to be built out the maximum
permitted under zoning. Furthermore, using maximum
theoretical buildout as the basis for the CEQA analysis would exaggerate impacts and result in mitigation
measures requiring the construction of road and utility infrastructure in excess of what is need to support
growth resulting from the Proposed Project.

As noted in Master Response 3: Buildout and RHNA, at
a joint study session on September 3, 2019, the City
Council reviewed a limited set of land use changes
developed on the basis of community outreach
conducted in 2019 and directed City staff and
consultants to update the 2014 Draft General Plan
accordingly and prepare a Draft EIR. Subsequently, in
May 2021 the Association of Bay Area Governments
(ABAG) released draft RHNA numbers for Pacifica
which identified a need for housing far beyond the
realistic capacity of the Proposed Project Land Use
Diagram. These Final RHNA numbers were adopted by
the ABAG Board in December 2021. To accommodate
these new RHNA numbers, it is likely that Pacifica will need to consider additional land use changes;
however, such changes were beyond the scope of the
Proposed Project. Rather than start the General Plan
and EIR process over again and delay adoption by an
additional two years, the City elected to proceed with
the Proposed Project knowing that additional land use
changes, community engagement and environmental
analysis will be needed for the Housing Element. The
updated General Plan will provide a better basis for the subsequent Housing Element update, as the existing
General Plan from 1980 is out of date and
inappropriate for that purpose.

Separately, the City is preparing to initiate its 6th cycle

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Packet Pg. 956 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 862 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 75 Letter Commenter Date Comment Combined Response
Individuals (C)
Housing Element update. The Housing Element update
and development of the required housing sites
inventory will involve extensive community input and
be subject to separate CEQA review. The Housing
Element CEQA document will analyze the cumulative
effects of implementing the Housing Element Update –
including associated changes to the land use diagram -
in combination with the Proposed Project. Therefore,
this approach does not constitute “piecemealing,” or
dividing a large project into separate parts, each of
which might have individually minimal environmental
consequences.

Therefore, the DEIR correctly used a reasonably
foreseeable forecast of buildout under the Proposed
Project as the basis for the environmental analysis.

The DEIR therefore contains a valid and accurate
analysis of the effects that project buildout may have
on utility facilities.

C9-3 Bob Boles 3/7/22 LU-I-13 acknowledges that development may need to be limited and yet gives no analysis how
development may be limited. The Land Use
Diagram Figure 4-3 increases density on a number
of parcels scattered throughout Pacifica. For
example, is the land proposed to be rezoned to
Mixed Use
2 Neighborhood at the corner of Oddstad and
Terra Nova a lower priority than Sharp Park as
implied by LU-I-13 since it is not in the Coastal
Zone? It seems the owner of that property would
have a reasonable expectation based on the new
General Plan zoning density change to Mixed Use
Neighborhood that the property can be developed
to increase density.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response:

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

While land use designations describe what can be
developed on a gross acre, projects would also be
subject to the Zoning Code, and any other projectspecific requirements that could affect development, such as setback from a creek, siting to avoid sensitive resources, or slope constraints, for example. Individual projects are required to prepare a more precise,
project-level analysis to fulfill CEQA requirements. The lead agency responsible for reviewing these projects
shall determine the level of review needed, and the

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Packet Pg. 863 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 76 Letter Commenter Date Comment Combined Response
Individuals (C)
3/7/22scope of that analysis will depend on the
specifi3/7/21cs of the particular project. Should an
applicant propose to develop in an area with sensitive
resources or potential site-specific impacts or in an an area of known hazards, compliance with policies
requiring additional study would be a requirement for
project approval. Any project requiring discretionary
approval is required to make findings of General Plan
consistency and must demonstrate analytically that the
project is consistent with the General Plan, and how
they comply with applicable policies.

C9-4 Bob Boles 3/7/22 Are we making promises that we cannot necessarily keep and therefore exposing the city to
potential litigation from that property owner if the
city later denies his project based on inadequate
utility capacity for example? How would you know
if three other large projects in Sharp Park might be
submitted the following month which would have
priority and cap capacity? Or is the city then
obligated to expend capital improvement funds we
do not currently have on hand to expand our
pump stations and sewage plant? We need a
thorough evaluation of our capacity and ability to
expand capacity as part of this DEIR. Please
confirm how and when this will be provided.

See response to comment C9-2.

C9-5 Bob Boles 3/7/22 By the way, this property, I believe identified as Park Mall, backs onto San Pedro Creek on the
southern side – isn’t there a new DEIR policy that
requires a 100-foot setback from a creek? Has that
been considered? The parcel next to the creek is
currently zoned agriculture (see below), which per
the Growth Control Ordinance, requires a vote of
the people to alter zoning. Please confirm why this
parcel has been rezoned without this public vote.

The comment is noted. Policy CO-I-1, Creek Protection
and Restoration, would require a 100-foot setback
from the top of creek banks to be incorporated into a
project for any development adjacent to creeks.

According to the City's current zoning code, the parcel is zoned C-1 (Neighborhood Commercial). The
Proposed Project does not make any changes to
zoning; Zoning Code updates are required after
adoption.

C9-6 Bob Boles 3/7/22 2. Pacifica’s Limited Financial Resources for Expansion of Public Services.

The Bibliography on page 6-12 refers to “City of
Pacifica Annual Budget 2011-2012. Available:
http://www.
cityofpacifica.org/civica/filebank/blobdload.asp?Bl
obID=4400, accessed August, 2013.”
Please confirm what recent data and city budget
were used as part of this DEIR and provide detailed
information as to the city’s planning for both
maintenance and expansion of utility
infrastructure and additional land/sites for
infrastructure needed to support actual project
buildout over the next 8 years. We all know from
Pacifica’s current Vision 2025 that the city is broke
and in the next two to three years will not be able
to serve current residents with essential services,
much less future residents. Please identify and
break out economic costs of new infrastructure
The comment is noted. The comment is not related to
the adequacy of the DEIR, therefore no further
response is required in the FEIR. However, the
comment addresses the content of the Proposed
Project and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related
responses.

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Packet Pg. 958 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 864 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 77 Letter Commenter Date Comment Combined Response
Individuals (C)
needed, including new roads, fire stations, schools,
sewer, water, stormwater systems, etc. required
to achieve full Project buildout including RHNA
housing allocation numbers so the City Council can
make informed decisions as to our actual
economic capacity for growth.

C9-7 Bob Boles 3/7/22 B. Sewage (wastewater) Collection and Treatment I started by reviewing the Department of Public
Works’ Sewage Collection System Master Plan,
which dates to 2012, with a partial Update in 2021.

I was glad to see what appeared to be a
professionally organized document which
described and mapped the components of the
system. One of the goals of the Master Plan and
particularly its Update was to model the system to
assess its capacity with expected growth, and to
point out what elements would need
maintenance, repair or replacement, so that long
term budgeting could be planned.

There are some problems with the Update as its’
projections for future flows are based on early
2021 knowledge of near-term developments
(developments for which applications had already
been made) which even a year later are severely
out of date, and on the assumptions about open
developable land based on “allowable density in
the general plan”, presumably the 1980 General
Plan which is still in effect.

Project Implementation Recommendations on
Page ES-7 of the Sewage Collection System Master
Plan confirms that these growth projections,
including the Sharp Park Specific Plan, are not
included in the current analysis.
“Growth projections assumed herein should be
updated as needed to reflect the City’s General
Plan and Sharp Park Specific Plan updates, which
are currently ongoing, and need to meeting
regional housing needs. Based on the Draft
Regional Housing Needs Allocation (RHNA) Plan for
the San Francisco Bay Area, prepared in May 2021,
the City must plan to accommodate a total of
1,892 new households between 2023-2031 to
meet regional housing needs;” The DEIR is based in
part on these Master Plan documents so it is
likewise subject to a large error factor.

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

C9-8 Bob Boles 3/7/22 1. Please clarify and provide detailed calculations and analysis to show how the Project Buildout
number was obtained, where the various
additional units are proposed to be located, and
confirm the number of additional housing units
possible given our current sewage system capacity.

If additional sewage capacity is needed to meet
The comment is noted. Please see Master Response 3:

Buildout and RHNA for more information on how
buildout was calculated.

Analysis pertaining to whether the implementation of
the Proposed Project will have adequate wastewater
treatment capacity to serve the projects projected

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Packet Pg. 959 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 865 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 78 Letter Commenter Date Comment Combined Response
Individuals (C)
projected buildout, please confirm how and where
our existing plant might be expanded, which pump
stations would need to be upgraded, at what
projected cost, and how the city is planning to
secure these funds. I see no discussion of this in
the General Plan or DEIR. Please also note that
current development fees for sewage and storm
water improvements have not been updated in
some time and are woefully inadequate.
demands is discussed under criterion 3.13-3,
specifically on pages 3.13-25 to 3.13-26. Based on the
estimated wastewater flow under General Plan
buildout (see response to comment C9-2), there are
adequate wastewater treatment facilities in the City.

Additional Proposed Project policies ensure
compliance with stormwater discharge permits. One
such policy includes CO-I-10 which ensures compliance
with stormwater discharge regulations from new and
existing development. Therefore, the Proposed Project
will not result in the exceeding of wastewater
treatment requirements of the RWQCB.

C9-9 Bob Boles 3/7/22 2. Due to the date of its publication, the Update also makes no mention of the recent Linda Mar
flooding and the massive spills of recent untreated
sewage into the Pacific Ocean in October and
December of 2021. This is the elephant in the
room – the fact that the Equalization Basin hasn’t
done the job it was intended for even with current
demand, much less with any projected growth.

Please provide detailed information and
calculations showing the capacity of the
Equalization Basin and detail any proposed
improvements to increase capacity.

The comment is noted. The Wet Weather Equalization
Basin has a 2.1 million gallon capacity. See response to comment C9-2 regarding whether the implementation
of the Proposed Project would require or result in the
relocation or construction of new or expanded
wastewater treatment or storm water drainage
facilities.

C9-10 Bob Boles 3/7/22 3. Looking at the DEIR section for sewage, and assuming it would be based on the latest
information available, I was astonished to see in
the Environmental Setting section, on page 3.13-5,
under the heading Usage and Capacity, the phrase
“Flows are projected to rise to 3.2 mgd by 2012”,
and that this datum based on the General Plan
Update Wastewater Treatment Service Provider
Form from 2009.

Wait, our new general plan is written in reference
what was supposed to happen starting 10 years
ago? From a study which is 13 years old? This calls
into question the rest of the utility section – how
much of it is actually current and pertinent to
today and the next 20-40 years? Does it need to be
refreshed with current data? If the
recommendations are based on a document
written thirteen years ago, then the document is
fatally flawed and needs to be rewritten.

The comment is noted. The 2021 Collection System
Master Plan Phase 2 was released after publication of
the NOP but will be incorporated into the FEIR. The
second sentence of the third paragraph on page 3.13-5
is hereby amended to read, "Existing base wastewater
flow is estimated to be 1.96 mgd" (Collection System
Master Plan Update, 2021). This amendment
represents a minor clarification and does not affect the findings of the DEIR. In addition, the capacity of the
CCWRP has remained unchanged since cited by the
RWQCB.

C9-11 Bob Boles 3/7/22 4. Another example, on page 3.16-6: table 3.13-2 says it “represents the most recent wastewater
data that was available…”, but the source listed is
the Sewer Collection Master Plan, 2011. Please
update analysis and findings per current source
material from 2012 and 2021.

The comment is noted. The specific flow component
data represents the most recent data available for the
City of Pacifica.

C9-12 Bob Boles 3/7/22 5. Under the Planned Improvements heading, several items are listed that “…the City intends to
undertake…” The list is from 2009. Have these
projects already been done? Are they still
The comment is noted. The first bullet under the
Planned Improvements section on page 3.13-5 is
hereby amended to read, "Ultraviolet disinfection
system improvement project - feasibility study" (City of

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Packet Pg. 960 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 866 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 79 Letter Commenter Date Comment Combined Response
Individuals (C)
pending? Are there new projects in the works to
increase capacity and provide resilience from
climate change impacts? Please clarify and update
the documents accordingly with current
information.

Pacifica, 2021). This amendment represents a minor
clarification and does not affect the findings of the
DEIR. The following two bullets list projects that are
still pending in the City.

C9-13 Bob Boles 3/7/22 6. Reading on, in the section entitled IMPACT SUMMARY, starting on page 3.13-16, the DEIR
does reference the more recent data in the 2021
Update. But on page 3.13-17, data from BOTH
2006 and from 2021 are referenced! Please review
and clarify that there are no discrepancies
between these references that would impact the
proposed Project or cause confusion for
developers or planning commissioners utilizing
these documents as references for the next 20-40
years.

The comment is noted. The citations referenced
remain accurate and represent the most up to date
data available that can be used for this analysis.

C9-14 Bob Boles 3/7/22 7. CO-I-23 “Wastewater Treatment Capacity.

Continue to monitor wastewater generation rates
so decision-makers are aware of the impacts on
the treatment plant on new development, and
plan for additional capacity in advance of
projected need.” Again there are no details,
enforcement, or budgeting described to
implement this vague policy. Please expand.

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

C9-15 Bob Boles 3/7/22 C. Storm Water System
I was unable to find a Master Plan for the city’s
storm water system. I understand from Public
Works Director Lisa Peterson that a consultant has
been hired and this is being worked on now. I
therefore dug into the DEIR directly. 1. Storm
drains are (briefly) described on pages 3.13-6 and -
7, in the Environmental Setting section, as
comprising 290,000 linear feet of piping and 989
inlets with two pump stations. There aren’t any
hints to the age of the data, but the data points
listed are at least in conformance with the storm
drain description on the city’s website. Creeks are
mentioned as a destination for storm water, but
no mention is made of the open swales and
drainage channels that are an important part of
the storm water system. Isn’t a natural creek that
handles the city’s storm drainage part of the storm
drainage system? Please add this information as
necessary to the DEIR.

Information pertaining to open swales and drainage
channels is located in the Environmental Setting of
both the Hydrology and Flooding and Utilities chapters
of the DEIR. Pages 3.5-1 to 3.5-6 describe the city's
watershed system, as well as each of the major
watershed creeks that drain into the ocean or toward
the San Francisco Bay. The first full paragraph on page

3.13-7 mentions constructed wetland treatment
swales.

C9-16 Bob Boles 2. Further on, on page 3.13-19 in the IMPACT SUMMARY section, the storm drain system is
described again: “The system serves 178 miles of
roads and 986 inlets”. Oops, lost three inlets, but
then again, this data is from 2008 so maybe we
gained 3 outlets in the meantime? It’s curious that,
as there is commonly about one foot of storm
drain piping per foot of road, this would seem to
entail about 940,000 linear feet of piping…but
then I know from personal experience that, at
The comment is noted. The number of stormwater
inlets are edited on page 3.13-9 to 989 inlets. A note is added that storm water analysis may need to be
amended upon completion of the Storm Drainage
Master Plan. These amendments represent minor
clarifications and do not affect the findings of the DEIR.

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Packet Pg. 867 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 80 Letter Commenter Date Comment Combined Response
Individuals (C)
least in my own neighborhood, the official storm
drain block books are sometimes blank. It’s not
clear that anyone knows just how big the system
is. Please complete the Storm System Master Plan
and incorporate this important information in the
DEIR and General Plan, even if it needs to be done
as an amendment next year. For now, please add a
note as appropriate in the DEIR and GP that this
information is incomplete and will need to be
amended.

C9-17 Bob Boles 3/7/22 3. The DEIR concludes that the Plan (not sure exactly what plan is being analyzed here;
sometimes a ‘plan’ is referred to, sometimes ‘the
project’) will incorporate best storm water
practices in new projects and doesn’t envision any
changes to the existing infrastructure; therefore,
there will be no environmental impacts. There
seems to be no thought of climate change and its
effect on rainfall. Shouldn’t an Environmental
Impact Report take nature into account? Increased
rainfall intensity should be evaluated and planned
for as part of SB379’s climate change vulnerability
assessments and adaptation planning. Please add
this critical information to the DEIR and GP.

Perhaps the editors should be made aware of the
City’s recent Request for Proposals to Civil
Engineering Consultants for a Storm Water Master
Plan. Among other scopes of work, it calls for this
(emphasis added):
“Deficiencies in the Storm Drain System - Assess
conditions of storm drain infrastructure and
determine capacities of existing storm drain
facilities; include identification of isolated flooding locations, and determination of capacity
improvement needs. Flooding has occurred with
greater frequency in recent years – a trend that
can be expected to continue due to several
factors, such as weather events of greater severity
(related to increased ocean water temperatures)
and sea level rise.”
The comment is noted. The "Proposed Project" refers
to implementation of the General Plan and Sharp Park
Specific Plan. Analysis pertaining to whether the
implementation of the Proposed Project will require or
result in the relocation or construction of new or
expanded storm water drainage facilities as discussed
under criterion 3.13-1, specifically on pages 3.13-16 to

3.13-20. In regard to stormwater, development under
the Proposed Project will incorporate best
management practices from construction and
development, meeting the requirements of the City’s
stormwater permit, regional and state regulations, and
Proposed Project policies. The increasing incorporation of stormwater management in site planning will
further reduce the need for development of new storm
drainage infrastructure. Such Proposed Project policies to reduce impact on stormwater facilities include CO-I9, CO-I-10, CO-I-11, CO-I-12, CO-I-13, CO-I-14, CO-I-15, CO-I-16, and CO-I-17. Thus, the stormwater
infrastructure in Pacifica is adequate to provide for the Proposed Project buildout population.

C9-18 Bob Boles 3/7/22 4. The city engineers seem to know the score, have they reviewed this DEIR prior to recent
publication? Please provide copies of Public
Work’s review and input of these current
documents.

Chapter 7 of the DEIR on pages 7-1 ad 7-2 reflects the
latest contacts on persons and organizations consulted
in order to obtain access to Public Works comments on
their review of the DEIR.

C9-19 Bob Boles 3/7/22 D. Flooding

1. In a subsequent section, on page 3.13-12, the
City’s Flood Damage Prevention Ordinance is
mentioned. That dates to 2017. Can you confirm
whether this ordinance, the DEIR and the draft
Safety Element comply with the requirements of
Government Code Section 65302(g) (2) which I
have copied below for reference. I am still slowly
Government Code Section 65302 refers to the
authority for and scope of general plans. The comment
is not related to the adequacy of the DEIR, therefore
no further response is required in the FEIR. However,
the comment addresses the content of the Proposed
Project and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments
for more information about GP- or SPSP-related

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Packet Pg. 962 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 868 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 81 Letter Commenter Date Comment Combined Response
Individuals (C)
wading through the General Plan documents, but
have not seen all these items addressed, for
example flooding risk in Sharp Park without the
sea wall, and flooding risk in Fairway Park without
the berm, repeated flooding of Linda Mar as
recently as October and December 2021. What is
the flood history and current flood risk to the Linda
Mar Fire Station #72, which is located very near
San Pedro Creek? What about the Milagra Fire
Station? I believe that area has also had a history
of flooding and sink holes?
responses. Flooding in Linda Mar is described on DEIR
p. 3.5-8: "San Pedro Creek has a history of substantial flooding in the Linda Mar area. The low area of Linda
Mar has pump systems providing drainage to the
ocean, but these systems can be overwhelmed during
high flow/tide events." P. 3.5-9 also describes impacts due to coastal flooding in the Linda Mar area. Please
see response to comment C66-2 for more information
on added dates of historical flooding.

C9-20 Bob Boles 3/7/22 2. SA-I-24 Storm Drainage Impact Assessment. “Require developers to provide an assessment of a
project’s potential impacts on the local storm
drainage system as part of the development
review process. If development is found to have a
negative impact on storm drainage, the City should
require applicable and e!ective mitigation
measures, such as the creation of permanent or
temporary detention or retention basins, provision
of additional landscaped areas and green roofs,
installation of pump stations, and the use of
permeable paving in drive-ways, walkways and
parking areas.”
Please clarify how the city will define “local storm
drainage system”. Would that include all the
downstream storm drains, roads, and pump
stations to the point of treatment?
As described in the second paragraph on page 3.13-6,
Pacifica’s storm drainage system consists of a
collection system and two pump stations. This
drainage system acts to convey drainage to area creeks
or the ocean. Two areas in the City, Linda Mar and
lower Sharp Park, are too low to allow drainage to a
creek or the ocean, and are served by pump stations to
prevent street flooding. The Streets Division of
Pacifica's Public Works Department maintains 290,000
linear feet of storm drain pipes with 989 storm drain
inlets within the City right-of-way and easements.

C9-21 Bob Boles 3/7/22 3. Figure 3.5-1 Hydrology and Flood Zones neglects to show the flow of Big Inch Creek between the
homes on Monterey and Nelson, undergrounding
at Ocean Shore School. This is also an area that
regularly floods from storm water runoff, despite
being on a hillside. The creek banks are also
eroding in several areas, as recently documented
by Christine Boles with extensive photos, videos
and over 30 neighbor testimonials. This data was
shared with Public Works on 12/2/2021.

The comment is noted. Figure 3.5-1, Hydrology and
Flood Zones Map, will be amended to add Big Inch
Creek to the map. This amendment represents a minor
clarification and does not affect the findings of the
DEIR.

C9-22 Bob Boles 3/7/22 4. CO-I-3 Funding for Creek Maintenance. “Establish funding mechanism to require property
owners with land adjacent to creeks to pay
proportionate share of creek improvement
maintenance.”
I strongly object to this requirement as written.

When creeks are part of the local hydrology and
used for drainage, they benefit the entire
community in the watershed, not just the
properties that back onto the creek. Responsibility
for maintenance should be shared by all the
properties within the watershed, which is easily
identified now with Figure 3.5-1 above.

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

2.f
Packet Pg. 963 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 869 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 82 Letter Commenter Date Comment Combined Response
Individuals (C)
C9-23 Bob Boles 3/7/22 I’d also like to call into question Section 6-12.208 of the PMC “Every person owning property
through which a watercourse passes, or such
person's lessee or tenant, shall keep and maintain
that part of the watercourse within the property
reasonably free of trash, debris, excessive
vegetation, and other obstacles which would
pollute, contaminate, or significantly retard the
flow of water through the watercourse.”
From surveying our neighbors on Monterey Road
and Nelson, not everyone can access the creek
from their back yards due to steep friable banks or
tall retaining walls. This means that large sections
are not maintained. This maintenance should
therefore be the responsibility of public works,
who can access the creek from the large gates at
the cross streets, which residents cannot access.

Again, costs can be shared by all the watershed
properties in a newly created special assessment
district. I also wanted to point out that there was
no disclosure of this maintenance requirement in
our purchase papers when we bought our
property.

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

C9-24 Bob Boles 3/7/22 E. Water

1. “CO-G-5 Water Conservation. Work with the
Water District to meet State targets for reducing
per capita urban water use by 10 percent by 2015
and 20 percent by 2020.” Please revise to include
appropriate targets for FUTURE dates. Were the
water reduction goals listed above achieved in
2015 and 2020? The current data actually shows
water use has increased to its highest level in
2019-2020. What does the water use data show
for 2021-2022?
As stated in the fourth sentence of the second
paragraph on page 3.13-2, "water demand within the
District is projected to decrease to 819 MG (or 2.24
mgd) by 2045, a reduction of 4.4 percent compared to
the 2016-2020 average". In addition, see Table 3.13-4
on page 3.13-23 for estimated future water demand
and supply. Therefore, the existing water allocation is sufficient to meet the needs of the District from the
present through 2045.

C9-25 Bob Boles 3/7/22 2. CO-I-22 Water Storage. “ Support the NCCWD in its efforts to provide adequate emergency water
storage in Pacifica.”
Do we have adequate amounts of water storage?
NCCWD is not currently planning for growth of 990
new units or 1892 new units under RHNA in the
2020 Urban Water Management Plan. Are the
large, heavy water tanks located on hillsides
secure in the event of a substantial seismic event?
This analysis is missing from the public documents
the NCCWD has released to date.

As noted on DEIR p. 3.13-2, "NCCWD system’s 11
storage tanks or reservoirs have a total capacity of

18.25 million gallons, enough to supply the service
area with water for 5.8 days at the District’s average
daily
usage rate of 2.43 million gallons per day (mgd)...water demand within the District is projected to decrease to
819 MG (or 2.24 mgd) by 2045, a reduction of 4.4
percent compared to the 2016-2020 average. This
existing allocation is sufficient to meet the needs of the District from the present through 2045." This indicates that storage will remain adequate with future demand.

As stated in the second sentence of the first paragraph on page 3.13-4, the NCCWD's current Capital
Improvement Plan is focused on pursuing additional
sources of water supply, addressing water storage
deficits by increasing tank size or adding new tanks,
and pipe upgrades. In addition, California Assembly Bill 1823 identifies nine projects essential to the
maintenance of water supply following a major

2.f
Packet Pg. 964 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 870 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 83 Letter Commenter Date Comment Combined Response
Individuals (C)
earthquake, and
requires that they be carried out. In 2002, the SFPUC
adopted a $2.9 billion capital improvement program to
undertake a system upgrade. The General Plan
proposed policy SA-I-93 also requires a priority place
on water storage facility locations that are the least
impacted by seismic activity and land sliding.

C9-26 Bob Boles 3/7/22 3. The Bay Delta Plan may significantly lower available potable water to Pacifica – where is this
discussed in relation to possible limits to new
housing? What about droughts limiting water
hookups, which is discussed in the NCCWD’s 2020
Urban Water Management Plan? Should that not
be included in the DEIR especially as it relates to
climate change adaptation and resiliency as
required by SB379?
Analysis pertaining to whether the implementation of
the Proposed Project will have sufficient water supplies available to serve the project and reasonable
foreseeable future development during normal, dry
and multiple dry years is discussed under criterion

3.13-2, specifically on pages 3.13-22 to 3.13-25.

NCCWD projects there will be adequate water supply
to provide for the population under General Plan
buildout in a normal year. However, significant
shortfalls are projected in dry year conditions, which if realized would require the District to enact its Water
Shortage Contingency Plan. Numerous uncertainties
exist in the assumptions that drive the projected dry
year shortage estimates, and the District anticipates
revising its water service reliability assessment within the next five years as some of these uncertainties are
resolved. Even so, as implementation of the Proposed
Project would not result in rapid or substantial
population growth that would exceed NCCWD’s
current demand rates, and because proposed policies
concentrate on reducing water use and ensuring
adequate supply, this impact is considered less than
significant.

C9-27 Bob Boles 3/7/22 F. Waste/Recycling

1. ES-I-4 Recycling Center Relocation. Work with
Recology, Inc. to identify a new location for a
recycling yard to free up land for visitor-based
economic development. The current Recology
location is in an area experiencing high erosion of
coastal cliffs. This is an essential public health and
safety issue and it is not discussed at all in the DEIR or General Plan. A new location should be
identified now as part of resiliency planning under
SB379, not at some vague time in the future.

Please provide a discussion/plan for resolving this
issue along with a plan to address the potential
loss of Palmetto Avenue in this location across
from the current Recology site due to projected
Coastal Erosion.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Project and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C9-28 Bob Boles 3/7/22 2. “6-G-6 Adequate Infrastructure.

Manage utility infrastructure and waste
management systems that are adequate to protect
the health and safety of all current and future
Sharp Park residents and businesses.”
First of all, is this item numbered properly? It
seems different than other Guiding or
The comment is noted. Guiding Principles are
renumbered to correspond with the correct GP
Principle in the redlined DEIR. As the remainder of the comment is not related to the adequacy of the DEIR,
therefore no further response is required in the FEIR.

However, the comment addresses the content of the
Proposed Project and will be shared with decisionmakers in that context. Please see Master Response 1:

2.f
Packet Pg. 965 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 871 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 84 Letter Commenter Date Comment Combined Response
Individuals (C)
Implementation Policies. Secondly this is so vague
it is meaningless. Utility infrastructure in Sharp
Park will need to be moved inland for resiliency
from sea level rise. Please provide a discussion of
when and where infrastructure will be moved, and
identify an inland site for the relocation of Sharp
Park Sewage Pump Station.

The Sharp Park Sewage System serves
approximately 40% of the population of Pacifica,
well beyond the boundaries of Sharp Park. With a
pump failure, waste backup could reach every
corner of the sewer system. Even with triggers and
a plan in place by that time, it would take years to
add details to finish the plans, raise the money,
process the permits through the Coastal
Commission, and actually complete moving the
sewer system landward. By waiting so long to
complete the rebuild the cost could double or
triple what it would cost if done in the near future.

The lack of any current plan to move the pump
station as part of this General Plan or of the Beach
Boulevard Infrastructure Resiliency Project seems
negligent on the part of the city of Pacifica, and is
most certainly not building long term resiliency
from climate change effects of sea level rise and
coastal erosion.

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

C9-29 Bob Boles 3/7/22 In conclusion, all public service and utilities impacts should be found to be significant and
unavoidable unless new analysis is provided that
services and utilities can meet the demands of the
full development allowed by the Proposed Project
(much more than 990 units as demonstrated in
detail by Planning Consultant Terry Watt)
The comment is noted. See response to comment C9-

2. C9-30 Bob Boles 3/7/22 I urge you to pull the documents, update them properly and consistently with current data in
consultation with Public Works and Wastewater
divisions, NCCWD and Recology, organize the
documents clearly with proper indexes and tables
of contents and an updated Bibliography;
recirculate them as necessary, and hold public
hearings to study them. These are important
documents and need to be properly prepared and
publicly vetted in a fair and reasonably manner.

We cannot possibly approve a General Plan with
990 new units (or more under RHNA) without a
proper understanding of our infrastructure
capacity as well as the necessary improvements
for climate change resiliency and adaptation.

The comment is noted. See response to comment C9-

2. 2.f
Packet Pg. 966 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 872 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 85 C10: Christine Boles, 1/27/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C10-1 Christine
Boles
1/27/22 I would like to officially record my objections to the 45-day public review process given the poor quality of
the documents posted on the Plan Pacifica website
for public review on January 7, 2022 at approximately
10:30pm. Please reference the email to council from
Pete Shoemaker sent on January 23, 2022, which I
have copied below, and which you can see my name
is officially signed on to. I also reference my previous email to you on 1/20/22 with a specific example of
the difficulties I am facing in using these documents
related to Greenhouse gas emissions.

After substantial public outcry, the city made
available searchable word documents on 1/25/22, but
at that point we had already lost 17 out of 45 days of
our already minimal review period the city has
allowed. The fact that the Word documents contain
text but not graphs or other visuals means that they
are still difficult to use and take more of our time as we are forced to go back and forth between
documents and formats. This is unprofessional and an
unnecessary burden to both residents and state and
local agencies tasked with reviewing these
documents.

In fact, I received a phone call from Will Kanz of the
California Department of Fish and Wildlife yesterday
afternoon. Their department is also having issues with
not being able to search documents, and with not
being able to cut and paste from the pdf to prepare
their official comments and responses. He told me he
had sent the city a letter requesting an extension, but that the request was denied. On what grounds what
this request denied? I would like to remind city staff
and Council that the basic purpose of these
documents, as described in the DEIR introduction
Section 1.1, is to “inform decision makers, responsible and trustee agencies, and the general public of the
proposed action and a range of potential
environmental impacts of that action. The EIR process
provides (is supposed to provide) an opportunity to
identify environmental benefits of the Proposed
Project that might balance some potentially
significant adverse environmental impacts.” It is not
only in all of our interests to ensure these documents
are properly prepared and reviewed, but also our
utmost duty as the current stewards of this land we
coinhabit. How can honestly claim at the beginning of
each Council meeting to honor the Ohlone Ramaytush
peoples whose land we profess still belongs to them
without a full and robust review and engagement
process on these most critical environmental
documents. I urge you to pull the documents, fix the
According to 14 CA ADC § 15105, The public review
period for a draft EIR shall not be less than 30 days
nor should it be longer than 60 days except in
unusual circumstances. The public comment period
was extended on 2/14/2022 to 3/8/2022.

2.f
Packet Pg. 967 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 873 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 86 pdfs as previously requested, and reset the 45 day
clock.

2.f
Packet Pg. 968 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 874 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 87 C11: Monica Meagher, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C11-1 Monica
Meagher
3/8/22 It is clear from the Draft General Plan that the city is mindful of preserving a large amount of open space,
and focusing on dense, high uses for vacant or
undeveloped space. There is also clear thought put
into better utilizing currently developed land. We
appreciate the balance of open space and smart
development.

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

C11-2 Monica
Meagher
3/8/22 We love and fully support the plans to further
develop Palmetto Avenue into a retail and visitor
destination. We try to spend as much money locally
as possible. This is very easy with the many
restaurant options, local grocery store, and
recently, a few local toy stores. However, this is
difficult for home goods and sundries. We’d love to
see options for sustainable home goods that we can
purchase locally and hope a revitalized Palmetto
Avenue is attractive for retail.

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

C11-3 Monica
Meagher
3/8/22 It is also clear that Pacifica is car centric. This has become a chicken and egg problem. Since Pacifica
does not invest as heavily in walking, biking, and
transit, people must drive; therefore we are a car
centric town that does not invest heavily in
alternatives. We appreciate the focus beyond cars
and considerations for pedestrians, bicycles, and
transit. We hope the city prioritizes planning for
alternative modes before investing further in car
infrastructure. This will start to shift the balance and allow residents to use alternative modes to get
around town. The Draft General Plan notes that all
studied intersections have crosswalks. However,
there is no crosswalk across Esplanade Avenue at
any point, which makes it very dangerous for the
many pedestrians trying to get to the walking path
to enjoy the view. We hope this is addressed.

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

C11-4 Monica
Meagher
3/8/22 We appreciate the Existing and Proposed Bike
Network but did notice some discrepancies
between current conditions and what is marked on
the map, especially regarding the north section of
Palmetto (between Ingrid B Lacey and West Avalon)
and Esplanade. There is one “bike path” sign and no
road markings on Esplanade so we are surprised to
see it classified as a bike path. There are many
bikers who use that portion of the road and have
difficulty navigating around parked cars. The path
does not link up to the well created paths along
Palmetto.

We would love to see the path on Esplanade
updated and linked to the rest of the city. We think
many residents would bike around town to shop
locally with safer and connected bike paths. We
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

2.f
Packet Pg. 969 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 875 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 88 Letter Commenter Date Comment Combined Response
Individuals (C)
hope Pacifica will look to Berkeley as an example for
safe, usable bicycle paths.

C11-5 Monica
Meagher
3/8/22 It is also clear from the small number of transit trips today that Pacifica can benefit from better
connections to the world-class transit available just
over the hill. The Linda Mar Park N Ride is a great
example of what can be done, but could be
executed better. If a Linda Mar resident wanted to
park and bus to BART, they would have to stop 36
times between Linda Mar and BART. Even someone
from the north end of the city would need 22 stops.

Pacifica should partner with SamTrans to make an
effective connection to BART with fewer stops for
Pacifica residents. Rather than providing more
stops, reduce stops to serve just a few central Park
N Ride locations to make for a fast commute to
BART or Caltrain. Park N Ride facilities can be
located in the major residential areas (Manor, Sharp
Park, Linda Mar) and Limited stop or Rapid bus lines
can be used during commute times to supply buses
just stopping at Park N Ride locations. These same
locations could be used on weekends (with the
addition of Rockway) to provide trolleys or some
festive way for BART or Caltrain riders to access
Pacifica beaches on the weekends. Again,
minimizing stops (rather than expanding services) to
just be in key commercial areas for visitors and
residents. We would happily take our family via
transit down to Linda Mar for a beach day rather
than struggle with parking if there was only one
stop along the way.

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

C11-6 Monica
Meagher
3/8/22 These suggestions around walking, biking, and
transit align with the Caltrans’ Smart Mobility
Framework for suburban locations. It recommends
the prioritization of transportation projects and
programs that:
- Invest in complete streets and safer walking and
biking conditions
- Increase commute transit service and ridesharing
- Improve connectivity to reduce trip lengths and
increase non-auto trips
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

C11-7 Monica
Meagher
3/8/22 In line with the last suggestion, we would like to suggest clearer prioritization. There are many
policies outlined in the Draft General Plan. While we
hope the city is able to realize them all, we must be
mindful of our limited resources (of both time and
money). Can the city work to balance various needs
and make it more clear which policies are priorities?
There should only be a handful in order to be
effective.

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

2.f
Packet Pg. 970 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 876 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 89 C12: Jewel Walli, 3/5/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C12-1 Jewel Walli 3/5/22 1. Please include some recreation requirements in the approval of new building permits for those
large complexes that are being discussed. We are
a city with no public tennis courts/pickle ball
courts.

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

C12-2 Jewel Walli 3/5/22 2. In the general plan please include some pickleball courts . Work with the Parks and
Recreation department and start applying for
grants. This sport, most popular in America,
appeals to older adults so there are probably
grants available.

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

C12-3 Jewel Walli 3/5/22 3. Negotiate with the High School District and go in jointly with a new library. Oceana and Terra
Nova have a lot of unused land (That would work
for some public pickleball courts as well).

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

C12-4 Jewel Walli 3/5/22 4. Quit approving buildings (like the church) that have a huge negative impact on the residents
that live there. Would you want a house on Cape
Brenton?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for more information about GP- or
SPSP-related responses.

2.f
Packet Pg. 971 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 877 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 90 C13: Christine Boles, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C13-1 Christine
Boles
3/8/22 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.

Please see response to comment 13-3 for more
information about adequacy of sea level rise analysis
and response to comment C69-8 for more information
about adequacy of coastal erosion analysis. Maps of
coastal erosion projections and sea level rise are
included in the 2018 Sea Level Rise Vulnerability
Assessment, referenced on DEIR p. 3.5-10 and 3.6-1.

These maps are also included in the LCLUP, which will
govern permitting and coastal resiliency thresholds for sea level rise and erosion in the Coastal Zone once
certified. Policies in the GP share policies with the
LCLUP and are based on this latest mapping effort.

Maps chosen represent the latest and best available
sources of information; existing conditions reports
from 2010 represent data that is outdated.

C13-2 Christine
Boles
3/8/22 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?
The 2018 Sea Level Rise Vulnerability Assessment is
referenced on p. 3.5-10 and 3.6-1; the DEIR
incorporates its coastal erosion and sea level rise
projections. A link to the report is found on DEIR 3.5-

10. The reference will be included in errata.

C13-3 Christine
Boles
3/8/22 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.

The comment is noted. Background information using
some of the latest widely accepted scientific research
on climate change and sea level rise, including recent
(2013) work from the Coastal and Ocean Working
Group of the California Climate Action Team (CO-CAT),
was incorporated into the Draft EIR analysis as
provided on pages 3.5-9 and 3.5-10. In 2018, the City
of Pacifica prepared a Sea Level Rise Vulnerability
Assessment using the best available science.

Consistent with the San Mateo County Vulnerability
Assessment, existing and future coastal flooding was
evaluated using the Our Coast, Our Future (OCOF;
produced by US Geological Survey) mapping products,
while future coastal erosion was evaluated using the
Pacific Institute (PI) erosion maps. The Vulnerability
Assessment projected sea level rise scenarios ranging
from 1-2 feet by 2050, and 3-6 feet by 2100. The 6 feet projection is an extreme scenario in which sea levels
rise at a rate about 30-40 times faster than the rate
experienced in the 20th century. Rising sea levels have occurred over the last century and are expected to
continue over the coming century, likely at a rate that

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Packet Pg. 878 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 91 Letter Commenter Date Comment Combined Response
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exceeds the rates experienced thus far. Modeling has
provided estimates of potential increases in sea levels but as stated on page 3.5-11 of the Draft EIR,
predictions become less reliable as you go further into the future. In addition, different modeling efforts have been conducted to reflect various possible outcomes
resulting in a range of estimates for the amounts of
sea level rise that could be experienced, largely due to the difficulty in determining a more defined predictive value.

Prior to experiencing inundation hazards from a higher
sea level rise, some developed areas are likely to be
subject to changes in flooding hazards as stated on
page 3.5-28 of the Draft EIR. Low coastal flood zone
areas could expand over time as sea levels rise. The
use of maps such as those found in the 2009 California
Climate Change report (The Impacts of Sea-Level Rise
on the California Coast) are not recommended to be
used in place of official FEMA FIRM flood zone maps.

The FIRM maps are periodically updated and future
maps will likely incorporate the latest findings of sea level rise as it becomes more defined. Nonetheless,
the Draft EIR on page 3.5-8 and 3.5-11, identifies the
areas within the City that could be subject to
increased flooding hazards (i.e., areas of West Linda
Mar, lower Pedro Point, Rockaway Beach, West Sharp
Park and the Sharp Park Golf Course). Further, the
proposed policies including SA-G-4 (Key Coastal Act
Policies), SA-G-5 (Sea Level Rise and Best Available
Science), SA-I-15 (New Development in Coastal Zone),
SA-I-28 (Vulnerability Identification and Mapping), and SA-(-30 (Monitoring Shoreline Change) specifically
address the potential hazards of sea level rise and
provide the flexibility in making the appropriate
adjustments as the science improves to ensure that
future development is adequately protected. Any
development in the Coastal Zone is also required to
apply for a Coastal Permit; Coastal Commission
certification will be functionally equivalent to CEQA
analysis for other Coastal Act and LCLUP policies.

C13-4 Christine
Boles
3/8/22 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
The comment is noted. Analysis used the best
available data for sea level rise projections. Further, the proposed policies including SA-G-4 (Key Coastal
Act Policies), SA-G-5 (Sea Level Rise and Best Available Science), SA-I-15 (New Development in Coastal Zone),
SA-I-28 (Vulnerability Identification and Mapping), and SA-(-30 (Monitoring Shoreline Change) specifically
address the potential hazards of sea level rise and
provide the flexibility in making the appropriate
adjustments as the science improves to ensure that
future development is adequately protected.

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Packet Pg. 879 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 92 Letter Commenter Date Comment Combined Response
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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.

C13-5 Christine
Boles
3/8/22 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.

The comment is noted. Please see response to
comment C13-3 for more information about adequacy
of sea level rise analysis and response to comment
C69-8 for more information about adequacy of coastal
erosion analysis. As the commenter notes, the CCC has
project permitting authority in the Coastal Zone, and
several of the policies in the LCLUP require additional project-level review.

C13-6 Christine
Boles
3/8/22 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.

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

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

C13-7 Christine
Boles
3/8/22 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.

Please see response to comment C137-1

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Packet Pg. 974 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 880 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 93 Letter Commenter Date Comment Combined Response
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C13-8 Christine
Boles
3/8/22 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?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C13-9 Christine
Boles
3/8/22 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
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.

The comment is noted. All development will comply
with California Coastal Act regulations. New
development in Coastal Zones will adhere to proposed
policy SA-I-15 which states that the Proposed Project
will continue to enforce provisions of the California
Coastal Act requiring new development within the
Coastal Zone to:
• Minimize risks to life and property in areas of high
geologic, flood, or fire hazard;
• Assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding
area or in any way require the construction of
protective devices that would substantially alter
natural landforms along bluffs and cliffs;
• Not accelerate the need for a shoreline structure or
increase the likelihood of a future seawall beyond the
existing development’s expected life; and
• Not violate required setback provisions.

Small improvement projects are exempt, including
improvements that would increase height, bulk or
floor area by less than ten percent.

C13-
10 Christine
Boles
3/17/22 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.

Proposed Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take on an
ongoing basis as the Proposed Project is implemented
and the DEIR has correctly considered the effects of
implementing these policies, including any beneficial
effects they would have in reducing potentially
significant impacts of the Proposed Project. The Draft
EIR on page 3.5-11, identifies the areas within the City that could be subject to increased flooding hazards

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Packet Pg. 975 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 881 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 94 Letter Commenter Date Comment Combined Response
Individuals (C)
(i.e., areas of West Linda Mar, lower Pedro Point,
Rockaway Beach, West Sharp Park and the Sharp Park
Golf Course). Further, the proposed policies including
SA-G-3 (Sea Level Rise Adaptation), SA-I-22 (Sea Level
Rise Model), and SA-I-35 (Sea Level Rise Surveys),
specifically address the potential hazards of sea level rise and provide the flexibility in making the
appropriate adjustments as the science improves to
ensure that future development is adequately
protected.

C13-
11 Christine
Boles
3/8/22 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.

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.

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

C13-
12 Christine
Boles
3/8/22 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.

The DEIR analyzes scenic resources within state scenic
highways on pages 3.9-22 through to page 3.9-24. As
mentioned on page 3.9-23 'Sharp Park lies to the west
of Highway 1, screened by large trees. No historic
buildings, ridgelines, views of the ocean, or other
scenic resources are visible from Highway 1 where it
traverses the Planning Area. Policies in the Proposed
General Plan also apply to the Sharp Park Specific Plan area.' Due to the topographical differences between
the highway and its immediate surroundings, the
potential future taller buildings along Palmetto would
not have a significant impact of view from Highway 1.

Additionally, simulations are not required for CEQA.

Guiding Policy CD-G-7 ensures viewsheds from
Highway 1 and Sharp Park Road are preserved and
enhanced through scenic corridor plans (CD-I-22),

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roadway design or modification that minimizes visual
impacts to views from scenic routes (CD-I-26). The
DEIR also has regulations and policies that would
further reduce impact on scenic resources on pages

3.9-23 and 3.9-24.

C13-
13 Christine
Boles
3/8/22 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.

The DEIR analyzes scenic resources within state scenic
highways on pages 3.9-22 through to page 3.9-24. No
historic buildings, ridgelines, views of the ocean, or
other scenic resources are visible from Highway 1
where it traverses the Manor Plaza section of the
Planning Area. Due to which any potential future
development at Manor Plaza would not have a
significant impact of view from Highway 1.

Additionally simulations are not required for CEQA.

C13-
14 Christine
Boles
3/8/22 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.

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

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

C13-
15 Christine
Boles
3/8/22 16. Page 3.9-6 of the DEIR states......

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?
Please see response to comment C13-30.

The sea wall is a LCLUP-related issue; construction of
the sea wall is beyond the scope of the DEIR as it not
part of the Proposed Project. The comment is not
related to the adequacy of the DEIR, therefore no
further response is required in the FEIR. However, the
comment addresses the content of the Proposed Plan
and will be shared with decision-makers in that
context. Please see response to comment C13-3 for
more information about coastal flooding and sea level
rise.

C13-
16 Christine
Boles
3/8/22 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.

Economic analyses are not required under CEQA. The
comment is not related to the adequacy of the DEIR,
therefore no further response is required in the FEIR.

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

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

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Packet Pg. 977 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 883 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 96 Letter Commenter Date Comment Combined Response
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C13-
17 Christine
Boles
3/8/22 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.

The DEIR analyzes scenic vistas on page 3.9-14
through 3.9-22. As mentioned on page 3.9-14 'A
number of the Proposed Project’s policies provide
long-term protections for scenic vistas in Pacifica while also creating opportunities for development in
already-developed areas of the city; these policies
include the continuation of the Hillside Preservation
District program and Design Guidelines and Review for
development projects (including Guiding Policies CDG-4 and CD-G-5; and Implementing Policies CD-I-4; I7; I-11; I-12; I-13; I-14; I-15; I-16; and I-17).' As well as 'Future redevelopment projects and development of
vacant lots within and adjacent to already-developed
neighborhoods will be subject to regulation and
review mechanisms to ensure there is no substantial
adverse effect on scenic vistas.' Implementation of
these policies and regulations, as well as additional
ones mentioned on pages 3.9-19 through 3.9-22, will
decrease the impact of the Proposed Project to a less
than significant level. Additionally simulations are not required for CEQA.

C13-
18 Christine
Boles
3/8/22 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.

The comment is noted. Section 3.9 does not mention
the use of screening to hide an otherwise
unacceptable structure. This comment is not related
to the adequacy of the DEIR, thus no further response
is required.

C13-
19 Christine
Boles
3/8/22 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.

The DEIR analyzes scenic vistas on page 3.9-14
through 3.9-22. As shown in Figure 3.9-7, increasing
building heights does not substantially impacts views
of the ocean as compared to existing zoning (35').

Figures 3.9-8 through 3.9-9 in the DEIR show that by
implementing policies such as 5-I-67 along with
additional design standards/guidelines specified in the SPSP, the impacts will be reduced to a less than
significant level.

C13-
20 Christine
Boles
3/8/22 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.

The DEIR analyzes scenic vistas on page 3.9-14
through 3.9-22. As described on DEIR p. 3.9-13, "While
the Proposed Project eliminates the existing single
height limit in the city with height limits that vary by zone, future development will be subject to regulation
and review mechanisms to ensure there is no
substantial adverse effect on scenic vistas...The land
use changes in the Proposed Project will not
substantially degrade the existing visual character or
quality of Pacifica and would not conflict with
applicable zoning and regulations governing scenic
views. All existing open space areas are preserved and

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scenic resources are protected under the Proposed
Project. Policies, zoning designations and design
guidelines included in the Proposed Project will
sensitively govern the formal characteristics of new
development to ensure they are compatible with
existing neighborhood character and quality The
Coastal Act requires scenic and visual qualities of
coastal areas to be considered and protected as a
resource of public importance, and the Sharp Park
Specific Plan includes design standards to minimize
impacts to these areas.

Figures 3.9-4 through 3.9-9 in the DEIR show that by
implementing 3-G-3, 3-I-2, 3-1-35 and 4-G-4 policies
along with additional design standards/guidelines
specified in the SPSP, the impacts will be reduced to a less than significant level.

C13-
21 Christine
Boles
3/8/22 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.

As described on DEIR p. 3.9-18, the Sharp Park Specific Plan proposes land use and corresponding density and
intensity changes along Palmetto Avenue, Francisco
Boulevard, and Eureka Square. The intent of these
changes is to support development of additional
housing, including affordable housing; create a
balanced mix of residential options and compatible
commercial land uses; improve the public realm and
streetscape to promote commercial activity and
walkability; and create a defined commercial center
for Pacifica. To accommodate desired densities and
intensities, the Specific Plan allows for additional
building heights of up to 45 feet for Mixed Use
Neighborhood land uses and up to 55 feet for Mixed
Use Center land uses.

As described in the Environmental Settings, there are
three designated coastal view corridors in the
Planning Area, looking down Paloma Avenue, Salada
Avenue, and Clarendon Road to the ocean. The
vantage point at the top of the bluff where the
Horizons West Apartments are located offers views of
the ocean and the surrounding city, though it is not a
protected view. Between existing buildings and trees,
glimpses of the surrounding hillsides to the east can
be found along Palmetto Avenue. East-west oriented
streets provide views of both the ocean and hillsides.

Views of other important community landmarks, like
the Pacifica Beach Park, the Pacifica Municipal Pier,
and the Sharp Park golf course exist along Beach
Boulevard.

All development under the Proposed Project is
required to comply with existing General Plan and
Local Coastal Land Use Plan policies related to
protected views, particularly new buildings along
Palmetto Avenue with frontage on the coastal view
corridors of Paloma Avenue, Salada Avenue, and
Clarendon Road. While the Sharp Park Planning Area is
mostly flat, there are some points of

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Packet Pg. 885 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 98 Letter Commenter Date Comment Combined Response
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elevation around Hilton Way. From Hilton Way, the
undeveloped portion of the 2212 Beach Boulevard site
provides a more expansive viewshed to the ocean. At
the corner of Palmetto Avenue
and Hilton Way looking south, views to Mori Point and
other southern hills are visible. Pacifica’s existing
height limit of 35 feet begins to obstruct these views
should all buildings reach their existing height
maximum, as shown in Figure 3.9-3 and Figure 3.9-6.

Because the Sharp Park Specific Plan allows for
additional heights up to 55 feet, new development has
the potential to further impede views.

However, the Sharp Park Specific Plan includes several
urban design standards and guidelines would reduce
impacts to these viewsheds, including setbacks, upper
stepbacks above the second
floor, and policies directing site design at the 2212
Beach Boulevard site to preserve part of the viewshed.

Thus, the impacts of taller buildings on scenic
resources are less than significant.

C13-
22 Christine
Boles
3/8/22 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.

The comment is noted. As described in on p. 3.6-37,
geotechnical investigations would be required to
thoroughly evaluate site-specific geotechnical
characteristics of subsurface soils and bedrock to
assess potential hazards and recommend site
preparation and design measures to address any
hazards which may be present. These measures are
enforced through compliance with the CBC to avoid or
reduce hazards relating to unstable soils and slope
failure. In addition, Policy SA-I- 8 of the proposed
General Plan strengthens these precautions by
requiring geotechnical studies subject to review by
City staff, which identify any geologic hazards affecting proposed project sites in Coastal and Hillside zones,
any necessary mitigation measures, and a statement
of the site’s suitability for the proposed development
and whether or not it will be safe from geologic hazard for its expected life."
C13-
23 Christine
Boles
3/8/22 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.

Due to its location, taller buildings would not obscure this view to LBC. This is a minor correction made to
clarify and does not affect the findings of the DEIR.

The following change is thereby made: "No historic
buildings, ridgelines, views of the ocean, or other
scenic resources are visible from Highway 1 where it
traverses the Planning Area. The historic Pacifica
Coastal Museum is visible from Highway 1, but it
fronts the freeway, and no development would occur
in front of the structure that would obsctruct views to this resource."
C13-
24 Christine
Boles
3/8/22 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
Analysis pertaining to whether the implementation of
the Proposed Project will impair implementation of or
physically interfere with an adopted emergency
response plan or emergency evacuation plan is
discussed under criterion 3.11-6, specifically on pages

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Packet Pg. 980 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 886 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 99 Letter Commenter Date Comment Combined Response
Individuals (C)
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

3.11-21 to 3.13-23. The Safety Element of the General
Plan provides policies that address conformance with
local emergency response programs and continued
cooperation with emergency response service
providers. For example, proposed Sharp Park Specific
Plan policy 6-I-4 states that the plan will "Work with
PFD to ensure fire services have the capacity to serve
four- and five-story buildings prior to construction of buildings of that height."
C13-
25 Christine
Boles
3/8/22 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?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C13-
26 Christine
Boles
3/8/22 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 limate
change and reduction in coastal fog. Page 3.14 of
the DEIR talks about parking in Sharp Park and yet,
it only mentions observations, not a real study that
was done. Please confirm.

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

C13-
27 Christine
Boles
3/8/22 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.

C13-
28 Christine
Boles
3/8/22 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
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

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Packet Pg. 981 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 887 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 100
Letter Commenter Date Comment Combined Response
Individuals (C)
considered. Be prepared for pushback from the
community on these assumptions.

C13-
29 Christine
Boles
3/8/22 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.

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

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

2.f
Packet Pg. 982 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 888 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 101
Letter Commenter Date Comment Combined Response
Individuals (C)
C13-
30 Christine
Boles
3/8/22 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.

All hazard analysis and description of potential
impacts required under CEQA is present in the DEIR,
including landslides (Impact 3.6-1), erosion (Impact

3.6-2), wildfire (Impact 3.11-4 and 3.14, 1-4), flooding (Impacts 3.5, 3-4), and greenhouse gases (Impacts 3.4,
1-4). Please see response to comment C22-10 for
more information about adequacy of hazards mapping
and data sources; C69-8 for information about coastal
erosion; C13-3 for more information about sea level
rise and flooding, and Master Response 5: Wildfire for
wildfire analysis adequacy. The San Mateo County MJLHMP, incorporated by reference in many DEIR sections, includes information on how climate change
may exacerbate hazards in accordance with SB379.

Regarding sea level rise and climate change, the City of Pacifica received a Local Assistance Grant from the
California Coastal Commission (CCC) and California
Coastal Conservancy, which provided funding to the
City of Pacifica to hire a consultant to conduct
technical analyses and prepare a vulnerability
assessment and adaptation plan. The City Council
approved and adopted Coastal Resiliency Policies in
2018. These policies are included as part of Chapter 8, Safety, and in Chapter 6, Coastal Resiliency, of the
LCLUP.

C13-
31 Christine
Boles
3/8/22 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.

Please see Master Comment: Buildout and RHNA for
more information on RHNA numbers and adequate
description of project buildout

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Packet Pg. 983 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 889 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 102
C14: William Leon, 3/3/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C14-1 William Leon 3/3/22 Today, March 3, 2021, I dropped of my comment letter and attachments to the letter. It's addressed to you and was received at the front desk; I was told it
would be stamped received and dated. I have
attached digital copies of the letter and the
attachments that I dropped off. Please confirm that
you received the letter and attachments.

No response necessary. Comment followed by 128
pages of Appendix items.

C14-2 William Leon 3/3/22 RE: City of Pacifica General Plan Update (GPU) and Local Coastal Land Use Plan (LCLUP) and 2022 Draft
EIR for the GPU Comments
Dear Mr. Murdock, I am writing to point out specific
areas where information in the LCLUP and General
Plan Update are inconsistent and/or missing, and
need to be corrected for the public and decision
makers to understand the impacts of the Project.

1. Sensitive and Critical Habitat
• GPU Figure 7-3, Potential Environmentally Sensitive
Habitat Areas
• 2022 Draft EIR Figure 3.7-3 Sensitive and Critical
Habitat
• 2020 LCLUP Figure 4-3, California Coastal
Commission, Staff Report 2-18-21 CDP Application 2-
19-0026 In reviewing these Figures, I noticed
inconsistency and omissions with areas described in
the Figures as:

A. Potential Environmentally Sensitive Habitat Areas
(ESHA)
B. Critical Habitat: California Red-legged Frog
C. Other Sensitive Areas:

1. High Habitat Value/Threatened by Fragmentation

2.Wildlife Movement Corridor

2. Inconsistencies:

A. Neither GP Figure 7-3 nor 2022 Draft EIR Figure

3.7-3 show California Red-legged Frog listed under
Critical Habitat as shown in Figure 4-3 at Laguna
Salada (Sharp Park Golf Course) and Mori Point
(GGNRA).

The EIR used best available from State and federal
sources. Figure 3.7-3 of the DEIR uses data
established under Critical Habitat for Threatened
and Endangered Species, U.S. Fish & Wildlife
Service. This figure also shows potential
Environmentally Sensitive Habitat Areas (ESHA)
and Wildlife Movement Corridor areas. Figure 3.7-
4 of the DEIR shows where Special Status Species
habitat may be located, which shows the CRLF
habitat at Laguna Salada and parts of Mori Point,
and is not a federally-established Critical Habitat.

The DEIR contains policies to address impacts in
the event that sensitive species are discovered
during construction or pre-construction as
outlined in Master Response 6: ESHA and other
State regulations, like from the California Coastal
Commission, would apply.

C14-3 William Leon 3/3/22 B. Neither GP Figure 7-3, 2022 Draft EIR Figure 3.7-3 or Figure 4-3 show 1) Sensitive and Critical Habitat at the undeveloped field adjacent to San Pedro Avenue,
or 2) the unnamed Waterway that runs from San
Pedro Avenue and eventually connects to San Pedro
Creek. Instead, GP Figure 7-3 and 2022 Draft EIR
Figure 3.7-3 show the undeveloped field adjacent to
San Pedro Avenue designated as Urban and NonUrban Land with Little or No Habitat Value. Figure 4- 3 shows no designation of either Potential ESHA or
Critical Habitat for the undeveloped field adjacent to
San Pedro Avenue.

Figure 7-3 of the General Plan and Figure 3.7-3 of
the DEIR uses data established under Critical
Habitat for Threatened and Endangered Species,
U.S. Fish & Wildlife Service. This figure also shows
potential Environmentally Sensitive Habitat Areas
(ESHA) and Wildlife Movement Corridor areas.

Figure 3.7-4 of the DEIR shows where Special
Status Species habitat may be located, which
shows the CRLF habitat at the vacant San Pedro
site. This is not a federally-established Critical
Habitat.

C14-4 William Leon 3/3/22 3. Omission of Potential ESHA and Critical Habitat Information Possessed by the City.

Neither GP Figure 7-3 nor 2022 Draft EIR Figure 3.7-3
nor the narrative discussions within the documents
Please see Master Response 6: ESHA for more
information on how compliance with federal,
state, and local regulations, in addition to
Proposed Plan policies, reduce impacts to less than

2.f
Packet Pg. 984 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 890 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 103
Letter Commenter Date Comment Combined Response
Individuals (C)
consider the studies, statements and the decision of
the California Coastal Commission (“CCC”), which
found the undeveloped area adjacent to San Pedro
Avenue to contain ESHA and the unnamed waterway
to be considered as Waters of the United States.
significant, regardless of the final determination.

The Army Corps of Engineers has not made a final
determination of environmental significance to the
site.

C14-5 William Leon 3/3/22 Furthermore, this CCC delineation showed that the adjacent watercourse that runs along the western
edge of the undeveloped San Pedro Avenue site
constitutes areas of both federal and state wetlands,
with the state wetlands spanning the full length of
the watercourse, thus comprising the entire length of
the San Pedro Avenue property’s western boundary.

See Pages 6-12: California Coastal Commission, Staff
Report 2-18-21, CDP Application 2-19-0026:

See response for C14-4
C14-6 William Leon 3/3/22 Both the Coastal Act and the LCP, as guidance, emphasize the need to protect sensitive habitats
within the coastal zone, including wetlands and
environmentally sensitive habitat areas (ESHAs). In
communication with the City of Pacifica, Coastal
Commission staff expressed concerns going back
over a decade with regard to potential impacts of
development on the habitats located on and
adjacent to undeveloped San Pedro Avenue site,
indicating that any proposed development at the
undeveloped San Pedro Avenue Site should consider
measures to avoid or reduce potential impacts on the
adjacent unnamed watercourse, which most likely
would meet the one-parameter definition of
wetlands under the Coastal Act, and stating that a
one-parameter wetland delineation should be
conducted (see comments in Exhibit 6).

Despite the CCC recommendation to conduct a oneparameter wetland delineation at an earlier stage in the process, a delineation undeveloped San Pedro
Avenue site and adjacent drainage channel was not
prepared for this project until November 2019, after
the City of Pacifica had already approved a local CDP
for the portion of the project located in their CDP
jurisdiction. This delineation showed that the
adjacent watercourse that runs along the western
edge of the undeveloped San Pedro Avenue site
constitutes areas of both federal and state wetlands,
with the state wetlands spanning the full length of
the watercourse, thus comprising the entire length of
the western boundary, undeveloped San Pedro
Avenue site. On the northern end of the property,
the federal and state wetlands encompass an
approximately 0.096-acre arroyo willow thicket that
partially extends onto the undeveloped San Pedro
Avenue site and takes up approximately 0.048-acres
at the northern border of the(see delineation
undeveloped San Pedro Avenue site of these features
in Exhibit 5). The federal and state wetlands present
onsite include arroyo willow thicket, perennial rye
See response for C14-4

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Packet Pg. 985 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 891 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 104
Letter Commenter Date Comment Combined Response
Individuals (C)
grass fields, small-fruited bulrush marsh, smartweed
patch, the flow channel, and the wetted watercourse
channel.

During an initial assessment of the project-related
biological information, Commission staff ecologist Dr.

Lauren Garske-Garcia identified for the Applicant
that the Commission typically applies a minimum
wetland buffer of 100 feet. Examining the site-
specific circumstances associated with the property
known at that time, Dr. Garske indicated that the
minimum possible justifiable wetland buffer, if
appropriately mitigated, would be 50 feet from the
edge of the arroyo willow thicket and 25-feet from
the remainder of the state wetlands that comprise
the entire length of the drainage channel along the
property’s western edge. The Applicant submitted
revised plans in response to this feedback; however,
the revised plans did not adhere to these buffer
minimums and continued to propose development
within this already reduced buffer area.

After further research in response to the Applicant’s
updated submittals and, while Commission staff and
the Applicant were in further discussions regarding
the ESHA and wetland buffers, interested parties
provided information documenting the presence of
California red-legged frog in the watercourse area.

California red-legged frog (Rana draytonii; “CRLF”) is
a California special-status species and a federally-
listed threatened species due to loss and degradation
of habitat, predation, and human disturbance. CRLF
are known to occur in San Pedro Creek, which is
connected to the unnamed watercourse by a culvert
on the northern end of the parcel, near the arroyo
willows. As such, Dr. Garske-Garcia, along with
consulting reports that she reviewed, considered the
site in question to have moderate potential for CRLF
upland habitat and watercourse use, which extends
the full length of the property along the western
edge (see Exhibit 5). However, Dr. Garske-Garcia also
recognized the degraded state of the undeveloped
San Pedro Avenue site and adjacent watercourse as
relatively unfavorable when compared to nearby
habitats, and no published record had appeared
documenting CRLF at this location.

Subsequently, Commission staff received
documentation from multiple Pacifica residents,
including from a San Francisco State University
ecologist, in April 2020 demonstrating positive
observation of more than one CRLF, including time-
stamped photographs from various dates in April
showing as many as five CRLF at the same location at
one time (see Exhibit 9). In addition, Commission
staff received letters written by local biologist Peter

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Packet Pg. 986 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 892 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 105
Letter Commenter Date Comment Combined Response
Individuals (C)
Baye (dated May 4, 2005 and July 7, 2014) that
report ongoing observations of CRLF at the location
over a sustained period of time (see Exhibits 7 and 8).

Altogether, this evidence points to the watercourse
area adjacent to the San Pedro Avenue site as being
used by CRLF more than just a single frog passing
through, and the information provided to the City of
Pacifica and the CCC indicates that undeveloped San
Pedro Avenue site is used as CRLF aquatic and/or
dispersal habitat. While the Applicant’s consultant
argued that the location is unlikely to provide
“consistent, stable long-term habitat for [CRLF] over
time,” CRLF does not have to carry out its full life
cycle in the watercourse area itself for the area to
have ecological value for this sensitive species. Dr.

Garske-Garcia consulted with California Department
of Fish and Wildlife (CDFW) and U.S. Department of
Fish and Wildlife (USFWS) on this matter, and CDFW
confirmed that the information received by the CCC
in April was valid, including the species identification.

USFWS did not have the 2005 Peter Baye record
available digitally but indicated it was likely available in their hard files; however, USFWS staff was not
surprised by the recent observations and provided
information on recent CRLF observations from
nearby San Pedro Creek.

In short, the watercourse running adjacent to the San
Pedro Avenue site constitutes part of a larger habitat
corridor for CRLF. In addition, the watercourse
adjacent to the San Pedro Avenue site likely also
supports several other species as a habitat corridor,
as it remains green throughout the seasons and
compared to adjacent parcels, and connects to San
Pedro Creek, the shore, the Pacific Ocean, a large
open space to the west, and a major forested area.

Although there have been recent development
encroachments, the watercourse provides a
connection across the landscape capable of
supporting species including birds and small
mammals. The Coastal Commission consistently finds
this type of important and vulnerable habitat to be
an ESHA due to the rarity of the physical habitat and
its important ecosystem functions, including that of
support for sensitive species, as found in this case by Dr. Garske-Garcia. Thus, the drainage channel
adjacent to this site is considered ESHA under the
Coastal Act. In addition, per Dr. Garske-Garcia’s
advice (see Exhibit 11,Page 11), Commission staff
also concluded that the arroyo willow thicket, as well
as the small-fruited bulrush marsh both constitute
ESHA, and would recommend a buffer of 50 feet at
these locations as well. Coastal Act Section 30240
and LUP Policy 18 prohibit non-resource dependent
development within ESHA, prohibit any development
in ESHA that would significantly disrupt habitat

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Packet Pg. 987 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 893 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 106
Letter Commenter Date Comment Combined Response
Individuals (C)
values, and prohibit any development in areas
adjacent to ESHA that would significantly degrade
those ESHA areas. In addition, Coastal Act Section
30231 protects the biological productivity of coastal
streams and wetlands. According to Lief Gould, the
USFWS biologist for this region, the USFWS would
typically recommend a 300-foot dispersal corridor
around similar occupied CRLF habitat. Considering all
this and applying a 300-foot corridor (i.e., where the
area within the corridor constitutes ESHA due to its
CRLF habitat functions), Dr. Garske-Garcia
determined that the subject property is all ESHA, and
that no level of precaution could avoid the loss of
habitat with the proposed project. Even if the 300-
foot corridor were centered on the watercourse, it
would extend across and beyond the subject parcel.

In addition, Dr. Garske-Garcia believes that the 300-
foot corridor is the minimum that is acceptable for
protecting this ESHA as required by the Coastal Act
and that a reduced corridor width is not appropriate.

The undeveloped San Pedro Avenue site is in ESHA, is
development which is not a resource-dependent,
would significantly disrupt habitat values. As a result, development of undeveloped San Pedro Avenue site
was found inconsistent with Coastal Act Section
30240. In addition, and for similar reasons, the
proposed project is also inconsistent with Coastal Act
Section 30231 and 30233.

C14-7 William Leon 33/3/22 In short, the portion of the San Pedro Avenue site within the Commission’s permitting jurisdiction is all
ESHA and undevelopable for the proposed range of
uses and structures. Although some provisions in the
LCP allow for reductions to habitat buffers in the
event that the buffer renders the site undevelopable,
in this case it is the actual ESHA area that is affected by development (and not the buffer from it), and the
City has approved development in the portion of the
property that is within its jurisdiction and subject to the LCP. The CCC found that there is no location on
the part considered in undeveloped San Pedro
Avenue for development, outside of ESHA and
sufficient to protect the habitat, as required by the
Coastal Act. And, as such, there aren’t siting and
design conditions available to the Commission to
correct this Coastal Act inconsistency. Therefore, the
CCC found the proposed project inconsistent with
the Coastal Act’s sensitive habitat protection
requirements cited above, requiring project denial.

At this point however, these buffer
recommendations are moot since the entirety of the
site constitutes ESHA and are constrained regarding
allowable development because of that
determination. Considering all of the facts present, I
hereby request that the City of Pacifica correct and
See response for C14-4

2.f
Packet Pg. 988 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 894 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 107
Letter Commenter Date Comment Combined Response
Individuals (C)
update its relevant documents, in both the GPU, the
LCLUP and the 2022 Draft EIR, to accurately reflect
what is currently known about the location and
designation of places with Sensitive and Critical
Habitat and Potential Environmentally Sensitive
Habitat Areas. Especially, as it relates to the
undeveloped lands and waterway adjacent to San
Pedro Avenue in Pedro Point.

2.f
Packet Pg. 989 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 895 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 108
C15: Allison West, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C15-1 Allison West 3/8/22 I have lived in Pacifica for 19 years and over 5 in Pedro Point. The unique natural beauty, access to
the ocean, views of surrounding hills, mountains
and valleys, access to coastal and hillside trails,
along with the natural habitat seen in the Pedro
Point neighborhood, make this a special place to
live.

For decades, the issue of the land use designation of
the San Pedro Ave Field (“Field” and formerly called
the Pedro Point Field or Calson Field) has come
before the City. For over a decade the PPCA, on
behalf of the residents in this area, has made
consistent efforts to help educate the City Council,
Planning Commission, and your office about the
proposed land use designation and its detrimental
impact to our neighborhood. I am writing to state
my urgent and vehement objection to the
GPU/DEIR’s proposed new land use designation of
“Coastal Residential Mixed Use” (CRMU) for the
undeveloped Field site in the Pedro Point
neighborhood.

I also incorporate by reference each of the impacts
and concerns noted in my comment letter to you in
my role as the President of the Pedro Point
Community Association. Below are just a few of the
significant impacts and concerns:

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

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

C15-2 Allison West 3/8/22 1. Traffic/Parking/Pedestrian Risks Our neighborhood is a magnet to those who love
the beach to surf, relax, grab a coffee, burger, or
other delights as they enjoy the hiking trails and
beach. Except, our neighborhood is not equipped
right now for those who drive to Pedro Point. Our
area becomes congested with increased street
parking (all the way up to my house (across from
the cat clinic) and a substantial increase in
pedestrian traffic. We have no sidewalks; the roads
are in places uneven, and this creates more hazards
as we navigate our way around cars and the
increase in foot traffic.

The change to CRMU and any potential building in
the Field would make the traffic and parking
untenable for the residents. Adding another 100+
vehicles during the workweek would create traffic
issues of monumental proportions just to get to
Highway 1. Importantly, the issue related to the
emergency vehicles struggling to make their way on
our narrow one lane San Pedro Ave creates safety
concerns that the City has neglected to address. On
top of this, the increased traffic would also have
The comment is noted. Congestion is not a required
topic for CEQA analysis and the DEIR correctly analyzed and mitigated VMT impacts on pages 3-40 to 3-43. As
discussed in Impact 3.2-4, project level review required by the City includes site access review for emergency
vehicles and traffic control plans as needed that
account for emergency vehicles. Thus, new
development would be required to comply with
Municipal Code requirements for emergency access to
the site and LHMP and Emergency Plan
implementation will reduce impacts to the maximum
extent practicable. In addition, new development
would be subjected to policies listed under Impact 3.2- 4 as well as the existing programmatic framework to
reduce impacts of evacuation to less than significant
level. See also Master Response 7: Emergency Access
for more information about evacuation.

2.f
Packet Pg. 990 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 896 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 109
Letter Commenter Date Comment Combined Response
Individuals (C)
related air quality issues that the City has failed to
note as an impact.

C15-3 Allison West 3/8/22 2. Significant adverse aesthetic impact:

From my porch and front room, I can see the Field
which provides me, my son, and our community
with beautiful, scenic views. There is a natural flow
of seeing trees, the open space, the wildlife there,
and we enjoy seeing our neighbors walking in and
around the Field each day. We moved here because
we and those who visit us enjoy seeing the scenic
views of the surrounding hillsides and use the easy
access footpaths to get to the beach. The proposed
CRMU designation would not only ruin the aesthetic
enjoyment of the field for my family, but for our
neighbors and visitors to our community as well.

Any foreseeable development would absolutely
degrade the existing visual character of the
neighborhood.

The DEIR analyzes scenic vistas on page 3.9-14 through

3.9-22. Typically, scenic vistas would include mountain ranges, ridgelines, or bodies of water as viewed from a highway, public space, or any other area designated
for the express purpose of viewing and sightseeing.

The view from the commentator is not a scenic vista
(not along a coastal view corridor, have any prominent
ridges or prominent landforms as seen on Figure 3.9-
1).

The land use changes in the Proposed Project will not
substantially degrade the existing visual character or
quality of Pacifica and would not conflict with
applicable zoning and regulations governing scenic
views.

The DEIR also has regulations and policies that would
further reduce an already less than significant impact
on scenic vistas on pages 3.9-19 through 3.9-22.

C15-4 Allison West 3/8/22 3. Significant adverse biological impact:

Like most who live on Pedro Point or those who
come to visit here, my family has long enjoyed the
diversity of wildlife we’re able to observe in and
around the Pedro Point field. Walking the
neighborhood by the Field we can see a variety of
birds and walk by the Red Legged Frog habitat
which was confirmed by the California Department
of Fish and Wildlife (please review the California
Coastal Commission rejection of the Rhodes
project). We have seen coyotes, deer, mountain
lions and a wonderful variety of birds. All
development from the proposed CRMU designation
would irrevocably harm the wildlife, the natural
habitat, and our enjoyment of this treasured
neighborhood environmental asset.

The San Pedro site (field) is not considered to be a
federally-protected Critical Habitat. Occurrences of
red-legged frog on the site are noted in Figure 3.7-4.

Please see Master Response 6: ESHA for more
information about how compliance with federal, state,
and local regulations, in addition to Proposed Project
policies, reduce impacts to less than significant. Please also see Master Response 4: Undeveloped San Pedro
Ave Sites and Master Response 2: Programmatic EIR
for more information on how site-specific biological
study would reduce potential impacts. Please also see
response to comment C159-1.

2.f
Packet Pg. 991 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 897 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 110
Letter Commenter Date Comment Combined Response
Individuals (C)
C15-5 Allison West 3/8/22 4. Significant adverse flooding impact:

The Field is designated by the City as a tsunami
evacuation area. The Field sits at the lowest part of
Pedro Point which means it is a catch basin from the
rain runoff. My neighbors have provided pictures
showing that the field turned into a lake during the
October atmospheric river event.

As shown on Figure 3.5-1, page 3.5-3 of the DEIR, the
site is not in a FEMA identified special flood area,
however it is subject to localized floods as noted on
page 3.5-8 ‘The broadest mapped flood hazard areas
are located along San Pedro Creek, covering much of
the Linda Mar area north of the creek extending down
to the coast. A broad 0.2 percent annual chance flood
area is mapped at the confluence of the main stem
with the North Fork of the San Pedro Creek.’ Please
see also response to comment C13-3 for more
information about coastal flooding and sea level rise.

The Proposed Project would allow for mixed use
development, in event of development of the site, it
would be subject to regulations to prevent loss
life/property in the event of a tsunami. In addition to new policies, including SA-I-26, SA-G-2 SA-I-15, that
will further reduce the risk to less than significant and therefore the analysis in the DEIR is valid. See response to comment C13-9 regarding California Coastal Act
Regulations.

The comment also mentions that the field in Pedro
Point acts as a catch basin from the rain runoff. This
does not mean the development cannot take place
here. If development were to happen, the building/s
would have to follow several measures including - SA-I17, SA-I-19, SA-I-20, SA-I-22, SA-I-23, SA-I-25, SA-I-39, SA-I-40, SA-I-88, to decrease impact to a less than
significant level.

C15-6 Allison West 3/8/22 In conclusion, my family urges you to change the proposed land use designation for the Pedro Point
field from CRMU to Conservation (C) which is most
consistent with the current state of the
undeveloped property. A Conservation designation
would also address the many DEIR deficiencies
noted by the PPCA and their expert advisors and be
in compliance with CEQA and Coastal Act policies. It
would therefore be not only the most responsible
solution, but also the most expedient solution to
help move the GPU and DEIR approval process
forward.

Thank you in advance for considering our comments
and I urge you to preserve open spaces like the
Pedro Point Field, and for maintaining Pacifica’s
beautiful, natural assets to ensure our City’s future
as desirable coastal destination and a safe place for
all of us to live.

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

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

2.f
Packet Pg. 992 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 898 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 111
C16: Clifford Lawrence, 2/22/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C16-1 Clifford
Lawrence
2/22/22 Our DEIR Material Hazards does not include
reference to the Mussel Rock Landfill which
continues to present risk to nearby West Fairmont
properties in Pacifica and Daly City. By its
proximity it is a threat to all lower properties,
regardless of the municipal line. How do we justify
ignoring this obvious threat?
The Mussel Rock Transfer Station is located outside of
the City's jurisdiction. AS described in Impact 3.11-1, "Hazardous materials are regularly used, transported,
and disposed of in Pacifica.... these activities are subject to a variety of local, State and federal regulations.

Hazardous materials would be required to be
transported under DOT regulations. Future
development under the Proposed Project would be
subject to regulatory programs such as those overseen
by the Regional Water Quality Control Board and the
Department of Toxic Substances Control. San Mateo
County has substantial regulations concerning
hazardous materials under its Toxic Programs; for
example, all businesses in San Mateo County must
submit a Business Plan for the safe storage and use of
chemicals if the business handles and/or stores a
hazardous material equal to or greater than the
minimum reportable quantities. Compliance with
federal, State and local regulations, combined with
Proposed Project policies outlined below, will reduce
the potential for a significant adverse effect on the
environment, due to upset and accident involving the
use, transport, and disposal of hazardous materials, to a less than significant level.

2.f
Packet Pg. 993 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 899 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 112
C17: Deb MacC, 2/14/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C17-1 Deb MacC 2/14/22 Increasing residential use is of importance to me.

I'd like to see the GP provide for an increase in
Medium Density Residential zoning, and for
policies to immediately encourage ALL residential
building to be multi-unit. For example in a
proposed development of 10 homes, 20 percent
would have common walls, ie: duet homes,
resulting in more open space for that immediate
development and for the public generally. I do not
want to see a gated community anywhere in
Pacifica. Maybe the GP should include that
exclusion.

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

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

C17-2 Deb MacC 2/14/22 Hillside Preservation design guidelines need to include additional emergency egress routes, even
if they exist on easements limited to emergency
use, which are otherwise open, wild space,
drainage routes etc. Fire safety exit routes must
be aggressively included in hillside planning
design.

The comment is noted. As discussed in Impact 3.2-4,
project level review required by the City includes site access review for emergency vehicles and traffic
control plans as needed that account for emergency
vehicles. Thus, new development would be required to
comply with Municipal Code requirements for
emergency access to the site and LHMP and
Emergency Plan implementation will reduce impacts to
the maximum extent practicable. In addition, new
development would be subjected to policies listed
under Impact 3.2-4 as well as the existing
programmatic framework to reduce impacts of
evacuation to less than significant level. Please see
Master Response 7: Evacuation Routes for more
information regarding emergency access.

C17-3 Deb MacC 2/14/22 I'd like to see the work focused on Sharp Park be reproduced in the Park Mall area of Pacifica.

Sharp Park's plan is a good one, Let's do it again,
modified as necessary, in another underdeveloped area of our town The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

2.f
Packet Pg. 994 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 900 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 113
C18: Jim Louderback, 2/28/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C18-1 Jim
Louderback
2/28/2
2 Hi, given that the UN’s latest climate report
released today shows that sea rise is irreversible
and will inundate low lying land -
https://www.bbc.com/news/scienceenvironment-60525591
And that during a Tsunami, low-lying areas of
Pacifica are at extreme risk. This website for San
Mateo county -
https://www.conservation.ca.gov/cgs/tsunami/m
aps/san-mateo – at CA.Gov shows the hazard
areas in Pacifica, and particularly around Linda
Mar Beach.

In both situations, the field on San Pedro Avenue,
in between the Pedro Point neighborhood and
the Pedro Point Shopping Center should not have
anything built on it. I believe the plan is in error in how it treats this property. It will likely be flooded
during climate change over the next 10-20 years
and at any time with a Tsunami just slightly worse
than what we experienced on January 25th In
fact, our own city map shows that this is
extremely likely as well -
https://www.cityofpacifica.org/civicax/filebank/b
lobdload.aspx?BlobID=2499
Because of that, I would like to formally lodge a
comment to have this area excluded from any
building.

As shown on Figure 3.5-1, page 3.5-3 of the DEIR, the
site is not in a FEMA identified special flood area,
however it is subject to localized floods as noted on
page 3.5-8 ‘The broadest mapped flood hazard areas
are located along San Pedro Creek, covering much of
the Linda Mar area north of the creek extending
down to the coast. A broad 0.2 percent annual
chance flood area is mapped at the confluence of the
main stem with the North Fork of the San Pedro
Creek.’.

The Proposed Project would allow for mixed use
development, in event of development of the site, it
would be subject to regulations to prevent loss
life/property in the event of a tsunami. In addition to new policies, including SA-I-26, SA-G-2 SA-I-15, that
will further reduce the risk to less than significant
and therefore the analysis in the DEIR is valid. See
response to comment C13-9 regarding California
Coastal Act Regulations.

See response to comment C13-3 for more
information about coastal flooding and sea level rise.

2.f
Packet Pg. 995 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 901 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 114
C19: Peter Loeb, 3/5/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C19-1 Peter Loeb 3/5/22 I reviewed the Pacifica General Plan Draft Environmental Impact Report (DEIR) released on Jan.
7, 2022, State Clearing House number 2020089010.

Subsequent to that DEIR, another DEIR was released
on Feb. 1 4, 2022. This new DEIR had a new State
Clearing House number, 2012022046, but with the
same publication date of Jan. 7. I compared the 2
DEIRs and there are differences between the
documents. The newer one now has a 12-page Table
Of Contents which the previous DEIR did not have.

The text of the newer DEIR is searchable; this was not
true of the previous DEIR. There are other differences
between the 2 documents. For example, the first DEIR
had a repeated section on Wildfires and the second
DEIR eliminates that section repeat. There may be
other differences but I don’t know because I can’t
compare two thousand-page documents, especially
when the text in one is not searchable.

In my attempt to compare the 2 documents, I
discovered that the earlier version is no longer on the city of Pacifica’s Plan Pacifica web site,
https://www.planpacifica.org/project-docs. I had
previously downloaded the earlier version of the
DEIR, so it is saved on my computer.

The result is that there are now 2 DEIRs for the
Pacifica General Plan and they are different. Which
DEIR should we be commenting on? If we should be
commenting on the DEIR released on Feb. 14, then
the comment period should be restarted from that
date. If we are commenting on the first DEIR, then my
comment is that document is unusable as published
and should be revised and recirculated. Furthermore,
the first DEIR appears to no longer be available
through the city’s web site. This means that the only
DEIR that we can review and comment on is the one
released on Feb. 14 (still with a Jan. 7 publication
date). This alone seems to require a new public
comment period.

Thank you for your comment. Per public request
the comment period was extended until March 8,
2022 to allow for additional public review time.

2.f
Packet Pg. 996 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 902 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 115
C20: Andre Mettier, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C20-1 Andre
Mettler
3/8/22 Pacifica General & Sharp park Plan comments
Note: Quote from the paper are in black
My comments are in green
Questions are in red
The General Plan Must Be Internally Consistent.

This requirement means that the general plan
must fully integrate its separate parts and relate
them to each other without conflict.
“Horizontal” consistency applies both to figures
and diagrams as well as general plan text. It also
applies to data and analysis as well as policies.

The General Plan Must Be Long-Range.

I will try to point out a few inconsistencies and
follies towards that goal to encourage
reconsideration of the outlines
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-2 Andre
Mettler
3/8/22 Manor Drive Overpass! I really have a problem
with this one!
Quote: The Manor Drive overcrossing is planned to
be widened and coordinated signal control is
recommended to be added at the intersections of
Manor Drive with Oceana Boulevard and Palmetto
Avenue. This project includes a new on-ramp to SR
1 from Oceana at Milagra Drive. Table 5-6 And
here the projections for the project showing
NEGATIVE IMPROVEMENTS AFTER COMPLITION!!…
Quote Page 115 The intersections of Manor Drive
and Oceana Boulevard, and West Manor Drive and
Palmetto Avenue, and Paloma Avenue and Oceana
Boulevard may need to be modified in terms of
traffic control (traffic signalization), efficiency
(widening of the overcrossing to provide shoulders
and flaring curb returns without changing the
existing number of lanes), and Highway 1 access
(adding the Milagra Drive on-ramp). The City’s
planned improvements to the two intersections as
well as the overcrossing and Milagra Drive onramp as part of the Manor Drive overcrossing project will allow traffic to flow through the area in
a much better manner, by remaining on the
intended streets and reducing the diversion to side
streets and neighborhoods.

HELLO? Table 5-6 shows that the situation is
getting worse after the “improvements” but on
page 115 it says the traffic will flow much better..

Maybe someone can explain why we would go
through years of agony and huge expenses just to
arrive in a worse situation because I think it is a
costly stupid mistake to take on such a project but
The comment is noted. Congestion is not a required
topic of analysis under CEQA. However, the comment
addresses the content of the Proposed Plan and will be
shared with decision-makers in that context. Please see Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

2.f
Packet Pg. 997 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 903 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 116
Letter Commenter Date Comment Combined Response
Individuals (C)
maybe you can clarify a few questions.. · How long
will the project take? 2-3 years and totally destroy
the passage for that time?
· Since no lanes will be added how will the traffic
flow be improved?
· Signaling appears to be the answer, but the
bridge will still only hold 4-5 cars max if either end
is on red. Since we quite often have at least 20 or
more cars on Palmetto lined up going south to
make a left turn and sub sequentially quite a few
another left on Oceana to go north both lights
would have to be on green at the same time to
clear the bridge otherwise only 4 cars will make it
through the light IF the bridge is clear. Now if the
bus that is going east on the bridge trying to make
a right turn into Oceana he won’t be able to do
that because the light for the northbound Oceana
traffic is necessarily on red and the turning radius
does not allow the bus to turn till the fist or first 2 cars north bound have cleared that area which the
bus driver can indicate to the drivers to do now.

But with a red light in their way they will refuse to
do that since they are afraid of traffic fines which
this paper also encourages in order to support the
stated objectives. This is just one other problem
for just this scenario. Please keep in mind that now
all other flows on Manor, Palmetto and Oceana are
shut down. After the light change the people
picking their kids up at Ingrid Lacy school who
want to go up to Fairmont are in the same
situation having a need for clean passage, In the
meantime everyone else on Manor going east or
west and Oceana is waiting. I’d like to see an
engineering flow chart for the two intersection for
pm traffic. PLEASE. I believe in this case human to
human interaction is more productive than AI
imposed traffic rules & orders · Who is going to be
served by the new entrance to SR1 the Milagra
Drive onramp? How much traffic will be eliminated
on Manor?
C20-3 Andre
Mettler
3/8/22 Bicycles
Bicycle paths/trails, bicycle storage, bicycle
parking, bicycle safety and priority for bicycles
sounds all very good and healthy and progressive.

But who pays for it and what is the real benefit to
the whole community In a world of unlimited
resources anything can get paid for, but if we
already have instituted all kind of extra fees and
special tax assessments just to provide basic
services to operate like the fire department,
shouldn’t we ask how all this gets paid for and
what all of us get out of it except feeling good
when we vote for it?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

2.f
Packet Pg. 998 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 904 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 117
Letter Commenter Date Comment Combined Response
Individuals (C)
Is there anywhere a cost benefit analysis available.

C20-4 Andre
Mettler
3/8/22 CI-I-65 Parking Enforcement. Continue to make
parking enforcement a priority at public visitor
parking areas.

Since they have a hunch that their plans might
have some problems, they have to be enforced at
additional expenses
Are those tickets really the best 1000s of ways to
promote a cool and friendly city by the ocean?
Because that’s what it would take just to carry the
expense of a control officer..

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

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

C20-5 Andre
Mettler
3/8/22 Public Traffic
In fact, only 14 percent of Pacifica’s employed
residents work locally. Page 105 Only about 1.5
percent of trips beginning or ending in Pacifica are
made using public transportation
CI-G-17 Improved Public Transit. Advocate for
SamTrans and other public transit providers to
improve transit service and facilities, to enable
trips to be made without use of a car. In particular,
advocate for the expansion of public transit
services and facilities to improve public access and
recreation opportunities along the coast. Reality
versus wishful thinking!
Could you please ask these consultants to come to
Pacifica from their place of business in Sacramento
with public transit for the next meeting at city hall
and tell us all in person why they would advocate
for such hair brained ideas?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-6 Andre
Mettler
3/8/22 Conclusion
Hiring the same urban planners for millions of $$
that have destroyed the historic and individual
character of other small cities as an alibi of “doing
something” is a grotesque and counterproductive
top down, one template fits all approach!
Monetizing “ a problem” does not necessarily solve
it, just makes it lucrative for a few.

What we are looking at is a typical, non
enthusiastic, bureaucratic and unimaginative
approach to a government imposed decree that
will stifle local and individual life in its core. The
study is presented by some principals hiring some
just out of school graduates to fill in an industry
produced template to fulfill an imposed
requirement to the detriment of us all I think we
should sue the planners for shoddy work and the
state agencies for imposing the requirement to
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

2.f
Packet Pg. 999 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 905 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 118
Letter Commenter Date Comment Combined Response
Individuals (C)
produce it and asking them to pay for the plans
themselves, present us with the options and let us
vote to see if we want to accept it! Amen
C20-7 Andre
Mettler
3/8/22 Sharp Park Specific Plan is a sham too; please see following pages for easy to notice inconsistencies
in the plan.

We like our quaint little neighborhood with
relatively easy beach parking. <> The alternatives
presented in SPSP demand another suburban mall
with overregulated parking, and congestion for
which we have to go in eternal debt to make it
possible and pay off . More money for the city
along with more expenses with a net zero benefit
financially BUT at huge environmental and social
costs for the community! = Another bridge to
nowhere messing up the scenery!
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-8 Andre
Mettler
3/8/22 LAND USE & HOUSING
What’s planned and what we are supposed to get
vs what we like! And this is what it looks like when
they say Ensure development honors the area’s
character, history, and coastal locale.
— Promote development of housing in mixed-use
settings, which accommodates residents of all
incomes, family types, and life stages. (page15)
Nobody would mistake that as a place in Tracy
since it has soooo much P-Town character?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-9 Andre
Mettler
3/8/22 The Sharp Park Specific Plan emphasizes a peoplescaled approach to development which will translate into a walkable, friendly, safe, and
appealing pedestrian realm. How did they get here
and where did they (the visitors and residents
living on the 5th floor penthouse) park if they are
allowed to come in with a car? Remember there
will not be any parking access from Palmetto only
on the side streets. What all the most popular,
quaint “downtown” areas with character have in
common is that they are low rise (max. 2 stories)
like in Bolinas, Burlingame, San Mateo ,etc. with a
variety of building styles <> NOT 4 or 5 story
monsters built to the property line trying to
suggest open space by having big window fronts as
demanded, looking like Santana Row So this this is
more what we like and want!
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-10 Andre
Mettler
3/8/22 3-G-12 Housing Opportunity. Support
development of a diverse range of housing
opportunities suitable for people of all incomes,
abilities, and stages of life. By charging
Development impact fees, Park In-Lieu Fee
(Quimby), Sharp Park Specific Plan Parking In-Lieu
fee up to $40,260 per space? <> That will make it
more affordable for all incomes? Really
This comment is noted. The comment does not relate
to the adequacy of the DEIR, thus no further response
is required.

C20-11 Andre
Mettler
3/8/22 MOBILITY & PARKING
Did they explain how an arterial like Palmetto with
2 bus routes will work/co-exist as a pedestrian
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of

2.f
Packet Pg. 1000 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 906 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 119
Letter Commenter Date Comment Combined Response
Individuals (C)
zone?
General plan
-Arterials In Pacifica, arterials are classified as
roadways that are wider, accommodate higher
volumes of traffic, (4.1-Page 51) The main arterials
in the Sharp Park Specific Plan Area include
Palmetto Avenue, Oceana Boulevard, and Paloma
Avenue to the west of Highway 1.
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-12 Andre
Mettler
3/8/22 Parking?
Page72 The in-lieu fee, if approved for a
development project, would allow a waiver of offstreet parking requirements for an individual development and require payment of a per-space
fee (initially adopted at $40,260 per space and
indexed to increase annually) that would allow the
City to provide centralized off-street parking
facilities. Centralized parking facilities are another
strategy to “right size” parking and to achieve
other planning goals such as minimizing the
number of curb cuts along pedestrian
thoroughfares.

Could anybody point me to the suggested location
of the “centralized” parking facility please?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-13 Andre
Mettler
3/8/22 Figure 4-8:

Existing Parking, shows current weekday parking
mostly AND weekend parking full around the pier!
BUT the report concludes that as of 2021,
Pacifica’s current parking standards result in an
oversupply of parking relative to demand in Sharp
Park. The high cost of parking construction and
maintenance drives up the cost of housing and
reduces the supply of affordable housing. To
balance these parking issues, “right sizing,” or
converting the parking provisions to a more
appropriate or optimum level, helps to strike a
supply-to demand balance.

And again how many more million $ will they need
tell us exactly what right sizing means. And where
we put it!
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-14 Andre
Mettler
3/8/22 Table 4-4 Retail; Eating and Drinking
Establishments:

Three parking spaces for each 1,000 square feet of
gross leasable space. That will fill up about 3 tables
at a restaurant; all the other patrons are
encouraged to use the bicycle Is a hot date in biker
shorts on a cold, foggy July evening gonna be the
new thing or will the UBER driver have to use the
arterial roadway through the pedestrian zone to
drop guests off in a more conventional attire?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-15 Andre
Mettler
3/8/22 4-I-20 On-Street Parking Supply Management.

Manage on-street parking supply with an ongoing
strategy to generally have 15 percent of on-street
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of

2.f
Packet Pg. 1001 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 907 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 120
Letter Commenter Date Comment Combined Response
Individuals (C)
spaces available for short-term parking to meet
needs of commercial patrons. When parking
availability falls below this threshold, consider first limiting free parking periods, then implementing
paid parking, and then pursuing other parking
supply management strategies, including addition
of public lots or structures. Figure 4-8 shows we
are already at 85% or above?! Where are the
additional lots again? Also, we need to hire 1-2
parking control officers, NO?
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-16 Andre
Mettler
3/8/22 2212 Beach Boulevard Uses.

Prioritize full-service hotel use at the 2212 Beach
Boulevard site. For any non-hotel project,
emphasize land uses that are of interest to visitors
and generate revenues for the City.

And all these visitors are getting there to the
attraction by taking Paloma Ave to the beach? The
Paloma Ave that is dedicated to get bicycle and
pedestrian improvements? Oh, Maybe Clarendon?
Uuups, that is another bicycle and pedestrian
heaven we cannot pollute with cars AND one way
the wrong way.

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

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

C20-17 Andre
Mettler
3/8/22 Page 143 …to the extent that bicycle and
pedestrian improvements reduce the need for
parking in the Specific Sharp Park Specific Plan
Area, it would be appropriate to spend fee
revenue on bicycle and pedestrian infrastructure
improvements. But then we hear that This new
residential development, when it occurs, as well as
new development elsewhere in the city, will
contribute to park impact fee revenue. If the
envisioned development does not materialize as
expected, associated impact fee revenue may not
be received by the City.

Do they take into consideration that
pedestrian/bicycles are commonly short distance
transportation <> trying to attract out of town
(car) business? So the whole concept that
pedestrian improvements reduce the need for
parking is just another assumption/wishful thinking
without any basis/foot notes. They pile one wishful
thought on top of the other into a circular, absurd
compilation to prove their assumptions possible.

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

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

C20-18 Andre
Mettler
3/8/22 Promote the addition of curb bulb-outs at street corners and midblock crossings to calm traffic,
plant street trees, and heighten pedestrian
visibility and comfort. And who will maintain/pay
for these doggie toilets?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C20-19 Andre
Mettler
3/8/22 Page 137 – figure 7-12 shows a map of the outline of the storm flood & flood prone zone as well as
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the

2.f
Packet Pg. 1002 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 908 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 121
Letter Commenter Date Comment Combined Response
Individuals (C)
the envisioned coastal erosion by 2100, 80 years
from now – Right smack overlapping the Sharp
Park Development. And what is the solution
according to the paper?
These maps are not a substitute for site-specific
erosion analyses but do show important
information necessary to make general planninglevel decisions about the vulnerability of portions of the Sharp Park Specific Plan Area.

How many more millions do they want to tell us
that a billion $ sea wall will be the solution in order not only just build our future under water
financially but actually and that we can fund it
with… Development impact fees Park In-Lieu Fee
(Quimby) Sharp Park Specific Plan Parking In-Lieu
fee up to $40,260 per space, Or maybe a special
lien/assessment on each lot in town for a million
$$ Sounds like a great way to bankrupt the whole
city when we get sued down the road because we
encouraged someone to build there and are
therefore liable for the losses. Can we get flood
insurance? How much per year? What have we
learned from Esplanade Ave?
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

2.f
Packet Pg. 1003 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 909 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 122
C21: Gary Emich, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C21-1 Gary Emich 3/8/22 It's encouraging to see that after more than 40 years the Pacifica General Plan is being updated. Thank you
for overseeing this effort.

Below are my comments regarding the draft Pacifica
General Plan.

Preface
The purpose of the following comments, related
specifically to the Pedro Point Basin also known as the Pedro Point Field (PPF), is to:
1) Document the numerous sections throughout the
Pacifica General Plan Update (PGPU) that are
contradictory and do not adhere to Section 1.2,
General Plan Requirements, that stipulate: "the
general plan must fully integrate its separate parts
and relate them to each other without conflict"
(underline added). Refer to Part A - Sections Not
Integrated / Conflicting within the PGPU (below).

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

Please see Master Response 1: EIR Comments for
more information about GP- or SPSP-related
responses. Please also see Master Response 4:

Undeveloped San Pedro Ave Sites.

C21-2 Gary Emich 3/8/22 2) Highlight the sections of the PGPU that repeatedly and consistently underscore the inappropriateness
and unsuitability of the proposed PPF Coastal
Residential Mixed Use designation based on factors of
tourism, critical habitat, liquefaction and flooding.

Refer to Part B - Factors Documenting the
Inappropriateness and Unsuitability of the PPF as
Coastal Residential Mixed Use (below).
3) Demonstrate, based on the PGPU's Land Use
definitions and descriptions, that the PPF should be
designated as either Visitor-Serving Commercial or
Low-Intensity Visitor Serving which is in keeping with
the California Coastal Commission's original March
24, 1980 certification of the PPF as Commercial
Recreation (see Background section immediately
following). Refer to Part C - Arguments for
Designating the PPF as Visitor-Serving Commercial or
Low-Intensity Visitor Serving (below).

Please see Master Response: San Pedro Avenue
Site, which addresses how CRMU is a compatible
land use with Coastal Act policies, and how
compliance with federal and state regulations, as
well as policies in the Proposed Project, reduce
impacts to sensitive species (see also Master
Response 6: ESHA), liquefaction, and flooding risks
to less than significant levels.

C21-3 Gary Emich 3/8/22 Background As reflected in the "Pedro Point Basin" section of the Pedro Point Community Association's
(PPCA) webpage (www.pedropoint.org/the-pedropoint-field), on March 24, 1980, the California Coastal Commission certified the PPF in the existing Local
Coastal Land Use Plan as Commercial Recreation (low
density, visitor-serving, commercially-viable
recreational uses). The Coastal Commission further
stated: "The designated land use for this area is
commercial with emphasis on coastal related and/or
visitor-serving uses... this small, ocean side
commercial center could be rejuvenated and
expanded to become an attractive visitor destination,
as well as provide for neighborhood retail needs.

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

2.f
Packet Pg. 1004 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 910 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 123
Letter Commenter Date Comment Combined Response
Individuals (C)
throughout the commercial development would
complement the existing attractive design elements in
the Pedro Point area. Adequate public access through
the development to the shoreline and a general
orientation to coastal related/visitor-serving uses
within the project would be appropriate in this
location. Given these criteria, commercial use of this
portion of the neighborhood is consistent with
the....policies of the Coastal Act." Also, as reflected in the "Pedro Point Basin" section of the PPCA webpage,
Pedro Point residents historically, repeatedly and
consistently have voiced their opinion and sentiments
pertaining to zoning changes and developments in the
PPF, e.g.
* 1995 Pedro Point Community Plan wherein
residents registered strong support for preserving a
major portion of the PPF in some form of open space,
* 2011 Letter "In Opposition to the Proposed Land
Use Designation Change" wherein the PPCA rejected
Pacifica's Draft General Plan Use (GPU) proposed land
use designation change, and recommended that it
adopt Commercial-Recreational , the designation
most similar to the existing land use.
* 2011 Letter "In Support of Commercial-Recreational
Use" wherein the PPCA voted for the PPF to retain its
current zoning of Commercial-Recreational which is
intended for land use that would remain in a primarily
undeveloped state but would allow for limited
commercial establishments supporting recre3eational
uses.
* In 2014, the PPCA unanimously voted to pool their
resources to hire experts and an attorney citing
deficiencies in the City's draft GPU and draft
Environmental Impact Report. The proposed land use
change did not pass; and the approved land use
designation remained Commercial- Recreational.

C21-4 Gary Emich 3/8/22 Part A - Sections Not Integrated / Conflicting within the PGPU
1) PGPU - page 2-5 and page 4-24
The photo in the lower right hand corner (showing
Pedro Point) on page 2-5 is captioned: "With its scenic setting along Highway 1, south of San Francisco,
Pacifica has potential for more tourismbased retail."
The photo on page 4-24 (depicting the residential
homes on Pedro Point sitting above Pacifica State
Beach) is captioned:
"The scenic Pedro Point neighborhood overlooks
Pacifica State Beach." Both photos and captions
create visions of a Pedro Point that lures tourists to a "visitor-serving, commercially-viable, recreational
use" destination and are inconsistent with the
proposed Coastal Residential Mixed Use designation.

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

2.f
Packet Pg. 1005 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 911 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 124
Letter Commenter Date Comment Combined Response
Individuals (C)
C21-5 Gary Emich 3/8/22 2) PGPU- page 2-7
"Tourist-oriented retail districts often succeed by
providing a unique mix of small-scale "boutique"
stores that offer arts, craft and other goods or
services with a distinctive local flavor....Pacifica could potentially focus on beach/coastal-related businesses,
drawing on its very name to help establish a strong
identity" (underline added).

This section likewise argues for maintaining the PPF's
original land use designation of CommercialRecreational (visitor-serving, commercially-viable, recreational uses) and, again, is inconsistent with the proposed Coastal Residential Mixed Use designation.
3) PGPU - Section 2.5 - Economic Development
Strategy - page 2-11
The first Guiding Policy under this section is ES-G-1,
Leverage Assets (page 2-12): "Leverage Pacifica's
coastal location...focusing on increasing tourism
facilities, including shops...and hiking trails."
Implementing Policies, ES-I-4, Increase Tourism (page
2-13): 1)" focus on attracting ...a visitor's center or other key attraction, tourism-based shopping...and 2)
"brand" and market Pacifica's parks, open spaces,
beaches and other natural amenities."
Implementing Policies, ES-I-34, Expanded Commercial
Recreation (page 2-17): "develop low-intensity
outdoor commercial recreation uses on sites near
Pacifica State Beach" (underline added)."
Implementing Policies, ES-I-35, Preserve the
Experience of the Natural Environment (page 2-17):
"ensure that new development projects do not
disrupt view corridors ..or otherwise interfere with
residents' and visitors' experience."
Implementing Policies, ES-I-36, Appropriate Site
Design (page 2-7): "ensure development projects
adjacent to protected natural areas are designed to
minimize impacts on those areas by employing low
impact development techniques." (As discussed later,
the waters along the south and east perimeters of the
PPF are home to a number of California Red-Legged
frogs.)
Thus far, all Implementing Policies of the PGPU noted
above support maintaining and arguing for the
retention of the PPF as a "visitor-serving,
commercially-viable, recreational uses" area and run
counter to any possible argument in support of new
residential units as the proposed Coastal Residential
Mixed Use designation would permit.

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

2.f
Packet Pg. 1006 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 912 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 125
Letter Commenter Date Comment Combined Response
Individuals (C)
the PPF as a "visitor-serving, commercially-viable,
recreational use area," Figure 4-3, Land Use Diagram
(page 4-6), abruptly departs with a non sequitur by
listing the PPF as Coastal Residential Mixed Use
instead of the more appropriate Visitor-Serving
Commercial. Visitor-Serving Commercial (page 4-9) is
defined as "intending to foster and protect areas that
attract and cater to visitors, including...a visitor
attraction such as an interpretive center or
conference center..retail and services, commercial
recreation or other compatible uses. Whereas,
Coastal Residential Mixed Use (page 4-8) is defined as
....mixed-use with housing and retail and/or smallscale visitor-oriented commercial uses such as retail, vacation rental and time-share units...Sites may be
developed up to an overall density of up to 15 units
per gross acre (which in the case of PPF would be up
to 75 units).

This conflicts with and is not integrated with the
numerous other sections of the PGPU that advocate
and encourage development of areas such as the PPF
as visitor-serving areas.

C21-6 Gary Emich 3/8/22 4) PGPU - Section 6.2-Trail System - page 6-17 and Section 6.3 - Coastal Access - page 6-25
With the acquisition of the Colt Property, the PGPU
states (page 6-17): "it should be possible to construct a trail west of Highway 1 to extend the Coastal Trail
from its current terminus [at Ace Hardware]
southward through the Pedro Point Headlands to
connect with the Devil's Slide Trail."
Implementing Policies, OC-I-38 New Development
and Coastal Access (page 6-26): "Require that new
development along the coastline provide public
access from the nearest public roadway to the
shoreline and along the coast, and be designed to
minimize impacts to public coastal access and
recreation.

Ensure that impacts are mitigated through the
dedication of access or trail easements or the
provision of improvements to other public access
points."
Implementing Policies, OC-I-41, Impediments to
Public Access (page 6-26): "Prohibit restrictions on
public parking that would adversely affect public
access to beaches, trails, or other recreational lands
along coast."
As anyone who has attempted to find parking at
either the north or south end of the San Mateo
County's Devil's Slide Trail knows parking is at a
premium. Currently, there is only parking space for 15
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

2.f
Packet Pg. 1007 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 913 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 126
Letter Commenter Date Comment Combined Response
Individuals (C)
vehicles immediately north of Ace Hardware that
allow for access to the Headlands; they are always
filled. And, the entire east side of San Pedro Avenue
across from Grocery Outlet is marked as "No Parking."
This existing situation is not in alignment with these
two Implementing Policies.

C21-7 Gary Emich 3/8/22 Section 3.3 Hillside and Coastal Development (page 3- 10), calls for: "the protection and enhancement of the
coastal environment, including its visual resources. As shown in Figure 4-8, Land Use, Pacifica /Southwest
(page 2-23), there are three "visual resources" on
Pedro Point. They are the old railroad berm north of
the PPF (site #25), at the Shelter Cove overlook (site
#26) and on the Pedro Point Trail in the headlands
(site #27).

Finally from page 4-27 regarding the PPF: "Future
development should include a small park and access
to the berm and the beach beyond. Completion of the
Devils Slide Tunnel project has provided the
opportunity to create a new trailhead and trails
through open space land on the headlands."
With authorization to build up to 75 residential units
on the PPF under the proposed Coastal Residential
Mixed Use designation, it is highly unlikely the two
Implementing Policies could be actuated, that the
three "visual resources" could be enhanced or that a
small park could be created with access to the berm
and the beach beyond. Designation of the PPF as
Visitor-Serving Commercial or Low-Intensity Visitor
Serving could ensure "dedication of access or trail
easements" (including but not limited to additional
trailhead parking for the Pedro Point Headlands
section of the Coastal Trail) as well as creation of a
"visitor attraction such as an interpretive center" and allow for the enhancement of the three "visual
resources."
Please see Master Response 4: Undeveloped San
Pedro Avenue Sites for more information about
development on this site.

C21-8 Gary Emich 3/8/22 Part B - Factors Documenting the Inappropriateness and Unsuitability of the PPF as Coastal Residential
Mixed Use
1) Tourism
As demonstrated above, developing PPF as a
residential site is inappropriate; and it conflicts with the PGPU, Section 1.4 Plan Themes and Key Initiatives
(pages 1-12 and 1-13) which calls for: "Creating a
Destination for Tourism..Throughout the update
process, community members and stakeholders
emphasized the need for more economic activity.

There is a widely shared sense that Pacifica has the
potential to attract more tourists, and that this should be a key component of the City’s economic
development strategy. The Plan includes strategies to
enhance tourism by leveraging Pacifica’s natural
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

2.f
Packet Pg. 1008 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 914 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 127
Letter Commenter Date Comment Combined Response
Individuals (C)
assets, creating more attractive places in visitororiented districts [and] marketing.

C21-9 Gary Emich 3/8/22 2) Critical Habitat
Figure 7-3, Sensitive and Critical Habitat (page 7-19)
showing California Red-legged Frog habitat
egregiously and erroneously does not designate the
PPF as sensitive habitat. There is a significant
population of California Red-legged frogs living in the waterway that begins at the intersection of Grand
Avenue and San Pedro Avenue and flows along the
eastern perimeter of the PPF. Guiding Policies, CO-G7: Wildlife and Critical Habitat (page 7-25) mandates:
"Conserv[ing] and protect[ing] indigenous,
threatened, endangered, and other special status
species by preserving critical habitat. Habitat can be
protected by allowing very limited or no
development, by identifying habitat areas as top
priorities for permanent conservation, and by
managing public land to ensure species protection
(underline added).

Permitting up to 75 residential units on the PPF is a
far cry from "allowing very limited or no
development" and is completely contrary to the cited
Guiding Policy above.

Critical habitat is an official designation made by the CDFW. The CDFW has not determined the PPF to be
an area of critical habitat as of the publication of
this DEIR. Please see Master Response 4:

Undeveloped San Pedro Ave Sites for more
information on policies that further limit
development through zoning, as well as additional
required biological study. Please also see Master
Response 6: ESHA.

C21-
10 Gary Emich 3/8/22 3) Liquefaction
Figure 8-1, Seismic Hazard Zones (page 8-4) shows a
very significant part of the PPF in a liquefaction zone.

As stated on page 8-5: "Medium liquefaction
potential exists in many low-lying neighborhoods,
including...parts of Pedro Point." And Figure 8-2,
Liquefaction Potential Zones (page 8-6) actually
classifies parts of the PPF at a very high risk of
liquefaction. And despite Implementing Policy, SA-I-2
(page 8-11) which clearly states: "Prohibit
development in areas of...high or very high
liquefaction risk, the PGPU ignores this policy in its
proposed designation of the PPF as Coastal
Residential Mixed Use. Simple common sense
questions the feasibility and sensibility of building
residential units in a liquefaction zone.

The comment is noted. The DEIR includes a robust
analysis of potential liquefaction impacts p. 3.6-25
and 3.6-26, noting "The impacts from ground
failure, including liquefaction, from development of
land uses associated with the General Plan would
be addressed through site-specific geotechnical
studies prepared in accordance with CBC
requirements and standard industry practices.

Subsequent development would be required to
conform to the current seismic design provisions of
the CBC to minimize losses from ground failure as a
result of an earthquake. These future projects
would also be required to adhere to proposed
General Plan policies that contain seismic safety
requirements and help strengthen existing code
requirements such as referencing known hazard
areas that must contain measures to resist ground
failure through modern construction techniques.

Therefore, the potential impact related to
seismically related ground-failure including
liquefaction is less than significant."
The undeveloped San Pedro Avenue site is in a
Seismic Hazard Zone, as shown in Figure 3.6 The
DEIR notes that on p. 3.6-18 and 3.6-19,
"Geotechnical investigations conducted within
Seismic Hazard Zones must incorporate standards
specified by the California Geologic Society (CGS)
Special Publication 117, Guidelines for Evaluating
and Mitigating Seismic Hazards". Policies addressing
use of maps include Policy SA-I-1: "Fault Zone. New

2.f
Packet Pg. 1009 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 915 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 128
Letter Commenter Date Comment Combined Response
Individuals (C)
development shall be sited and designed to
minimize risks from seismic events. Buildings for
human occupancy shall avoid surface traces of
active faults, consistent with the Alquist-Priolo
Earthquake Fault Zone Act and other relevant state
laws. (See the Seismic Hazards map, Figure 8-1). "
C21-
11 Gary Emich 3/8/22 4) Flooding
Figure 8-4, Flood Zones (page 8-15) designates the
entire PPF as a Tsunami Evacuation Area.

Implementing Policy, SA-I-26 Tsunami Evacuation
Zone (page 8-18) states: "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." Suffice it to question whether
a tsunami evacuation area is conducive or suitable for
building new residential dwellings.

As shown on Figure 3.5-1, page 3.5-3 of the DEIR,
the site is not in a FEMA identified special flood
area, however it is subject to localized floods as
noted on page 3.5-8 ‘The broadest mapped flood
hazard areas are located along San Pedro Creek,
covering much of the Linda Mar area north of the
creek extending down to the coast. A broad 0.2
percent annual chance flood area is mapped at the
confluence of the main stem with the North Fork of
the San Pedro Creek.’.

The Proposed Project would allow for mixed use
development, in event of development of the site, it
would be subject to regulations to prevent loss
life/property in the event of a tsunami. In addition
to new policies, including SA-I-26, SA-G-2 SA-I-15,
that will further reduce the risk to less than
significant and therefore the analysis in the DEIR is
valid. See response to comment C13-9 regarding
California Coastal Act Regulations.

C21-
12 Gary Emich 3/8/22 Part C - Arguments for Designating the PPF as VisitorServing Commercial or Low-Intensity Visitor Serving The current Pedro Point residential area (excluding
the PPF and Shelter Cover), consists of about 250
single family residences and sits on approximately 55
acres (or fewer than 5 homes per acre). Most homes
have a partial, if not full, view of the Pacific Ocean and Pacifica State Beach. For decades, the open-space PPF
has been utilized by residents for recreation, as an
impromptu dog park and for passage to Pacific State
Beach as well as to the Coastal Trail.

As proposed, the designation of the PPF as Coastal
Residential Mixed Use would allow up to 75
residences to be constructed. This would increase the
total number of homes on Pedro Point by over 25% ,
all squeezed together in an area less than 10% the
size of the entire rest of the community. Such a highdensity infusion of homes in this relatively small parcel of land is completely out of character with the
rest of the Pedro Point Community.

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

C21-
13 Gary Emich 3/8/22 PGPU - Section 4.2 - Land Use Framework page 4-8:
"[the designation of Coastal Residential Mixed Use]:
"is intended for sites...with housing and retail, and/or small scale visitor-oriented commercial uses such as
retail, vacation rental, or time-share units. Residential uses are allowed in the same building as commercial
Please see Chapter 3.9 for more information on
impacts to visual resources. As described on DEIR p.

2.f
Packet Pg. 1010 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 916 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 129
Letter Commenter Date Comment Combined Response
Individuals (C)
uses above the ground floor [vertical mixed-use]."
Vertical mixed-use structures, including potential for
a large number of vacation rental and time-share
units, fundamentally would change the existing core
character of Pedro Point from one of single family
residences to one of a much higher density apartment
/ condo nature. And, if allowed, it would violate the
previously cited Implementing Policy, ES-I-35, which
states: "ensure that new development projects do not
disrupt view corridors...or otherwise interfere with
residents' and visitors' experience." Figure 4-8 (page
4-23) clearly depicts the view looking north from the
PPF as a "View Corridor." Allowing vertical mixed-use
structures in the PPF would effectively obstruct,
either partially or totally, the view of the ocean and
Pacifica State Beach for nearly half the residents on
Grand and Livingston Avenues and for a good number
of those on Sterling and Stanley Avenues.

Reinforcing the Coastal Commission's original 1980
vision for this parcel of land:
"The designated land use for this area is commercial
with emphasis on coastal related and/or visitorserving
uses... this small, ocean side commercial center could
be rejuvenated and expanded to become an
attractive visitor destination, as well as provide for
neighborhood retail needs. Small scale, rustic design
and ample landscaping throughout the commercial
development would complement the existing
attractive design elements in the Pedro Point area.

Adequate public access through the development to
the shoreline and a general orientation to coastal
related/visitor-serving uses within the project would
be appropriate in this location. Given these criteria,
commercial use of this portion of the neighborhood is
consistent with the....policies of the Coastal Act."
This description aptly describes a blend of the PGPU's
Visitor-Serving Commercial and Low-Intensity VisitorServing Commercial designation, both descriptions found on page 4-9. Visitor-Serving Commercial: [this]
designation is intended to foster and protect areas
that attract and cater to visitors, including...a visitor attraction, such as an interpretive
center...commercial recreation, or other compatible
uses. Low-Intensity Visitor-Serving Commercial: [this]
designation allows uses that create public access to
the coastal setting and are adaptable to changing
environmental conditions: ...concession stands,
warming huts, outdoor event sites and similar
uses....the long-term goal of transition to recreationoriented land uses." ensure there is no substantial adverse effect on
scenic vistas...The land use changes in the Proposed
Project will not substantially degrade the existing
visual character or quality of Pacifica and would not
conflict with applicable zoning and regulations
governing scenic views. All existing open space
areas are preserved and scenic resources are
protected under the Proposed Project. Policies,
zoning designations and design guidelines included
in the Proposed Project will sensitively govern the
formal characteristics of new development to
ensure they are compatible with existing
neighborhood character and quality The Coastal Act
requires scenic and visual qualities of coastal areas
to be considered and protected as a resource of
public importance.

The DEIR also has regulations and policies that
would further reduce an already less than
significant impact on scenic vistas on pages 3.9-19
through 3.9-22.

C21-
14 Gary Emich 3/8/22 Conclusion The PGPU's proposed designation of the PPF as Coastal Residential Mixed Use:

Habitat, liquefaction, and flooding are adequately
addressed in the DEIR. Please see response to

2.f
Packet Pg. 1011 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 917 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 130
Letter Commenter Date Comment Combined Response
Individuals (C)
* Is inconsistent with and contradicts other sections
of the PGPU that recommend different utilizations of
properties such as the PPF,
* Ignores the decades long sentiment of Pedro Point
residents who repeatedly have resisted changing the
land use designation from the original vision
articulated by the Coastal Commission,
* Does not acknowledge the inappropriateness and
unsuitability of this parcel as residential mixed use
based on factors of tourism, critical habitat,
liquefaction and flooding, and
* Would forever change the very fiber and unique
characteristic of Pedro Point.

I strongly recommend the draft PGPU land use
designation for the PPF is changed to either VisitorServing Commercial or Low-Intensity Visitor Serving in the final PGPU. Thank you for the opportunity to
share my comments
comment C21-10 for more information on
liquefaction impacts and coastal flooding. Please
Master Response 4: Undeveloped San Pedro
Avenue Sites, for more information about required
project-level analysis on the site, including for
biological resources.

2.f
Packet Pg. 1012 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 918 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 131
C22: Dinah Verby, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C22-1 Dinah
Verby
3/8/22 These are my comments on the General Plan (GP)
Update and associated Draft Environmental Impact
Report (DEIR). (I apologize for the helter-skelter
organization, but I worked on different parts over
time, and did the best I could to piece it together.)
Since I haven’t had time to review the complete
documents in depth, my comments primarily focus on
the Land Use, Open Space and Conservation Elements
of the GP and the Biological Resources section of the
DEIR, particularly as they relate to the Pacifica Quarry, which is located in the Coastal Zone.

I. General Comments:
• As others have commented, there are numerous
mis-labeled Guiding and Implementing Policies in the
DEIR. Many policies identified as mitigation for
impacts in Table ES-3 and elsewhere do not match the
correspondingly numbered policies in the GP. (Please
refer to comment and Excel spreadsheet from Pete
Shoemaker showing the many mislabeling errors.)
Since so many citations in the DEIR are inaccurate, the impact analysis is unreliable and it cannot be
determined whether the impacts are truly mitigated.

Please update and correct the DEIR so that it
accurately tracks the GP and recirculate the DEIR.

The comment is noted. Policies in the executive
summary will be noted in errata, however, policies
are listed in full in each of the Impacts chapters, so
analysis remains adequate and does not change any
findings of significance.

C22-2 Dinah
Verby
3/8/22 • The color-coded maps in the GP and DEIR are
difficult to interpret (especially the land use maps).

Many shades of colors are so close to each other that
one can’t determine what the true land use
designation is. For example, in GP Figure 4-7 (GP page
4-20) the color for “Conservation” is nearly
indistinguishable from that for “Open
Space/Agriculture/Residential.” The accompanying
text in the GP is often vague and does not describe the land areas with sufficient specificity. In other
instances, the text conflicts with the maps. (See “Map
Errors” below) Since the maps seem to be the primary
tool for guiding land use decisions, they should be as
precise and accurate as possible. Suggestion: Is it
possible to use another method such as assessor
parcel nos. and maps to identify the proper
designations?
Map edits will be made for clarity; they do not
change any findings of significance in the DEIR. Maps
are shown at the appropriate level for a
programmatic document; site-specific analysis would
occur on a project-level basis.

C22-3 Dinah
Verby
3/8/22 Map Errors: There are apparent errors in the following maps in the GP and DEIR.

Figure 3.7-4 in DEIR: Special Status Species: The map
legend does not match the map markings with regard
to California Red-legged Frog (CRLF) Habitat. These
areas are marked with red diagonal lines on the map,
whereas the legend uses a red and white dotted
pattern (which doesn’t appear anywhere on the map
that I can find). Please correct the legend so that it
corresponds with the diagonal markings on the map.

The comment is noted; the map legend will be
revised. This map change clarification does not affect
findings of significance.

2.f
Packet Pg. 1013 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 919 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 132
Letter Commenter Date Comment Combined Response
Individuals (C)
C22-4 Dinah
Verby
3/8/22 Figure 6-1: Parks and Open Space System (GP Page 6- 3)/DEIR Figure 3.12-2:

Rockaway Quarry: The GP at page 6-11 states that
portions of the Quarry are designated in Figure 6-1 as
“Partial Conservation with Development,” where
conservation areas should be determined based on
habitat needs and site conditions. However, Figure 6-1
contains no such designation. The Quarry uplands and
Calera Creek are shown as “Other Protected Open
Space,” while the remaining parts of the Quarry have
no discernable color code. The same error exists in the corresponding Figure 3.12-2 in the DEIR. Oddstad Park:

GP Page 6-3, Figure 6-1 (Figure 3.12-2 in DEIR)
indicates that District, Neighborhood and Pocket Parks
should be dark green. However, Oddstad Park is
shown as greenish-yellow. Please correct this so that it is solid dark green.

Cattle Hill & Pedro Point Headlands: Shows GGNRA as
the owner of the city-owned Cattle Hill property and
the Pedro Point Headlands (PPH). PPH is owned by the
City of Pacifica and the State of California (California Coastal Conservancy). It is uncertain whether GGNRA
will take title to either of these areas. Proposed
Changes: Delete “GGNRA” under Pedro Point
Headlands. Separate the cityowned Cattle Hill
property from GGNRA property on Sweeney Ridge.

These changes should be made on this and other maps
throughout the GP and DEIR, including: GP Figure 6-2
Trail System (GP page 6-16/DEIR Figure 3.12-3); GP
Figure 6-3 Coastal Access Trail (GP page 6-21); GP
Figure 6-4 Schools and Community Facilities (GP page
6-28/DEIR Figure 3.12-1) See also maps in the Land
Use, Conservation elements and many others that I
don’t have time to list.

Map edits will be made for clarity; they do not
change any findings of significance in the DEIR.

C22-5 Dinah
Verby
3/8/22 Figure 6-2 Trail System (GP Page 6-16/DEIR Figure

3.12-3):

Pedro Point Headlands: Shows "Pedro Point Trail” as a
proposed trail or trail improvement. The restoration
efforts of the Pacifica Land Trust Stewards have
completed the trails as mapped. Please mark the trails
as “Existing Trails.” Also, the completed Devil's Slide Trail should be shown as an "Existing Trail” rather than a proposed trail.

The comment is noted; the map text will be revised.

This map change clarification does not affect findings
of significance.

C22-6 Dinah
Verby
3/8/22 Figure 7-3 Sensitive and Critical Habitat (GP Page

7.19/DEIR Figure 3.7-3):

These maps fail to show the entire habitat of the
California Red-legged Frog (CRLF). Habitats in the
Coastal Zone such as Mori Point, the Quarry, and
Pedro Point are omitted. Additional habitats are
shown in DEIR Figure 3.7-4, page 3.7-24 and should be
included in Figure 7-3.

Official critical habitat is designated by the US Fish
and Wildlife Service. The locations this commenter
mentions are shown in DEIR p. 3.7-4, which shows
special status species occurrences.

2.f
Packet Pg. 1014 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 920 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 133
Letter Commenter Date Comment Combined Response
Individuals (C)
C22-7 Dinah
Verby
3/8/22 Typos:

GP Page 1-14: under “Non-Residential Development
and Employment” heading: “7,6310 jobs” should be
7,310 jobs.

GP Page 4-30 Table 4-3: There is a citation to footnote 4 which does not exist. Footnotes 1 and 2 do not
correspond to this table, and appear to belong with
Table 4-2.

GP Page 6-5, Table 6-1, footnote 4: “at 202
population” should presumably be “at 2020.”
GP Page 6-11, right column: “Harmony@1” is now
known as “Ohlone Point.”
The comment is noted. The text changes are
incorporated in the General Plan errata. They do not
relate to adequacy of DEIR analysis.

C22-8 Dinah
Verby
3/8/22 DEIR Page 3.7-18, Table 3.7-3: “Pacific” Ocean
misspelled. Under SOURCE: “Pacifica” misspelled.

DEIR Page 3.7-50: footnotes out of order and not
properly numbered.

DEIR Page 3.7-57: first full paragraph starting with
“Additionally” duplicates most of previous paragraph.

This comment is noted. The following edits are made
for clarity:

DEIR p. 3.7-18, Figure 3.7-3:The comment is noted;
the map text will be revised. (There is no Table 3.7-3) DEIR Page 3.7-50: The footnotes will be renumbered.

DEIR Page 3.7-57: "Additionally, if development or
any land use changes are to occur in or around a
river, stream, or lake then the project proponent
would be required at a minimum, to submit a
Notification of Lake or Streambed Alteration to
CDFW. Through consultation with CDFW, a Lake or
Streambed Alteration Agreement as per the
California Fish and Game Code Section 1600-1616
would be required. Typically, no new grading or
development at any site is allowed within 20 feet of
the edge of riparian vegetation or top of bank,
whichever is further from the creek centerline, as
delineated by a qualified, City-approved biologist."
These edits do not change any findings of
significance.

C22-9 Dinah
Verby
3/8/22 Hillside Preservation District:

I support the addition of new parcels to HPD, as shown
on Figure 4-4 (GP Page 4-12). I oppose the removal of
the Quarry flatlands from HPD, because this area is a
Potential Environmentally Sensitive Area as shown in
Figure 3.7-3 of the DEIR. It is therefore unsuitable for development and should be designated
“Conservation,” as explained below. Furthermore, it is
difficult to tell whether Figure 4-4 accurately lists all of the existing HPD parcels. Please carefully compare
Figure 4- 4 to the Zoning Maps to make sure that all
HPD lands are included.

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

2.f
Packet Pg. 1015 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 921 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 134
Letter Commenter Date Comment Combined Response
Individuals (C)
C22-
10 Dinah
Verby
3/8/22 Create New Overlay Districts in Hazard Areas: I haven’t had the time to delve into the Safety Element in detail, but I will generally comment that the data and maps
regarding hazards such as fire, landslides, sea level rise and flooding are out of date and do not accurately
reflect current conditions. As a result, the DEIR
impacts analysis cannot be relied upon, since the
actual risks from these hazards is not disclosed in the GP. I understand that it is possible to create overlay
designations in the GP to mitigate against these
hazards and to protect valuable biological resources.

Examples are prohibiting new subdivisions, limiting
development to one unit per legal lot of record, and
requiring development to be transferred where
possible through mechanisms such as a Vehicle Miles
Traveled (VMT) exchange program and an updated
Transfer of Development Rights (TDR) program for
areas with inadequate evacuation routes and
hazardous conditions. Please update the GP to include
such overlay designations and also update the data to
reflect current conditions.

Risks of hazards are adequately described in the
DEIR, and the mapping uses the best and latest
available data to characterize hazards.

The DEIR characterizes wildfire hazards within the
Planning Area on pages 3.11-4 through 3.11-6 and

3.14-1 through 3.14-4, making use of data and
information from CALFIRE and from the MultiJurisdictional Local Hazard Mitigation Plan (MJLHMP) for San Mateo County. The characterization in the DEIR includes a description of vegetation in the
Planning Area, a history of wildfire occurrence in the
Planning Area, the probability of a fire occurring in
the future, and identification of Fire Hazard Severity
Zones designated by CALFIRE based on factors such
as fuel, slope, and weather. The data and information
referenced in the DEIR, including the data used to
prepare the above referenced maps, was the latest
and most current available at the time the NOP was
released and remains the most current available as of
publication of this FEIR. Please see Master Response
5: Wildfire for more information.

The most up-to-date mapping is represented in
Figure 3.6-1. The Landslide Zone data was released
by the Department of Conservation in 2021, the
authoritative source for mapping Zones of Required
Investigation. As noted in the map methodology, "As
a part of the geologic data compilation, an inventory
of existing landslides in the San Francisco South
Quadrangle, San Mateo County was prepared by
analysis of shaded relief maps (various illumination
directions) and contour data, limited field
reconnaissance, and a review of previously published
(Harding-Lawson, 1983; Bonilla, 1988; Jacobs
Associates, 1999; Brabb and others, 2000;
Wentworth and others, 1998) and unpublished
geologic-landslide mapping. Landslides were
reviewed using the lidar shaded-relief map (USGS,
2005), Google Earth Pro DigitalGlobe and Historical
Imagery, and stereo-paired aerial photos. For each
landslide included on the map several characteristics
(attributes) were collected and compiled in a
geodatabase. These characteristics include recency
of activity, type, thickness, associated geologic
unit(s), and the confidence of interpretation
(definite, probable, or questionable). The completed
landslide map was digitized, and the attributes were
entered into a database. Landslides rated as definite
or probable were carried into the landslide zone..."
Background information using some of the latest
widely accepted scientific research on climate change
and sea level rise, including recent (2013) work from
the Coastal and Ocean Working Group of the

2.f
Packet Pg. 1016 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 922 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 135
Letter Commenter Date Comment Combined Response
Individuals (C)
California Climate Action Team (CO-CAT), was
incorporated into the Draft EIR analysis as provided
on pages 3.5-9 and 3.5-10. In 2018, the City of
Pacifica prepared a Sea Level Rise Vulnerability
Assessment using the best available science.

Consistent with the San Mateo County Vulnerability
Assessment, existing and future coastal flooding was
evaluated using the Our Coast, Our Future (OCOF;
produced by US Geological Survey) mapping
products, while future coastal erosion was evaluated
using the Pacific Institute (PI) erosion maps. The
Vulnerability Assessment projected sea level rise
scenarios ranging from 1-2 feet by 2050, and 3-6 feet
by 2100. The 6 feet projection is an extreme scenario
in which sea levels rise at a rate about 30-40 times
faster than the rate experienced in the 20th century.

Rising sea levels have occurred over the last century
and are expected to continue over the coming
century, likely at a rate that exceeds the rates
experienced thus far. Modeling has provided
estimates of potential increases in sea levels but as
stated on page 3.5-31 of the Draft EIR, predictions
become less reliable as you go further into the
future. In addition, different modeling efforts have
been conducted to reflect various possible outcomes
resulting in a range of estimates for the amounts of
sea level rise that could be experienced, largely due
to the difficulty in determining a more defined
predictive value.

Flooding. Flood mapping utilizes the latest and best
available data from FEMA.

C22-
11 Dinah
Verby
3/8/22 Consider Designation of a proposed Greenbelt
(Multiple benefit resilience buffer): For vacant parcels with hazards and/or valuable biological resources that
would constrain development, utilize a VMT exchange
program or Purchase/Transfer of Development rights
program to generate funding to purchase
undeveloped properties from willing sellers within the
Greenbelt area at the edge of the community.

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

C22-
12 Dinah
Verby
3/8/22 II. Rockaway Quarry (aka Pacifica Quarry):

The proposed land use designation of Visitor-Serving
Commercial in the parts of the Quarry known as the
Flatlands and the Pit or Pad is inconsistent with the
fact that these areas have been identified as Potential Environmentally Sensitive Habitat Areas (ESHA), as
shown in Figures 7-3 of the GP and 3-7.3 in the DEIR. It is also internally inconsistent with many Guiding and
Implementing Policies articulated in the GP update for
protection of such areas. The level and intensity of
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

2.f
Packet Pg. 1017 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 923 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 136
Letter Commenter Date Comment Combined Response
Individuals (C)
development contemplated in the Preferred Plan is
incompatible with Coastal Act policies and seems
unlikely to be approved by the Coastal Commission.

C22-
13 Dinah
Verby
3/8/22 It appears in many instances that the GP and DEIR are relying on old, outdated data with regard to the
biological assessments. Furthermore, analysis of the
biological impacts is improperly deferred with a
general statement that “any development of the
Quarry site will require detailed evaluation of
biological resources to ensure that sensitive habitat
and wetlands are protected.” (GP Page 4-22) Other
than an oblique acknowledgement at GP Page 4-22
that the development footprint “could be smaller than
the area designated” due to the existence of “sensitive habitat and wetlands,” there is no analysis of welldocumented current conditions and biological resources, such as the existence of seasonal and
emergent wetlands in the Flatlands and Pit sections of
the Quarry, which are habitat for threatened and
endangered species such as the San Francisco Garter
Snake (SFGS) and the California Red-Legged Frog
(CRLF).

The General Plan and DEIR make use of best available
evidence from reputable federal and State
governmental sources at the time of publishing.

Project-specific analysis does not represent a
deferral; please see Master Response 2:

Programmatic EIR for more information on
requirements of program-level EIRs.

C22-
14 Dinah
Verby
3/8/22 Furthermore, the DEIR improperly fails to analyze the impacts of the pending Quarry Reclamation Plan
submitted in 2020 and revised on February 14, 2022.
(A separate DEIR for the Reclamation Plan is presently
circulating for public comment.) While the existence of the Reclamation Plan is mentioned at Page 3.15-1 of
the DEIR, there is no cumulative impacts analysis of
this known, anticipated development. Of special note
is the fact that the Reclamation Plan proposes to
create mitigation wetlands and a CRLF mitigation pond
in the middle of the Quarry Flatlands – the very area
designated “Visitor-Serving Commercial.” The
Reclamation Plan also contemplates creation of a
Conservation Easement over some portion of the
Flatlands, which would preclude any development in
that area.

This comment raises two issues: plan consistency,
and cumulative impacts. The Quarry Reclamation
Plan does not include the development of any
buildings or change in use of the Quarry site. Any
future development on the Quarry site will require
an application to the City of Pacifica and a public
review process. The end result of the Quarry
Reclamation Plan is a safe site that is suitable for
reuse in accordance with City of Pacifica land use
regulations. The General Plan is the guiding
document, and proposes a Visitor-Serving
Commercial designation on the Quarry site. A land
use designation is implemented through more
specific zoning. While the Visitor Serving land uses
applies broadly to the area, zoning implementation
could provide different standards to the subsection
of this area. Thus, analysis of the Draft DEIR is valid and adequate.

Regarding cumulative impacts: A cumulative impact
would occur if there was a greater amount of
development resulting than what was anticipated in
the General Plan or in the DEIR's cumulative analysis.

As stated previously, the Quarry Reclamation Plan
does not include development of any buildings or
change in use of the Quarry site. Thus, there is no
additional cumulative impact not analyzed under the
DEIR.

C22-
15 Dinah
Verby
3/8/22 Based on all the above considerations, the appropriate designation for the entire Quarry and Flatlands area is “Conservation.” It would be a substantial waste of City time, money and resources to pursue a strong
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with

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Packet Pg. 924 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 137
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Individuals (C)
commercial center in the Quarry. Accordingly, the City
should strongly consider adopting some form of
Alternative 2 identified in the DEIR, which involves the greatest amount of conservation and the least amount
of development in the Quarry.

More specific comments are detailed below, with
references to the Plan documents.
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

C22-
16 Dinah
Verby
3/8/22 Wetlands Missing or outdated data; deferred analysis Policy CO-I-4 in the Conservation Element of the
General Plan (GP) “prohibits new development in
existing wetlands except as allowed under the federal
Clean Water Act and the California Coastal Act.”1
Figure 3.7-2 of the DEIR contains a National Wetlands
Inventory Map dated 2021, but footnote 10 notes that
“many smaller wetlands do not appear on the map”
and subsequent projects may be subject to “sitespecific wetland delineations that identify the location and extent of federal, state and locally jurisdictional wetlands and other waters.”2 One area where
wetlands are not shown is the Rockaway Quarry,
located in the Coastal Zone where seasonal wetlands
have served as habitat for threatened and endangered
species including the San Francisco Garter Snake
(SFGS) and the California Red-Legged Frog (CRLF). The
existence of the wetlands along Calera Creek as well as in other parts of the Quarry, including a drainage ditch immediately west of Highway 1, was acknowledged in
the 2013 FEIR for the CalTrans State Route 1/Calera
Park Highway widening project (which ultimately was
not built). Refer especially to the U.S. Fish & Wildlife Service’s Biological Opinion No. 81420-2009-F-1328
which confirmed these areas to be habitat for the
SFGS and CRLF.

More recent wetlands & habitat studies were done by
the current owner of the Quarry and are on file with
the City as part of the Rockaway Quarry Reclamation
Plan (as revised on Feb. 14, 2022), for which a Draft
EIR is currently circulating for public comment. Figure 4 of the Reclamation Plan depicts “Wetlands
Potentially Subject to Corps Jurisdiction” which exist
throughout the Flatlands. Here is a link to those
documents:
https://www.cityofpacifica.org/depts/planning/propos
ed_pacifica_quarry_reclamation_pr oject.asp
The DEIR uses the best available evidence from
credible government sources, such as the National
Wetlands Inventory and the U.S. Fish & Wildlife
Services, at the appropriate scale of a Programmatic
EIR for a General Plan. Quarry wetlands delineations
were released after the Impacts to specific sites
would be analyzed as part of a Project EIR. Please see
response to comment C22-13 for more information
on how specific zoning and project-level analysis
would be required. Please see also response to
comment A2-3 for more information about Proposed
Project policies that reduce the impact.

C22-
17 Dinah
Verby
3/8/22 Missing Cumulative Impacts Analysis
Other than a couple of acknowledgements in the GP
that the Quarry needs reclamation work, I can find no
analysis of the actual pending Reclamation plan, which
proposes filling the wetlands west of the creek and
creating new mitigation wetlands in the middle of the
Quarry flats, as well as a conservation easement.

Though not yet approved, it is an anticipated project
that is not analyzed in the GP or DEIR (at least not in Please see Master Response 2: Programmatic EIR.

Please see response to comment C22-14.

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Individuals (C)
what I’ve read so far). Absent this analysis, there is no factual basis for the DEIR’s conclusion that the
Project’s impacts are less than significant.

C22-
18 Dinah
Verby
3/8/22 Special Status Species and Potential ESHA
GP Figure 7-3 in the Conservation Element3 and DEIR
Figure 3-7.3 entitled “Sensitive and Critical Habitat,”4 show that the entire Quarry – including the Flatlands
and the area known as the Pit or Pad, are “Potential
Environmentally Sensitive Habitat Areas” (Potential
ESHA) that should be protected from development
under GP Conservation Policies CO-G-7 and CO-G-11.5
GP Land Use Policy LU-G-7 additionally provides for
protection of critical wildlife habitat and special status species.6
Missing or outdated data DEIR Figure 3.7-4 entitled
“Special Status Species” shows the federallythreatened California Red-Legged Frog (CRLF) to be extant in the Quarry Flatlands.7 Furthermore, the DEIR
states that the endangered San Francisco Garter Snake
(SFGS) “…are presently known to occur…in the Pacifica
Quarry,” citing a 2005 study by Swaim Biological
Consulting. 8 A more recent study by Swaim concluded
that the entire Quarry including the Flatlands was
habitat for the CRLF and that no developable footprint
could be identified under Coastal Commission rules.

See “STATUS OF THE SAN FRANCISCO GARTER SNAKE
(THAMNOPHIS SIRTALIS TETRATAENIA) AT PACIFICA
QUARRY, SAN MATEO, CALIFORNIA” Revised Feb. 27,
2007 by Swaim Biological, Inc.] (copy attached).

The Swaim report is quoted extensively in more recent
studies in the pending Quarry Reclamation Plan on file
with the City, which are not mentioned in the GP or
DEIR. That work, if approved, would place wetlands
and a CRLF mitigation pond in the middle of the
Quarry flatlands, which would presumably preclude
most if not all development in that area. Contrast the
above-noted conservation policies with GP Figure 4-3
“Land Use Diagram,” which shows the Quarry flatlands
and Quarry Pit/Pad as Visitor-Serving Commercial.9
The Quarry Reclamation Plan was published after
release of the NOP; thus, the DEIR used the best
available public information at the time. The
Reclamation Plan DEIR includes potential significant
impats as well as mitigation measures, but does not
conclude that development would not be able to
occur, as the commenter suggests. This represents a
difference of expert opinion, which is allowed under
CEQA.

While the Quarry Reclamation Plan is a projectspecific plan, the Proposed Project is programmatic and includes an appropriate level of analysis. Please
see Master Response 2: Programmatic EIR. As a
programmatic document, this EIR presents a citywide
assessment of the potential impacts of the proposed
Pacifica General Plan. It does not assess projectspecific impacts of potential future projects under the proposed Plan, all of which are required to
comply with CEQA as applicable.

3.7-3 and Figure 3.7-4 indicate that there are
potential Environmentally Sensitive Areas (ESHAs)
within the Quarry site. Any development proposed
on the Quarry site would be required to comply with
federal, state, and local regulations, in addition to
the policies described in response to comment As-16.

C22-
19 Dinah
Verby
3/8/22 Inconsistency
GP Fig. 4-7 ‘Pacifica, Central” shows the same.10
Similarly, the Land Use Element describes the Quarry
as Pacifica’s “most prominent potential development
site” and designates the Flats and Pad for hotels,
visitor attractions and retail uses. The Economic
Sustainability Element contains similar statements.

Table 4-3 in the Land Use Element entitled “NonResidential Buildout Under the General Plan” projects 448,400 sq. ft. of new development in the Quarry,
which is more than 78% of all the projected VisitorServing Commercial development citywide.11 Further, Policy CD-I-1 of the Community Design
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses.

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Packet Pg. 926 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 139
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Individuals (C)
Element states: “Rockaway Beach will be the visitororiented center. Its charming coastal character will be strengthened by new development and the district will
be extended with a connective street pattern onto the
flat portion of the Quarry site. It may gain a new,
defining feature such as a destination hotel or
conference center.”12 Continuing with that theme,
Policy CI-I-6 of the Circulation Element provides for
new streets in the Quarry.13
C22-
20 Dinah
Verby
3/8/22 Deferred Analysis
Policy LU-I-25 of the Land Use Element is to “enable
the responsible development and environmental
conservation of the Quarry site.”14 It goes on to say
that “any development of the Quarry site will require
detailed evaluation of biological resources to ensure
that sensitive habitat and wetlands are protected; as a result, the footprint of development could be smaller
than the area designated.”15 Again, while noting that
reclamation work must occur, there is no analysis of
the impacts of the actual Reclamation Plan. Instead,
analysis of the biological resources is deferred to the time of a future development, which means that the
amount of allowable development in the Quarry
remains unknown. This in turn means that there is no
basis for the DEIR’s conclusion that the Project impacts are less than significant.

Please see Master Response 2: Programmatic EIR.

The Reclamation Plan does not propose a land use;
please also see response to C22-14.

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Packet Pg. 1021 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 927 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 140
C23: Therese Langille, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C23-1 Therese
Langille
3/9/22 I am writing to express my opposition to the GPU update and DEIR’s proposed land use designation
change of the undeveloped field along San Pedro
Avenue in Pedro Point. I request that you do NOT
change the land use designation to Coastal
Residential Mixed Use (CRMU). My reasonings are
numerous, but here are some of the most important:

This field is in a flood plain, as evidenced by the many photographs presented to you. Rain waters flood
down from the Pedro Point Headlands on to San
Pedro Avenue and on to the undeveloped field. This
field will eventually be underwater from projected
sea level rise. There is strong scientific evidence that supports this fact. Homes should NOT be built below
sea level. Just look at the home along that East Coast
that are constantly flooded at high tides.

The field supports crucial wildlife habitat for so many species. On our daily neighborhood walks, we see
great heron and red tailed hawks resting in the trees
and catching their prey on the field. We see snakes,
red-legged frogs and other species in their native
habitat. Where will they go if there is no open space
for them? Pacifica must be a good steward of its
ecology and environment. Like it or not, Pedro Point
has become a free parking area for surfers. Adding
construction and homes to the field along San Pedro
Avenue will NOT stop the surfers/visitors from
coming, but will just impede vehicular and pedestrian
traffic even further for the residents of the area.

The comment is noted. Land use designation
changes and vehicular congestion are not required
topics in the DEIR analysis, thus, no further
comment is required.

As shown on Figure 3.5-1, page 3.5-3 of the DEIR,
the site is not in a FEMA identified special flood
area, however it is subject to localized floods as
noted on page 3.5-8 ‘The broadest mapped flood
hazard areas are located along San Pedro Creek,
covering much of the Linda Mar area north of the
creek extending down to the coast. A broad 0.2
percent annual chance flood area is mapped at the
confluence of the main stem with the North Fork of
the San Pedro Creek.

The Proposed Project would allow for mixed use
development, in event of development of the site, it
would be subject to regulations to prevent loss
life/property in the event of a tsunami. In addition
to new policies, including SA-I-26, SA-G-2 SA-I-15,
that will further reduce the risk to less than
significant and therefore the analysis in the DEIR is
valid. See response to comment C13-9 regarding
California Coastal Act Regulations. Please also see
response to comment C13-3 for more information
about sea level rise.

The comment also mentions that the field in Pedro
Point acts as a floodplain. This does not mean the
development cannot take place here. If
development were to happen, the building/s would
have to follow several measures including - SA-I-17,
SA-I-19, SA-I-20, SA-I-22, SA-I-23, SA-I-25, SA-I-39,
SA-I-40, SA-I-88, to decrease impact to a less than
significant level.

Please see Master Response 6: ESHA for more
information about how regulations and policies
reduce impacts to less than significant, and Master
Response 4: Undeveloped San Pedro Ave Sites for
more information about Coastal Act consistency
and project-level requirements.

C23-2 Therese
Langille
3/9/22 Pacificans have been accused of burying our heads in the sand for our denial of climate change in the press
lately. We can do better! There are other great
opportunities to utilize the undeveloped Pedro Point
field that can be a win-win for everyone involved.

The easiest solution to address these issues is to
change the land use designation for the Pedro Point
field to one that is closest to it's current state, which is Low-Intensity Visitor-Serving Commercial (LIVC).

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

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Packet Pg. 928 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 141
C24: Joanne Gold, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C24-1 Joanne Gold 3/9/22 My husband, Ed Gold, and I are 23 year residents of the Pedro Point neighborhood and are writing to
submit comments on City of Pacifica General Plan
Update (GPU) and 2022 Draft Environmental Impact
Report (DEIR). As active and involved members of
the community, we’re very pleased that the
Planning Commission and City Council are
committed to updating the General Plan as guiding
document for Pacifica’s vibrant future. Thank you
for your efforts.

However, we’re writing to state our strongest
possible objection to the GPU/DEIR’s proposed new
land use designation of “Coastal Residential Mixed
Use” (CRMU) for the undeveloped San Pedro
Avenue site in the Pedro Point neighborhood. We
have gone on record many times over more than a
decade to cite our personal objections to a CRMU –
or any residential land use designation – for this
property (known locally as the “Pedro Point field”).

We have also personally supported the Pedro Point
Community Association (PPCA) - both as donors and
as community organizers - to help submit
comments objecting to this designation from legal
and environmental experts. Therefore our
comments in this letter incorporate by reference
the 2022 DEIR/GPU comment letters prepared by
the PPCA, and those prepared on behalf of the PPCA
which were submitted separately by CEQA
consultant Richard Grassetti, attorney Brian
Gaffney, and Coastal Ecologist Dr. Peter Baye. These
experts have provided specific details of how a
proposed change of the existing land use of the
Pedro Point field to CRMU is reasonably likely to
cause direct and indirect significant adverse impacts
and would conflict with CEQA and Coastal Act
policy.

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

C24-2 Joanne Gold 3/9/22 For us personally, there are many reasons a CRMU designation for the Pedro Point field would cause
significant and direct negative impacts – here are
just a few:

1. Significant adverse aesthetic impact:

Our home directly overlooks the Pedro Point field
which provides us with beautiful, scenic views
we’ve enjoyed every single day for the past 23
years. From our windows we can also see scores of
our neighbors walking in and around the field each
day. Like us, they all enjoy the grassy open space to
observe wildlife, exercise pets (and kids), take in
scenic views of the surrounding hillsides, and use
long-worn footpaths to get to the adjacent Linda
Mar Beach. The proposed CRMU designation would
not only ruin the aesthetic enjoyment of the field
Please see Chapter 3.9 for more information on
impacts to visual resources. As described on DEIR p.

3.9-13, "While the Proposed Project eliminates the
existing single height limit in the city with height
limits that vary by zone, future development will be
subject to regulation and review mechanisms to
ensure there is no substantial adverse effect on
scenic vistas...The land use changes in the Proposed
Project will not substantially degrade the existing
visual character or quality of Pacifica and would not
conflict with applicable zoning and regulations
governing scenic views.

All existing open space areas are preserved and
scenic resources are protected under the Proposed
Project. Policies, zoning designations and design

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Letter Commenter Date Comment Combined Response
Individuals (C)
for my husband and I, but for our neighbors and
visitors to our community as well. Any foreseeable
development would certainly degrade the existing
visual character of the neighborhood.

2. Significant adverse biological impact:

Like most who live on Pedro Point or those who
come to visit here, our family has long enjoyed the
diversity of wildlife we’re able to observe in and
around the Pedro Point field. From California Redlegged Frogs (CLRF), to San Francisco Garter Snakes, to deer and coyotes, and a myriad of nesting and
foraging birds - over the years we’ve encountered a
veritable guidebook of native wildlife species (and
have gone on record to document endangered
species observed with the California Coastal
Commission, such as CLRF). Foreseeable
development from the proposed CRMU designation
would irrevocably harm the wildlife, the natural
habitat, and our enjoyment of this treasured
neighborhood environmental asset.

3. Adverse Parking/Traffic Conditions & Pedestrian
Safety Hazards:

We love to walk and ride bikes in and around our
neighborhood. But the increased street parking and
vehicular traffic along San Pedro Avenue in the past
several years has made these outings more and
more hazardous. Reasonably foreseeable
development under the proposed CRMU
designation would literally choke our streets,
making this main thoroughfare un-navigable, and
present significant adverse hazards for both
emergency access and pedestrians (there are no
sidewalks!). The increased traffic would also have
related air quality and greenhouse gas emission
impacts.
guidelines included in the Proposed Project will
sensitively govern the formal characteristics of new
development to ensure they are compatible with
existing neighborhood character and quality .The
Coastal Act requires scenic and visual qualities of
coastal areas to be considered and protected as a
resource of public importance.

The DEIR also has regulations and policies that
would further reduce an already less than
significant impact on scenic vistas on pages 3.9-19
through 3.9-22. There are no alleged deficiencies
with the EIR analysis as the EIR used best available
from State and federal sources.

Figure 3.7-3 of the DEIR uses data established under
Critical Habitat for Threatened and Endangered
Species, U.S. Fish & Wildlife Service. This figure also shows potential Environmentally Sensitive Habitat
Areas (ESHA) and Wildlife Movement Corridor
areas. Figure 3.7-4 of the DEIR shows where Special
Status Species habitat may be located, which shows
the CRLF habitat at Laguna Salada and parts of Mori
Point, and is not a federally-established Critical
Habitat.

Parking and congestion are not significant impacts
under CEQA.

C24-3 Joanne Gold 3/9/22 Lastly, in reviewing the GPU Land Use map (section 4-6, p. 67) we note that it appears the one main
property in the entire City of Pacifica being
proposed for the new CRMU designation is the
privately-owned, undeveloped San Pedro Avenue
field. It seems as if this property and its landowner
have been singled out for special treatment. The
GPU should be a guiding document for the
development and policy making decisions of the
entire community, not just for the benefit of a
single landowner.

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

C24-4 Joanne Gold 3/9/22 In conclusion, we urge you to change the proposed land use designation for the Pedro Point field from
CRMU to Conservation (C) which is most consistent
with the current state of the undeveloped property.

A Conservation designation would also address DEIR
deficiencies noted by the PPCA and their expert
advisors, and be in compliance with CEQA and
Please see reference to Master Response on
Emergency Access and respond to the comments on
traffic, such as noting VMT was studied.

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Packet Pg. 930 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 143
Letter Commenter Date Comment Combined Response
Individuals (C)
Coastal Act policies. It would therefore be not only
the most responsible solution, but also the most
expedient solution to help move the GPU and DEIR
approval process forward. Thank you in advance for
making the smart decision to preserve open spaces
like the Pedro Point field, and for valuing Pacifica’s
natural assets as a way to ensure our city’s future as
a vibrant and desirable coastal destination.

2.f
Packet Pg. 1025 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 931 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 144
C25: Gary Furlong, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C25-1 Gary Furlong 3/7/22 I am writing to you in regards to my objection to the General Plan Update and Draft Environmental Impact
Report's proposed land use designation change of the
undeveloped field in Pedro Point from Commercial
Recreation to Coastal Residential Mixed Use. My name
is Gary Furlong and I have lived on Pedro Point for
almost 22 years. My husband, David Costa, has lived
here for about 37 years. We have seen dramatic
change to the Pedro Point neighborhood; most of it
good. I object to what is being proposed for this
neighborhood primarily for four reasons:
(1) It will damage and completely change the nature of
the Pedro Point neighborhood.
(2) It will be dangerous for this neighborhood and the
city will bear the responsibility for that.
(3) It will be environmentally unsound and foolish.
(4) The owner of the field bought the property
knowing its designation and I resent a land use
designation change, that the neighbors object to,
simply to enrich someone who bought property based
on changing its nature.

1. Pedro Point is a real neighborhood in the best sense of those words. People know each other, socialize
together and look out for each other. We have
potlucks, parties and communal events together. To
add a staggering number of new homes, while
removing a green space, will change the basic nature
of the neighborhood. I walk almost daily throughout
Pedro Point and my walks certainly take me around
the field, which serves as a communal area for
socializing, as it has done for decades now. I have
greatly enjoyed my chance encounters with various
wildlife as I walk by the field (including what appeared to a heron that was a bit lost, as it was standing in the field!). Over the many years of its use by the
neighborhood, it has become the unofficial heart of
the neighborhood for catching up on the local news
and visiting with friends, as well as for people walking their dogs and children learning to ride bikes. It should be obvious that reasonably foreseeable development
allowed by the proposed new land use designation of
the General Plan Update will ruin my enjoyment of
this established neighborhood character.

2. There is one road into our neighborhood; just one
road. When I moved here there was only limited
beach traffic, especially since at that point, San Pedro Road didn't serve as an exit for some of the beach
parking. That was also before almost half of the
parking lot at our retail center became beach parking.

Now days, particularly on sunny days, the traffic going into and out of Pedro Point is almost unbearable and
it's getting worse. Frequently San Pedro road is almost impassable due to great number of people parking
there to use the shopping center, the beach, or who
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Project and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

2.f
Packet Pg. 1026 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 932 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 145
Letter Commenter Date Comment Combined Response
Individuals (C)
actually live in the neighborhood. This traffic,
especially the beach going part of it, has increased
significantly every year for years now and will only get worse. If there is a need to suddenly evacuate the
neighborhood, such as a forest fire, our one single
road will not be up to the current challenge. I cannot
imagine what it would be like if many new homes are
built on the field, making traffic significantly worse.

3. The field is environmentally sensitive. Others will
have commented on the presence of endangered
species. I will limit myself to pointing out that we're currently in a drought, as we have been for some time
now. However, during our regular weather cycle this
field is marshy and can be prone to flooding. This was
before numerous additional houses were built on the
hillside, which will further increase the runoff when
our weather cycle returns to a more normal, wet
winter. In addition to the runoff that is to be expected, many of these new homes also have been built with
pumps that are pumping water out from around their
foundations, further adding to the water that will flow down to the field. An environmentally sensitive field
that is prone to being marshy during normal weather
years, not a great choice for cramming in dozens of
homes.

4. I believe that everyone has the right to expect a
decent return on their investment as long as it is a
reasonable expectation. However, the current owner
bought this property knowing its land use designation
so I feel that the city has no responsibility to help
them make a profit by insisting on a land use
designation change, especially one that will be
harmful both to the neighborhood and the
environment.

C25-2 Gary Furlong 3/7/22 I believe that one of the highest duties of a city, and its land use designation, is to protect the nature of its
neighborhoods and the lives of its residents. I believe that this land use designation change will do just the
opposite; as I mention above, is should be obvious
that reasonably foreseeable development allowed by
the proposed new land designation of the General
Plan Update will destroy the valued character of the
neighborhood and my enjoyment of it. It's almost
seems as if this particular parcel of land has been
singled out for special treatment.

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

2.f
Packet Pg. 1027 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 933 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 146
C26: Dina and Robert Horan, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C26-1 Dina and
Robert Horan
3/7/22 We are writing to object to the General Plan
Update and Draft Environmental Impact Report's
proposed land-use designation change for the
undeveloped San Pedro Avenue site (the "Pedro
Point Field"). As we understand it, the proposal
would change the designation of the Pedro Point
Field from “Commercial Recreation” to “Coastal
Residential Mixed Use.” For the sake of brevity,
rather than repeat facts presented by and
arguments and proposals made on behalf of the
community by the Pedro Point Community
Association and its counsel and consultant, as well
as the additional arguments, facts and proposals
presented by Sam Casillas, we incorporate them
as though fully set forth herein.

As the Pedro Point neighbourhood has
demonstrated over the years, this community
stands ready to provide the legal and financial
resources (and person-power) necessary to
protect our neighbourhood from ill-conceived
and/or unlawful decisions regarding the Pedro
Point Field. Accordingly, we respectfully urge all
decision makers to please carefully consider the
points made by the PPCA and its lawyers and
consultants, and Mr. Casillas, and work with the
community to appropriately designate the Pedro
Point Field in a manner that protects the
environment and is consistent with applicable law
(including the Coastal Act), neighbourhood
concerns, and science.

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

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

2.f
Packet Pg. 1028 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 934 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 147
C27: Cathy Glenn, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C27-1 Cathy Glenn 3/7/22 I'm writing to state my objection to the General Plan Update (GPU) and Draft Environmental Impact
Report (DEIR)’s proposed land use designation
change of the undeveloped San Pedro Avenue site in
Pedro Point (ie: the Pedro Point field) from
“Commercial Recreation” (CR) to a new “Coastal
Residential Mixed Use” (CRMU) designation.

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

C27-2 Cathy Glenn 3/7/22 In reviewing the DEIR, I know that the City has concluded that the GPU would not create significant
visual impacts related to 1) views of hillsides, 2)
degradation of existing visual character, or 3) glare
affecting day or nighttime views. As a local resident,
I disagree with these Draft EIR conclusions for the
following reasons:

My family has lived on Pedro Point for almost 30
years. Our front windows overlook the field, the
berm and the ocean. The view of the grassy field is
very relaxing and the wild life that we see in there
on a regular basis is just wonderful.

My biggest concern about the field being designated
Coastal Residential Mixed Use is the increase in
traffic and parking that will overtake the Point. Right now we are inundated with beach parkers every
sunny day. It is taking its toll on our roads and on our residents safety. The roadways are crumbling, have
bigger and bigger pot holes and the parking is
ridiculous. People park where ever there is space
whether it is a parking space or not. Just crossing
San Pedro Road can be an adventure and is getting
more and more dangerous. Adding more residents
will just exacerbate the problem. We have had to
call the police to have parkers ticketed for blocking
our driveways. Unless the City is willing to put the
money into fixing our infrastructure, this will be an
on going problem. My children grew up using the
field for play and for access to the beach. I would
like to see this continue for the next generation of
Pedro Point children.

In addition, reasonably foreseeable development
under a CRMU designation would degrade the
existing visual character and be out of scale with the
existing structures in the surrounding neighborhood.

I have lived here for almost 30 years and the small
town look and feel of this neighborhood are an
integral part of our community.

Please see Chapter 3.9 for more information on
impacts to visual resources. As described on DEIR
p. 3.9-13, "While the Proposed Project eliminates
the existing single height limit in the city with
height limits that vary by zone, future
development will be subject to regulation and
review mechanisms to ensure there is no
substantial adverse effect on scenic vistas...The
land use changes in the Proposed Project will not
substantially degrade the existing visual character
or quality of Pacifica and would not conflict with
applicable zoning and regulations governing scenic
views. All existing open space areas are preserved
and scenic resources are protected under the
Proposed Project. Policies, zoning designations
and design guidelines included in the Proposed
Project will sensitively govern the formal
characteristics of new development to ensure
they are compatible with existing neighborhood
character and quality The Coastal Act requires
scenic and visual qualities of coastal areas to be
considered and protected as a resource of public
importance.

The DEIR also has regulations and policies that
would further reduce an already less than
significant impact on scenic vistas on pages 3.9-19
through 3.9-22.

In regards to your comment on traffic and parking
issues, parking and congestion are not a topic of
required analysis under CEQA. The comment is
not related to the adequacy of the DEIR, therefore
no further response is required in the FEIR.

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

C27-3 Cathy Glenn 3/7/22 I'm also concerned about new sources of light and glare from exterior and interior lighting that would
be introduced by reasonably foreseeable
development under the General Plan Update’s new
The DEIR analyzes new sources of substantial light
or glare on pages 3.9-29 through 3.9-31. The
proposed project was found to have a less than
significant impact. As mentioned on page 3.9-13

2.f
Packet Pg. 1029 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 935 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 148
Letter Commenter Date Comment Combined Response
Individuals (C)
land use designation for the field. My nighttime
environment would be negatively impacted, as the
additional lighting and glare would be visible from
my home and take away the peaceful darkness of
the evening. As it is now, we can see the ocean in all
of its glory day and night, but we won’t be able to
watch the waves crash onto the rocks and see the
beautiful waterfalls that they create.
of the DEIR 'New development under the
Proposed Project is not expected to create new
sources of light or glare that could substantially
affect day or nighttime views in the area.' The
DEIR also mentions proposed general plan policies
that would further reduce an already less than
significant impact on pages 3.9-30 and 3.9-31.

C27-4 Cathy Glenn 3/7/22 For each of these reasons, I believe this project will result in a significant adverse visual impacts. The
simplest solution to address these issues is to
change the land use designation for the Pedro Point
field to one that is closest to it's current state, which is Low-Intensity Visitor-Serving Commercial (LIVC).

The comment is noted. Please see to response to
comments C27-2, C27-3 and C27-4.

2.f
Packet Pg. 1030 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 936 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 149
C28: Clif Lawrence, 2/21/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C28-1 Clif
Lawrence
2/21/22 Good evening. My name is Clifford (Clif) Lawrence. Our First U.S. President was born on this date 290 years
ago. He commended us to remain mindful of the
importance of the role of "Citizen". We are all here this evening as concerned citizens, and as such honored.

Next I wish to express my thanks for the recent upgrade revisions to the Draft General Plan and Draft EIR
documents. These indexes and search friendly
capabilities have opened a window of opportunity to
identify what IS and what IS NOT there. Tonight I
thought I would share with you somethings you might
not have known about our 2022 Draft EIR. More
specifically some nerdy things about its Bibliography...

First...there are 193 references. The oldest 1974. The
newest 2013. There are no references in the
Bibliography newer than 2013. In fact, the 2022
Bibliography is IDENTICAL in substance to the version
made public in 2014. There are at least 5 references
with NO DATE. There is even one document referenced
by year as 3013. Mind you, I accept I may have made
some errors in the creation of this profile. But then I was a little rushed compared to the years utilized by
our high paid consultants.

We spent a lot of money on these consultants in 2021
and 2020. Somehow they managed to add 300+ pages
to the 2014 DEIR without a single change to the
Bibliography. How is that?
References will be updated to reflect the latest
data used in analysis. This does not change any
findings of significance in the DEIR.

C28-2 Clif
Lawrence
2/21/22 There is another matter of concern. The word
"contingency" only appears ten times in the one
thousand pages of the DEIR. Twice in reference to
water. Eight times regarding access for emergency
vehicles. Should I conclude, there is no contingency for the eventual loss of infrastructure under Beach Blvd? Is there no contingency for the potential erosion loss of
Palmetto Ave at the South Canyon? How much longer
will it take emergency vehicles to get to West Fairmont, if they can't use Palmetto Ave? In conclusion I ask you this question. Since you are not only Planning
Commissioners, you are Pacifica Citizens. As Citizens,
how do you grade this DGP and DEIR? Are you also
concerned? What have we paid for "The Emperor's
Clothes?" I thank you for your time.

Planning for critical infrastructure is not a
required topic of analysis under CEQA, but it is
addressed in the MJ-LHMP and in policies SA-I35 and SA-I-36. Please see response to C47-3 for more information about coastal erosion and sea
level rise mapping, and Master Response 7:

Emergency Planning for more information on
adequacy of evacuation planning.

2.f
Packet Pg. 1031 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 937 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 150
C29: Nancy Merchant, 3/3/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C29-1 Nancy
Merchant
3/3/22 In West Sharp Park, the failing shoreline protection (aka “seawall”) has not been reinforced, and the vulnerable
infrastructure behind it has not been moved, yet
instead of prudently scaling back on allowable
development to mitigate existing and future inevitable
risks, these planning documents recommend increased
intensity and also promoting the tallest buildings
Pacifica has ever allowed. Some of these four- to fivestory buildings, suggested for affordable housing, would be located north of San Jose Avenue, which is a mere
block away from the most vulnerable section of
shoreline in West Sharp Park. This does not meet the
standards for sustainable development – and, if built,
would pass the buck to those who have risked their
livelihoods to live or try to build a business based on the city’s lack of transparency.

Issues related to coastal protection are addressed
in the LCLUP. The LCLUP is not included for
analysis under CEQA.

C29-2 Nancy
Merchant
3/3/22 The Land Use and Housing sections in all three
documents don’t even mention sea level rise. The
ocean has visibly encroached in the last 30 years in
spite of (or perhaps even because of) shoreline
protections. Each month the City Council adopts the
Continuation of Proclamation of Local Emergency of the
Pacifica Coastline from Westline Drive to the End of
Beach Boulevard. Sea level rise is probably the most
significant influence affecting land use in Pacifica. Yet, hazards appear not to have been considered at all in
determining acceptable land uses.

Please see response to comment C13-3 for more
information about coastal flooding and sea level
rise.

2.f
Packet Pg. 1032 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 938 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 151
C30: James Kremer, 2/20/22
Letter Commenter Date Comment Combined Response
Individuals (C)
C30-1 James
Kremer
2/20/22 Initially, I want to address elected and city officials, and the senior staff (Planning Commissioners, City
Council, and Planning Staff). I expect that understaff will deal with the public comments that are received, collating and responding. Some of my
comments are at a different level however, and I
hope this helps them get noticed.

You all know that the released documents were
technically flawed: Table of Contents not linked to
pages (EIR with no TOC, text not searchable).

Releasing WORD versions was very little help,
since altered pagination required adjusting all
notes to apply to PDF (not easily searchable K). All
together too much time lost bouncing around
trying to keep track so my notes will be accurate…
This inefficient effort multiplied by all the persons
in Agencies, NGOs, and the public.

More importantly, it seems clear to me that no
one proof-read the document. Consider: there are
two sections 3.14 (p. 721 & 750) nearly identical†;
one paragraph I saw begins with a phrase then
abruptly begins again with the same words; a table
I missing; plans are mentioned to replace the
pedestrian walkway over Hwy 1 by Eureka Square
(OC-I-31, p6-20), which was completed more than
2 years ago; and perhaps understandable,
“Rockaway Point” is mentioned repeatedly to in
the GP despite acknowledgement in one place of
the new name Aramai Point; oh, & many obvious
typos. I’d think that at some point city staff, if not
the Dyatt & Bhatia authors, would subject each
part to a final read-through. Public/outside review
should NOT be a kludge mechanism to do this
basic task. († note: This duplication was removed,
and non-standard pagination corrected in the
revised DEIR released later.)
The comment is noted. Clarifications will be noted in
a redlined version of the DEIR; these do not change
findings of significance.

C30-2 James
Kremer
2/20/22 O.K. Here are general issues I hope will receive consideration –
Process. There is a expectation from some in the
public that all comments received will be logged,
given perfunctory dismissive responses by staff,
and PC and CC will approve as is. Since substantive
changes cannot be made later without
recirculating, this seems to imply the city views
these documents acceptable as is. That seems to
leave only legal challenge as a path to achieving
improved documents. Is that your understanding?
I think you may get a chance to resurrect this
process. Should become apparent from the critical
The comment is noted. Adequacy of the DEIR is
expressed in responses to comments as part of the
FEIR.

2.f
Packet Pg. 1033 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 939 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 152
Letter Commenter Date Comment Combined Response
Individuals (C)
reviews that major changes must be made, I want
to suggest that an extended review will probably
save time. Here is what I mean:

After all the input from this hasty round of review
is collated, and if crucial changes are made,
perhaps the product will be closer to what might
be called a First Draft, one that is worthy of careful
review. My idea is that THAT is the time to actively
engage citizen volunteers again. Many are
interested. A “Call” from the city for citizen
volunteers to actually read whole sections might
be wellreceived – free labor (!) that would find
more improvements. With such a collaboration, a
2nd Draft can emerge, worthy of the recirculation
review that is deserved.

C30-3 James
Kremer
2/20/22 Missing content – Decarbonization, Electrification and Reach Codes should be major topics for a
responsible plan, yet seem to be glossed over or
missing. I know some Councilors are aware of this
regulatory “wave”! I applaud the mention of
decarbonization in control measure EN1 (Table

3.3-5 p 3.3-32) but am disappointed there are
rampant code errors that make it impossible to
look into how seriously this initiative is being
considered here or in the GP. I found Guidance
policies related to this topic (EN1: CO-G-13, -51, -
59) but code CO-G-13 in GP (p7-34) states an
entirely different policy from that in the EIR; a
different code# for -51 (=”CO-I-57” GP p7-39) ;
different code# for CO-I-59 (=CO-I- 62 in EIR pE133, & CO-I-57 in GP p7-39). Oh my. Just pecking around, the same numbers are different words,
and the same words are different numbers.

Repeatedly. (This turns out to be a general
problem not just with decarbonizing.)
These are mainly errors of haste and lack of
proofreading, but I want to emphasize the lack of
discussion in text body of they key words that
appear in policies, which seems strong evidence
that this topic is not being taken seriously in our
future planning. This is a major, significant
omission. A missed opportunity – or obligation!
The comment is noted. All text in the DEIR analysis
references policies that are described in full in
analysis chapters. Discrepancies in numbering will be
addressed in errata.

2.f
Packet Pg. 1034 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 940 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 153
Letter Commenter Date Comment Combined Response
Individuals (C)
C30-4 James
Kremer
2/20/22 Change from historical emphasis. In a number of places HPD discussions focus on esthetics, scenic
views. There are hardly any mention of hillside
restrictions in terms of public safety with
landslides, water runoff, and wildfire risk, to which
we should add then environmental risk to wildlife
corridors. While the esthetic emphasis is
commonly appreciated, the near exclusion in this
new doc of explicit mention of the importance of
restricting any development on hillsides as a
function of slope is, dare I say, unacceptable. This
appears to be a conscious shift in emphasis, which
has no basis in public guidance, and strikes me as
city over-reach.

This can be seen clearly in the explicit new
definitions of zoning categories. The lengthy
wording from the 1980 G.P. emphasizing
environmental preservation in various categories
has been omitted in all cases. Seems to be a
conscious shift of guidance. I strongly recommend
the original wording be added back in.

Specifically, wording has been omitted from new
zone definitions that in 1980 consistently included
phrases such as, “will be determined by the
existing conditions on the site, such as slope,
geology, soils, access, availability of utilities,
availability of adequate sewage and highway
capacity, public safety, visibility, and
environmental sensitivity.” (see all these 1980
categories: OSR, VLDR, LDR, MDR, & HDR)
Steep slopes and CEQA-required impacts to the
environment, including landslides, water runoff, and
wildfire risk, are analyzed under the DEIR.

Landslides and slope failure are described on p. 3.6-
13 and analyzed under Impact 3.6-1. On p. 3.6-26,
the DEIR notes, "The impacts from landslides on
development of future land uses associated with the
Proposed Project would be addressed through sitespecific geotechnical studies prepared in accordance with CBC requirements and standard industry
practices, which would specifically address landslide
hazards located in landslide hazard areas.

Development would conform to the current design
provisions of the CBC to mitigate losses from
landslides. Proposed developments would also
adhere to the hillside development requirements
contained in the proposed policies as well as the
existing regulations in the Hillside Preservation
District to resist landslides through modern
construction design and slope stabilization
techniques. General Plan Policies SA I-2 and I-9
maintain restrictions on hazardous areas including
those in the Hillside Preservation District, while
Policy SA I-8 requires that proposed development in
hillside areas undertake geotechnical studies which
analyze erosion and landslide potential. Policy LU-I14 extends the Hillside Preservation District on the zoning map to ensure that all steep and sensitive
terrain is subject to these regulations. Given State
and local regulations, including those in the Proposed
Project, the potential for adverse landslide impacts
due to the implementation of he
Proposed Project at the regional and local level is
considered less than significant."
Water runoff impacts are analyzed as part of Impact

3.5-3. As noted on p. 3.5-29 and 3.5-30, compliance
with MS4 NPDES Draining control requirements,
Provision C.3 in the NPDES permit, compliance with
the County's SMCWPPP, and adherence to the City's
stormwater guidelines would control stormwater
volume. Compliance with these regulations reduces
potential impacts to less than significant.

Slopes and wildfire risk are described in Impacts 3.14-

2. "Rugged ridges" and vegetation are described on
DEIR p. 3.14-14, which also describes the “very high,”
“high,” and “moderate” fire threat levels within the
City", also shown in Figures 3.11-4 and 3.14-1. All
new development must consider fire protection
systems and equipment, defensible space, and
vegetation management consistent with
requirements in the CBC, NCFA guidelines, and the
Pacifica Municipal Code. Continued compliance with

2.f
Packet Pg. 1035 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 941 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 154
Letter Commenter Date Comment Combined Response
Individuals (C)
existing programs and standards as well as Proposed
Project policies would reduce potential fire hazards
to a less than significant level. Please see Master
Response 5: Wildfire for more information.

2.f
Packet Pg. 1036 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 942 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 155
Letter Commenter Date Comment Combined Response
Individuals (C)
C30-5 James
Kremer
2/20/22 Vague intent and enforceability. Many policies I read struck me as platitudes, with giant loopholes
of active facilitation via variances. Many in the
public feel variances are being used to bypass
reasonable regulations, city and state. I observe at
city meetings when officials question staff
recommendations, staff responses are often
tangential even dismissive, and then
Commissioners or Councilors acquiesce. It would
be desirable to formally stipulate in policy or
regulation that variances are to be used rarely
under well constrained conditions. Too bad this is
necessary.

The commenter's assertion that "policies are
platitudes" are untrue. Proposed Project policies are
not intended to act as mitigation measures; rather,
they are policy statements indicating actions the City
will take on an ongoing basis as the Proposed Project
is implemented and the DEIR has correctly
considered the effects of implementing these
policies, including any beneficial effects they would
have in reducing potentially significant impacts of the Proposed Project. As a programmatic document, this
EIR presents a citywide assessment of the potential
impacts of the proposed Pacifica General Plan. It
does not assess project-specific impacts of potential
future projects under the proposed Plan, all of which
are required to comply with CEQA as applicable.

As a program EIR, the preparation of this document
does not relieve the sponsors of specific projects
from the responsibility of complying with the
requirements of CEQA. As noted, individual projects
are required to prepare a more precise, project-level
analysis to fulfill CEQA requirements. The lead
agency responsible for reviewing these projects shall
determine the level of review needed, and the scope
of that analysis will depend on the specifics of the
particular project. Should an applicant propose to
develop in an area with sensitive resources or
potential site-specific impacts or in an area of known
hazards, compliance with policies requiring
additional study would be a requirement for project
approval. Any project requiring discretionary
approval is required to make findings of General Plan
consistency and must demonstrate analytically that
the project is consistent with the General Plan, and
how they comply with applicable policies. Please see
Master Response 3: Buildout and RHNA for more
information.

C30-6 James
Kremer
2/20/22 I suppose all this is my “Executive Summary”(!). I have compiled detailed comments and sent all of
them to the City email for public comment. I
expect staff will be the only one who sees the bulk
of them. I am sending only this to Planning staff
and city officials. FYI, should you want to explore,
my detailed comments there include sections on:

I. Philosophy - big picture concerns that don’t
translate easily into discrete modifications
II. General Comprehensibility - Suggestions to
improve the overall structure of the docs, for
easier use, especially important for the G.P. as a
forward reaching, useful resource.

III. Specific comments:
• Itemized specifics with substantive problems, in
page order
• Focus: 3.7 Biological Resources - I spent extra
time on this
The comment is noted. This comment does not
contain CEQA-related comments.

2.f
Packet Pg. 1037 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 943 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 156
Letter Commenter Date Comment Combined Response
Individuals (C)
IV. BIBLIOGRAPHY, problems with sources and
citations
V. Typos and picky nits
At a later date I will submit comments on the
General Plan, with similar sections.
-------------- This is the END of introductory
comments also sent directly to City officials. -------- ------
C30-7 James
Kremer
2/20/22 I. Philosophy - EIR
Confusion about “the plan.” The DEIR considers
multiple plans. The SPSP is “the” plan, previously
chosen to proceed and the basis for EIR impact
analysis. In this context, considering the Quarry as
an “alternative” is confusing. Why consider only
one? Indeed, is it not the case that the City is
proceeding with Huele to consider that option
too? So the whole framework for the EIR seems to
me to be a “straw man.” Artificial, and perhaps
inaccurate. oes anyone really believe we won’t
consider both Palmetto and the Quarry? I do
understand the need for a “no action” alternative.

On p E-6, “Additional elements may be included as
well”. If this were to be considered, it could not
happen only in the GP, for surely the EIR must
include all appropriate details. So both the GP and
the EIR would have to be re-circulated for agency
and public comment? Wow. Seem unlikely; why
say this?
The CEQA Guidelines require EIRs to describe a
reasonable range of potentially feasible alternatives
to a proposed project or program. That is, the EIR
needs to analyze those alternatives that will help
decision-makers make reasoned choices. The range
of alternatives shall include those that “would
feasibly attain most of the basic objectives of the
project but would avoid or substantially lessen any of
the significant effects of the project” (CEQA
Guidelines, Section 15126.6(a)). “Feasible” means
that the alternatives “are capable of being
accomplished in a successful manner within a
reasonable period of time, taking into account
economic, environmental, legal, social and
technological factors" (CEQA Guidelines, Section
15364). The alternatives contain different land use
categories, densities, and intensities along Palmetto
and at the Quarry site. The differences between the
alternative concepts are described on p. 4-2:

Alternative A, Strong Center at Quarry Site,
establishes one major mixed-use and visitor-oriented
center for Pacifica, and a series of commercial nodes
throughout the city; while Alternative B, MultiCentered, West Sharp Park Emphasis, creates a smaller visitor-oriented node at the Quarry Site and a
civic and mixed-use district in West Sharp Park.

Alternative C assumes very little development on the
Quarry Site, and more intensive transit-oriented
development at several nodes. The General Plan and
Specific Plan most closely resemble Alternative B,
which becomes the Alternative 2:"Proposed Plan".

This Alternative is evaluated in full in the DEIR
analysis chapters, 3.1-3. Policies in these elements
that may reduce environmental impacts for CEQArequired analysis areas are found in this DEIR, as applicable.

C30-8 James
Kremer
2/20/22 Sequence of LCLUP with GP+EIR. The EIR & GP
acknowledge the linkage to the an updated LCLUP.

The current plan is to approve the EIR, GP and
SPSP now, then go back change then when the
LCLCP is done. This seems badly out of order.

Many of the Policies have the icon implicating
consistency with LCLUP. It is my understanding
that the “Certification Draft” has not been
accepted even for review by the CCC, having
instead been rejected as insufficiently responsive.

Would the whole process not be expedited if an
The City of Pacifica started an LCLUP update in 2009
and continued its work through 2014. Between 2014
and 2018, the update work paused. Work on the
LCLUP update resumed in 2019 with a series of five
community meetings and study sessions with the
Planning Commission and City Council. On February
24, 2020, the City Council considered the PostConsultation Draft LCLUP and approved transmittal of the LCLUP to the California Coastal Commission for
review and certification. The LCLUP was transmitted
to the Coastal Commission on June 12, 2020.

2.f
Packet Pg. 1038 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 944 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 157
Letter Commenter Date Comment Combined Response
Individuals (C)
acceptable LCLUP were to be accepted, or at least
under review by the CCC at this point in time? If
this process for the EIR and perhaps GP are
delayed for significant revision, it really makes
sense to back off and do this in the right order. It
really begs the question in any action can be taken
based on an “approved” GP without a current LUP.

No one knows, right?
Although the LCLUP is a separate planning document,
the LCLUP policies and relevant narratives are
included in the General Plan Update to ensure
coordination between the two documents. The City
has prepared a draft of the LCP Update in 2019,
approved by the City in 2020, and which is currently
under review for certification by the California
Coastal Commission. To the extent the General Plan
Update proposes any policies beyond those which
were sent to the California Coastal Commission for
review and certification, a subsequent LCP
amendment would be necessary to make the LCP
consistent with the General Plan.

C30-9 James
Kremer
2/20/22 What is the future of these docs after approval.

The format and constraints for review of the initial
documents suggest that the city was not
interested in public review. When final and
approved, however, it seems to me that not even
the GP will be read through by many people.
(Certainly not the EIR.) So what should be the goals
in finalizing them:

I suggest they must be tractable as working
documents for future reference. Details that
clearly fell below the threshold of necessity in
these versions become super critical: Searching;
Crosscomparing and checking; Accuracy and
consistency; Clear and well documented
explanation. I must believe that staff appreciates
that improvement in this vein is a good idea. But
the apparent strategy to not allow serious review
with intent to make changes now is confusing and
alarming. If not now, when? I see lip-service to the
only real goal but hasty pressure to getting it done.

We will find this to be a serious mistake.

Constructive action, not words, is needed.
[Note, after the DEIR release of revised version
2/14/22: This doc is more navigable. It IS different
however, and it should have been identified as a
different version, or release date – something!
Changing the name of the file is unreliable and
having no distinguishing phrase somewhere in the
revision is unacceptable.]
The comment is noted. There are no significant
differences among the DEIRs filed with the State. Per
public request for extension and ease of use, a DEIR
with interactive table of contents was added and
submitted to the State Clearinghouse on February
14, 2022. While a duplicated wildfire chapter was
removed to reflect a usable TOC, there are no other
differences between the document.

C30-
10 James
Kremer
2/20/22 Loopholes for enforcement. For all Policies
suggested to reduce Impacts (DEIR p 3.7-56 ff),
such as:

LU-G-7 Open Space Conservation and Habitat
Protection.

CO-G-7 Wildlife and Critical Habitat. Conserve and
protect indigenous threatened, endangered, and
other special status species by preserving critical
habitat.

These are example of vague wording, more
platitudes than enforceable policies. The city has
shown willingness to not look carefully at claims
Critical habitat is an official CDFW designation; the
undeveloped San Pedro Ave sites are not within
critical habitat. Please see Master Response 6: ESHA
for more information, as well as response to
comment A22-21.

2.f
Packet Pg. 1039 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 945 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 158
Letter Commenter Date Comment Combined Response
Individuals (C)
that projects impact critical habitat for the CRLF, if
the developer offers conflicting assertions. This
may seem snarky of me, but I worry that these
policies are being overlooked as if the city wants to
approve a project. Example: the city decides a
project does not need CEQA review, then
professional testimony submitted by outside
experts is dismissed in favor of the project’s claim.

Yet I understand it is legally required that such
case be resolved by requiring an EIR. Some
variances are judgment calls, but I have trouble
understanding how these evasive actions are
permitted. Lapses like this look to the public like
pro-developer bias, and can result in justified legal
action.

C30-
11 James
Kremer
2/20/22 How about a POLICY on Variances? Policies that
are vague and superficial compromise future
efficacy because they do not provide clear
guidance to future staff and governors. It may be
that Guidance Policies can be platitudes, but
Implementation must not be. This concern led me
to seek the word “variance” in the EIR. (thank you
for a searchable doc! J) This word appears on only
2 pages. Unsurprisingly, none offers guidance that
this tool should be rarely used. In the GP, the word
never appears.

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

C30-
12 James
Kremer
2/20/22 II. General comprehensibility – EIR Hierarchical structure of headings is impossible to follow. I
looked at Ch. 3, sec 3.4 “Energy and GHGs” trying
only to follow the structure of the layout, i.e.
outline levels indicated by the font style.

There are SEVEN levels, indicated by font
size/bold/italics/ALL CAPS or Upper-Lower case. I
daresay it is IMPOSSIBLE for a reader to know
where a section falls in the structure of the
presented information – am I going down deeper
or rising up? – and if up, by one level or more? Of
course this is essential to comprehend the points
being made in the intended context. Ideally, this
would be made more apparent by successive
indenting, but with 7 levels, the prose paragraphs
become too narrow! Yet it is straightforward to fix:

MS WORD offers “Outline Numbered” that
remains clear with many levels. A full seven layers
gets messy, but that is rarely encountered and at
least it is clear: 1.1.1.1.1.1.1. Without this or
something else explicit, readers have NO CHANCE
of discerning the relative hierarchy of the content.

To preclude this is unacceptable, an impediment
to readers’ understanding. WORD will add these
prefixes and update them automatically (I think; at
least it will show where they all are in Outline
view, and can then be added to text).

The comment is noted. Clarifications will be noted in
a redlined version of the DEIR.

2.f
Packet Pg. 1040 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 946 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 159
Letter Commenter Date Comment Combined Response
Individuals (C)
Names in headings are repetitive and thus unclear.

See e.g. Sec. 3.7 BIOL, (e.g p3.7-49 pdf=p 537)
starting below “SUMMARY OF IMPACTS” (& the
same applies throughout all elements). Each
individual “Impact” has only that word as a
heading, so they all look identical (in the layout,
but also in the TOC eventually). This is also true for
subsequent headings that are recurrent (I made a
TOC for 3.7 and the Headings are very repetitive,
minimally informative.) This prevents readers from
knowing where they are, or when scanning, from
keeping track. This is counter-productive and
awkward. Even if it is difficult to make the text for
all lower subheadings unique, at least do so with
heading level numberings that are included in the
body of the document. E.g. “Impact 3.7-1” should
be the Heading 4 for that item.

Placement of Figures and Tables inconvenient. In
my experience, cited graphics should always be
placed after text references. This helps the reader,
knowing to look down for the info. I encountered
some places were this was backwards. When the
text is finalized, this could be changed throughout
the documents relatively easily.

C30-
13 James
Kremer
2/20/22 III. Specific comments - EIR
-POLICIES wording do not agree within the EIR and
between it and the GP. In a significant number of
items, the same code is followed by different
statements. They have to be consistent. In some
cases, the same code ID is used for different and
unrelated policies. In one case just in the DEIR, a
specific policy is cited throughout the DEIR with 2
different ID codes. For example:

LU-I-14 “Hillside Preservation. Update the Hillside
Preservation District and the zoning map to ensure
that all steep and sensitive terrain is subject to
these regulations. The Hillside Preservation map
(Figure 4-4 of the proposed General Plan) should
be used as a guide.” [p E-15, E-78, E-104, E-142,

3.9-21.]
LU-I-12 “Hillside Preservation. Update the Hillside
Preservation District on the zoning map to ensure
that all steep and sensitive terrain is subject to
these regulations. The Hillside Preservation map
(Figure 4-4 of the General Plan) should be used as
a guide.” [p E-68, 3.1-27, 3.7-57, 3.12-36, 3.14.19.]
The comment is noted. Clarifications will be noted in
a redlined version of the DEIR.

C30-
14 James
Kremer
2/20/22 Policy CO-I-54 Climate Action Plan is referred to, and 5 bullets propose future goals to be done.

Why are these actions deferred? Baseline
inventory of sources, projected emissions by city
operations, feasible reduction measure sand –
most of all - an implementation plan – all these
Please see response to comment C125-7 for more
information on GHG, the CAP, and mitigation
measures.

2.f
Packet Pg. 1041 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 947 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 160
Letter Commenter Date Comment Combined Response
Individuals (C)
seem appropriate PARTS of the planning process
that the GP is about.

These would properly be done ahead and
included, so they only need updating into the
future. To put this off obviates our chance to get
ahead of the curve! (Same policy also on p.3.3-35
(p317) in Table 3.3-

5. C30-
15 James
Kremer
2/20/22 -p.3.1-19 (p 217) Confusing process sequence. in Impact Summary: “following the adoption of the
proposed project the proposed project, the
specific plan in zoning ordinance, as well as other
safety policies and regulations, will be amended to
ensure consistency with the proposed project.”
The EIR seems to take total precedence. It must be
approved and then the rest brought into
compliance. But the construction of this EIR is
weird, and so how can this work? Citizens have NO
IDEA of what is happening, given the preeminent
1000 pg document they can’t review or
understand?
To clarify: The Proposed Project refers to the General
Plan and Specific Plan. Adopted policies, specific
plans, programs, the zoning code, and other
implementing tools will be amended to conform to
the adopted General Plan. Following adoption of the
General Plan, the specific plans and Zoning
Ordinance, as well as other City policies and
regulations, will be amended to ensure consistency
with the General Plan, which is the guiding
document.

C30-
16 James
Kremer
2/20/22 -Assertions stated but not explained. Policies listed in EIR & GP as reducing the impact significance are
stated but not these assertions are not explained
and justified. Inability to search text in PDF as
released badly complicates finding place where
this might be explained, but in the GP where text
can be searched also came up empty for any
discussion that might offer justification. Example: I
sought to understand how the Policies in Table ES3 in DEIR were explained with respect to their benefits claimed in the EIR. I followed one
example, policy LU-G-2. This policy is stated in
Table ES-3 of DEIR (p E-134, pdf p 14) but search
fails to return any mention elsewhere. Of course, it
is there, but very hard to find because the search
works only in the headings and tables – of the EIR
only– not in the explanatory text. Interestingly,
each specific policy is also listed verbatim in the
GP, yet a text search there for the Policy also
comes up empty. I was unable to find any
explanatory justification there either.

The comment is noted. A DEIR with interactive table
of contents was made available on the Plan Pacifica
website on February 14, 2022.

2.f
Packet Pg. 1042 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 948 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 161
Letter Commenter Date Comment Combined Response
Individuals (C)
C30-
17 James
Kremer
2/20/22 -sec 3.14 “p6” (real p. 778) Incorrect statement.

Local Hazard Mitig Plan: states “Pacifica’s …SMC
MHMP…updated 2021…identifies City’s hazards”.

That doc’s draft Fire Hazard map was empty and
DID NOT identify any hazard in the City as
incorrectly stated here; and despite being shown
that the map in the draft, this map was NOT
updated in the final MHMP. I’ve heard that the
MHMT is just a tool to facilitate funding. OK, but it
is incorrect to cite that error here. Later
substantive discussion (p. 781ff) refers repeatedly
to the MJ-LHMP which had minimal discussion of
Fire Hazard due to the vacuous Map, so these
should be checked for similar inaccuracy.

A clarification is made as follows: "Per the 2021 MJLHMP, Pacifica had no population or structures within very high wildland severity zones. At this time, CAL FIRE does not provide mapping data for high or
moderate fire risk zones in LRA."
The DEIR characterizes wildfire hazards within the
Planning Area on pages 3.11-4 through 3.11-6 and

C30-
18 James
Kremer
2/20/22 -sec 3.9, p3.9-11 (pdf p586) Misleading statement of HPD intent. Although sec 3 is “Visual Resources”
the justification for HPD in that ¶ is NOT limited to
that benefit, as the paragraph now reads. The text
of the HPD code states: [Intent is to:] “b. Help
protect people and property from all potentially
hazardous conditions particular to hillsides”. This
really should be be identified as the primary goal
of HPD and certainly not omitted entirely. The
paragraph as written does not represent the
emphasis of the HPD intent accurately. This is
misleading, even in a section on Visual Resources.

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

2.f
Packet Pg. 1043 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 949 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 162
Letter Commenter Date Comment Combined Response
Individuals (C)
Note: Land Use sec. p4-13 (p74) does state this
better referring to Ch 3 & 8.

C30-
19 James
Kremer
2/20/22 3.7 BIOLOGICAL RESOURCES -EIR - I focused on this • Missing content. No mention of wildlife friendly
fencing, requested in NOP (EIR p 489).

Wildlife friendly fencing is addressed as policy CO-I31.

C30-
20 James
Kremer
2/20/22 >> CRLFrog, which is specifically mentioned in
NOP, has many errors and discrepancies:
• Inconsistent spelling: “red legged frog” is
misspelled, this spelling does not appear
elsewhere in sec. 3.7, it is often spelled “redlegged frog” or “Red-Legged Frog”. Citations have to follow source., but the doc should be consistent
This is a minor correction made to clarify and does
not affect the findings of the DEIR.

C30-
21 James
Kremer
2/20/22 • Inconsistencies between Figs, & between Figs
and text & Factual assertions
Fig. 3.7-3, p3.7-17 Figure errors: (Note: in G.P. Fig
7-3, p7-19, EXACTLY SAME MAP figure but
“Pacific” is not misspelled!?)
a) Pacific Ocean misspelled;
b) CRLF habitat not shown in Sharp Park Golf
Course, & other places yet specifically mentioned
elsewhere.
c) Missing source specification. CRLF has been
widely discussed in Golf Course preservations, and
is shown in GGNRA public info signs for the area.

Fig. 3.7-4, p3.7-23 (p512) Another depiction of
habitats, including CRLF
a) CRLF habitat shows differently from Fig. 3.7-3,
here with many specifics.
b) Key box does not match symbol on map.

KEY BOX: Zone marking in map (1 or many)
≠
p 3.7-50 (p538) Inconsistency. Text of the EIR
asserts the presence of CRLF in Sharp Park and
Mori Pt, BUT these habitat are not shown in Fig.

3.7-3 p.7-17 (p506) Table 3.7-1 is missing although
this Table is cited 3 times in Ch. 3.7. Perhaps the
mention of CRLF on p3.7-21 (PDF p509) is
intended? but it is not a real table, and not
identified as it. E.g. see mention on p3.7-33 (PDF
p521) where the table appears in a list “SpecialStatus Plants & animals.” The comment is noted; Fig. 3.7-3 shows critical
habitat, an official designation made by CDFW. Figure

3.7-4 shows occurrences of special status species.

Other map clarifications will be made in the redlined
version.

2.f
Packet Pg. 1044 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 950 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 163
Letter Commenter Date Comment Combined Response
Individuals (C)
C30-
22 James
Kremer
2/20/22 IV. BIBLIOGRAPHY - EIR
Citation of Sources are mostly incomplete. (This
comment applies to the GP also, and was included
in those comments as well.)
This is so pervasive and important, I feel I need to
justify my criticism. The convention employed in
GP & EIR would be unacceptable in any peerreviewed journal, or in agency funding proposals.

While abbreviated citations may be included inline
in text or figures (e.g.: Kremer and Nixon, 1975),
every one should appear later in a list complete
with details for the full source (e.g. document title,
date, authors, journal or agency). In all these docs,
however, abbreviated parenthetic citations are not
fully cited later, and the list of references does not
even include items cited in the body of the
document at all. This is not only unconventional,
but unacceptable, as the actual source of
fundamental information is not knowable.

Specifically:

Throughout the GP &EIR footnotes are given in
text, or for Tables and Figures, that do not specify
the actual source in sufficient detail. Example:
neither “Source: Dyett & Bhatia, 2021” in Table 1-1
(p1-4), or “San Mateo County, 2019” for map
Figure 7-4 (p7-43) gives the specific actual source.

If D&B have a document that the map was based
on, that exact document should be cited whether
inline, by footnote, or later in an itemized list of
citations. The citation is not in the Bibliography,
anywhere I looked, certainly not for Ch. 3.7 Biol.

Res.

A citation “IPCC, 2018” may be barely adequate,
although probably not, since certainly the IPCC
published more than one document in a given
year, so the one being cited is unknowable. But
“City of Pacifica, 2012” is insufficient–what does
this even refer to? Similarly, reference to “Dyett
and Bhatia, 2019” are simply not sufficiently
informative. This general problem compromises
virtually ALL tables and figures, and many text
footnotes.

Notice that “City of Pacifica, 2012” is listed twice in GP REFERENCES on p R-1 & only for sec 2.

Economic Sustainability and sec 4. Land Use but
not for sec 7. Conservation where Table 7-5, p7-42
(pdf p213) uses this phrase. How can the same
vague citation be adequate for these different
topics?
So, “REFERENCES” in the GP and “BIBLIOGRAPHY”
Ch 6 in the EIR include some that were used but
not cited elsewhere? The source information for
all the maps and tables and footnotes appear only
inline (where it is insufficiently specific). Adding
full citations for all to the appropriate sections of
The comment is noted. Please see Chapter 6 of the
Final EIR for clarification of citations in the
Bibliography. The City notes that Dyett & Bhatia is
the primary source for data or information when
listed is the source in maps and tables per MLA
standards. The comment does not pertain to the
adequacy of the environmental analysis.

The comment is noted; footnotes in text will be
updated accordingly in the Bibliography. Dyett &
Bhatia citation means that D&B was conducted map
and figure compilation and analysis. Bibliography
references will be updated to reference in-line
citations.

As noted on DEIR p. 3.5-10, the DEIR uses sea level
rise analysis from the 2018 Sea Level Rise
Vulnerability report. In 2018, the City of Pacifica
prepared a Sea Level Rise Vulnerability Assessment
using the best available science. Consistent with the
San Mateo County Vulnerability Assessment, existing
and future coastal flooding was evaluated using the
Our Coast, Our Future (OCOF; produced by US
Geological Survey) mapping products, while future
coastal erosion was evaluated using an updated
methodology from Pacific Institute (PI) erosion maps.

The Vulnerability Assessment projected sea level rise
scenarios ranging from 1-2 feet by 2050, and 3-6 feet
by 2100.25 The 6 feet projection is an extreme
scenario in which sea levels rise at a rate about 30-40 times faster than the rate experienced in the 20th
century." This information is noted in a footnote but
will be updated to in the bibliography.

2.f
Packet Pg. 1045 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 951 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 164
Letter Commenter Date Comment Combined Response
Individuals (C)
both (probably all 3) documents is needed.

However, it is more confused. Some in the final list
ARE cited in the text body. See p 3-1-16 ftnt 2 is
“San Mateo County, San Mateo County General
Plan General Land Use Background Chapter, Page

7.1” and this exact citation appears in BIBLIO
including the partial italicization and BOTH have no
year. Repeatedly, however, “San Mateo County,
2021” or “County of San Mateo, 2009”, or other
years iare given as a source for figures (3.1-1, 3.1-
3, ) in this and other sections (3.2-1, …). Which one
is in BIBLIO, which are not? Not using “best
available data”? No recent references are cited for
especially time-sensitive technical Sections (3.4,

3.5, 3.6 & 3.7). I compiled all citations from the
entries in the Ch. 6 (p849-862). There are no
references since 2013. Oh my. While it is true that
inline footnotes and “Source” blocks in Figures and
Tables are not even included in the lest in EIR Ch.
6, they almost all are cited in an inadequately. I
didn’t include them in my graph. Climate sources
are especially inadequate. For Climate, an
especially time-sensitive topic for current range of
predictions of sea-level rise, the most recent
reference is 2014. The most recent IPCC
publication is the 4th Assessment Report in 2007
that was “accessed July, 2013” (p6-3) Another IPCC
doc from 2008 is a Synthesis for the 2007 report
(p6-4). The 5th Assessment Report (2014) was not
cited, and 6th Report some of which was dated
2021 are not either. Old forecast data are not
useful basis for planning. I am aware that we want
to pay special attention to explicit guidelines that
the State Coastal Act gives on sources acceptable
for risk assessments. I’m not sure what their
current positions are.

Citations with problems: (just the ones I stumbled
across…)
Sec 3.5 Hydrology & Flooding p6-4
• typo: year is not 3013! Coastal and Ocean
Working Group of the California Climate Action
Team (COCAT), State of California Sea Level Rise
Guidance Document, also available online
http://www.opc.ca.gov/webmaster/ftp/pdf/docs/
2013_SLR_Guidance_Update_FINAL1.pdf, March
3013 update.
• Listed twice. Coastal Environments, Tsunami
risks in the City of Pacifica, California: A
probabilistic approach, final Report by Hany
Elwany June 2007
• Stops mid citation (p6-6, pdf p853] Cowardin,
Carter, Golet and LaRoe. Classification of Wetlands
and…
• Out of order. Last 5 references cited in Biol. Res
bibio p6-11 (pdf p 858) Larson…Sparling
• No date, citation incomplete (& out of order).

2.f
Packet Pg. 1046 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 952 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 165
Letter Commenter Date Comment Combined Response
Individuals (C)
USFWS 5-year review of San Francisco garter snake
• Not the title in BIBLIO. “Sec 3.6 Geology Soils &
Seismic Risk” p3.6-1 (pdf p446) Not the title in
BIBLIO. “Geology & Seismicity” is there p6-11 (pdf
p858), AFTER Biol. Res (sec 3.7) So the section is
out of place in BIBLIO.

C30-
23 James
Kremer
2/20/22 V. Typos & Nit-picks - EIR
-p. E-2 typo: “the proposed General Plan includes
seven the seven elements”
p. 1-9 Intro (pdf p157) Redundant sentence.

TIMEFRAME ¶ has 3 sentences, the last of which is
redundant.
p. 3.1-4, Fig. 3.1-1 (p. 202) Map drafting error.

Beach fill pattern does not agree with that used on
Linda Mar Bch?
p 3.1-12 (p 210) Misleading assertion. LUP is not
technically under CCC review; last correspondence
in the public record the CCC says the document is
NOT suitable for consideration since the city has
not responded to the earlier CCC requests &
stipulations.
p 3.1-14, Fig 3.1-3, (p 212) Map drafting error.
“Sandy Beach” is not indicated at Pac St Bch.?! (&
this is the fill pattern used in the Fig. 3.1-1 but
This comment is noted. The following edits are made
for clarity:

DEIR p. E-2: "The proposed General Plan includes
seven the seven elements required by state law,
including, Land Use, Circulation, Housing,
Conservation, Open Space, Noise, and Safety.

Additional elements may be included as well, at the
discretion of the city. Optional elements for the
proposed General Plan include Economic
Development and Community Design."
DEIR p. 1-9: For analytic purposes in this EIR, the year 2020 is the base year (existing conditions), while the
year 2040 is the horizon year (future conditions)
when the proposed Pacifica General Plan will be fully
implemented. In cases where current data is not
available, the default is to use the latest known data

2.f
Packet Pg. 1047 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 953 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 166
Letter Commenter Date Comment Combined Response
Individuals (C)
incorrectly noted)
-- Possible Map error. Ridgelines seem
incomplete? Are there none in Milagra, North
Pacifica, or south near the southern border?
p 3.1-17 (p 215). Impact Criterion 2 of Significance
is worded unclearly. This may be “boiler plate” but
the terminal phrase is ambiguous. “…adopted for
the purpose…effect;” Who adopted? – the City or
the other agency?
sec 3.14 Wildfire - entire section repeated nearly
ver batim, starting real PDF p751 & 776. 2nd is a
bit different & looks like it is the right one?
sec 3.14 non-standard section numbering: pages
omit the section, i.e “1,2,3,4...). Should use 3.14-1,
etc.
sec 3.14 “p2” (real p. 751) Typo: Fig (Fire Threat)
should be 3.14-1 not 3.14-2 . This Fig. ref is correct
in the redundant section following (p776).
sec 3.14 “p7” (p. 779) Ungrammatical sentence
under SIGNIF CRITERIA: “Implementation…have an
impact..if located…in zones, it would:” =run-on
sentence
p3.3-56 (p 336) Footnote 2 dated “2012” is either
very old, or a typo for 2021 the previous note. This
affect the next citations too, both of which are ibid
and referring to the same very old ref..
p3.4-5 GHGs (p340) Poorly worded 1st sentence of
¶2: “remains under debate” is a poor choice of
words. Better to say “remains subject to poorly
understood uncertainty, so predictions must
consider a range.” This is not debate, it is science.
p3.4-7 (p342) The first 2 of 3 bullet points are
nearly irrelevant for Pacifica. This is someone’s
copied boiler-plate - is that what we paid for?
p3.4-23 (p358) Both footnote citations are
incorrect. FN34 does not agree with Biblio citation
p6-2,
(p849) in title or year; FN34 year disagrees–“US D
of E 2014” is shown as 2013 in Biblio (p6-3)
(p1013) http://www.afdc.energy.gov/fuels/
to depict the baseline (i.e., existing conditions). The Proposed Project
covers approximately a 20-year planning period, and
the year 2040 represents the last year of the plan
when projects/programs are anticipated to be fully
implemented.

DEIR p. 3.1-4, Figure 3.7-3:The comment is noted;
map edits will be made for clarity.

DEIR p. 3.1-12: The City has prepared a draft of the
LCP Update in 2019, approved by the City in 2020,
and which is currently under review for certification
by the California Coastal Commission.

DEIR p. 3.1-14, Figure 3.1-3:The comment is noted;
map edits will be made for clarity.

DEIR p. 3.1-17: This text has been directly taken from
CEQA, therefore no change required.

DEIR p. 3.14-1: The comment is noted. This issue was
resolved in the updated DEIR uploaded made
available on the Plan Pacifica website on February 14,
2022.

DEIR p. 3.14-1: The comment is noted. The issue with
numbering of the figure was resolved in the updated
DEIR uploaded made available on the Plan Pacifica
website on February 14, 2022.

DEIR p.3.14-7. The comment is noted.

DEIR p. 3.3-56: References will be updated to reflect
the latest data used in analysis.

DEIR p. 3.4-5: GCC is now generally accepted;
however, the precise extent and speed of change to
be expected, and the exact contribution from human
sources, remains under debate.

DEIR p. 3.4-7: The comment is noted.

DEIR p. 3.4-24: References will be updated to reflect
the latest data used in analysis.

References will also be updated to reflect the latest
data used in analysis. These edits do not change any
findings of significance.

2.f
Packet Pg. 1048 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 954 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 167
C31: Bradley Angel, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C31-1 Bradley Angel 3/7/22 Comments on Draft Environmental Impact Report for the Pacifica General Plan and Sharp Park Specific Plan
An Environmental Impact Report is supposed to
evaluate the potential impacts of the City of Pacifica’s General Plan and the Sharp Park Specific Plan. While
the Draft EIR contains a lot of information and
provides some good analysis, parts of it are deficient
and fail to fully evaluate some potential negative and
significant impacts of the two plans.

As 21-year Pacifica residents, homeowners and
taxpayers, we agree with the broad goal of the
general planning process to “create economic
development,” “support sustainable practices,” and
“preserve open space.” Very importantly, the plan
must protect our quality of life as the City strives to increase tourism and economic development. The
City must do better than it has it recent years to
protect the quality of life and preserve what makes
Pacifica a great place to live.

Open Space Preservation and Trail System Expansion
– and becoming a tourist destination We strongly
support Open Space Preservation. However, we have
concerns about the draft plan’s reference to “allowing
limited development” in areas that should remain
open space. The ocean, beaches and hills of Pacifica
are integral to our community’s identify. Our open
spaces and environment need to be preserved in
reality, not just in words in an EIR or plan.

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

C31-2 Bradley Angel 3/7/22 Since the pandemic, the beach and area along Beach Boulevard have seen an enormous increase in
visitation by people coming to our community.

Unfortunately, the City has not kept up with the
resulting litter, illegal dumping, parking congestion,
and increased traffic including on neighborhood
streets including where we live. The EIR must address
and provide solutions for these negative and
significant impacts.

The comment is noted. Litter, illegal dumping,
parking congestion, and increased traffic are not
required topics of analysis under CEQA. The
comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C31-3 Bradley Angel 3/7/22 Sustainable Development and Practices, including better zoning to protect the health and well-being of
residents We fully support green building and
sustainable development. We also support planning
that takes into consideration the reality of rising sea levels caused by climate change. Rising sea levels
need to be considered in all planning and permit
decisions.

The comment is noted. See response to comment
C13-3 for more information about coastal flooding
and sea level rise
C31-4 Bradley Angel 3/7/22 Pacifica should also work to reduce greenhouse gas emissions.

The comment is noted. As the comment does not
address the adequacy of the environmental analysis
contained in the DEIR, no further response is

2.f
Packet Pg. 1049 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 955 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 168
Letter Commenter Date Comment Combined Response
Individuals (C)
required. Analysis of GHG impacts are discussed in
DEIR Ch 3.4
C31-5 Bradley Angel 3/7/22 Rising Sea Levels and Beach Boulevard area development including Hotel Concept We applaud the
City for generally taking the threat posed by sea level rise caused by climate change seriously, but
unfortunately not seriously enough. As the State of
California’s scientists project that sea levels may rise up to 7 ½ feet by the end of the century (California
Coastal Commission) it is an invitation to economic
disaster and makes no sense to propose a hotel at the
site of the former wastewater treatment plant. Beach
Boulevard frequently is flooded, with waves
increasingly crashing into the street and even onto
the properties of Beach Boulevard homes. The City
should explore a more appropriate use of that
property such as a modest ocean-front seafood
restaurant or food-truck space that would not have
the size, footprint or infrastructure that a hotel would have.

The comment is noted. Please see response to
comment C13-3 for more information about coastal
flooding and sea level rise.

C31-6 Bradley Angel 3/7/22 In west Sharp Park, the failing shoreline protection (aka “seawall”) has not been reinforced, and the
vulnerable infrastructure behind it has not been
moved. Instead of proposing to scale back allowable
development to mitigate existing and future
inevitable risks, these planning documents
recommend increased intensity and also promoting
the tallest buildings Pacifica has ever allowed. Some
of these four- to five-story buildings, suggested for
affordable housing, would be located north of San
Jose Avenue, which is a mere block away from the
most vulnerable section of shoreline in West Sharp
Park. This does not meet the standards for
sustainable development – and, if built, would pass
the buck to those who have risked their livelihoods to
live or try to build a business based on the city’s lack of transparency.

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

C31-7 Bradley Angel 3/7/22 Sharp Park Specific Plan Visualization The visualization developed by consultants of what
Palmetto and adjacent buildings might look like is a
portrayal of ugly, box architecture with zero
architectural and cultural appeal. We totally oppose
the idea for tall, multi-story buildings higher than
what is currently in existence. We do not need, and
do not want, four or five story buildings in our
neighborhood. We do not want high density
buildings. This would completely change the character
of the neighborhood in a terrible way, adding
eyesores, blocked views, and congestion.

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

C31-8 Bradley Angel 3/7/22 Affordable Housing and Diversity Pacifica needs substantially more truly affordable
housing. As home prices and rental prices in Pacifica
continue to soar, our community is becoming yet
another San Francisco area community that is no
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see

2.f
Packet Pg. 1050 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 956 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 169
Letter Commenter Date Comment Combined Response
Individuals (C)
longer accessible to low income and working class
people and families. Proposing building more housing
without rent control will make the goal of a
sustainable and affordable community impossible to
achieve. The goal of population diversity is truly at
risk. Pacifica already lacks racial diversity, and the cost of housing is an enormous obstacle to a truly diverse
community.

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

C31-9 Bradley Angel 3/7/22 Land Use, Appropriate Zoning, Code Enforcement, Environmental Reviews
The Plan must ensure that the City start properly
managing and properly regulating land use. For
example, an active Recology facility is located on our
residential street, Pacific Avenue and has been a
source of concern for many residents. City staff was
unable to provide us with copies of any use or
operating permit the facility might have – and we
were told there were none. It also appears that the
Recology facility never underwent any environmental
review despite emissions into the environment and
despite being located on a residential street.

There has been little to no oversight of their
operations despite their operations frequently
constituting a nuisance and emitter of pollutants into
our neighborhood. Up until a few years ago, Recology
regularly had their trucks line up in front of our
homes. The trucks would illegally idle their engines,
and the facility manager curiously claimed she was
not aware of the laws restricting and regulating idling.

It was only after we documented the idl ing, filed
complaints with the Bay Area Air Quality
Management District, complained directly to the
facility manager, and threatened to take legal and
public action to shut the facility that the idling
stopped. Where was the City?
However other problems continued, including noxious
odors from operations inside their facility and on the
public sidewalk. In the last two months the problem
has improved somewhat due solely to our complaints
to the City and Bay Area Air Quality Management
District. Recology often has used the public sidewalk
as a place they use for their business operations.

Employee and company vehicles have often been
parked partially on the sidewalk, forcing pedestrians
to walk in the street – clearly a safety hazard. Last
year Recology had a truck sized container on Palmetto
just south of Pacific Avenue for many months,
blocking the view for motorists when turning from
Pacific onto Palmetto. Did Recology apply for and
receive a permit to leave this on the public street for months? I am sure residents are not allowed to use
the public street and block the public sidewalk for
their own purposes as an ongoing practice.

The comment is noted. The City implements a
variety of local, State and federal regulations
designed to address the use, transportation, and
disposal of these materials. Although such activities
are relatively well regulated and monitored,
accidental release due to accidents, misuse or
natural disasters (e.g., earthquakes) could occur.

Additional residential, commercial, and industrial
development resulting from buildout of the
Proposed Project would likely increase the amount
of hazardous materials transported, used or
disposed of in the City. Although a number of
businesses in the Planning Area routinely store,
handle, and transport hazardous substances, the
use of these hazardous materials is controlled and
permitted by San Mateo County’s Toxic Programs
and regulations, and otherwise ensures that risks
associated with the use of hazardous materials in
the community are minimized.

Compliance with federal, State and local
regulations, combined with Proposed Project
policies outlined below, will reduce the potential for
a significant adverse effect on the environment, due
to upset and accident involving the use, transport,
and disposal of hazardous materials, to a less than
significant level.

2.f
Packet Pg. 1051 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 957 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 170
Letter Commenter Date Comment Combined Response
Individuals (C)
In addition, Recology was able to get away with not
maintaining the corner landscaping on Palmetto and
Pacific Avenue. For almost a year it was essentially an abandoned, weed covered lot, despite Recology’s
promise to the city to maintain the lot as part of
neighborhood improvements in exchange for the
public relations signage. It was only after we
complained to the Mayor and City Council that the
company finally cleared the weeds. It is obvious the
city looks the other way when it comes to Recology,
favoring a big corporation over the health and wellbeing of residents.

C31-
10 Bradley Angel 3/7/22 The Draft EIR fails to address the reality of these types of situations and identify potential and actual
significant negative impacts.

The City’s Plan and Zoning ordinance should learn
from these problems and prohibit industrial activities
on residential streets and require environmental
reviews for businesses that have the potential to
impact the community and environment.

As shown in the Proposed Land Use Diagram, no
areas of industrial use are proposed as part of the
General Plan; however, commercial service uses or
other commercial uses may use or transport
hazardous materials. CEQA requires analysis of how
implementation of the proposed Pacifica General
Plan and SPSP could create a significant hazard to
the public or the environment through reasonably
foreseeable upset and accident conditions involving
the release of hazardous materials into the
environment (Impact 3.11-2).

As noted, The City implements a variety of local,
State and federal regulations designed to address
the use, transportation, and disposal of these
materials. although such activities are relatively
well regulated and monitored, accidental release
due to accidents, misuse or natural disasters (e.g.,
earthquakes) could occur. Additional residential,
commercial, and industrial development resulting
from buildout of the Proposed Project would likely
increase the amount of hazardous materials
transported, used or disposed of in the City.

Although a number of businesses in the Planning
Area routinely store, handle, and transport
hazardous substances, the use of these hazardous
materials is controlled and permitted by San Mateo
County’s Toxic Programs and regulations, and
otherwise ensures that risks associated with the use
of hazardous materials in the community are
minimized. Furthermore, the proposed Plan
includes several policies, set forth below, that have
been developed to ensure a safe environment for
its residents, visitors, and businesses. Policies in the Proposed Plan that also reduce impacts include
enforcement of NDPES permits (SA-I-19) and
protection against oil and hazardous substance
spills (CO-I-18).

C31-
11 Bradley Angel 3/7/22 To show that it is serious about protecting community health and sustainability while supporting businesses
and economic development, the City should work
with Recology to relocate the Pacific Avenue facility to As a programmatic document, this EIR presents a
citywide assessment of the potential impacts of the
proposed Pacifica General Plan. It does not assess
project-specific impacts of potential future projects

2.f
Packet Pg. 1052 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 958 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 171
Letter Commenter Date Comment Combined Response
Individuals (C)
a more appropriate location.

As the City Plan calls for increased economic
development, this must be accompanied by proper
environmental review, proper permitting processes
with opportunities for public participation,
enforcement against violations of permits or other
laws, and appropriate siting of businesses to avoid
negative impacts on the health and well-being of
residents.

Recreational Opportunities and Activities for Youth
We support increased opportunities, activities and
facilities for the youth of our community.
under the proposed Plan, all of which are required
to comply with CEQA as applicable.

2.f
Packet Pg. 1053 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 959 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 172
C32: Andrew Meiman, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C32-1 Andrew
Meiman
3/7/22 We have lived on Pedro Point for 17 years, raising our kids here, and enjoying all the natural beauty and
outdoor recreation that Pacifica, and Pedro Point in
particular, provides. Unfortunately, the GPU and the
Draft EIR threaten those very items that make the
Point special. We disagree with the Land Use
designation change for the Pedro Point Field to
Coastal Residential Mixed Use (CRMU). It will
negatively impact the quality of life for us and our
family in many ways.

Additionally, as long-term residents of Pacifica who
plan to live here the rest of our days, I don't want the City, or my community, to be stuck with the costs and
impacts of a housing development built on a wetland
next to a rising sea.

We fully support the comments of Pedro Point
Community Association and the many other
community members from the neighborhood and
beyond that recommend a more appropriate land use
designation such as Low-Intensity Visitor Serving
Commercial.

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

T. Please see Master Response 6: ESHA for more
information on how implementation of the
Proposed Project will have a less than significant
impact on wetlands, which are classified ESHA
under the Coastal Act. Please see Master Response
4: Undeveloped San Pedro Ave Sites for more
information on how compliance with federal, state,
and local regulations, as well as Proposed Project
policies, reduce the impact to less than significant.

2.f
Packet Pg. 1054 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 960 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 173
C33: Richard Campbell, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C33-1 Richard
Campbell
3/8/22 Planning for a City that the State wishes to grow by nearly 2,000 homes (i.e., the Regional Housing
Needs Allocation) necessitates careful consideration
of a wide variety of environmental issues, including
water supply. The City must take into consideration,
and provide itself the flexibility, to limit water
consumption for new development so that it does
not over-build relative to available water supply.

The DEIR correctly used a reasonably foreseeable
forecast of buildout under the Proposed Project as
the basis for the environmental analysis. The
adequacy of buildout and more information about
why RHNA estimates were not included can be
found in Master Response 3: Buildout and RHNA.

C33-2 Richard
Campbell
3/8/22 The City’s environmental review of the General Plan should involve a review of NCCWD’s Urban Water
Management Plan (UWMP), which NCCWD. The City
environmental review should reflect a consideration
of projected water supplies in NCCWD’s recently
updated 2020 UWMP, released in June of 2001, as
part of this new General Plan.

See response to comment C9-26.

C33-3 Richard
Campbell
3/8/22 In the draft General Plan, the City indicates it will undertake a planning and community engagement
process to update the Housing Element and
accommodate its 6th Cycle Regional Housing Needs
Allocation (RHNA 6) of 1,892 housing units following
adoption of the other required elements of the
General Plan. Adoption of a Housing Element to
reflect RHNA 6 must occur by January 31, 2023. The
City must do more now to link the available supply
of water, and projected water shortages discussed
in the 2020 UWMP, to the Housing Element under
development as well as the current 5th Cycle RHNA
(RHNA 5) currently in effect.

Please see response to comment C33-1.The
Housing Element update and development of the
required housing sites inventory will involve
extensive community input and be subject to
separate CEQA review. The Housing Element CEQA
document will analyze the cumulative effects of
implementing the Housing Element Update –
including associated changes to the land use
diagram - in combination with the Proposed
Project. Therefore, this approach does not
constitute “piecemealing,” or dividing a large
project into separate parts, each of which might
have individually minimal environmental
consequences. Please see Master Response 3:

Buildout and RHNA for more information.

C33-4 Richard
Campbell
3/8/22 NCCWD acknowledged in its 2020 UWMP (pg. 3)
that:

This Plan provides information specific to water
management and planning by the District. However,
water management does not happen in isolation;
there are other planning processes that integrate
with the UWMP to accomplish urban planning.

Some of these relevant planning documents include
relevant city and county General Plans, District
Water Master Plans, recycled water facility plans,
integrated resource plans, Integrated Regional
Water Management Plans, and others.

This Plan is informed by and helps to inform these
other planning efforts. In particular, this Plan
utilizes information contained in General Plans,
climate action plans, local hazard mitigation plans,
and local and regional water resource plans to the
extent data from these plans are applicable and
available. (Emphasis added.)
Yet, the City does not acknowledge this 2020
UWMP, nor address water supply, or even make
The DEIR acknowledges and references NCCWD's
2020 UWMP. See response to comment C9-26.

2.f
Packet Pg. 1055 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 961 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 174
Letter Commenter Date Comment Combined Response
Individuals (C)
mention of NCCWD. NCCWD has it right: The City
must integrate water management to effectively
accomplish urban planning. To not do so,
particularly as we head into year three of a
megadrought of unknown duration, is the definition
of arbitrary and capricious decision-making.

Whether the City acts in an arbitrary and capricious
manner is measured by what the City knew at the
time the General Plan (and the Housing Element) is
adopted. And the City is aware of the possibility of
significant shortfalls in water supply from the 2020
UWMP. Thus, the availability of adequate waters
supply to accomplish the City’s land use and
housing goals must be addressed as part of its
environmental review.

2.f
Packet Pg. 1056 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 962 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 175
C34: Richard Grassetti, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C34-1 Richard
Grassetti
3/8/22 Grassetti Environmental Consulting (GECo) is
submitting this comment letter on behalf of the Pedro
Point Community Association (PPCA). As Principal of
GECo, I have prepared these comments based on my
40 years of experience preparing and reviewing
California Environmental Quality Act (CEQA)
documents. A copy of my CV is attached.

Summary of Findings
The PPCA requested a thorough evaluation of the
potential effects of the General Plan Update (“GPU” or
“the Project”) on the undeveloped San Pedro Avenue
Site (“the Site” or “San Pedro Avenue Site”). This letter identifies deficiencies in the General Plan Update Draft EIR (“DEIR”) with respect to the Site. It is based on my reading of the proposed GPU and DEIR, as well as a
review of sensitive resources and hazards from
available sources. General deficiencies are described
first, followed by some specific comments on the
adequacy of technical analyses. Under CEQA, the GPU
DEIR must focus not only on the direct impacts, but
also on the secondary effects that will follow from
adoption of the General Plan update (CEQA Guideline
15146). The City is not relieved from considering
reasonably foreseeable impacts of the Project on
specific parcels, including the Site here. Given the
voluminous information provided by experts on the
undeveloped San Pedro Avenue Site, including
extremely detailed evidence presented in the California Coastal Commission 2020 Staff Report on the Rhodes
Mixed Use Development (“CCC Staff Report”) proposed
for the Site, this GPU and DEIR must consider that
information, submitted herewith. The land use
designations are the heart of the General Plan. Because the General Plan serves as “the constitution for all
future developments” within the City once a land use
for a site is designated, applicants have certain
development rights. Therefore it is essential that the
City of Pacifica (“City”) fully consider environmental
values and constraints prior to re-designating parcels, not after a parcel is redesignated. This GPU fails to do that, and, as detailed below, the DEIR fails to
adequately or accurately assess impacts of the
proposed re-designation of the undeveloped San Pedro
Avenue Site.

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

The DEIR does consider impacts resulting from a
land use change designation; impacts related to
flooding, biological resources, and others are
adequately analyzed in the DEIR. Please see Master
Response 4: Undeveloped San Pedro Ave Sites for
more information.

C34-2 Richard
Grassetti
3/8/22 Inadequacy of Project Description
The DEIR must present a clear and stable project
description. The DEIR’s project description is
inadequate because it fails to narratively or graphically identify which specific areas/parcels would be redesignated or changed by the Project. Instead, the DEIR focuses solely on general buildout numbers, as if site
conditions were uniform throughout the City.) This
The Proposed Project land use is shown in Figure

2.2-1. The existing Project Land Use is shown in
Figure 3.1-1. Comparison of these two maps shows
land use designation changes. The Proposed Project
provides concentrated and compact development
primarily in already developed areas, with policies
to provide more linkages and enhanced connectivity
within and between those areas. As noted on DEIR

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failure makes it very difficult for the reader to
understand how various areas of the City would be
affected by implementation of the proposed Project.
p. 3.1-20, the “Proposed Project includes new land
use designations that replace older and more
generic land use designations in the same or nearby
areas; the new land use designations accommodate
more diverse housing types, densities, and
commercial developments, primarily in alreadydeveloped areas. There are three mixed use classifications to create areas where housing and
active commercial uses may be integrated.” As
shown in Table 2.4-2, approximately 76 percent of
new units are projected to occur in these new
mixed use classifications, shown in Figure 2.2-1. The
remaining units would be accommodated in smaller
vacant “infill” lots found primarily in the West Sharp
Park, East Sharp Park, Westview-Pacific Highlands,
Rockaway, and Pedro Point neighborhoods; these
vacant parcels are shown on the existing land use
map, Figure 3.1-1. Given environmental factors such
as slope and sensitive species, there are some
constraints on the development potential of these
sites.

C34-3 Richard
Grassetti
3/8/22 DEIR Land Use Chapter 3.1 does include a very smallscale map of existing land use designations, which, critically shows the undeveloped San Pedro Avenue
Site land use designation as “Commercial” but omits
consideration that the Site is zoned “Commercial
Recreation”. The General Plan states, “The land directly west of the Pedro Point Shopping Center was identified
as a commercial recreation site in the previous General Plan, and has been zoned for general commercial
uses.” By failing to include this information, the DEIR does not serve its informational disclosure
requirement. The public should not be forced to ferret
out information and connect the dots to understand
the Project and its impacts. This combination of
incomplete and incorrect information renders the DEIR
Project Description useless as the basis for determining impacts of the proposed GPU. Given the limited
number of sites proposed for designation changes in
the GPU, the DEIR should clearly identify them
narratively and graphically, and include
Zoning is a tool to implement land use; any rezoning
would occur after the Proposed Plan is adopted.

Omission of zoning descriptions thus do not
represent a withholding or inadequacy.

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

C34-4 Richard
Grassetti
3/8/22 Further, the DEIR project description compares the Project to the existing plan, but does not provide the
necessary information on existing on-the-ground
conditions from which to conduct the impact
assessment. With limited exceptions, CEQA does not
permit plan-to-plan analyses. Per the CEQA Guidelines
(Section. 15126.2) “In assessing the impact of a
proposed project on the environment, the lead agency
should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published, or where no notice of preparation is published, at the
time environmental analysis is commenced.”
The DEIR does include existing, on-the-ground land
use; these uses are shown in Figure 3.1-1. The
commenter does not provide an example of a "planto-plan" analysis. All "Environmental Settings" chapters describe existing, on-the-ground
conditions for each of the corresponding chapters.

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C34-5 Richard
Grassetti
3/8/22 In order to adequately evaluate environmental
impacts, the DEIR must identify which parcels are
undeveloped, what their existing physical condition is, and how conditions would change with reasonably
foreseeable development allowed under the proposed
Project. The actual impacts would be the difference
between the existing undeveloped state and full
development of a site under the new designation.

The DEIR describes and maps vacant and
undeveloped land on DEIR p. 3.1-2 through 3.1-4. As
noted in Master Response 3: Buildout and RHNA,
For the DEIR, a projection of likely buildout of the
Proposed Plan was developed based on the realistic
potential for development in the Planning Area. As
noted on DEIR p. 2-20, buildout is calculated based
on assumptions about new residential and nonresidential development that could be built under the Plan’s land use designations and their respective
densities and intensities, adjusted to match
expected demand” as assessed through an adjusted
regional projection from the 2019 Association of
Bay Area Governments 2040 growth forecasts. To
identify areas of possible change, vacant and
underutilized parcels were identified, and capacity
was projected based on economic and market
conditions, historical growth trends, and approved
development in the pipeline.

Buildout projections were calculated on a parcel
basis; however, the assumptions for particular sites
do not guarantee that any given site will be
developed or redeveloped with that use or assumed
density during the planning period, as future
development will rely primarily on each property
owner’s initiative. Cumulatively though at the
citywide level these projections represent a
reasonably foreseeable basis for assessing the
environmental impacts that could result from
Proposed Plan implementation.

Cal Code Regs. Tit. 14§ 15144 recognizes that
drafting an EIR necessarily involves some degree of
forecasting and requires that the lead agency “use
its best efforts to find out and disclose all that it
reasonably can.” Further, the statute allows for the
use of projected future conditions that are
supported by reliable projections based on
substantial evidence in the record.

Furthermore, using maximum theoretical buildout
as the basis for the CEQA analysis would exaggerate

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Packet Pg. 1059 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 965 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 178
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impacts and result in mitigation measures requiring
the construction of road and utility infrastructure in
excess of what is need to support growth resulting
from the Proposed Plan. Therefore, the DEIR
correctly used a reasonably foreseeable forecast of
buildout under the Proposed Plan as the basis for
the environmental analysis. All settings sections in
the DEIR describe how implementation of the
Proposed Project could generate significant impacts
over current conditions and describes federal, state,
and local regulations and policies to reduce those
impacts.

C34-6 Richard
Grassetti
3/8/22 Inadequate Project Objectives
The DEIR’s stated Project Objectives (pp. 2-9 and 2-10) are so general and vague that they cannot be
effectively used to fulfill their primary purpose, namely to guide development and assessment of an adequate
range of alternatives.

The assertion that the project objectives are vague
is unfounded. As described in CEQA, "A clearly
written statement of objectives will help the lead
agency develop a reasonable range of alternatives
to evaluate in the EIR and will aid the decision
makers in preparing findings or a statement of
overriding considerations, if necessary. The
statement of objectives should include the
underlying purpose of the project and may describe
project benefits." These objectives informed
development of reasonable DEIR alternatives as
described in Chapter 4.

C34-7 Richard
Grassetti
3/8/22 This deficiency is reflected in the Alternatives chapter (p. 4-2), which substitutes three different “criteria” for use in developing and selecting project alternatives
(although those criteria are similarly vague and
generic).

The CEQA Guidelines require EIRs to describe a
reasonable range of potentially feasible alternatives
to a proposed project or program. That is, the EIR
needs to analyze those alternatives that will help
decision-makers make reasoned choices. The range
of alternatives shall include those that “would

2.f
Packet Pg. 1060 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 966 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 179
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feasibly attain most of the basic objectives of the
project but would avoid or substantially lessen any
of the significant effects of the project” (CEQA
Guidelines, Section 15126.6(a)). “Feasible” means
that the alternatives “are capable of being
accomplished in a successful manner within a
reasonable period of time, taking into account
economic, environmental, legal, social and
technological factors" (CEQA Guidelines, Section
15364). The alternatives contain different land use
categories, densities, and intensities along Palmetto
and at the Quarry site. The differences between the
alternative concepts are described on p. 4-2:

Alternative A, Strong Center at Quarry Site,
establishes one major mixed-use and visitororiented center for Pacifica, and a series of commercial nodes throughout the city; while
Alternative B, Multi-Centered, West Sharp Park
Emphasis, creates a smaller visitor-oriented node at
the Quarry Site and a civic and mixed-use district in
West Sharp Park. Alternative C assumes very little
development on the Quarry Site, and more
intensive transit-oriented development at several
nodes. The General Plan and Specific Plan most
closely resemble Alternative B, which becomes the
Alternative 2:"Proposed Plan".

C34-8 Richard
Grassetti
3/15/2
2 Inadequacy of Impact and Mitigation Discussion
The DEIR fails to disclose that the undeveloped San
Pedro Avenue Site is currently zoned commercial
recreation, with a floor area ratio (FAR) of 0.2, which means that total development footage cannot exceed
20% of the site area. This current designation promotes non-intensive recreational use of the Site, retaining
most of the Site in open space. If, for example, a 2-
story recreational facility were constructed, only 10%of the San Pedro Avenue Site would be disturbed, and
sensitive resources and environmental hazards on the
remainder of the Site could be avoided.

The GPU would re-designate the Site as Coastal
Residential Mixed Use, which would allow housing or
commercial uses at an FAR of 0.5 (DEIR Figure 2.1-2 and table 2.3-
1). That FAR does not include roads or parking, which
could result in further environmental impacts. The DEIR fails entirely to address potential Project impacts at this Site, and never even mentions the Site in its impact
analyses.

A program EIR differs from a project EIR, which is
the most common type of EIR and examines the
environmental impacts of a specific development
project. A project EIR “should focus primarily on the
changes in the environment that would result from
the development project [and] examine all phases
of the project including planning, construction, and
operation.” (CEQA Guidelines, Section 15161; In re
Bay Delta etc. (2008) 43 Cal.4th 1143, 1169.)
As a programmatic document, this EIR presents a
citywide assessment of the potential impacts of the
proposed Pacifica General Plan. It does not assess
project-specific impacts of potential future projects
under the proposed Plan, all of which are required
to comply with CEQA as applicable.

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Packet Pg. 1061 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 967 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 180
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C34-9 Richard
Grassetti
3/8/22 For most topics, the DEIR only provides overgeneralized statements of impacts, lists plan policies, and then assumes – without explanation - that the
policies would effectively reduce all impacts to lessthan-significant levels, without any analysis of the prepolicy impact or the actual applicability and effectiveness of the policies to the impact. In contrast, for traffic, the DEIR does conduct an intersectionspecific assessment. This shows that it is possible for the DEIR to conduct a site-level analysis for the areas where changes in land use are proposed. The DEIR
should be revised to conduct those analyses for all of
the resource categories.

The commenter's assertion is unfounded. As a
programmatic document, this EIR presents a
citywide assessment of the potential impacts of the
proposed Pacifica General Plan. It does not assess
project-specific impacts of potential future projects
under the proposed Plan, all of which are required
to comply with CEQA as applicable. The commenter
does not cite specific examples in this comment of
where analysis is inadequate. As noted in CEQA
Guidelines Article 10, 15142, qualitative analysis is
permitted: "An EIR shall be prepared using an
interdisciplinary approach which will ensure the
integrated use of the natural and social sciences and
the consideration of qualitative as well as
quantitative factors."
The DEIR includes an adequate environmental
setting description. It describes the existing local
and regional physical environment, as it existed
when the notice of preparation of the EIR was
published in September 2020. This specific
comment does not highlight any specific examples
of inadequate environmental settings.

The DEIR adequately addresses Project impacts for
each of the required topics under CEQA. The DEIR
analyzes the impact of the policies by focusing on
where and what type of development the plan
would allow. Then it also considered the beneficial
impacts of the policies and the extent to which they
would reduce or avoid impacts in conjunction with
existing regulations. As a programmatic document,
this EIR presents a citywide assessment of the
potential impacts of the proposed Pacifica General
Plan. It does not assess project-specific impacts of
potential future projects under the proposed Plan,
all of which are required to comply with CEQA as
applicable.

Impacts on intersections does not represent a sitespecific analysis; it analyzes effects of cumulative buildout under the Proposed Plan and projects
future traffic flows. Air quality, Energy and GHG,
Noise, and Public Utilities all take this similar
cumulative Citywide approach.

C34-10 Richard
Grassetti
3/8/22 In short, the DEIR fails to go through CEQA’s required steps of first disclosing impacts and whether those
impacts are potentially significant, and only then
discussing proposed mitigation measures including
their feasibility. As the court stated in Trisha Lee Lotus v. Department of Transportation:
“The purposes of Section 21801 are that there be some
evidence that the alternatives or mitigation measures
in the EIR were considered by the decision-making
agency and, as the Supreme Court stated in a similar
situation, that there be a disclosure of the analytic
The commenter's allegation that the DEIR did not
adequately analyze impacts is untrue. Each of the
analysis chapters in the DEIR include an
environmental settings section, which describes onthe-ground conditions. Impacts analysis focused on how where and what type of development the plan
allows might lead to significant impacts for CEQArequired topics. Then, it also considered the beneficial impacts of the policies and the extent to
which they would reduce or avoid impacts in
conjunction with existing regulations. Proposed

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Packet Pg. 968 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 181
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route the…. agency traveled from evidence to action.”
And, “The EIR does not, however, include any
information that enables the reader to evaluate the
significance of these impacts.” (p.13) “Caltrans
compounds this omission by incorporating the
proposed mitigation measures into its description of
the project and then concluding that any potential
impacts from the project will be less than significant. As the trial court held, the “avoidance, minimization,
and/or mitigation measures”, as they are characterized
in the EIR, are not “part of the project”. By compressing the analysis of impacts and mitigation measures into a
single issue, the EIR disregards the requirements of
CEQA.” (p. 15).

Project policies are not intended to act as mitigation
measures; rather, they are policy statements
indicating actions the City will take on an ongoing
basis as the Proposed Project is implemented and
the DEIR has correctly considered the effects of
implementing these policies, including any
beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project.

C34-11 Richard
Grassetti
3/8/22 Here, the proposed changes in land use designations would cause the loss of biological resources,
recreational resources, and flood storage from the Site.

The DEIR must first disclose and analyze those impacts, determine the significance of each impact, and then
discuss whether and how general plan policies and
mitigation would reduce the impact. The applicability
of policies must be identified, as well as their
effectiveness. If policies are assumed to be mitigation, then they must be presented in a manner that assures
their implementation on any particular site.

Please see also responses to Comment C34-17 and
C46-46. Proposed Project policies are not intended
to act as mitigation measures; rather, they are
policy statements indicating actions the City will
take on an ongoing basis as the Proposed Project is
implemented and the DEIR has correctly considered
the effects of implementing these policies, including
any beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project.

Please also see response to comment C34-11 for
more information about policies that reduce the
impacts.

The DEIR analyzes impacts to potential biological
resources in Chapter 3.7, flooding in Chapter 3.5,
and parks, public services, and facilities in Chapter

3.12. Please see Master Response 4: Undeveloped
San Pedro Ave Sites for more information on.

C34-12 Richard
Grassetti
3/8/22 California courts have made it clear1 that cities are not obligated to implement all of the General Plan’s
policies applicable to a site, therefore the GPU’s
Proposed Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take on
an ongoing basis as the Proposed Project is

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Packet Pg. 1063 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 969 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 182
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proposed policies cannot be assumed to mitigate for
development of a site under the GP.
implemented and the DEIR has correctly considered
the effects of implementing these policies, including
any beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project. Some objective policies require
implementation, such as those that require specific
studies, or that would be implemented through
zoning changes.

As a program EIR, the preparation of this document
does not relieve the sponsors of specific projects
from the responsibility of complying with the
requirements of CEQA. As noted, individual projects
are required to prepare a more precise, projectlevel analysis to fulfill CEQA requirements. The lead agency responsible for reviewing these projects
shall determine the level of review needed, and the
scope of that analysis will depend on the specifics of
the particular project. Should an applicant propose
to develop in an area with sensitive resources or
potential site-specific impacts or in an area of
known hazards, compliance with policies requiring
additional study would be a requirement for project
approval. Any project requiring discretionary
approval is required to make findings of General
Plan consistency and must demonstrate analytically
that the project is consistent with the General Plan,
and how they comply with applicable policies.

C34-13 Richard
Grassetti
3/8/22 Further, applicable measures must be included in a Mitigation Monitoring and Reporting Program. At a
planning level, a more effective, enforceable,
monitorable, mitigation would be to change the
undeveloped San Pedro Avenue Site land use
designation to Open Space or retain the 0.2 FAR
Commercial-Recreation designation, rather than the
proposed intense 0.5 FAR designation.

The comment is noted. Mitigation measures will be
included in an MMRP. The commenter's opinion on
site-specific mitigation measures is noted; however,
programmatic-level impacts are assessed in the
DEIR; not site-specific impacts. Please see response
to comment C30-5 and C34-12 for more
information, as well as Master Response 2:

Programmatic EIR, and Master Response 4:

Undeveloped San Pedro Avenue Sites.

C34-14 Richard
Grassetti
3/8/22 However, given CEQA’s requirement to compare
impacts of a project (or plan) to existing on-the-ground conditions, impacts of development even at an FAR of

0.2 must be assessed, and mitigated to the extent
feasible. This is particularly important given CEQA’s
infill exemptions. It is likely that, for some of the sites, no additional CEQA review will occur, and the impacts
will not be addressed at all. This DEIR’s lack of detailed analysis would allow the City to play a shell game in
deferring analysis that may never occur, and thereby
fails to meet CEQA’s purpose of full disclosure.

Please see Master Response 3: Buildout and RHNA
for more information on the adequacy of buildout
projections.

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Packet Pg. 1064 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 970 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 183
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As a program EIR, the preparation of this document
does not relieve the sponsors of specific projects
from the responsibility of complying with the
requirements of CEQA. As noted, individual projects
are required to prepare a more precise, project-
level analysis to fulfill CEQA requirements. The lead
agency responsible for reviewing these projects
shall determine the level of review needed, and the
scope of that analysis will depend on the specifics of
the particular project. These projects may, however,
use the discussion of impacts in this EIR as a basis of their assessment of these regional, citywide, or
cumulative impacts. Please see comment C34-12 for
more information on project-level review in areas
with known sensitivities or hazards. Any project
requiring discretionary approval is required to make
findings of General Plan consistency and must
demonstrate analytically that the project is
consistent with the General Plan, and how they
comply with applicable policies.

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Packet Pg. 1065 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 971 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 184
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C34-15 Richard
Grassetti
3/8/22 In summary, the DEIR fails to address the impacts of land use changes proposed under the GPU because it
concludes that GPU policies would mitigate any
undisclosed impacts. In essence, the DEIR claims that
the Project would mitigate itself – despite the fact that there may be significant unmitigable impacts of
implementing the proposed land use designations on a
given site, as is the case for the undeveloped San Pedro Avenue Site.

The DEIR analyzes effects implementation of the
locations, proposed land uses, land uses and
buildout estimate under proposed under the
Proposed Plan. Please see Master Response 3:

Buildout and RHNA for more information. Each of
the analysis chapters in the DEIR include an
environmental settings section, which describes onthe-ground conditions. Impacts analysis focused on how where and what type of development the plan
allows might lead to significant impacts for CEQArequired topics. Then, it also considered the beneficial impacts of the policies and the extent to
which they would reduce or avoid impacts in
conjunction with existing regulations. Proposed
Project policies are not intended to act as mitigation
measures; rather, they are policy statements
indicating actions the City will take on an ongoing
basis as the Proposed Project is implemented and
the DEIR has correctly considered the effects of
implementing these policies, including any
beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project.

Please see response to comment C34-12. As a
program EIR, the preparation of this document does
not relieve the sponsors of specific projects from
the responsibility of complying with the
requirements of CEQA. As noted, individual projects
are required to prepare a more precise, projectlevel analysis to fulfill CEQA requirements. The lead agency responsible for reviewing these projects
shall determine the level of review needed, and the
scope of that analysis will depend on the specifics of
the particular project. Should an applicant propose
to develop in an area with sensitive resources or
potential site-specific impacts or in an area of
known hazards, compliance with policies requiring
additional study would be a requirement for project
approval. Any project requiring discretionary
approval is required to make findings of General
Plan consistency and must demonstrate analytically
that the project is consistent with the General Plan,
and how they comply with applicable policies.

C34-16 Richard
Grassetti
3/8/22 A City may approve a project if it “substantially complies” with the planning policies– full compliance is not required. This means that assuming full
implementation of policies is a best-case scenario, not a likely scenario as required for CEQA review.

Please see response to comment C34-12
C34-17 Richard
Grassetti
3/8/22 Also, many of the plan policies are couched in language such as “to the extent feasible”, “strive to”, “study”, “consult with”, ‘coordinate with” and similar vague,
non-committal terms that fail to assure that mitigation will be implemented or, if implemented, will be
successful in reducing a project’s impacts to a lessThe DEIR identifies the potential environmental impacts that could result from implementation of
the Proposed Project and discusses the effects that
existing regulations and Proposed Project policies
would have in reducing or avoiding those impacts.

In cases where compliance with existing regulations

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Packet Pg. 1066 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 972 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 185
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thansignificant level. There are numerous examples of
this in the Plan, including Policies CO-G-3, CO-I-1, CO-G4, CO-I-19-23, SA-I-29, SA-I-109, SA-I-12, and many, many more. In addition, as can be seen in these
examples and many others, in many cases, the City
relies on policies that assume mitigation by other
agencies and jurisdictions over which it has no control. and implementation of Proposed Project policies
would not reduce a potentially significant impact to
a less than significant level, the DEIR recommends
feasible mitigation measures and makes a finding of
significance after implementation of mitigation.

Proposed Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take on
an ongoing basis as the Proposed Project is
implemented and the DEIR has correctly considered
the effects of implementing these policies. Further,
the City notes that subsequent projects pursuant to
the Proposed Project will be required to conducted
separate project-level CEQA review to the extent
they may result in impacts not considered in the
DEIR.

Please see response to comment x for more
information on agency responsibility.

C34-18 Richard
Grassetti
3/8/22 Under CEQA mitigation measures must include
performance standards, rather than just aspirational
goals or deferred studies. The DEIR must also translate these policies to enforceable measures before it can
consider any potentially significant impacts to have
been mitigated to less than significant.

Proposed Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take on
an ongoing basis as the Proposed Project is
implemented and the DEIR has correctly considered
the effects of implementing these policies, including
any beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project. Please see response to comment C34-12.

As a program EIR, the preparation of this document
does not relieve the sponsors of specific projects
from the responsibility of complying with the
requirements of CEQA. As noted, individual projects
are required to prepare a more precise, projectlevel analysis to fulfill CEQA requirements. The lead agency responsible for reviewing these projects
shall determine the level of review needed, and the
scope of that analysis will depend on the specifics of
the particular project. Should an applicant propose
to develop in an area with sensitive resources or
potential site-specific impacts or in an area of
known hazards, compliance with policies requiring
additional study and any required mitigation would
be a requirement for project approval. Any project
requiring discretionary approval is required to make
findings of General Plan consistency and must
demonstrate analytically that the project is
consistent with the General Plan, and how they
comply with applicable policies.

C34-19 Richard
Grassetti
3/8/22 The City is required to comply with SB379 as stated in Chapter 1.2, General Plan Requirements: “Climate
Change Adaptation and Resiliency Legislation (SB
The comment is noted. Please see Master Response
1 for more information on GP-related responses.

Climate change and requirements for SB379 are

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Packet Pg. 973 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 186
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379)…requires the safety elements of general plans to
be reviewed and updated to include climate adaptation
and resiliency strategies.” SB379 further requires the
identification of hazard zones that can serve as
mitigation areas for said hazards. Despite this
requirement, the GPU and the DEIR fail to identify any
properties in Pacifica for such mitigation. It is also
insufficient to only set “Coastal Resiliency Policies” but not designate appropriate resiliency sites/areas; areas like the undeveloped San Pedro Avenue Site would
qualify to be designated as hazard mitigation sites due to its many hazard vulnerabilities and ESHA
designation.
included in the MJ-LHMP, incorporated by
reference into the Pacifica GP. All hazard analysis
and description of potential impacts required under
CEQA is present in the DEIR, including landslides
(Impact 3.6-1), erosion (Impact 3.6-2), wildfire
(Impact 3.11-4 and 3.14, 1-4), flooding (Impacts 3.5,
3-4), and greenhouse gases (Impacts 3.4, 1-4).

Impacts to sensitive communities, including ESHA,
are described on p. 3.7-49, Impact 3.7-1. The DEIR
describes special status wildlife in the Planning
Area. All federally and state threatened species are
protected under the Federal Endangered Species
Act and California Endangered Species Act,
respectively. For specific development projects
under the Proposed Project, consultation may be
required with USFWS by FESA, and/or with the
California DFW by ESA. Prior to project construction
under the Proposed Project, the applicant would be
required to conduct biological resource assessments
and pre-construction plant and wildlife surveys at
development sites. Specific provisions of the Coastal
Act, as implemented within the Local Coastal
Program, as they relate to wetlands and other ESHA
are described in the section on Local Ordinances
Plans and Policies. Please see Master Response 6:

ESHA for more information on ESHA on this site.

C34-20 Richard
Grassetti
3/8/22 In addition to rendering the DEIR inadequate, these omissions subvert the basic purpose of planning, which
is to plan so that appropriate land uses can be located so as to avoid or minimize environmental impacts.

Rather than plan for sensitive sites such as the
undeveloped San Pedro Avenue Site, as detailed below,
the City is proposing to adopt non-protective land uses (at the Site, Coastal Residential Mixed Use) and then
use general policies (full compliance with which is not mandatory) relying mostly on deferred studies to
reduce impacts. This approach (and the underlying
DEIR) is inadequate because it uses magical thinking - in theory, the plan policies reduce all impacts to less than significant in spite of on-the-ground evidence to the
contrary – rather than evidence-based analyses.

Please see response to comment 34-12.

C34-21 Richard
Grassetti
3/8/22 Criteria of Significance/Topics Addressed
As detailed in specific comments below, the DEIR fails
to focus its impact analysis to reasonably foreseeable
types of impacts. Instead, the impacts are just the same questions in the standard Initial Study checklist. This is an EIR, not an Initial Study. This DEIR is required to
identify and focus on impacts of importance, not the
items in the CEQA Initial Study checklist. For example, impacts and mitigation measures should be called out
for each special-status species that may be affected by buildout of the plan.

This claim of inadequate analysis is unsubstantiated.

Potential impacts for each of the three special
status species in Pacifica are described on DEIR p.

3.7-49 and 3.7-50. For specific development
projects under the Proposed Project, consultation
may be required with USFWS by FESA, and/or with
the California DFW by CESA. Prior to project
construction under the Proposed Project, the
applicant would be required to conduct biological
resource assessments and pre-construction plant
and wildlife surveys at development sites.

Compensatory mitigation would also be required in
order to offset the loss of or alteration to special

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Packet Pg. 1068 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 974 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 187
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status species’ habitat. Individual special status
species requirements for steelhead (CO-G-9; CO-I-1)
California red legged frog and San Francisco garter
snake (CO-I-37; CO-I-44) are included in the General
Plan.

C34-22 Richard
Grassetti
3/8/22 Specific Comments
We have reviewed the Land Use, Hydrology, Geology,
Recreation, and Alternatives sections of the DEIR with
respect to CEQA adequacy. Our comments on those
sections are summarized below. We understand that
biological resources issues are addressed under
separate cover in an expert letter from Dr. Peter Baye, coastal ecologist. The general issues of lack of adequate impact/mitigation analyses, as detailed above, apply to all sections; some representative specific examples of
these deficiencies that appear in the sections that we
reviewed in detail are presented below.

Please see comments C34-12 and C134-1 for more
information on the general adequacy of analysis in
the DEIR. Specific examples referenced will be
addressed below in response to comments C23-23,
24, and 25.

C34-23 Richard
Grassetti
3/8/22 Biological Resources
As noted in a letter submitted separately by Dr. Peter
Baye, the site is valuable habitat for a number of
special status species. In addition, habitat values and flooding hazards for the adjoining Rhodes development
site, which extend onto the San Pedro Avenue Site, are
presented in painstaking detail by expert technical
specialists in the California Coastal Commission’s Staff Report for the proposed development of that site (CDP
Application 2-19-0026, dated 2/18/2021), which was
never referenced or considered in this DEIR. Willful
omission of this critical information on its face renders this DEIR invalid.

This DEIR does not accurately disclose the San Pedro
Avenue Site’s conditions as part of the environmental
setting, disclose project impacts, nor discuss the
effectiveness of plan policies as mitigation. For
example, Figure 3.7-3 in the Biological Resources
chapter shows this Site as having no sensitive or critical habitat values, yet evidence by Dr. Peter Baye as well
as that provided by the Coastal Commission’s expert
biologists shows that it does have sensitive species and habitats. The CCC Staff Report for the adjacent Rhodes
project site considers that entire site to be an
Environmentally Sensitive Habitat Area (“ESHA”), and
similar habitat exists on the San Pedro Avenue Site,
making it likely that that Site also would be ESHA.

Similarly, the DEIR focuses on the National Wetlands
Inventory while excluding detailed wetlands mapping
of this Site, thereby rejecting on-the-ground analyses in favor of large-scale remote mapping (see Figure 3.7-2).

The CCC Staff Report on the Rhodes site further
identifies the undeveloped San Pedro Avenue Site as
“likely wetlands” (see Figures 1a and 1b, on p. 134 of
the CCC Staff Report).

Similarly, as described in the CCC Staff Report, a
California Red Legged Frog (“CRLF”) was found in the
The DEIR uses the best available evidence from
credible government sources, such as the National
Wetlands Inventory and the U.S. Fish & Wildlife
Services, at the appropriate scale of a Programmatic
EIR for a General Plan.

Please see Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro Ave Sites for
more information on how compliance with federal,
state, and local regulations, in addition to Proposed
Plan policies ,reduce impacts to less than significant, regardless of the final determination.

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Packet Pg. 975 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 188
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drainage separating the undeveloped San Pedro
Avenue Site from the Rhodes site, and would clearly
have important habitat on the San Pedro Avenue Site
(see CCC Staff Report Figure 2, on p. 134). Further,
given that the frog was found at the upstream end of
the drainage on the Site, and likely traveled up that
drainage to the point where it was encountered, it is
likely that a much greater portion of the San Pedro
Avenue Site is CRLF habitat than shown on that figure.

C34-24 Richard
Grassetti
3/8/22 The lower portion of San Pedro Creek also has been found to be habitat for the special-status tidewater
goby (see Baye report referencing Sutter and Kinziger,
2019). This habitat may be adversely affected by
contaminated runoff that would result from
development of the undeveloped San Pedro Avenue
Site. This impact also must be addressed in the DEIR.

The tidewater goby is mentioned in Table C-1 (page
A-98) of the DEIR and states that the potential for
the tidewater goby to occur in the Planning Area is
low. The tidewater goby is a Special Status species,
all federally and state threatened, endangered, and
candidate wildlife species are protected under the
Federal Endangered Species Act and the California
Endangered Species Act, respectively. In addition to
State and federal species and habitat protection
laws, the General Plan includes multiple policies to
address biological resources and habitat protection
which would apply to potential tidewater goby and
wetland habitat which include:
(CO-I-1) Creek Protection and Restoration.

Maintain, protect, and restore Pacifica’s creeks,
including San Pedro, Calera, Sanchez, and Milagra
creeks, as environmental and aesthetic resources.

Actions will include, but are not limited to:
• Continuing restoration efforts along San Pedro
Creek to improve conditions for steelhead by
removing obstacles to fish passage, placing rock
weirs to facilitate fish passage, and by monitoring
the effectiveness of these projects;
• Partnering with local organizations, such as the
San Pedro Creek Watershed Coalition, Go Native,
the Pacifica Land Trust, and others, on restoration
efforts;
• Exploring opportunities to collaborate with other
agencies and organizations on stream restoration
and riparian habitat restoration along Sanchez and
Calera creeks;
• Enforcing restrictions on the planting of invasive
species near creek areas;
• Identifying and working with property owners to
take advantage of unique opportunities where
human active use (e.g., through trail development)
would enhance creek appreciation without
disrupting ecological function;
• Requiring a minimum of 100-foot setbacks from
the top of creek banks, or from the outer edge of
riparian vegetation, where it exists, for
development proposed adjacent to creeks, in
keeping with City regulations and Best Management
Practices. Exceptions to such buffer requirements
should be supported by a biological report

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Packet Pg. 976 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 189
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demonstrating that the adjusted buffer, in
combination with incorporated siting, design or
other mitigation measures, shall prevent impacts
that significantly degrade the creek. Buffer
adjustments should also be limited to where the
entire subject legal lot is within the buffer or where
it is demonstrated that development outside the
buffer would have a greater impact on the creek.
(CO-I-4) Wetlands Preservation. Prohibit new
development in existing wetlands except as allowed
under the federal Clean Water Act and the
California Coastal Act. Continue to require formal
delineations wetlands subject to State or federal
regulations prior to any proposed development
project in an area where potential wetlands have
been identified. If impacts on wetlands are
unavoidable, compensation measure should be in
line with the State’s no-net-loss goal regarding
wetlands.
(CO-I-38) Biological Productivity. Maintain—and
where feasible, restore—the biological productivity
and the quality of coastal waters, streams,
wetlands, and lakes in order to maintain optimum
populations of marine organisms and to protect
human health.

Techniques may include:
• Minimizing adverse effects of wastewater
discharge;
• Controlling runoff, preventing depletion of ground
water supplies and substantial interference with
surface waterflow;
• Encouraging wastewater reclamation,
maintaining natural vegetation buffer areas that
protect riparian habitats; and
• Minimizing alteration of natural streams.
(LU-G-7) Open Space Conservation and Habitat
Protection. Protect beaches, oceanfront bluffs,
wetlands, riparian corridors, Environmentally
Sensitive Habitat Areas (ESHA), ridgelines, hillside
areas adjacent to existing open space, and areas
that support critical wildlife habitat and special
status species.
(CO-G-11) Other Environmentally Sensitive Areas.

Protect other potential ESHAs, high habitat value
areas, and wildlife movement corridors from
development that would significantly disrupt
habitat values.
(CO-I-27) Verification of ESHA. Prior to any
proposed development in an ESHA or potential
ESHA, require that a habitat survey be conducted by
a qualified botanist or biologist. The habitat survey
will verify whether the site is an ESHA, and
document the extent of the sensitive resources,
document potential negative impacts to the habitat,
and recommend appropriate mitigation measures.

Verification of an ESHA shall be based on the

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Packet Pg. 977 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 190
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following considerations:
• Presence of natural communities identified as rare
by the California Department of Fish and Wildlife
(determined by a state rarity ranking of S1 to S3).
• Recorded or potential presence of plant or animal
species designated as rare, threatened or
endangered under State or federal law.
• Recorded or potential presence of plant or animal
species for which there is compelling evidence or
rarity, such as a designation of 1B (rare or
endangered in California or elsewhere) or 2 (rare,
threatened, or endangered in California, but more
common elsewhere) by the California Native Plant
Society.
• Presence of coastal waterways.
• Integrity of the habitat and its connectivity to
other natural areas.
(CO-I-28) Management of ESHA. If the area qualifies
as an ESHA under the California Coastal Act, the
following regulations apply:
• No new development shall be allowed within
primary habitat areas with the exception of
resource-dependent uses that can be demonstrated
to have no significant adverse impact.
• Buffer areas shall be established around all
sensitive resources, providing a minimum of 100
feet, and varying as needed to account for feeding,
breeding, nesting, and other habitat requirements.

New buildings in buffer areas shall be allowed only
if there are no other feasible development areas on
the parcel. Exceptions to such buffer requirements
should be supported by a biological report
demonstrating that the adjusted buffer, in
combination with incorporated siting, design or
other mitigation measures, will prevent impacts
that significantly degrade the ESHA and will be
compatible with the continuance of the ESHA.

Buffer adjustments should also be limited to where
the entire subject legal lot is within the buffer or
where it is demonstrated that development outside
the buffer would have a greater impact on the
ESHA. Development shall be sited and designed to
prevent impacts that would degrade adjacent
habitat areas, taking into account drainage,
vegetation, topography, and other considerations.
• Alteration of landforms, removal of vegetation,
impervious surfaces, noise, light, and glare shall be
minimized.
(CO-I-31) Habitat Preservation. Require a habitat
survey be prepared by a qualified botanist or
biologist for any development proposed for the
following areas, as shown in Figure 7-3.
• Designated Critical Habitat for Endangered or
Threatened Species;
• Potential Environmentally Sensitive Habitat Area
(ESHA);

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Packet Pg. 978 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 191
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• High Habitat Value; and
• Wildlife Movement Corridor.

The survey will be used to determine the exact
location of habitat areas and to recommend
mitigation measures that minimize potential
impacts.
(CO-G-7) Wildlife and Critical Habitat. Conserve and
protect indigenous threatened, endangered, and
other special status species by preserving critical
habitat.

Critical Habitat in the Coastal Zone is considered
Environmentally Sensitive Habitat Area (ESHA).
(CO-I-26) Protection of Biological Resources with
New Development. Protect sensitive habitat areas
and special-status species through implementation
of the following measures:
1) Discourage development and/or buildout in
critical habitat of special status species during the
development review process.
2) Pre-construction plant and wildlife surveys:

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Packet Pg. 1073 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 979 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 192
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The City will coordinate with the U.S. Fish and
Wildlife Service, National Marine Fisheries Service,
California Department of Fish and Wildlife, and
Regional Water Quality Control Board in providing
project applicants with the best guidance to avoid
impacts to special status species and habitat areas
including creeks, wetland features, woodlands, or
other sensitive natural features.

If the tidewater goby was found as part of a projectlevel EIR analysis, then these policies would mitigate habitat impacts to the greatest extent practical.

Therefore, potential impacts to Sensitive Species or
Critical Habitat will be fully mitigated with
implementation of the General Plan.

C34-25 Richard
Grassetti
3/8/22 Finally, the proposed site designation fails to meet CCC policies, as summarized in the 2020 Staff Report for the denied Rhodes Project (emphasis added):
“In short, the portion of the site within the
Commission’s permitting jurisdiction is all ESHA and
undevelopable for the proposed range of uses and
structures. Although some provisions in the LCP allow
for reductions to habitat buffers in the event that the buffer renders the site undevelopable, in this case it is the actual ESHA area that is affected by development
(and not the buffer from it), and the City has approved development in the portion of the property that is
within its jurisdiction and subject to the LCP. The
Commission finds that there is no location on the site
that is outside of ESHA and sufficient to protect the
habitat, as required by the Coastal Act, and, as such,
there aren’t siting and design conditions available to
the Commission to correct this Coastal Act
inconsistency. Therefore, the Commission finds the
proposed project inconsistent with the Coastal Act’s
sensitive habitat protection requirements cited above,
requiring project denial.”
Given the evidence already provided to the City that
much, if not all, of the undeveloped San Pedro Avenue
Site is environmentally sensitive habitat and likely
qualifies as an ESHA, the DEIR must investigate to what extent those conditions exist on the Site. It is entirely possible that the whole Site is ESHA, and therefore
should be designated as such in the General Plan.

Alternatively, designating it for residential mixed-use development likely assures a significant environmental
impact will occur, and the DEIR must disclose those
potential impacts. It should be noted that this is not a disagreement among experts, as the DEIR provides NO
evidence supporting its finding that the proposed land
use designation for that Site would not result in a
significant impact, and the City is in receipt of
substantial
evidence to the contrary.

Please see Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro Ave Sites for
more information.

CEQA permits differing opinions of expert and
competing evidence; if the site is determinedto
qualify as ESHA, then potential site-specific impacts
and/or mitigation measures would be analyzed as
part a Project EIR for when a development proposal
is brought forth. The DEIR for the General Plan
(which is not a Project EIR for the site in question)
includes a comprehensive list of policies to protect
ESHA habitats.

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Packet Pg. 1074 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 980 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 193
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Individuals (C)
C34-26 Richard
Grassetti
3/8/22 Land Use Environmental Setting
Chapter 3.1, overall: The list of General Plan Policies that purportedly reduce impacts fails to describe how
or to what degree impacts are reduced. Please add this
analysis for Impacts 3.1-1, 3.1-2, and 3.1-3, considering that not all General Plan policies are required to be
implemented by the City.

Each of the analysis chapters in the DEIR include an
environmental settings section, which describes onthe-ground conditions. The comment does not provide an example of how analysis under the
impacts listed is deficient. Required topics of
analysis under CEQA for Land use and Housing
include the following:

Criterion 1: Physically divide an established
community. As described on DEIR p. 3.1-9, the
Proposed Project does not physically divide any
established community. Rather, by allowing for
compact and concentrated development in alreadyurbanized neighborhoods, increasing opportunities for housing and economic development, and
improving linkages, the Proposed Project provides
improved connections to and continuity with
surrounding neighborhoods. Thus, no division of a
community would occur. Policies listed in the DEIR
describe how this concentrated development will
occur; this impact is less than significant.

Criterion 2: Implementation of the Proposed Project
would not conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding or
mitigating an environmental effect. As described on
DEIR p. 3.1-26, The Proposed Project does not
contain policies that conflict with the San Mateo
County General Plan. The City’s LAFCO-approved
Sphere of Influence overlaps with County land south
of the City limits on the slope of San Pedro
Mountain. The Proposed Project calls for
coordination between the City and the County to
ensure that development of unincorporated county
land that is in the City’s Sphere of Influence is
developed at a maximum density of five acres per
unit. For developments over 50 acres or for the site
of Shamrock Ranch, the Proposed Project aims to
guide potential development outside the City limits
but inside its Sphere of Influence with a master
planning process, potential annexation into the
city, and an amendment to the General Plan.

Through this master planning and annexation
process, any discrepancy between the County
General Plan and the Proposed Project will be
rectified.

Criterion 3: Induce substantial unplanned
population growth in an area, either directly or
indirectly. As noted on DEIR p. 3.1-29 and 3.1-30,
the Proposed Project includes allowable density
ranges in those land use designations where
housing is allowed to be developed, which would
direct housing development to those locations
where it is intended to be developed and at the
densities for which it is planned.

New homes and businesses developed in the
Planning Area as a result of the Proposed Project

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Packet Pg. 1075 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

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Packet Pg. 981 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 194
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would intend to accommodate growth in Pacifica
that is commensurate with the city’s size, growth
rate, and place in the region. Furthermore,
development will occur incrementally over time,
not immediately after adoption of the Proposed
Project, in anticipation of the growth,
thus preventing development from inducing growth
greater than that projected. Additionally, the
Proposed Project proposes making streets more
efficient for transit, bicycles, and walking rather
than extending roads or adding lanes (including
policies that support Complete Streets, walkable
neighborhoods, and bicycle and pedestrian routes).

Furthermore, policies in the Proposed Project
encourage infill development that would avoid
unplanned development that could be induced
through infrastructure expansions into new growth
areas. This reduces the potential for unplanned,
induced growth. Therefore, the Proposed Project
would not induce substantial unplanned population
growth, either directly or indirectly, and the
Proposed
Project’s impact would be less than significant.

Impacts analysis focused on how where and what
type of development the plan allows might lead to
significant impacts for CEQA. It is speculative to
assume that development would not comply with
adopted policies; any projects would be required to
show consistency with the General Plan during the
permitting process.

C34-27 Richard
Grassetti
4/3/22 With respect to the undeveloped San Pedro Avenue Site please address the clear non-compliance of the
GPU’s high intensity land use designation with the
policies of promoting wetlands preservation (CO-I-4),
minimizing impacts of coastal development on
vegetation (CD-I-16), Open Space Conservation and
Habitat Protection (LU-I-13), Open Space Preservation
(OC-G-5), Protection of Creeks and Riparian Areas (COG-9), Other Environmentally Sensitive Areas (CO-G-11) , and Protection of Biological Resources with New
Development (CO-I-26). Please revise the land use
designation for consistency with the policies.

As noted in its Staff Report for Application CDP-2-19-
00262, the California Coastal Commission has declared
areas adjacent to the Rhodes property as an ESHA,
Further, the July 7, 2014 comments of ecologist Dr.

Peter Baye are that the seasonal wetlands at the
undeveloped San Pedro Avenue site and the zone
bordering the CRLF habitat of the swale meet the
definition of ESHA. Dr. Baye has provided additional
evidence of the suitability of much of the Site as CRLF habitat in his March 2022 letter. Dr. Baye further
provides substantial evidence that development of the
The General Plan and associated DEIR review citywide sensitive and Critical Habitat and general locations of Special Status Species. The General Plan
proposes numerous policies to reduce habitat loss,
as described in response to comments A2-3, A2-16,
and A2-20. Please see Master Response 6: ESHA
and Master Respones: Undeveloped San Pedro Ave
site for more information.

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Packet Pg. 982 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 195
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site may adversely affect the special-status tidewater
gobi which occurs at the lower end of San Pedro Creek.

Please revise the land use designation for consistency
with Verification of ESHA (CO-1-27) and Management
of ESHA (CO-I-28), and Habitat Preservation (CO-I-31).

C34-28 Richard
Grassetti
3/8/22 Chapter 3.1 also needs to be revised to address
potential land use incompatibilities. As written there is no assessment of any potential incompatibilities of
proposed new land uses with existing nearby uses. For
example, the DEIR does not disclose if intense
residential development of the undeveloped San Pedro
Avenue Site will have noise or traffic incompatibilities with surrounding residential land uses. The DEIR also
does not disclose if intense residential development of the undeveloped San Pedro Avenue Site would displace
flood storage, important habitat, or recreational uses
of the Site.

C34-29 Richard
Grassetti
3/8/22 Geology, Soils, and Seismic Risk
CEQA Guideline 15126.2(a) states, “The EIR shall also
analyze any significant environmental effects the
project might cause by bringing development and
people into the area affected…..Similarly, the EIR
should evaluate any potential significant impacts of
locating development in other areas susceptible to
hazardous conditions (e.g., floodplains, coastlines,
wildfire risk areas) as identified in authoritative hazard maps, risk assessments, or in land use plans addressing such hazard areas.” As described below for both
geology and hydrology, this DEIR fails to conduct these required assessments.

The DEIR includes robust analysis of geology and
hydrology impacts at a programmatic level and finds
impacts to be less than significant. Authoritative
hazard maps from the Department of Conservation
(For Seismic Hazard Zones, Figure 3.6-1 and
Tsunami Evacuation Areas, Figure 3.5-1); and FEMA
(Flood Zones, Figure 3.5-1) are included in the DEIR.

As noted in the DEIR summary, Potential seismic
impacts associated with implementation of the
Proposed Project could include exposure to ground
shaking, liquefaction, and soil settlement. In
addition, the Alquist-Priolo Earthquake Fault Zone
for the San Andreas fault intersects the northern
portion of the Plan Area which has the potential for
surface fault rupture. Soil erosion and loss of topsoil is most likely to occur during construction, when it
is not protected by vegetation or structures. Coastal
erosion is also a known hazard for the Planning
Area. Erosion is often caused by waves and wind,
and may be exacerbated by stormwater if not
handled effectively; please see comment C69-8 for
more information on how regulations and policies
in the Proposed Plan reduce the impacts. The
potential for expansive soils is determined on a sitespecific basis and likely present in some areas.

Compliance with the California Building Code and
other state and local regulations, as well as

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proposed General Plan and Sharp Park Specific Plan
policies, ensures that impacts are reduced to a less
than significant level.

For hydrology, the potential impacts associated
with implementation of the Proposed Project
include increased rates of storm water runoff and
subsequent flooding hazards, erosion, increase in
nonpoint source pollutants affecting receiving water
quality, and coastal erosion and flooding that may
be intensified by sea level rise. These impacts would
be reduced to less-than-significant levels through
regulatory compliance and with implementation of
proposed policies.

C34-30 Richard
Grassetti
3/8/22 Figure 3.6-1: The undeveloped San Pedro Avenue Site appears to include areas of Very High and Medium
liquefaction potential (DEIR Figures 3.6-1 and 3.6-2). It also may be subject to impacts from coastal erosion, as described on DEIR p. 3.6-14 and elaborated upon in the
CCC’s Staff Report for the adjacent Rhodes site. Yet the GPU’s land use designation seems oblivious to these
threats, and the DEIR fails to analyze these reasonably foreseeable potential Project impacts.

The comment is noted. The DEIR includes a robust
analysis of potential liquefaction impacts and
coastal erosion impacts on p. 3.6-25 and 3.6-26,
noting "The impacts from ground failure, including
liquefaction, from development of land uses
associated with the General Plan would be
addressed through site-specific geotechnical studies
prepared in accordance with CBC requirements and
standard industry practices. Subsequent
development would be required to conform to the
current seismic design provisions of the CBC to
minimize losses from ground failure as a result of an
earthquake. These future projects would also be
required to adhere to proposed General Plan
policies that contain seismic safety requirements
and help strengthen existing code requirements
such as referencing known hazard areas that must
contain measures to resist ground failure through
modern construction techniques. Therefore, the
potential impact related to seismically related
ground-failure including liquefaction is less than
significant." Impacts due to coastal erosion are
described on p. 3.6-30. In addition to policies like
SA-I-8: Geotechnical Studies, which require
geotechnical site investigation in Coastal Zone or
hillside areas, any proposed development
permitting in the portion of the site within the
Coastal Zone would be under the jurisdiction of the
Coastal Commission, and subject to additional
policies in the certified LCP. Please see also Master
Response 4: Undeveloped San Pedro Ave Sites.

C34-31 Richard
Grassetti
3/8/22 Impacts 3.6-1 and 3.6-3: The DEIR provides no analysis of the potential impacts of proposed land use
designations shown in the GPU land use map.

It also fails entirely to address whether and how the
listed general policies will reduce impacts such as those identified above for the undeveloped San Pedro
Avenue Site to less-than-significant levels and then
inexplicably finds the impacts to be minimal. The DEIR
just lists the policies and concludes that the impacts
would be less than significant. There’s a big difference The comment does not provide an example of how
analysis under the impacts listed is deficient.

Required topics of analysis under CEQA for Land use
and Housing include the following:

2.f
Packet Pg. 1078 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 984 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 197
Letter Commenter Date Comment Combined Response
Individuals (C)
between reducing impacts, which is what the policies
are aimed at, and reducing them to a less-thansignificant level. The DEIR must be revised to analyze the impacts of the proposed changes in land use
compared to existing conditions.
for housing and economic development, and
improving linkages, the Proposed Project provides
improved connections to and continuity with
surrounding neighborhoods. Thus, no division of a
community would occur. Policies listed in the DEIR
describe how this concentrated development will
occur; this impact is less than significant.

New homes and businesses developed in the
Planning Area as a result of the Proposed Project
would intend to accommodate growth in Pacifica
that is commensurate with the city’s size, growth
rate, and place in the region. Furthermore,
development will occur incrementally over time,
not immediately after adoption of the Proposed
Project, in anticipation of the growth,
thus preventing development from inducing growth
greater than that projected. Additionally, the
Proposed Project proposes making streets more
efficient for transit, bicycles, and walking rather
than extending roads or adding lanes (including
policies that support Complete Streets, walkable
neighborhoods, and bicycle and pedestrian routes).

2.f
Packet Pg. 1079 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 985 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 198
Letter Commenter Date Comment Combined Response
Individuals (C)
shall determine the level of review needed, and the
scope of that analysis will depend on the specifics of
the particular project. These projects may, however,
use the discussion of impacts in this EIR as a basis of their assessment of these regional, citywide, or
cumulative impacts.

C34-32 Richard
Grassetti
3/8/22 Further, please provide monitorable, enforceable mitigation for these potentially severe impacts on the
undeveloped San Pedro Avenue Site. The proposed
policies mostly involve future studies, which do not
suffice as mitigation, particularly in the absence of
express performance standards. Please note that
Geologic Hazard Abatement Districts do not ensure
mitigation, but rather just shift funding responsibilities for mitigation from the City to buyers of subject
properties.

The comment is noted. This DEIR is a programmatic
DEIR and addresses where impacts could potentially
occur. As a programmatic document, this EIR
presents a citywide assessment of the potential
impacts of the proposed Pacifica General Plan. It
does not assess project-specific impacts of potential
future projects under the proposed Plan, all of
which are required to comply with CEQA as
applicable.

C34-33 Richard
Grassetti
3/8/22 Hydrology and Water Quality
The Hydrology and Flooding section introduction states
that the section analyzes water resources “in relation
to the location of projects comprising the buildout of
the Proposed Project [General Plan].” (DEIR p. 3.5-1).

However no such analysis is included relative to those
projects.

This comment is untrue. One example of how the
DEIR analyzed locational impacts can be found as
DEIR p. 3.5-31: "While the proposed General Plan
would include relatively few new housing units,
many of which would be placed outside these
hazard areas, there are areas of new development
or other structures that may be located within 100-
year flood zone areas." These areas are identified in
maps and in the Settings sections.

As noted in Master Response 2: Programmatic EIR,
"as a programmatic document, this EIR presents a
citywide assessment of the potential impacts of the
proposed Pacifica General Plan." However, analysis
was conducted on land use parcels that changed or
developed from existing conditions (see Master
Response 3: Buildout and RHNA). These vacant
parcels are shown on Figure 3.1-1; the General Plan
Land Use Diagram is shown in Figure 2.2-1.

C34-34 Richard
Grassetti
3/8/22 The DEIR also states, “San Pedro Creek has a history of flooding in the Linda Mar area,” (p. 3.5-8) but the DEIR provides no information on flooding at the sites where
land use is proposed to intensify substantially as a
result of the GPU. The PPCA has provided the City with
photos of the Site entirely flooded to a depth of several feet, indicating that substantial flooding has occurred The comment states that the DEIR provides no
information on flooding at sites where land use is
proposed to intensify as a result of the GPU. On
page 3.5-8, the DEIR mentions 'The broadest
mapped flood hazard areas are located along San
Pedro Creek, covering much of the Linda Mar area
north of the creek extending down to the coast. A

2.f
Packet Pg. 1080 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 986 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 199
Letter Commenter Date Comment Combined Response
Individuals (C)
on the Site. This flooding occurred again in the 2021-
2022 rainy season. The City has been provided with
evidence (attached hereto and submitted by PPCA
under separate cover) that the Site has been frequently flooded by San Pedro Creek, the adjacent hillsides, is
subject to flooding under projected sea level rise, and is subject to tsunami hazards.
broad 0.2 percent annual chance flood area is
mapped at the confluence of the main stem with
the North Fork of the San Pedro Creek.'
Figure 3.5-1 was created based on the following
sources:
the latest tsunami evacuation zone data which is
available at the City's website
(https://www.cityofpacifica.org/civicax/filebank/blo
bdload.aspx?BlobID=2499), as well as the National
Flood Hazard Layer for San Mateo County mapped
by the Federal Emergency Management Agency
(FEMA). Please see response to comment C13-3 for
more information on coastal flooding and sea level
rise.

C34-35 Richard
Grassetti
3/8/22 The 2014 DEIR for the Pacifica General Plan Update at Figure 3.5-1 showed the Site is subject to flooding from tsunami runup. However, without explanation, that
figure has been omitted from this DEIR. Why was this
figure deleted? As noted in the DEIR and the CCC Staff
Report, tsunami runup is a hazard that will only worsen with sea level rise.

This comment is noted.

The map was updated to account for new tsunami
evacuation zone data which is available at the City's
website,
https://www.cityofpacifica.org/civicax/filebank/blo
bdload.aspx?BlobID=2499

2.f
Packet Pg. 1081 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 987 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 200
Letter Commenter Date Comment Combined Response
Individuals (C)
C34-36 Richard
Grassetti
3/8/22 As detailed in the CCC Staff Report on the adjacent Rhodes project site, “With respect to coastal hazards,
the site would be subject to potential future impacts
from the combination of shoreline retreat, sea level
rise, wave runup, and inundation. As proposed, the
structures are not sufficiently sited and designed to
avoid such problems, and the northernmost building
includes a basement structure, all of which would be
subject to flooding over the expected life of the
development. “
“… Commission staff geologist Dr. Joseph Street
estimates that with 6.6 feet of sea level rise, wave
runup with the 100-year storm could extend about 170
feet inland of the shoreline (i.e., of MHTL) across the beach and flatter ground near San Pedro Creek,
northeast of the project site. This provides a more
conservative estimate of potential storm wave runup
beyond the future shoreline position. If 170 feet of
horizontal wave runup distance is added to the
projected future shoreline position (with 5.7 or 6.6 feet of sea level rise), the seaward portion of the project
site (where Building 1 is proposed which includes the
two-story surf shop on the first floor, office and storage space on the second floor, and a 3,500 square-foot
basement subgrade) would be affected by wave runup
within the 100-year analytic period referenced by the
LCP.
“Another option to approximate the future wave runup
hazard risk to the site is to add projected sea level rise to the current FEMA 100-year flood elevation. Adding
the medium-high risk scenario sea level rise projection (+5.6 to +6.9 feet by 2090-2100) to the current FEMA
100-year flood elevation of the VE zone (representing
areas within the 1% annual chance coastal floodplain
which have additional hazards associated with storm
waves) where the proposed project is located (i.e., at
+17 feet elevation) yields a rough estimate of the
future 100-year flood elevation in the range of +22.5 to +24 feet NAVD88. Given the existing elevations at the
project site (+16 to +21 feet) and the elevations of the topographic lows adjacent to the project site (+16 to
+17 feet NAVD88), it is thus possible that future flood elevations in this range affect at least a portion of the project site toward the end of the project life. At the very least, additional, more detailed analysis would be needed to rule out this possibility.” The San Pedro
Avenue Site is lower than the adjacent Rhodes project
site, rendering it even more likely to be impacted from coastal flooding hazards. This should have been
considered in planning for Site development in the
GPU, as well as in determining impacts in the DEIR.

Please see response to comment C13-3 for more
information on sea level rise data, and how
compliance with federal, state, and local regulations
as well as Proposed Plan policies reduce impacts to
coastal flooding to less than significant. The
Proposed Plan is programmatic; a land use
designation does not represent a project. As noted
in Master Response 2: Programmatic EIR, As a
programmatic document, this EIR presents a
citywide assessment of the potential impacts of the
proposed Pacifica General Plan. It does not assess
project-specific impacts of potential future projects
under the proposed Plan, all of which are required
to comply with CEQA as applicable.

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

As noted in policy LU-I-29,"an assessment of
potential geotechnical hazards must also be part of
the development application and environmental
review process, including assessment of the Ocean
Shore railroad berm under hazard and vulnerability
scenarios consistent with policies in Chapters 7 and

8."
C34-37 Richard
Grassetti
3/8/22 Because the undeveloped San Pedro Avenue Site is located in the Coastal Zone, designation of the Site
Please see response to comment C34-36

2.f
Packet Pg. 1082 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 988 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 201
Letter Commenter Date Comment Combined Response
Individuals (C)
must be assessed for compliance with Coastal
Commission policies with respect to flooding and sea
level rise. The Commission’s draft polices state that
LCP’s must integrate sea level rise into planning, using a maximum rise of 6.3 feet, which is based on the best
available science as identified in the CCC Staff Report on the adjacent Rhodes project site. The Coastal
Commission Guidance is that coastal hazard risks
should be avoidable, wherever feasible. Increasing
development density on an undeveloped site subject to
sea level rise and other coastal hazards is the opposite of this Coastal Commission Guidance. The DEIR fails to
even mention this impact.

C34-38 Richard
Grassetti
3/8/22 The DEIR Hydrology discussion fails to even disclose, much led address, the tsunami and sea-level-rise
flooding related hazards associated with this Site (see, for example, DEIR Figure 3.5-1, which shows the Site as having no flooding hazards), in spite of detailed
evidence of those hazards provided by the California
Coastal Commission’s experts. The DEIR consistently
ignores on-the-ground analyses, in favor of lessaccurate generic mapping, rendering the document inadequate.

The comment states that the DEIR does not
accurately portray tsunami and sea-level-rise
flooding related hazards associated with this site.

Figure 3.5-1 was created based on the following
sources:
the latest tsunami evacuation zone data which is
available at the City's website
(https://www.cityofpacifica.org/civicax/filebank/blo
bdload.aspx?BlobID=2499), as well as the National
Flood Hazard Layer for San Mateo County mapped
by the Federal Emergency Management Agency
(FEMA).

The DEIR also mentions localized flooding risks
along San Pedro Creek: 'The broadest mapped flood
hazard areas are located along San Pedro Creek,
covering much of the Linda Mar area north of the
creek extending down to the coast. A broad 0.2
percent annual chance flood area is mapped at the
confluence of the main stem with the North Fork of
the San Pedro Creek.'
C34-39 Richard
Grassetti
3/8/22 In the 2014 DEIR for that General Plan Update, the Hydrology section included an impact on sea level rise
(Impact 3.5-6). Inexplicably that impact, as well as
Impact 3.5-7 in the 2014 DEIR, have been deleted,
leaving a jump from Impact 3.5-5 to 3.5-8 in the 2022
DEIR. Given that the undeveloped San Pedro Avenue
Site would be subject to extreme flooding from sea
level rise and that runoff to and from the project Site would aggravate that flooding (see CCC comments),
this issue must be addressed in the stormwater runoff
and flooding discussions of this Project and DEIR.

In Ballona Wetlands Land Trust v. City of Los
Angeles (Ballona Wetlands), the California Court of
Appeal held that CEQA does not require the lead
agency to analyze or disclose the effects of sea-level
rise on the proposed development. However, in the
spirit of full disclosure, sea level rise impacts are
addressed in impacts 3.5-3 and 3.5-4. Please see
response to comment C13-3 for more information
on sea level rise mapping.

C34-40 Richard
Grassetti
3/8/22 Also, designating this Site for development is in clear violation of sea-level-rise policies in the General Plan Update itself. The fact that the City is willing to adopt a land use plan that is inconsistent with the policies in the very same plan shows that the policies are not
effective mitigation.

As mitigation, please revise the land use element of the Project to eliminate the density increases in these
Policies within the LCLUP related to effects of
climate change and sea level rise are addressed in
the LCLUP. See response to comment C13-3 for
more information about coastal flooding and sea
level rise. Please also see Master Response 4:

Undeveloped San Pedro Ave Sites.

2.f
Packet Pg. 1083 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City

2.B
Packet Pg. 989 Attachment: Attachment B - Planning Commission Agenda Packet - June 6, 2022 (5049 : Appeal of Planning Commission Recommendation to 202
Letter Commenter Date Comment Combined Response
Individuals (C)
areas and respond to the real hazards by reducing
densities instead. The DEIR – by suggesting
unenforceable policies that conflict with the underlying land use as mitigation measures - does not comply with
CEQA requirements for mitigation, which must be both
enforceable and verifiable, and must actually mitigate
the impact.

C34-41 Richard
Grassetti
3/8/22 Public Services and Recreation
The draft general policies state that access to coastal areas shall be maximized. Yet, this Project would
eliminate an informal access trail to the beach, as
documented in a set of photos and maps attached to
our previous comments. The DEIR entirely omits
coastal access outside of designated parks from its
impact analysis. The Project’s impacts on access
through the Site are not disclosed in this DEIR.

The DEIR considers coastal access in its impact
analysis. Under Impact 3.12-2 on page 3.12-49, the
DEIR analyzes whether buildout of the Proposed
Project will result in an increase in the use of
existing parks and recreational facilities such that
substantial physical deterioration would occur or be
accelerated. The DEIR acknowledges that increased
traffic to these recreation areas could have a
negative impact on these resources unless access is
properly tended to and appropriate buffers and
conservation protections are enforced. Thus, the
Proposed Project promotes coordination with the
various entities that manage these areas to ensure
that they receive the necessary attention.

Additionally, the Proposed Project contains many
policies that extend trails and augment coastal
access for all visitors to keep the impact to a less
than significant level. Such policies that aim to
augment coastal access include OC-G-8, OC-G-9,
OC-G-10, OC-I-37, OC-I-38, OC-I-39, OC-I-40, OC-I41, OC-I-42, and OC-I-43.

C34-42 Richard
Grassetti
3/8/22 Alternatives
As described previously, the DEIR fails to provide clear objectives as required by CEQA. This makes it
impossible to determine if the range of alternatives in the DEIR is appropriate. This deficiency is compounded
because project alternatives must reduce impacts
compared to the Project and, as detailed above, the
DEIR fails to adequately address potential impacts of
the Project on nearly all topics. Further, it appears that the alternatives addressed in Chapter 4 are merely
planning options and not actual CEQA alternatives. In
fact, the three criteria on DEIR p. 4-2 state that the
alternatives were selected to, “bracket the range of
choices that have the broadest support from the
community”, apparently without specific consideration
of their potential environmental impacts.

Page 2 ends

Pacifica City CouncilJuly 11, 2022

Pacifica City Council
July 11, 2022