Pacifica City Council
July 11, 2022

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Packet Pg. 3682 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 20 roads would nearly double foot trail distance from the public roads to the shore from established access points.

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

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

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Packet Pg. 3683 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 21 Foot trail network (2013) of Pedro Point Field, showing connections to levee trail access to private shore with long-established public access. Freshwater wetland drainage swale connecting to San Pedro Creek mouth is shown in dashed blue line. 2013 Google Earth image.

Pedro Pt
Field
2-19-0026
Exhibit 8

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Packet Pg. 3684 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 22 Detail of Pedro Point field foot trail connection to the public access walkway to privately owned beach (with public access) across the historic railroad berm. 2013 Google Earth image.

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

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

PEDRO POINT FIELD
stairs
2-19-0026
Exhibit 8

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Packet Pg. 3685 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 23 The Pedro Point field is separated from the ocean only by the railroad berm, and in its original condition (backbarrier floodplain marsh) it was “oceanfront”, with line of sight to the ocean over the low barrier beach. According to Pedro Point long-term residents, the field has been used for recreation for years prior to and during the current land ownership. Recent recreational uses include children’s games, domestic animal feeding and observation (former llama and emu enclosure along the toe of the railroad berm), ball sports, playground activities extending from the adjacent Pedro Point firehouse playground, and dog walking. The field is suitable for these established recreational uses, and is suitable for other recreational uses as well.

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

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

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

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

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

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

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Packet Pg. 3686 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 24 The field contains extensive seasonal wetlands (winter-saturated and temporarily flooded depressional wetlands and drainage swales, ditches). The perennial wetlands of the drainage swale at the east end of the field supports California red-legged frog habitat and is typically occupied by a population (see comments in this letter, above). The seasonal wetlands and the zone bordering the frog habitat of the swale meet the definition of ESHA. Residential and mixed use commercial development would likely eliminate, significantly reduce, or degrade existing wetlands and ESHA on the site. Since the field is the last undeveloped lowland floodplain of San Pedro Creek within the Coastal Zone that is available for wetland restoration and enhancement, it is infeasible to mitigate impacts to these wetlands off-site; compensatory mitigation is not available for the red-legged frog populations in lower San Pedro Creek in the coastal zone. The DEIR failed to assess impacts to this Coastal Act policy or propose any feasible mitigation for it. The only feasible mitigation for this policy impact would be avoidance of impacts by not applying the residential mixed use land use designation.

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

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

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

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Packet Pg. 3687 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 25 removal of fill or addition of soil amendments to restore agricultural productivity similar to farms on the marine terraces and valleys along the San Mateo Coast south of Pacifica. There are no other potential highly productive historic farmland soils left in the Coastal Zone of Pacifica. Residential development of the field would conflict with this policy that requires the protection of long-term soil productivity. This impact was not assessed or mitigated in the DEIR.

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

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

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

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Packet Pg. 3688 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 26 alluvial soils (historical wetland) of the field have the same relative liquefaction (earthquake shaking) potential as diked bay muds and marshes in San Francisco Bay, like those that underlie filled San Francisco peninsula baylands. (Witter, Robert C., Keith L. Knudsen, Janet M. Sowers, Carl M.

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

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

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

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

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

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Packet Pg. 3689 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 27 (whether or not they meet federal wetland criteria for fill authorization under the Clean Water Act) would conflict with this policy.

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

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

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

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Packet Pg. 3690 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 28 mitigation is identified. Furthermore, the DEIR alleges that no mitigation is even required because it wrongly asserts that there is no impact.

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

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

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

2-19-0026
Exhibit 8

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Packet Pg. 3691 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

(415) 310-5109 [email protected]
Peter R. Baye Ph.D. [email protected]
Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 29 ATTACHMENT A – STATEMENT OF QUALIFICATIONS - Peter R. Baye, Ph.D.

I am a coastal ecologist and botanist with over 30 years of professional and academic experience. My Ph.D. research in coastal ecology (University of Western Ontario, Canada, Department of Plant Sciences, 1990) was followed by a career in applied ecology in California. I worked for the U.S. Army Corps of Engineers, San Francisco District, where I served as a senior environmental scientist and regulatory project manager conducting endangered species consultation, wetland jurisdictional determinations, wetland assessments, preparing Environmental Assessments and managing joint NEPA/CEQA Environmental Impact Statements/Reports. My Corps regulatory projects included sites adjacent to Port Sonoma (Sonoma Baylands, Carl’s Marsh). Subsequently I worked for the U.S. Fish and Wildlife Service, where I prepared endangered species recovery plans (including comprehensive plans covering all of Marin Baylands and tidal marshes) and endangered species biological opinions. I was a contributing author and participant in the Baylands Ecosystem Habitat Goals Report (Goals Project 1999), its companion volume on Bayland species and community profiles (2000), and its 2014 update (in preparation), for which I developed many Marin bayland recommendations. I have developed or substantially contributed to estuarine wetland restoration and management plans for many Marin coastal wetland sites, including some adjacent to the plan area: Corte Madera Baylands Conceptual Sea Level Rise Adaptation Strategy, prepared by The San Francisco Bay Conservation and Development Commission and ESA PWA (specific focal area: Corte Madera Ecological Reserve marshes); Aramburu Island, Richardson Bay (with Wetlands and Water Resources) and wetland restoration projects at Bahia, Novato (with ESA-PWA) and Bolinas Lagoon (Kent Island, with William Carmen & Associates).
2-19-0026
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----- Forwarded Message -----
Subject: Red-legged Frogs
May 19, 2020
2-19-0026
Exhibit 9

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Packet Pg. 3700 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan STATE OF CALIFORNIA – CALIFORNIA NATURAL RESOURCES AGENCY GAVIN NEWSOM,

GOVERNOR

CALIFORNIA COASTAL COMMISSION
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105
VOICE (415) 904- 5200
FAX (415) 904-5400
WWW.COASTAL.CA.GOV

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

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Packet Pg. 3701 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 2 x Wood Biological Consulting. One-Parameter Wetland Delineation for the Proposed NorCal Surf Shop Mixed-Use Development, San Mateo County, California (CDP Application 2-19-0026). Prepared for Shawn Rhodes, 5460 Pacific Coast Highway, Pacifica, CA 94044; May 14, 2019.

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

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

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

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

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Packet Pg. 3702 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 3 Wetlands
The 2005 biological report referenced in the Commission staff 2015 letter regarded the drainage adjacent to the subject parcel as an intermittent stream and the California Aquatic Resources Inventory (CARI) maps it as part of a natural fluvial drainage sourcing from across San Pedro Avenue and the forested area behind existing development (Figure 2). The drainage receives flows from the Pedro Point neighborhood, which primarily enter through a culvert directly east of the subject parcel and flow northward until meeting San Pedro Creek. A scour pool has formed at the mouth of the culvert, next to the roadside, and water generally ponds for some distance thereafter, even well after seasonal flows cease (Figure 3). During larger flows, surface water continues along the full length of the drainage paralleling the subject parcel and exits through a culvert largely obscured by the willow thickets at its north end, which daylights within a restoration area on City land for a short distance, enters another culvert, and then flows into San Pedro Creek on the other side of the San Pedro Shopping Center. Aerial imagery shows that throughout the year, the drainage remains largely green with vegetation even when surrounding areas dry out (Figure 4).

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

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

Biological productivity; water quality
The biological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes 3 Baye, P. 2014. Letter to City of Pacifica RE: Draft Environmental Impact Report for the Pacifica General Plan Update Project – SCH #2012022046. 29pp
4 Baye, P. 2014. Ibid.
5 City of Pacifica. 2018. 505 San Pedro Avenue Project Initial Study/Mitigated Negative Declaration, Public Review Draft. April 2018. 2-19-0026
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Packet Pg. 3703 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 4 appropriate to maintain optimum populations of marine organisms and for the protection of human health shall be maintained and, where feasible, restored through, among other means, minimizing adverse effects of waste water discharges and entrainment, controlling runoff, preventing depletion of ground water supplies and substantial interference with surface waterflow, encouraging waste water reclamation, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing alteration of natural streams.

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

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

6 United States Army Corp of Engineers jurisdictional wetlands, based upon the presence of all three parameters (hydrology, vegetation and soils), totaled 0.088 ac; Coastal Commission wetlands, based upon the presence of at least a single parameter, totaled 0.248 ac. 2-19-0026
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Packet Pg. 3704 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 5 northern end, in the Commission’s jurisdiction). Of note is that the increase in area delineated in 2019 relative to what was reported from 2005 (Thomas Reid Associates 2005a) supports observations also made by Dr. Baye that wetland areas have expanded at this location.7
According to estimates provided in the analysis of the November 2019 wetland delineation, the proposed development would occur inside the wetland boundary at the arroyo willow thickets where a retaining wall to support an existing earthen berm and proposed pedestrian pathway along the full length of the subject parcel would be constructed. Figure 5 illustrates that the retaining wall would in fact encroach roughly 20 ft into the willows and directly remove wetland habitat; however, the project fails to qualify as an allowable use under Coastal Act §30233 and moreover, the willow stand also qualifies as ESHA (see next section). Elsewhere along the length of the drainage, the retaining wall would be sited no more than 11 ft from the delineated Commission wetlands while the buildings and other development features would sit between 9 and 30 ft of the wetland boundaries at their nearest points.

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

Environmentally Sensitive Habitat Areas
Coastal Act §30107.5 defines environmentally sensitive [habitat] areas as:
… any area in which plant or animal life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and which could be easily disturbed or degraded by human activities and developments.

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

7 Baye, P. 2014. Ibid.
8 For example, see: Blackman and O’Connell (A-2-PAC-15-0046) where wetland buffers surrounding a willow stand were reduced to 50 ft, or Trask (A-1-DNC-07-036) where wetland buffers surrounding emergent vegetation were reduced to a minimum 68 ft. 2-19-0026
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Packet Pg. 3705 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 6 determinations.9 An ESHA determination may also be made on the basis of an area constituting ‘especially valuable habitat’ where it is of a special nature and/or serves a special role in the ecosystem, such as providing a pristine example of a habitat type or supporting important ecological linkages.

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

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

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

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

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

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

61.201.01) in California Sensitive Natural Communities list (version: September 9, 2020) – accessible online at https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153609&inline. 11 Bolsa Chica Land Trust v. Superior Court (1999) 71 Cal.App.4th 493 2-19-0026
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Packet Pg. 3706 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 7 (Scirpus microcarpus), is represented at this site and though unranked, is considered sensitive.12 The species is an obligate wetland indicator and like the arroyo willow, is necessarily treated under wetland policies but warrants the protection of a 50-ft buffer due to its ecological significance. Species such as the California red-legged frog (see below) frequently use bulrush habitat for breeding.

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

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

12 See Small-fruited Bulrush Marsh alliance (CaCode: 52.113.00) and Scirpus microcarpus association (CaCode: 52.113.01) 13 California Assembly Bill 2364, approved June 28, 2014 - http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201320140AB2364 14 USFWS. 2004. Federal Register: Endangered and Threatened Wildlife and Plants; Proposed Designation of Critical Habitat for the California Red-legged Frog (Rana aurora draytonii); Proposed Rule. 50 CFR. Part 17. Vol 69. No. 71: 19620-19642. 15 Fellers, G. 2005. Rana draytonii Baird and Girard, 1852b California red-legged frog. Pages 552-554 in M. Lannoo (editor). Amphibian declines: the conservation status of United States species. University of California Press. Berkeley, California; CWHA database 16 Bulger, JB, NJ Scott Jr. & RB Seymour. 2003. Terrestrial activity and conservation of adult California red-legged frogs Rana aurora draytonii in coastal forests and grasslands. Biological Conservation 110(1): 85-95. 17 Fellers, G. 2005. Ibid. 18 Hayes, MP & MR Tennant. 1985. Diet and feeding behavior of the California red-legged frog, Rana aurora draytonii (Ranidae). The Southwestern Naturalist 30(4): 601-605; Fellers, G. 2005. Ibid. 2-19-0026
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Packet Pg. 3707 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 8 Key threats to CRLF are recognized as habitat loss, urban encroachment, and the introduction of non-native species such American bullfrogs that can compete with CRLF for habitat as well as prey upon them. Several introduced freshwater fish species are also known prey on CRLF. Herbicide and pesticide use as well as disease may be other significant threats to CRLF, as has been documented for many amphibians around the globe.19 Prior to April 2020, we were unaware of any records affirming the presence of California red-legged frogs (Rana draytonii) at the subject parcel or its immediate surroundings although it has been well-documented at nearby San Pedro Creek.20 While I and the consulting reports I had initially reviewed for this project considered the species to have at least a moderate potential to occur given records from the nearby creek, there has also been recognition of the degraded state of the subject parcel and adjacent drainage as relatively unfavorable when compared to nearby habitat opportunities. No published record had appeared in the California Natural Diversity Database (CNDDB) beyond the creek’s main channel, the project’s IS/MND, or the other known reports for the location that staff generally relies upon. In addition, recent neighboring developments within the City’s jurisdiction along San Pedro Avenue had truncated the drainage’s corridor extension to more forested areas in the south and potential foraging, aestivation, and dispersal areas to the east (Figure 2). As such, my recommendations had focused on the wetlands and ensuring that appropriate measures would be taken during construction, in the off chance a frog was encountered.

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

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

19 Davidson, EW, M Parris, JP Collins, JE Longcore, AP Pessier, & J Brunner. 2003. Pathogenicity and transmission of chytridiomycosis in tiger salamanders (Ambystoma tigrinum). Copeia 2003(3): 601-607. 20 CNDDB records for Occurrence Number 652 cover the lower half-mile of San Pedro Creek since 2002, when a total of 5 frogs were recorded from approximately 0.2 mi north of the subject parcel; reports since 2014 have more frequently detailed occurrences, including as many as 129 frogs caught in June-October in 2014 and notes that that adults were observed year-round in 2015. Egg masses were documented in 2014 and 2015.
21 Vasey, M. (personal communication, April 18, 2020)
22 Harman, S. (personal communication, April 24-29, 2020) 23 Vasey, M. (personal communication, April 29, 2020)
24 Baye, P. 2014. Ibid.
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Packet Pg. 3708 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 9 He presents information on CRLF not found in the research various parties had conducted, including reporting having observed CRLF at the drainage over different seasons since at least 2005 and having submitted an official report to USFWS in 2005.25 Dr. Baye specifies that his observations have occurred regularly at the drainage and that CRLF have been most frequently found in the ponded, perennially wet area [scour pool] nearest San Pedro Avenue, the location neighborhood residents made reports from in April 2020. He hypothesizes that these animals may represent a local sub-population with a relationship to the lower San Pedro Creek wetland complex and that this perennially wet area may be breeding habitat given his observations of intermittent local population fluctuations and observation of other habitat requirements being immediately proximate, including the large field just west of the drainage. He also states that he believes this area would qualify as ESHA. Dr. Baye’s report goes on to note that CRLF was apparently absent throughout the drought period beginning in 2012 through the time of his report in 2014. As the drought ended in the winter of 2017, it is not all the surprising that the applicant’s consultants would not have observed CRLF at the site when conducting the biological assessments in 2015 (Coast Ridge Ecology) or January 2017 (Live Oak Associates) as the area was just coming out of drought status.26 I reached out to colleagues at CDFW and the USFWS in May 2020 to further investigate whether there was any other unpublished CRLF occurrence information, either from the drainage or otherwise nearby apart from San Pedro Creek. CDFW staff at the Biogeographic Branch were able to confirm that Dr. Vasey’s April 2020 CNDDB submission appeared to be valid, including the species identification; since then, his record has been processed and officially incorporated to the state database (Figure 2). USFWS staff from the Bay-Delta Regional Office indicated that while they did not have the 2005 record submitted by Dr. Baye available digitally, it was likely that it has been held as a paper file that cannot be accessed readily due to constraints imposed by the current pandemic. Nonetheless, they were not surprised by the contemporaneous observations and were able to provide comments on recent observations from nearby San Pedro Creek27 as well as advise that ESA Section 10 permitting may be necessary and that recommended habitat corridors for CRLF are typically 300 ft, which is consistent with Commission decisions elsewhere along this part of the coast.28 In response to the discovery of CRLF in April 2020 at the drainage channel, the applicant’s consultant at Coast Ridge Ecology (2020) has observed that significantly more water appears to be flowing through the drainage now than during their initial assessment in 2015. Notably, 2015 would have been several years into a drought (stage 3:
extreme drought) whereas conditions were less severe in 2020 (stage 1: moderate drought), so this might be reasonably expected.
29 The consultant speculates that the differences could be a result of supplemental water inputs from nearby residential properties but does not provide any evidence thereof or consider alternative explanations (including relative drought conditions). They also express doubt concerning CRLF’s ability to have moved from San Pedro Creek into the drainage and suggest that they may have been “assisted by humans (i.e. planted in the drainage)”. They consider the area “isolated” without acknowledging the dispersal range and known movement patterns of the species, particularly in the coastal fogbelt, where culverts connect the drainage channel directly to a City restoration area and ultimately, San Pedro Creek only 300 ft away from the north end of

25 Baye, P. 2005. Letter to United States Fish and Wildlife Service RE: Documentation of California red-legged frog occurrence at Pedro Point, Pacifica, San Mateo County. May 4, 2005.
26 https://www.drought.gov/historical-information for January 2017 27 For example: United States Fish and Wildlife Service. Consultation Letter to United States Army Corps of Engineers RE: Formal Consultation on the San Pedro Terrace Project in San Mateo County, California. Reference #08ESMF00-2017-F-1370. April 5, 2018. 28 UC Santa Cruz Marine Science Campus - Coastal Long Range Development Plan. January 2017. 344pp. 29 https://www.drought.gov/historical-information for March 2015 and April 2020 2-19-0026
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Packet Pg. 3709 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 10 the subject parcel. Though these avenues of dispersal are perhaps not the most idyllic, the species is capable of having used any variety of these. Finally, the consultant argues that the location is unlikely to provide “consistent, stable long-term habitat for [CRLF] over time” and that it would likely be considered a population sink. However, CRLF is known to use (and require) a mosaic of habitat types across the landscape and we cannot ignore that the species has been documented using this location intermittently for decades, even in the absence of focused study.

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

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

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

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

The recent repeated daytime observations of multiple CRLF at the roadside end of the drainage indicates that even in the absence of formal surveys, the area has been functioning as habitat for more than an individual transient CRLF. Consideration of this, the multiple reported occurrences of CRLF at the drainage since at least 2005, and the concurrence of information from colleagues at partner resource agencies informs my revised opinion that CRLF occurrence here is not a moderately hypothetical possibility but in fact, a demonstrated pattern of use. Given the connection to San Pedro Creek, including by way of the underground culvert, the observations of CRLF near San Pedro Avenue, wetlands, and evidence of the drainage’s role as a green corridor year-round, the full length of the drainage adjacent to the subject parcel should be considered habitat. In addition, because CRLF requires not only wetted areas but also makes use of upland habitats for foraging, dispersal, and estivation, this habitat is very likely extends to adjacent upland areas on either side of the drainage. Though we cannot presently delineate the full extent of CRLF use in these areas without protocol-level surveys, we can interpret that at a 2-19-0026
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Packet Pg. 3710 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 11 minimum, the drainage itself constitutes ESHA and is likely functioning as a habitat corridor for this species between San Pedro Creek and upland areas.

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

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

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

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

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

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

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Packet Pg. 3711 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 12 biological argument that would exclude CRLF from the subject parcel or limit its movement to the narrow drainage immediately adjacent. Provided the species ecology, including dispersal and foraging patterns along the central coast, I expect it will readily use nearby upland areas and move freely with little regard for topography or substrate. Given the USFWS recommendation of providing CRLF with at least a 300-ft dispersal corridor where it is known, we can conclude that even if this width was centered on the drainage, it would extend across and beyond the subject parcel well to the east (Figure 5); therefore, I find that the entire subject parcel constitutes CRLF ESHA and that this extends some yet-to-be-defined distance beyond the parcel. No buffer recommendation is provided since it is irrelevant in the absence of an outer habitat limit from which to apply.

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

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

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

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Packet Pg. 3712 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 13 Figure 1a: 505 San Pedro Avenue parcel (approximated in yellow) as situated in the broader surrounding landscape, and b: relative to specific features including the adjacent drainage (approximated by dashed white arrow), scour pool (red asterisk), and willow thickets. restored wetlands
forested area,
minor drainages
open field
(grassland, likely
wetlands)
willow
thickets
*
restored wetlands
open field
(grassland, likely
wetlands)
2-19-0026
Exhibit 11

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Packet Pg. 3713 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 14 Figure 2: CDFW Biogeographic Information and Observation System (BIOS) Viewer display of the California Aquatic Resources Inventory (CARI) stream layer and California Natural Diversity Database (CNDDB) records surrounding the subject parcel (yellow box). CARI data shown as blue lines, including the drainage immediately west (left) of the parcel and San Pedro Creek (far right). Red thatching represents areas with known occurrences of California Red-Legged Frog.
2-19-0026
Exhibit 11

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Packet Pg. 3714 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 15 Figure 3: Photos from site visits in March and October 2019, showing seasonal variation in drainage conditions – a-b: culvert running parallel to San Pedro Avenue, immediately west of the drainage and subject parcel; c-d: from San Pedro Avenue, facing north with scour pool in foreground; e-f: from San Pedro Avenue, facing northnorthwest into drainage (note Eucalyptus wind break on left (west) before open field and subject parcel on right (east), and duck (white circle) using drainage as resting area in e); g: from western side of drainage, looking south towards San Pedro Avenue (note continuation of tree canopy into forested area south of San Pedro Avenue). a b
c d
subject parcel
subject parcel
San Pedro Ave
San Pedro Ave
2-19-0026
Exhibit 11

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Packet Pg. 3715 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 16 z
f
e
g
subject parcel
field
subject parcel
field
subject parcel
field
(forest)
2-19-0026
Exhibit 11

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Packet Pg. 3716 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 17 Figure 4: Subset of larger aerial time series (2002-2020) of the subject parcel (yellow box) and the surrounding landscape, showing wet versus dry season patterns of vegetation. Note how the drainage immediately adjacent to the subject parcel consistently provides a green corridor and effectively links San Pedro Creek with the open field to the west while providing a valuable secondary connection to the forested habitat south of the site.

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

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Packet Pg. 3717 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210
125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 18 May 2010
September 2003
2-19-0026
Exhibit 11

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Packet Pg. 3718 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210
125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 19 April 2020
July 2020
recently developed parcels & interrupted tree canopy
recently developed parcels & interrupted tree canopy
2-19-0026
Exhibit 11

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Packet Pg. 3719 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 20 Figure 5: Delineated single-parameter wetlands (solid green lines) and approximate wetland buffers (dashed green lines) relative to proposed project. Note that 50-ft buffer was drawn around the willow ESHA but should also extend slightly further south around some small-fruited bulrush marsh ESHA, which would further overlap with the proposed footprint, even as potentially modified (red lines). * small-fruited
bulrush marsh ESHA
2-19-0026
Exhibit 11

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Packet Pg. 3720 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 21 Figure 6a: CRLF as observed at San Pedro Avenue on April 12, 2020 by Michael Vasey, Sheila Harman and Jon Harman (photo credit: Jon Harman); b-d: CRLF as observed at San Pedro Avenue on April 23, 2020 by Sheila Harman. Individual CRLF circled in white for visibility.

a b
c d
2-19-0026
Exhibit 11

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Packet Pg. 3721 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 22 Figure 7a: From San Pedro Avenue, looking northeast, view of scour pool in drainage with subject parcel as grassy area immediately behind the fence, and b: CRLF observed in scour pool by Peter Baye. Photos by Peter Baye, as submitted to USFWS in May 4, 2005 letter.
a
b
2-19-0026
Exhibit 11

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Packet Pg. 3722 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 23 Figure 8: Excerpt from California Essential Habitat Connectivity Project displaying the San Mateo-Santa Cruz Counties coastal corridor (within red box). The project location in Pacifica is approximately located at the black arrow, near the northern edge of the extent. Areas in green represent connected stretches of habitat and the yellow-brown spectrum represents areas that would ideally be added to provide better linkages. The Pedro Point area is among those areas identified as valuable additions to improving connections through this corridor.

Approximate
site location
2-19-0026
Exhibit 11

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Packet Pg. 3723 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 24 Figure 9: CNDDB display of the Pedro Point area in Pacifica, with CRLF occurrences observed in thatched red areas and finer-scale features identified as particularly valuable by the California Essential Habitat Connectivity Project in solid green. The proposed project site (yellow bar) is largely covered by the upper two CRLF occurrences and is situated to link multiple habitats across the landscape mosaic, including riparian, wetland, forest, and grassland.

GRASSLAND &

WETLANDS

RIPARIAN
FOREST

CEHC FEATURE

CEHC FEATURE
2-19-0026
Exhibit 11

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Packet Pg. 3724 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 3/3/22, 9:06 AM Mail - William.Leo Leon - Outlook
https://outlook.live.com/mail/0/id/AQQkADAwATMwMAItZmNiMi1hZjNiLTAwAi0wMAoAEACoAUllP52KTKf94K%2BNWXBu 1/1 Re: Endangered Species & Habitat, Photo Link
William.Leo Leon < >
Mon 8/16/2021 4:51 PM
To: Woodhouse, Kevin <[email protected]>; Wehrmeister, Tina <[email protected]>; Sue Vaterlaus <[email protected]>
Cc: Murdock, Christian <[email protected]>; Bigstyck, Tygarjas <[email protected]>; Ray Donguines <[email protected]>
Bcc: Cherie Chan < >; Carlos Davidson < >; Brian Gaffney < >; Kris Geiger < >
Hello Mr. Woodhouse, Honorable Mayor Vaterlaus and All, I am writing to inform you of good news and a matter of concern. The good news, this Sunday August 15, 2021 while walking on San Pedro Avenue, I found and photographed a population of adult Red-legged frogs and Red-legged frog Tadpoles in a small pond that is located between the Calson Field Property and Hauling Way. The concern I have, there is no protective barrier and it is near a busy street.

I understand this body of water and its wetlands was the subject of a recent project considered by the California Coastal Commission. It is situated near and behind Pedro Point Shopping Center and abuts San Pedro Avenue to the South. Post and cable systems are in use in sensitive habitat areas at various places in Pacifica. This area is compact and, in my opinion, would benefit from a simple barrier.

I am willing to donate the cost of materials for the installation of a Post and Cable barrier.

Please consider my offer and let me know what the City of Pacifica can do to protect this valuable biological resource and endangered species.

Here's a link to the photos: Pedro Point Pond, San Pedro Ave. Aug 15, 2021 Respectfully, Leo
William Leo Leon

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Packet Pg. 3725 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT
455 MARKET STREET, SUITE 300
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW.COASTAL.CA.GOV
F16a
Filed: 12/7/2020
Action Deadline: 6/5/2021
Staff: JKN-SF
Staff Report: 2/18/2021
Hearing Date: 3/12/2021

STAFF REPORT

CDP APPLICATION
Application Number: 2-19-0026
Applicant: Shawn Rhodes
Project Location: Undeveloped property located west of the Pedro Point Shopping Center and northeast of San Pedro Avenue (505
San Pedro, APN 023-072-010) in the City of Pacifica.

Project Description: Construction of a mixed-use commercial and residential development including: (1) a 6,475-square foot two-story building with a surf shop on the first floor, office and storage space on the second floor, and a 3,500-square foot
basement for storage; (2) a 3,010-square foot two-story building for storage and surf board shaping; and (3) a 3,346- square foot two-story building with retail on the first floor and two residential units on the second floor; (4) a 4,730-square foot skate park; (5) a 24-car parking lot; and (6) related development.

Staff Recommendation: Denial

SUMMARY OF STAFF RECOMMENDATION
The Applicant proposes to construct a mixed-use commercial and residential development on a 37,538 square-foot parcel on San Pedro Avenue, west of Highway 1 and south of Pacifica State Beach. Specifically, the proposed development would include a 6,475 square-foot two-story surf shop with office, storage space and basement (building #1); a 3,010 square-foot two-story building for storage and surf board shaping (building #2); a 3,346 square-foot two-story mixed-use building with retail on the first floor and two residential units on the second floor (building #3); a skate park;

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Packet Pg. 3726 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2-19-0026 (Rhodes Mixed-Use Development)

Coastal Commission CDP Application
Two of the proposed buildings (Buildings #1 and #2) and the skate park are located within the Commission’s jurisdiction. As referenced on the project plans, Building #1, the northernmost building, would be set back approximately 15 feet from the western property line and ranging between approximately 60-100 feet from the northern property line, with the proposed building footprint extending into the arroyo willow thicket.

Building #1 is a proposed 6,475 square-foot two-story building with a surf shop on the first floor, office and storage space on the second floor, and a 3,500 square-foot basement for additional storage space. The proposed 4,730 square-foot skate park would be immediately adjacent to the southern end of Building #1 and would be both fenced and roofed. It is proposed to be set back approximately 10 feet from the western property line. Building #2, at the southern end of the skate park, is a proposed 3,010 square-foot two-story building intended to be used for additional storage and surf board shaping, set back approximately 10 feet from the western property line and adjacent to the 24-car parking lot. The Applicant also proposes a paved pedestrian pathway fronted by a retaining wall immediately adjacent to and along the full extent of the western property line, spanning both the City and Coastal Commission jurisdictions, which would connect San Pedro Avenue to an existing coastal access pathway from the northern end of the Pedro Point Shopping Center to Pacifica State Beach. See Exhibit 3 for the proposed project plans.

D. Standard of Review
As noted above, this proposed project spans both Coastal Commission and City of Pacifica CDP jurisdictions. The standard of review for the portion of the proposed development within the Coastal Commission’s permitting jurisdiction (i.e., the subject of this CDP application) is the Chapter 3 policies of the Coastal Act, although the Commission may also consider the policies of the City of Pacifica’s certified LCP as non-binding guidance.

E. Biological Resources
Applicable Coastal Act Provisions
The Coastal Act provides protection for sensitive habitat areas, including those that are considered to be on and offshore marine resources, wetlands, and environmentally sensitive habitat areas (ESHAs), including as follows:
30107.5. “Environmentally sensitive area” means 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.
30231.The biological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes appropriate to maintain optimum populations of marine organisms and for the protection of human health shall be maintained and, where feasible, restored through, among other means, minimizing adverse effects of waste water discharges and entrainment, controlling runoff, preventing depletion of ground water supplies and substantial interference with surface

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Packet Pg. 3727 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2-19-0026 (Rhodes Mixed-Use Development)

waterflow, encouraging waste water reclamation, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing alteration of natural streams.
30233.
(a) The diking, filling, or dredging of open coastal waters, wetlands, estuaries, and lakes shall be permitted in accordance with other applicable provisions of this division, where there is no feasible less environmentally damaging alternative, and where feasible mitigation measures have been provided to minimize adverse environmental effects, and shall be limited to the following:
(1) New or expanded port, energy, and coastal-dependent industrial facilities, including commercial fishing facilities.
(2) Maintaining existing, or restoring previously dredged, depths in existing navigational channels, turning basins, vessel berthing and mooring areas, and boat launching ramps.
(3) In open coastal waters, other than wetlands, including streams, estuaries, and lakes, new or expanded boating facilities and the placement of structural pilings for public recreational piers that provide public access and recreational opportunities.
(4) Incidental public service purposes, including but not limited to, burying cables and pipes or inspection of piers and maintenance of existing intake and outfall lines.
(5) Mineral extraction, including sand for restoring beaches, except in environmentally sensitive areas.
(6) Restoration purposes.
(7) Nature study, aquaculture, or similar resource dependent activities. (b) Dredging and spoils disposal shall be planned and carried out to avoid significant disruption to marine and wildlife habitats and water circulation.

Dredge spoils suitable for beach replenishment should be transported for these purposes to appropriate beaches or into suitable longshore current systems.
(c) In addition to the other provisions of this section, diking, filling, or dredging in existing estuaries and wetlands shall maintain or enhance the functional capacity of the wetland or estuary. (…)
(…)

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Packet Pg. 3728 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2-19-0026 (Rhodes Mixed-Use Development)

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

LCP Policy Guidance
The City of Pacifica LCP emphasizes the Coastal Act’s protections for wetlands and environmentally sensitive habitat areas and provides additional guidance on the creation of buffers from such sensitive habitat areas, and allowable uses within buffer areas, including as follows:

LUP Page C-99. A wetland is defined as land where the water table is at, near, or above the land surface long enough to promote the formation of hydric soils or to support the growth of hydrophytes. In certain types of wetlands, vegetation is lacking and soils are poorly developed or absent. Such wetlands can be recognized by the presence of surface water or saturated substrate at some time during each year and their location within, or adjacent to, vegetated wetlands or deep water habitats.

LUP Policy 18. Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on such resources shall be allowed within such areas. Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade such areas, and shall be compatible with the continuance of such habitat areas.

IP 9-4.4302 Definitions. … (f) “Buffer” shall mean an area of land adjacent to primary habitat, which may include secondary habitat as defined by a qualified biologist or botanist, and which is intended to separate primary habitat areas from new development in order to ensure that new development will not adversely affect the San Francisco garter snake and wetlands habitat areas.

IP Section 9-4.4403 Habitat Preservation. (a) Intent. The provisions of this section shall apply to all new development requiring a coastal development permit in the CZ District and shall be subject to the regulations found in Article 43, Coastal Zone Combining District. The intent of these provisions is to protect, maintain, enhance and restore the following types of environmentally sensitive habitat as identified in the LCP Land Use Plan…
(c) Survey Contents. All habitat surveys shall include, at a minimum, the following information: …
(4) Delineation of all wetlands, streams, and water bodies;

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Packet Pg. 3729 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2-19-0026 (Rhodes Mixed-Use Development)

(5) Direct and indirect threats to habitat resulting from new development; (6) Delineation of the secondary habitat buffer area to be provided along the periphery of the primary habitat; and
(7) Mitigation measures to reduce impacts and to allow for the long-term maintenance of environmentally sensitive habitats.
(e) Development Standards for Wetlands and Wetland Buffer Areas. The following minimum standards shall apply to a wetlands and wetlands habitat area.
(1) No new development shall be permitted within a recognized wetlands habitat area;
(2) Limited new development may be permitted within a recognized wetlands habitat buffer area subject to the following standards: … (iv) Public access through wetlands shall be limited to low-intensity recreational, scientific, or educational uses. Where public access is permitted, it shall be strictly managed, controlled, and confined to designated trails and paths as a condition of project approval; (v) Alteration of the natural topography shall be minimized; (vi) Runoff and sedimentation shall not adversely affect habitat areas; (vii) Alteration of landscaping shall be minimized unless the alteration is associated with restoration and enhancement of wetlands; … (ix) New development adjacent to the buffer shall not reduce the biological productivity or water quality of the wetlands due to runoff, noise, thermal pollution, or other disturbances;
(x) All portions of the buffer shall be protected pursuant to Section 9-

4.4308, Permanent Environmental Protection;
(xi) Potential impacts identified in the habitat survey shall be mitigated to a level of insignificance where feasible; and
(xii) Mitigation measures identified in the habitat survey shall be considered and made conditions of project approval where necessary to mitigate impacts
(3) In the event that new development is not possible because the size of the buffer has rendered the site undevelopable, the buffer may be reduced in width if it can be demonstrated that a narrower buffer is sufficient to protect

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Packet Pg. 3730 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2-19-0026 (Rhodes Mixed-Use Development)

the habitat and new development may be permitted subject to standards established in (e)(2) above.

IP Section 9-4.4308 Permanent Environmental Protection. (b) Findings. The Director, the Planning Commission, or the City Council may determine that the proposed development is required to include a continuous and binding land use restriction through either a deed restriction, easement, offer of dedication, or other conveyance, as a condition of project approval based on any of the following findings: … (2) Such a restriction is necessary to protect sensitive coastal resources, including environmentally sensitive habitat, open space, and view corridors…
Analysis
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 the subject site, indicating that any proposed development 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 recommendation to conduct a one-parameter wetland delineation at an earlier stage in the process, a delineation of the 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. 5 This delineation showed that the adjacent watercourse that runs along the western edge of the subject property 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 subject property’s western boundary. 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 subject property and takes up approximately

0.048-acres at the northern border of the subject property (see delineation of these features in Exhibit 5). The federal and state wetlands present onsite include arroyo willow thicket, perennial rye 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 sitespecific circumstances associated with the property known at that time, Dr. Garske indicated that the minimum possible justifiable wetland buffer, if appropriately mitigated, 5 The delineation was prepared for the Applicant by Coast Ridge Ecology, LLC as part of the CDP application to the Coastal Commission.

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Packet Pg. 3731 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2-19-0026 (Rhodes Mixed-Use Development)

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 subject 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 subject parcel 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 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 as being used by CRLF more than just a single frog passing through, and the information provided and reviewed indicates that the area is used as CRLF aquatic and/or dispersal habitat. While the Applicant’s consultant argues 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 Commission 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 subject parcel constitutes part of a larger habitat corridor for CRLF. In addition, the watercourse 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

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Packet Pg. 3732 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2-19-0026 (Rhodes Mixed-Use Development)

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 concludes 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 well6.

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 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 proposed development in ESHA is not a resource-dependent use and it would significantly disrupt habitat values. As a result, the proposed project is 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.

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.
6 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.

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Packet Pg. 3733 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Paciÿca
Pier
Milagra R i dg e (GGNRA )
Sharp Par k
Golf Cours e
Mori Poin t (GGNRA )
Sha r p Pa r k
Sw e en e y
Ridg e
(GGNRA )
Sa n P ed ro Val le y
C ou n ty Pa r k
Pe d ro Poi n t
Headland s
(G G NRA )
Sharp
Park
Beach
Rockaway
Beach
Paciÿca
State
Beach
Northern
Coastal
Blu°s
(GGNRA)
(SFPUC )
Watersh e d
Pe n i n sul a
O cea n
Pac iÿ c

GAT EWAY DR

FIRECREST AVE

INVERNESS DR

MONTEREY RD

OLD COAST HWY

MANOR DR

SKYLINE BLVD

GLENCOURT

MONTEREY RD

P A OTTEMLA VE

EDGEMAR DR

MILLER AVE

AVALON DR

OCEANA BLVD

PALOMA AVE

TALBOT AVE

BRADFORD WAY

SHARP PARK RD

MOANA WAY

LUNDY WAY

FAIRWAY DR RIDGEWAY DR

BEACH BLVD

REINA DEL MAR AVE

ROCKA WAY BEACH AVE

TERRANOVA BLVD

EVERGLADES DR

ODDSTAD BLVD

CRESPI DR

LERIDA WAY

CRESPI DR

SEVILLE DR

MANZANITA D
A
R

LICANTE
LIN
DR

DA MAR BLVD

ADOBE RD

PERALTA RD

DE SOLO

LINDA MAR BLVD

FASSLER AVE

PARK LINCOLN

GRAND AVE

SKYLINE BLVD

MILAGRA DR

HICKEY BLVD

ESPLANADE AVE

MANOR DR

ROBERTS RD

SHARP PARK RD

SEASIDE DR

CLARENDON RD
Dev i l’s S l ide Tunne l
SOURCE: Critical Habitat for ˜reatened &
Endangered Species, U.S. Fish & Wildlife Service,
2015; Steelhead Critical Habitat - Coast, National
Marine Fisheries Service (NOAA), 2005; California
Dept of Forestry, 2005; California Dept of Fish &
& Wildlife, 2005; California Native Plant Society,
2005; U S Geological Survey, 2005; City of Paciÿca,
2020; San Mateo County, 2020; Dyett & Bhatia, 2020.

Milagra Ridge and Sharp Park/Sweeney Ridge
*100-400 foot wide corridor needed between
MILES
0 1/4 1/2 1 2
Planning Area
City Limits
Urban and Non Urban Land
with Little or No Habitat Value
Wildlife Movement Corridor*
˜ reatened by Fragmentation
High Habitat Value/
Other Sensitive Areas
California Red-legged Frog
Steelhead
Critical Habitat
Sensitive Habitat Areas
Potential Environmentally
Critical Habitat
Sensitive and
Figure 3.7-3:

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Packet Pg. 3734 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Pac
Ocean Devil’s Slid e Tunnel
Figure 4-3:

Potential
Environmentally
Sensitive Habitat
Areas
0 1/2 1 1/4
MILES
2 Coastal Zone
City Limits
Planning Area
SOURCE: U.S. Fish & Wildlife Service 201;
National Marine Fisheries Service, 20;
National Park Service, 200; 64%"
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California Natural Diversity
Database, 209; California Native Plant
Society, 20; California Dept of Fish &
Game, 20; FEMA, 20; ESA, 

City of PBDJGJDB

20; San Mateo County,
209; Dyett & Bhatia, 201.

Critical Habitat
Steelhead
California Red-Legged Frog
Pier
Sha rp Pa rk
Golf Course
Mori P oint (GGNRA )
Pe dro P oint
H ead lan ds
(GGNRA)
Sharp Park Beach
Rockaway
Beach
State
Beach
Northern Coastal
(GGNRA)

OLD COAST HWY

E AV TO TE LM PA

BRADFORD WAY

FAIRWAY DR

BEACH BLVD

GRAND AVE

ESPLANADE AVE

SEASIDE
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Packet Pg. 3735 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 7-19
Pacica
Pier
Milagra R i dg e (GGNRA )
Sharp Par k
Golf Cours e
Mori Poin t (GGNRA )
Sha r p Pa rk
Sw e en ey
Ridg e
(GGNRA )
Sa n P ed ro Val le y
C ou n ty Pa rk
Pe d ro Poi nt
Headland s
(G G NRA )
Sharp
Park
Beach
Rockaway
Beach
Pacica
State
Beach
Northern
Coastal
Blu
s
(GGNRA)
(SFPUC )
Watersh ed
Pe nin sul a
O cea n
P a cif ic

GAT EWAY DR

FIRECREST AVE

INVERNESS DR

MONTEREY RD

OLD COAST HWY

MANOR DR

SKYLINE BLVD

GLENCOURT

MONTEREY RD

P A OTTEMLA VE

EDGEMAR DR

MILLER AVE

AVALON DR

OCEANA BLVD

PALOMA AVE

TALBOT AVE

BRADFORD WAY

SHARP PARK RD

MOANA WAY

LUNDY WAY

FAIRWAY DR RIDGEWAY DR

BEACH BLVD

REINA DEL MAR AVE

ROCKA WAY BEACH AVE

TERRANOVA BLVD

EVERGLADES DR

ODDSTAD BLVD

CRESPI DR

LERIDA WAY

CRESPI DR

SEVILLE DR

MANZANITA D
A
R

LICANTE
LIN
DR

DA MAR BLVD

ADOBE RD

PERALTA RD

DE SOLO

LINDA MAR BLVD

FASSLER AVE

PARK LINCOLN

GRAND AVE

SKYLINE BLVD

MILAGRA DR

HICKEY BLVD

ESPLANADE AVE

MANOR DR

ROBERTS RD

SHARP PARK RD

SEASIDE DR

CLARENDON RD
D e v i l ’ s S l i d e T u n n e l
SOURCE: Critical Habitat for reatened &
Endangered Species, U.S. Fish & Wildlife Service,
2015; Steelhead Critical Habitat - Coast, National
Marine Fisheries Service (NOAA), 2005; California
Dept of Forestry, 2005; California Dept of Fish &
& Wildlife, 2005; California Native Plant Society,
2005; U S Geological Survey, 2005; City of Paci
ca,
2020; San Mateo County, 2020; Dyett & Bhatia, 2020.

Milagra Ridge and Sharp Park/Sweeney Ridge
*100-400 foot wide corridor needed between
MILES
0 1/4 1/2 1 2
Planning Area
City Limits
Urban and Non Urban Land
with Little or No Habitat Value
Wildlife Movement Corridor*
reatened by Fragmentation
High Habitat Value/
Other Sensitive Areas
California Red-legged Frog
Steelhead
Critical Habitat
Sensitive Habitat Areas
Potential Environmentally
Critical Habitat
Sensitive and
Figure 7-3: Figure 7-3: Sensitive and
Critical Habitat

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Packet Pg. 3736 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica General Plan Update (GPU) and Local Coastal Land Use Plan (LCLUP) Comments 1 | P a g e
DATE: March 2, 2022
To: Christian Murdock, AICP
Deputy Director of Planning
City of Pacifica Planning Department
540 Crespi Drive, Pacifica, CA 94044
RE: City of Pacifica General Plan 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).

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 Non-Urban 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.

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Packet Pg. 3737 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica General Plan Update (GPU) and Local Coastal Land Use Plan (LCLUP) Comments 2 | P a g e

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 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.

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:

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 one-parameter 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 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

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Packet Pg. 3738 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica General Plan Update (GPU) and Local Coastal Land Use Plan (LCLUP) Comments 3 | P a g e
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 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

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Packet Pg. 3739 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica General Plan Update (GPU) and Local Coastal Land Use Plan (LCLUP) Comments 4 | P a g e
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 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.

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.

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Packet Pg. 3740 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica General Plan Update (GPU) and Local Coastal Land Use Plan (LCLUP) Comments 5 | P a g e
Considering all of the facts present, I hereby request that the City of Pacifica correct and 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.

Respectfully,
William “Leo” Leon
Pacifica CA 94044
Attachments
Figures: 3.7.3 & 7.3 Sensitive and Critical Habitat
Figure 4.3 ESHA LCLUP,
F16a CCC Report,
CCC Report Exhibits: 5, 6, 7, 8, 9, 11
Email, August 16, 2021 CRLF

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Packet Pg. 3741 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: Christine Boles < >
Sent: Wednesday, May 25, 2022 7:49 AM
To: Berman, Lauren; Domurat, George; Ferguson, Alex; Godwin, James; Hauser, Samantha; Leal, David; Michelle Kenyon [BWS Law]; Murdock, Christian; Public Comment; Woodhouse, Kevin; _City Council Group; Wright, Greg
Subject: General Plan hearing urgent questions
[CAUTION: External Email]

Can someone please explain what is happening with the General Plan Planning Commission hearing? There was no announcement in the Tribune last week as is common for Planning Commission hearings and today’s Tribune says  it will happen in person at the Council Chambers on June 1st when the council voted Monday to suspend in person meetings.

I also have questions which I had asked of staff on Sunday the 22nd which  have not been answered.

See screenshot below.

Thank you for your response Tygar. Could you please ask how many pages the DEIR responses to comments totals, and how many pages of the GP and SPSP have been modified? ? A normal process would be to read and study the responses from the consultants, and then to go back and analyze the GP and SPSP in light of those responses. A release on Wednesday only gives a week for all this work, and this is a holiday weekend when many people, including myself, are traveling. As much as I care about Pacifica, my son's 22 years of hard work leading to his college graduation next Sunday takes priority.

There was no notice in this week's Tribune either, which is really unusual, as all Planning Commission items are typically noticed two weeks ahead of time. According to the latest Connect with Pacifica announcement, planning commission public comments will only be accepted on June 1st. Is that only one public comment for all the documents? Or will they be broken down and agendized to allow for comments on different sections? I know there has been a lot of talk with the recent goal setting and budget of increasing public engagement, and I have to ask you and Mary whether you think this meets those goals. These are really important documents that define our city's future for the next 20-40 years and the public should be allowed to have a voice in front of the planning commissioners, whose backgrounds and training typically allow them to understand these technical issues more than most council members who have not served in this capacity. We've been waiting 40 years, why can we not wait a few weeks to do this right? There should be enough information here to be able to start working on the critical Housing Element update concurrently. I do not understand the rush.

It breaks my heart when I think of all the public input that was allowed for the sole topic of our Hillside Preservation Ordinance, which can be read in less than 10 minutes. 14 public hearings with public comments at each one. What has changed in our governance that the public voice working in partnership with the city is treated as of such low value?
I appreciate any clarifications you may be able to get from staff since this is not agendized for discussion at tomorrow's meeting.

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Packet Pg. 3742 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 Christine Boles, Architect
‐‐
Christine
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3743 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: Christine Boles < >
Sent: Wednesday, May 25, 2022 12:25 PM
To: Murdock, Christian; Public Comment; _City Council Group; Berman, Lauren; Leal, David; Hauser, Samantha; Wright, Greg; Godwin, James; Domurat, George; Ferguson, Alex Cc: Michelle Kenyon [BWS Law]; Woodhouse, Kevin
Subject: Re: General Plan hearing urgent questions
[CAUTION: External Email]

Christian,
It is my opinion that the meeting should be delayed so that the correct meeting notification information can be given to the public in various formats. Not everyone is subscribed to the city's email updates, and not everyone is on social media. I have also heard from some people who submitted formal written comments that they never received the email notice you sent out last Friday, including a former Planning Commissioner. I believe this may be improper too as all "interested parties" should be contacted directly and given at least 10 days notice.

I would also like to ask the City Attorney to confirm whether this notice complies with the general requirements for public notifications and also the requirements for EIRs per California Code Title 14 Section 15088.

I have CC'd back in the City Council and Planning Commissioners as they should have a say in these decisions. The Mayor and Council members represent the public after all and should have the final say as to whether they feel their constituents are well represented by these decisions and processes. These are critical documents that the entire population of Pacifica should be able to weigh in on with the Planning Commissioners who are better suited to address and answer the technical issues in the documents. Even if it's legal, is it right that this hearing gets less notification than a residential remodel coming before the Planning Commission? The optics are not good and it certainly does not meet the Council's Goals of increased public engagement.

You also did not answer my question about whether the Planning Commission meeting agenda will be broken up so that we can discuss and make comments on the EIR, GP and SPSP separately? Or is staff's intention that the public is limited to one 2-3 minute comment on the entire plan update? There is so much important information in each of these documents and many residents and agencies spent a considerable amount of time researching and writing letters to try to improve the documents. Hopefully the updates incorporated our feedback, but at this point we don't know.

Please allow the public to partner with you to help you make these documents better so that they can properly serve all of us for the next decades. We need to be properly notified and we need to be given time to review the city's responses. I'd still like to know how many pages there are of responses to comments and how many pages of plan documents have been changed.

Can the Planning Commissioners even read and digest this much new information plus new comment letters coming in over the next week?
Thank you,
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044

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Packet Pg. 3744 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu On Wed, May 25, 2022 at 11:29 AM Murdock, Christian <[email protected]> wrote:

Christine,
The 6/1 Planning Commission meeting will occur via Zoom.  As you noted, the City Council decided on 5/23 that public health conditions warranted a shift to Zoom meetings effective immediately for the City Council and commissions/committees.  This shift occurred after publication of the legal ad for the 6/1 Planning Commission meeting in the San Mateo Daily Journal on 5/21 and after the point at which the City could request the Pacifica Tribune to pull the courtesy ad scheduled for publication in the 5/25 edition.  I apologize for the confusion.  City staff is working to address the change in meeting venue to the best of its ability, but some factors such as publication timelines for the Pacifica Tribune newspaper are beyond the City’s control.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]

From: Christine Boles < >
Sent: Wednesday, May 25, 2022 7:49 AM
To: Berman, Lauren <[email protected]>; Domurat, George <[email protected]>; Ferguson, Alex <[email protected]>; Godwin, James <[email protected]>; Hauser, Samantha <[email protected]>; Leal, David <[email protected]>; Michelle Kenyon [BWS Law] <[email protected]>; Murdock, Christian <[email protected]>; Public Comment

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Packet Pg. 3745 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 3 <[email protected]>; Woodhouse, Kevin <[email protected]>; _City Council Group <[email protected]>; Wright, Greg <[email protected]> Subject: General Plan hearing urgent questions

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Can someone please explain what is happening with the General Plan Planning Commission hearing? There was no announcement in the Tribune last week as is common for Planning Commission hearings and today’s Tribune says  it will happen in person at the Council Chambers on June 1st when the council voted Monday to suspend in person meetings.

I also have questions which I had asked of staff on Sunday the 22nd which  have not been answered.

See screenshot below.

Thank you for your response Tygar. Could you please ask how many pages the DEIR responses to comments totals, and how many pages of the GP and SPSP have been modified? ? A normal process would be to read and study the responses from the consultants, and then to go back and analyze the GP and SPSP in light of those responses. A release on Wednesday only gives a week for all this work, and this is a holiday weekend when many people, including myself, are traveling. As much as I care about Pacifica, my son's 22 years of hard work leading to his college graduation next Sunday takes priority.

There was no notice in this week's Tribune either, which is really unusual, as all Planning Commission items are typically noticed two weeks ahead of time. According to the latest Connect with Pacifica announcement, planning commission public comments will only be accepted on June 1st. Is that only one public comment for all the documents? Or will they be broken down and agendized to allow for comments on different sections? I know there has been a lot of talk with the recent goal setting and budget of increasing public engagement, and I have to ask you and Mary whether you think this meets those goals. These are really important documents that define our city's future for the next 20-40 years and the public should be allowed to have a voice in front of the planning commissioners, whose backgrounds and training typically allow them to understand these technical issues more than most council members who have not served in this capacity. We've been waiting 40 years, why can we not wait a few weeks to do this right? There should be enough information here to be able to start working on the critical Housing Element update concurrently. I do not understand the rush.

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Packet Pg. 3746 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 4 It breaks my heart when I think of all the public input that was allowed for the sole topic of our Hillside Preservation Ordinance, which can be read in less than 10 minutes. 14 public hearings with public comments at each one. What has changed in our governance that the public voice working in partnership with the city is treated as of such low value?
I appreciate any clarifications you may be able to get from staff since this is not agendized for discussion at tomorrow's meeting.

Christine Boles, Architect

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

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

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Packet Pg. 3747 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: Ringuette, Oceane@Coastal <[email protected]> Sent: Tuesday, May 24, 2022 10:47 AM
To: Murdock, Christian
Cc: KoppmanNorton, Julia@Coastal
Subject: RE: Notice of Public Hearing on 6/1/2022 - Plan Pacifica - General Plan Update and Sharp Park Specific Plan
Attachments: FW: NOP - Pacifica GP Update & Sharp Park Specific Plan - Comments; CCC Comment Letter 2018.08.31.pdf; CCC Comment Letter 2018.10.19.pdf; CCC Comment Letter 2019.11.22.pdf; Pacifica LCP Post-Consultation Draft Letter 2020.02.19.pdf; CCC Comment Letter 2018.08.29.pdf; CCC Comment Letter 2020.02.19.pdf; General Plan Update & Sharp Park Specific Plan - DEIR Comments.msg
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Hi Christian,
Thanks for notifying us about the Public Hearing 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 project. Broadly, to reiterate previous comments, the General Plan Update and Sharp Park Specific Plan 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.

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. 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.

Please let me know if you have any questions.

Thanks,

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Packet Pg. 3748 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 Oceane Ringuette
Coastal Planner
North Central Coast District
California Coastal Commission
Pronouns: she/her
From: Murdock, Christian <[email protected]>
Sent: Friday, May 20, 2022 1:54 PM
Subject: Notice of Public Hearing on 6/1/2022 ‐ Plan Pacifica ‐ General Plan Update and Sharp Park Specific Plan Dear Interested Party:

Please find attached a Notice of Public Hearing in relation to the City of Pacifica’s efforts to adopt a comprehensively updated General Plan and new Sharp Park Specific Plan, which are two components of the “Plan Pacifica” process.  The Planning Commission will meet to consider these items at a special meeting on June 1, 2022.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3749 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: KoppmanNorton, Julia@Coastal <[email protected]> Sent: Friday, November 13, 2020 9:12 AM
To: Rexing, Stephanie@Coastal
Subject: FW: NOP - Pacifica GP Update & Sharp Park Specific Plan - Comments Attachments: City Council 7/20 - Sharp Park Specific Plan Guiding Policy Framework Discussion From: "KoppmanNorton, Julia@Coastal" <[email protected]> Date: Wednesday, September 9, 2020 at 1:07 PM
To: "Murdock, Christian" <[email protected]>
Subject: NOP ‐ Pacifica GP Update & Sharp Park Specific Plan ‐ Comments Hi Christian,
Please add this email to the record for comments on the NOP for the General Plan Update and Sharp Park Specific Plan.

As noted in the attached email dated July 16, 2020 on the City Council’s framework discussion regarding the Sharp Park Specific Plan, as the Sharp Park Specific Plan proposes to increase height and density allowances within the Sharp Park neighborhood, the CEQA analysis should thoroughly analyze potential visual impacts of development as provided through the Specific Plan on the character of the surrounding area and on views through the neighborhoods of the ocean, impacts to community character as designated and provided in the LCLUP, impacts on public access and recreation, and impacts of potential geotechnical and coastal hazards on development that per the current proposal would be of increased height and density than currently allowed. More specifically, the analysis should include visual simulations, height and density alternatives, explanations of the hazards within this particular neighborhood, and the benefit to the public with regard to priority uses in this coastal area, and should consider:
 Potential impacts if the proposed maximum height is reduced in areas in which tall buildings (up to 55 feet in height) will impact the visual character of surrounding areas as well as public views to and from the ocean in visually sensitive areas, and
 Performing a thorough geotechnical analysis, including an evaluation of the potential hazards to this neighborhood (landslides and shoreline erosion) as well as a wave uprush study for the area. Such a wave uprush study should include an assessment of the potential hazards caused by 100‐year storm events (cumulative with high tide events, as well as projected sea level rise impacts and given a typical eroded beach condition).

In addition, any new General Plan and Sharp Park Specific Plan policies will need to be consistent with the LCP, and should not lessen protections or conflict with policy protections for coastal resources in the LCP. Please let me know if you have any questions. We look forward to continuing to work with the City on this CEQA process.

Thanks,
Julia
____________
Julia Koppman Norton
Coastal Planner

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Packet Pg. 3750 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 North Central Coast District
California Coastal Commission
(415) 904‐5292

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Packet Pg. 3751 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan

STATE OF CALIFORNIA-NATURAL RESOURCES AGENCY

CALIFORNIA COASTAL COMMISSION
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105- 2219
VOICE (415) 904-5200
FAX ( 415) 904- 5400
TDD (415) 597-5885
To: Bonny O'Connor
From: Coastal Commission staff
Date: August 29, 2018
EDMUND G. BROWN, JR., GOVERNOR
RE: Coastal Commission staff comments on the July 2018 Draft Sea-Level Rise Adaptation Plan
Dear Ms. O'Connor:

Thank you for the opportunity to comment on the July 2018 draft of the City of Pacifica's Sea Level Rise Adaptation Plan. This report is a deliverable for Task 3 of the City's LCP Local Assistance Grant, LCP-16-01. This draft includes a cost-benefit analysis and shoreline evolution findings for various adaptation alternatives for seven sub-areas in the City, as well as recommended adaptation approaches based on this analysis, and is meant to provide a foundation for developing new and updated LCP polices to help the City respond to sea level rise. Previous versions of this document which laid out the different adaptation alternatives that would be analyzed were also reviewed by Commission staff.

Overall, Commission staff believes that the Adaptation Plan currently lacks critical details regarding the feasibility of various approaches, does not provide for an adequate cost-benefit assessment of different adaptation alternatives, and lacks a defined adaptation approach that would meet Coastal Act requirements related to the protection of coastal resources for current and future generations. Given the criticality of this information for guiding policy development for the City's LCP, Commission staff recommends the following questions and concerns be addressed and that the adaptation plan be revised as necessary. 1) Recommended Adaptation Approach: In general, the adaptation plan seems to recommend an approach whereby development throughout the City would be protected with hard armoring, while beach nourishment would be used in continuity to try to preserve a stable beach width and retreat would be carried out on a voluntary basis. However, as discussed below, there is no analysis of how long shoreline armoring and beach nourishment would be feasible from an engineering or economic standpoint, and no discussion of the types of policies or programs that would allow the City to prepare for retreat at the scale necessary to relocate structures out of hazardous areas. The resulting emphasis on armoring would likely result in the loss of beaches and their associated public access, recreation, and habitat benefits as sea levels rise, and would leave the City unprepared for sea level rise in the long term. While armoring may protect existing development in the short to medium term, such an approach may not be technically or economically feasible in all areas and/or over longer timeframes, and would not, by itself, be consistent with Coastal Act requirements to ensure protection of coastal resources. This adaptation plan should be revised to identify how the City will 1 2.k
Packet Pg. 3752 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan balance the dual Coastal Act goals of ensuring safe development and protection of coastal resources such as beaches, habitat, and public access and recreation, as sea level rises over time.
2) Managed Retreat: Please update the discussion of managed retreat throughout the document by addressing the following questions and concerns.
a. On page 3 5, managed retreat is described as a strategy that encompasses the use of various measures such as short-term armoring or beach nourishment, which can buy time for existing development but eventually allows for shoreline recession over the long term.

In addition, on page 22, the report states that retreat may be cost effective in the long term in many subareas. Staff agrees with this characterization, but in order to effectively implement retre-at, a long-term planning approach is important to begin implementing now, including with strategies such as: limiting the extent and types of new development allowed in areas exposed to an increased risk of flooding or erosion; requiring hazards disclosures; requiring property owners to assume risks of those hazards; requiring new or existing development to be removed or relocated under certain conditions (e.g. when it is declared unsafe for occupancy, when access and utilities are no longer available to serve the development, when the blufftop edge erodes to a minimum setback line, or if required to be removed by subsequent adaptation planning); not allowing shoreline protection for new development (consistent with the Coastal Act); and ensuring that redevelopment is also sited and designed to be safe from sea level rise hazards without the reliance on existing or new shoreline armoring. Importantly, these types of policies would apply to both public and private development. Additionally, framing the idea of managed retreat as only optional for private development mischaracterizes this approach.

While voluntary relocation would certainly be an important part of such a strategy, it alone would not ensure that structures are removed before they become unsafe (such as was the case for the red-tagged apartment buildings in the City) nor would it ensure longterm protection of beaches and natural shoreline processes. Potential triggers for removal or relocation of existing development should be discussed accordingly. b. In the "Potential Funding Sources" section (pg. 31) the plan states that private property owners would be responsible for funding adaptation projects for their properties. While this may ultimately be true, the City can, and should, play a role in helping private property owners identify potential grant funding and/ or other methods for adapting to sea level rise. Indeed, this concept is included in the City's Hazard Mitigation Plan, as identified on page 16.
c. Managed retreat has not been analyzed for the area of West Linda Mar because this area is "outside of the City's coastal zone and therefore not subject to the Coastal Commission's directive to analyze managed retreat". While this maybe true, the City's vulnerability assessment shows portions of this area at risk for exposure to increased flooding as a result of sea level rise and the Commission recommends analyzing managed retreat city-wide because it is an important strategy to help ensure that development is safe and wetlands and other resources are protected. This concept is not only important on its own, but is emphasized in various statewide guidance including directives from the Governor, in the Ocean Protection Council's State Sea-Level Rise Guidance, and in the California Adaptation Plan {Safeguarding California).
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Packet Pg. 3753 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan d. In Appendix C, the figures showing beach width over time in response to the different adaptation options indicates that beach width under a retreat scenario narrows at almost the same rate as with an armoring scenario, but that seen1s like an erroneous assumption.

One of the objectives of a retreat scenario is to allow for natural shoreline processes, which should provide for beach migration (though the dynamics along rocky bluffs would be different than in low-lying beach areas). How was shoreline response to managed retreat modeled? There is currently no description provided in Appendix D. 3) Armoring: Overall, the City seems focused on using an armoring strategy, but the adaptation plan has not adequately described how the City will be able to protect coastal resources in conjunction with armoring. Portions of Section 4.1 state that a public access plan should be developed in concert with an armoring strategy, but there is no description of what such a plan might entail, and there is no information provided on how the City would be able to ensure public access is maintained or enhanced. Additionally, such plans seem to be presented as next steps. However, given that access is already reduced in many areas, including as a result of existing shoreline armoring, and impacts would only be exacerbated as sea levels rise, such plans should be developed now, and as armoring is repaired, expanded, and/ or constructed going forward.

Separately, the adaptation plan should explain the regulatory requirements of the Coastal Act regarding shoreline protective devices, as well as any relevant permit history throughout the area. Assumptions regarding Caltrans continuing to protect Highway 1 in place and the City of San Francisco continuing to maintain the Sharp Park berm as is should be described in the context of other actions these stakeholders have taken regarding realignment, relocation, and protection of other assets, as well as existing coastal development permit condition requirements. For example, pursuant to CDP 2-17-0702 the Sharp Park Berm is only authorized for ten years and requires a five year review by the Coastal Commission to evaluate whether any changed circumstances have occurred that would potentially necessitate a change of the authorization term given the uncertainties of climate change, sea level rise and the volatile history of the Pacifica shoreline.

Lastly, please discuss the engineering and economic feasibility of an armoring approach over time, especially in light of challenges with designing and maintaining armoring in the Esplanade area due to the nature of the bluff geology present. Are there areas of the city where armoring would not be feasible in the near, middle and/or long term? At what point would armoring no longer provide the level of protection necessary to prevent damage from storms and or higher amounts of sea level rise?
4) Beach Nourishment: Overall, there is no discussion of the geotechnical feasibility ofbeach nourishment over time. In order to evaluate the use of nourishment as a strategy for ensuring the continued existence of a beach, particularly in concert with any type of armoring strategies, a technical analysis is critical. How long is nourishment likely to be effective given the particular wave dynamics and geomorphology at various locations throughout the City? Similarly, if effective, how often and at what scale are these areas likely to need nourishment? At what point would the costs of nourishment make it infeasible? At what point would the rate of sea level rise be too high for nourishment actions to take place? Answers to these types of questions are essential if the City plans to pursue an approach that 3 2.k
Packet Pg. 3754 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan focuses on annoring and nourishment. At a minimum, these considerations should be qualitatively discussed.

Additionally, throughout the sub-area adaptation recommendations (starting on page 23), it is recommended that coarse sand or gravel be utilized because it would remain in place longer than finer sands. However, coarse sediment and gravel that is not comparable to area sand would likely result in significant environmental and recreational impacts, inconsistent with the Coastal Act. These Coastal Act requirements should be taken into consideration and described in the beach nourishment section.
5) Cost Benefit Analysis
a. The cost-benefit analysis seems to assume a fixed cost for beach nourishment over time.

However, the cost for sediment will likely increase over time as it becomes scarce. Given the focus on beach'nourishment as a preferr~d adaptation strategy, the adaptation plan should thoroughly explain this assumption and how it relates to the overall analysis. b. Are any mitigation costs associated with seawalls (e.g. required mitigation for sand supply and recreational impacts) incorporated in the costs for the cost-benefit analysis? Discuss whether or not these are incorporated and how this may affect the overall costs. c. Pg. 60 states that accelerating sea level rise would indicate an exponential cost increase for armoring but that this added cost is ignored for simplicity. What is the scale of this potential cost? How might it factor into the overall analysis? This assumption needs to be explained more and should be highlighted as needed to ensure the reader is aware of it. d. Page 61 states that a cost factor of2x was applied to account for demolition and replacement costs. Presumably these costs would generally not be the same, so how accurate is this assumption? In addition, the assumption that all structures would be rebuilt isn't necessarily accurate. These assumptions, and what they mean for the overall analysis, should be explained.
e. Does the $40/day beach recreation value account in any way for beach width? How is it actually factored into the analysis - does a narrowing beach result in a reduced recreational value? Does complete loss of beach result in complete loss of value? f. How does the recreational value of Sharp Park Golf Course actually get factored into the analysis? The Appendix seems to suggest that only the land value is accounted for- this should be described on page 65.
g. What do the transaction costs (page 65 and elsewhere) actually include? Why do they only accrue for managed retreat alternatives?
h. For the expected losses in property tax tables, the loss is significantly greater for the managed retreat alternatives. However, earlier in the report, the assumption is that structures would be demolished and rebuilt elsewhere which would suggest that the property tax would not be lost. Explain the assumptions used and why there are differences among these various cost factors.

1. Please explain why armoring strategies show increasing recreational value over time for each of the cost-benefit analysis tables, despite the fact that beaches would mostlikely be lost as a result of armoring. Is it due to the assumption that beach recreation will increase 4 2.k
Packet Pg. 3755 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan (broadly) over time? Even if recreation increases generally, it is unlikely that recreation would increase in areas where beach area is significantly reduced or eliminated. Please update this analysis and/or explain these assumptions.
j. For flooding impacts, are damage costs considered to be one-time costs? It is more likely that flood damage would happen repeatedly, more often, and to a greater degree as sea level rises if structures are not removed or protected. Relatedly, even the managed retreat alternatives show flood damage costs -what is being damaged in this alternative if structures are removed? The same question applies to Table 34 (regarding tidal flooding).

Additionally, for the tidal flooding table, this section discusses groundwater concerns - in such a case, how would armoring or nourishment protect structures? Also, what other adaptation measures might be needed to address groundwater concerns? Please explain these assumptions and how they impact the overall analysis. 6) Other Comments:
a. Section 4.1: Suggest moving this whole section, which amounts to the conclusions and recommendations, to the end of the document given that it is, presumably, based on the analysis presented in the later sections. Additionally, we suggest including a section that explains how individual strategies for each of the sub-areas would work together to address vulnerabilities for the City as a whole, and how the City would address both built and natural assets. This section should also discuss the types of strategies that could and should be used in all sub-areas, such as siting and designing new development to be safe from hazards.
b. Pg. 19: The document states that because extreme flooding occurs infrequently, sea level rise may be realized before extreme flooding. This statement runs counter to what is the case in most areas,.as the combination of even fairly routine storms riding on top of small increases in sea level are likely to cause damage earlier than higher amounts of sea level rise alone. Why would this not be the case in Pacifica? c. Pg. 20: Please provide more detail about Table 2. How were these stable beach widths and erosion offsets identified? What is the existing beach width/offset in these areas? d. Pg. 22 suggests that vulnerable public infrastructure be armored in the next 10 years, but later says that the adaptation plan includes contingency actions such as realignment if funding is unavailable for armoring. If relocation is an option as a contingency plan, why would it not be used as a primary means to ensure protection of this infrastructure? e. Pg. 31: Why are Prop 1A and Hazard Mitigation grant options not included in the table? We suggest also noting in the Table that, although State and Federal funding options vary over time, there are grant programs that support adaptation efforts (e.g. Coastal Commission, Coastal Conservancy, Ocean Protection Council, Caltrans, and NOAA grants).
f. Pg. 33: This section recommends that a plan be developed to maintain and potentially enhance various habitats as a next step. The Coastal Act requires protection of these resources, and thus such a plan should not be a next step, but rather something that should be a required element of this adaptation plan.
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Packet Pg. 3756 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan g. Pg. 33: Separate the bullet for the Coastal Commission and the Coastal Conservancy. The Conservancy does not have "jurisdiction" over actions in the Coastal Zone, but rather is an important partner in habitat and access related projects along the coast. h. Pg. 34: The description of setbacks states that there will be a question in the future about whether structures that become vulnerable in time would be removed or protected. In current practice, new structures must be sited and designed to be safe over their anticipated lifetime without the need for shoreline protective devices, consistent with the Coastal Act, and would therefore be required to be removed or relocated if they ever become unsafe due to sea level rise.
i. In the Table on page 40, why are setbacks not suitable for all sub-areas? Setbacks are fairly common for most development.

J. In Appendix C, explain how long-term, historic erosion rates were established and discuss whether or not the ongoing presence of existing SPDs may have affected the assumed background erosion rate.

Again, thank you for the opportunity to comment. Coastal Commission staff continues to appreciate the City's willingness to facilitate our involvement in the process ofcatrying out the grant requirements and updating the City's LCP, and we are available to discuss these comments in further detail.
/~) ... . . .I ~::~;~~cklow ~~7*i-~--,...,?--fl-o-.\L.- ') LCP Grant Coordinator and Climate Change Analyst
Cc:

Patrick Foster, Coastal Analyst, North Central Coast District 6 2.k
Packet Pg. 3757 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G. BROWN JR., GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW.COASTAL.CA.GOV
August 31, 2018
Tina Wehrmeister
Planning Director
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Draft Land Use Plan (LUP) Hazard Policies Dear Ms. Wehrmeister:

This letter is in response to the City of Pacifica’s request for comments on the “Proposed Updated Draft LUP Hazard Policies” provided to us in a memo from ESA to the City (entitled “Sea-Level Rise Policy Options for Pacifica LCP Update” and dated August 24, 2018). We note that we received this document just this week, and you have requested comments by today. As discussed with you, due to that abbreviated timeline of just a few days, we won’t be able to provide final or comprehensive comments, but we are happy to provide some preliminary thoughts and some broader observations regarding the current proposed policies. We look forward to continued dialogue on the policies, including with respect to refinements identified herein.

Overall, the proposed policies appear to provide a solid framework for advancing the City’s sea level rise adaptation efforts, which will be critically important in the coming decades. As is identified in its Sea Level Rise Vulnerability Assessment (June 2018), the City of Pacifica is already vulnerable to storm and wave impacts, including as evidenced by the loss of residential structures in recent years, and efforts to protect against such impacts have resulted in narrowed or completely inundated beaches backed by armoring where access can be largely unavailable at higher tides. These hazards are only expected to increase as sea levels rise, resulting in significant loss of public recreational beach resources and shoreline-area habitats, as well as damage to and loss of residential and commercial structures, and transportation, stormwater, and wastewater infrastructure. In particular, given its beaches are a fundamental backbone and significant part of the City’s social fabric and economic engine, it is critically important for the policies to reflect the importance of the City’s beaches, and to be transparent (and provided appropriate mitigations) where the policies might lead to increased impacts to same.

To this end, the proposed policies address the need to ensure that new development is sited and designed to be safe from coastal hazards and to avoid the need for armoring, and the policies provide many key mechanisms for future steps to take as sea level rise advances over time, including interim protection measures, beach nourishment, and eventual managed retreat in

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Packet Pg. 3758 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 certain locations. We want to commend the City for tackling such difficult issues head-on, and for starting to identify practical and substantive measures to address such issues moving forward.

At the same time, although many important sea level rise planning provisions are addressed in the proposed policies, and they provide a good foundation for the LCP update, we also believe that many important details will require refinement moving forward, including to ensure that the proposed policies are logical, feasible, realistic, and consistent with the Coastal Act. We look forward to working together with the City to refine this work so that it achieves Coastal Act and City objectives related to minimizing hazards and protecting coastal resources, even as sea level rises.

In the interim, and in drilling down a bit into the proposed policies, the current draft includes effective and important policies that address planning and accounting for coastal hazards longer term, but appear to require some focus on the shorter term horizon. For example, the “Standard Policies for New Development,” “Shoreline Structures,” and “Coastal Flooding and Other Hazards” sections provide policies for long-term planning throughout the City that should help ensure new development will be safe from current and future vulnerabilities and protective of coastal resources. However, we continue to have the same concerns that we have previously relayed to the City regarding how existing development will be addressed going forward in a manner that ensures beaches, habitat, public access, and recreation will be preserved for current and future generations, as required by the Coastal Act. Part of the challenge before us in refining the policies will be to make sure that the shorter term and longer term policies interact and seamlessly move towards similar objectives, and aren’t somehow at cross-purposes.

In addition, as you know we have previously identified issues associated with potential policy preparation as the City has worked through its Draft Adaptation Plan (including through meeting with you and your staff throughout this year as well as letters dated June 12, 2018 and August 29, 2018). One of our primary concerns was ensuring that such policy preparation was based on a detailed assessment of the feasibility and costs/benefits of different adaptation alternatives, and it is not clear that this sort of information has been fully developed. No matter what policies are ultimately proposed, it will be critical for decision-makers, both at the City and Commission level, to have the benefit of that sort of information as they weigh potential policy approaches.

We would be happy to work with you and your staff as this effort proceeds locally to ensure that such background is clearly provided.

In terms of more specific comments on the draft policies, here are some preliminary observations:
 The proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support it as a primary adaptation strategy through the proposed policies. In short, we think that policies that rely so heavily on nourishment, particularly in the shorter term, need to be

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Packet Pg. 3759 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 3 supported by more thorough data.
 The proposed policies refer to developing a “Shoreline Mitigation Program” in the future to address impacts associated with hazard response. The policies are going to need to be able to be structured to address such impacts now, and many policies seem to imply that is their intent. It may be appropriate to identify development of a future mitigation program as a refinement and a next step, but it needs to be clear that this does not negate the need for mitigation in the interim.
 It may be appropriate to reformat and reorganize the policies. For example, the “Standard Policies” sections from pages 14-19 account for the overarching approach for new development and substantial improvements to existing development, in all areas throughout the City, and in both the short- and long-term. It may make better sense to move these to the beginning. Additionally, although we understand the policy construct that suggests that general policies may be superseded by more specific policies for each sub-area, we are concerned that some of the more specific policies appear to be making prescriptions for outcomes that are not based on analysis (e.g., allowed armoring). It is not appropriate, in our view, to have policies state conclusions that have not yet been supported by analysis, and it may be that the overarching policies are required to take precedence in that regard unless and until conclusions can be drawn in that manner.
 The policies appear to be looking to the 2040 horizon as ‘longer term’, and this seems an appropriate framework. We would encourage a close review to ensure that policies referring to other time frames (e.g., 20-year approvals) are understood in terms of this horizon, including to ensure that development years out also times to the same horizon.  It appears that some critical policy language is missing from some of the draft policies.

Please ensure that the following are addressed:
o Please provide design standards for the construction of shoreline protection devices (e.g., they must: blend with natural environment; avoid significant habitat areas; minimize footprint; protect, and where feasible, provide public access; control erosion from surface and groundwater flows; etc.).
o Please identify specific details regarding how proportional mitigation for all unavoidable impacts of shoreline protection devices to coastal resources (e.g., shoreline sand supply, recreation, public views, and water quality) is to be measured and applied. o Please ensure that the policies require removal of shoreline protection devices when they are no longer required to protect existing structures in danger from erosion, including when structures are demolished and then rebuilt, or redeveloped. o Please define what constitutes “substantial improvements” to ensure that current development is brought into compliance with the policies as it is renovated and redeveloped. We have previously identified appropriate standards for such a definition, and would be happy to provide that again.
 Certain themes, concepts, and terms used throughout the draft policies need to be better defined, including as follows:
o Please better describe how the triggers would be implemented (e.g., trigger for when armoring/nourishment etc. would be implemented when the bluff offset reaches the

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Packet Pg. 3760 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 4 specified distance, or whether the specified distance triggers a different approach). In addition, please explain how the years and amounts of sea level rise pertain to the offset values and describe how beach width and bluff offsets will be measured. o Please explain how the hazard areas referenced in the policies will be defined, including the coastal hazard zones, coastal hazard maps, flood hazard zones, and tsunami run-up zones. In addition, for particular hazard areas that will be mapped, we recommend that the City add timeframes for how often these maps must be updated and include contingencies in the event that they are not updated by the prescribed deadline. o Please discuss how height limitations will be accounted for if/when structures need to be elevated to meet FEMA base flood levels in some areas.
o Please further expound upon what constitutes current “best available science” and whether there is a different standard for what amount of sea level rise should be evaluated in geotechnical studies versus what amount of sea level rise new development must be sited/designed to be safe from. For example, consider specifying that all new development must evaluate, at a minimum, the medium-high projection scenario (from the 2018 OPC Sea-Level Rise Guidance and in line with the Draft 2018 Science Update to the CCC SLR Policy Guidance) over its anticipated lifetime, but that if new development cannot be sited to avoid impacts over that time period certain minimum standards must be met (similar to the policies related to takings). We would be happy to work with the City on this topic.
o References to hazard policies are made without those specific policies’ reference numbers included. Please update the references accordingly.

Again, we appreciate and commend the City on developing these draft policies and the related policy framework, and look forward to helping to refine the policies and approach through our ongoing collaboration on the City’s LCP update. It is clear from these policies that the City is taking the issues and problems associated with coastal hazards seriously, and in a way that advances the City’s approach to sea level rise and LCP planning. We hope these comments help move us forward in that regard. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me or Patrick Foster of my staff. Again, we greatly appreciate the ability to be a part of this important planning process and look forward to continued coordination and discussion of this important effort.

Sincerely,

Jeannine Manna
North Central Coast District Manager
California Coastal Commission
cc: Bonny O’Connor, City of Pacifica Planner

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Packet Pg. 3761 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G. BROWN JR., GOVERNOR

CALIFORNIA COASTAL COMMISSION NORTH CENTRAL COAST DISTRICT OFFICE 45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW.COASTAL.CA.GOV
October 19, 2018
Tina Wehrmeister
Planning Director
City of Pacifica
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Draft Land Use Plan (LUP) Hazard Policies Dear Ms. Wehrmeister:

This letter is in response to the City of Pacifica’s request for comments on the “Proposed Updated Land Use Plan Coastal Hazards Policies” provided to us in a memo from ESA to the City (entitled “Sea-Level Rise Policy Options for Pacifica LCP Update” and dated August 24, 2018). As you know, we previously provided comments on a memo from ESA to the City with the same title and date (see attachment 1 for that memo, and see attachment 2 for our comments on it in a letter to the City dated August 31, 2018). We were surprised to see that the second memo (see attachment 3) was substantially different than the first memo and did not respond to the majority of our suggestions. Regardless of why the City may have chosen this approach, with respect to the second memo, many of our previous comments still stand, and are repeated below as appropriate. We have also suggested specific modifications to the policies and text within the new memo, including indicating where we believe that language from the first memo we reviewed should be re-inserted (see attachment 3). It is our understanding that the City Council will be considering these draft hazard policies by themselves now, but it is ultimately the City’s intention to incorporate them into an overall draft LCP update for consideration sometime in 2019. As such, although we provide some preliminary comments and suggestions here, it appears that there will also be future junctures when further refinement and comment is possible. Toward that end, we look forward to continued dialogue on the proposed policies, and to working with City staff to further develop this policy language in conjunction with the rest of the LCP update as the draft moves forward, including as it is modified in light of public and City Council input.

When we commented on the first memo we noted that we believed that the proposed policies began to provide a solid foundation and framework for advancing the City’s sea level rise adaptation efforts. As the Coastal Commission has routinely stated, clear, proactive policies for addressing sea level rise are critically important. This is undoubtedly true in Pacifica where, as is identified in the City’s Sea Level Rise Vulnerability Assessment (June 2018), the City is already vulnerable to storm and wave impacts. Such impacts are evidenced by the loss of blufftop residential structures in recent years, and by the fact that efforts to protect against such impacts have resulted in narrowed or completely inundated beaches backed by armoring where beach

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Packet Pg. 3762 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 access can be largely unavailable at higher tides. These hazards are only expected to increase as sea levels rise, resulting in a significant loss of public recreational beach resources and shorelinearea habitats, as well as damage to and loss of residential and commercial structures, and transportation, stormwater, and wastewater infrastructure. In particular, given its beaches are a fundamental backbone and significant part of the City’s social fabric and economic engine, it is critically important for the policies to reflect the importance of the City’s beaches, and to be transparent (and provide appropriate mitigations) where the policies might lead to increased impacts to same.

To this end, we are concerned that both the removal of some proposed policies from the first memo and the addition of new language in the second memo will result in policies that do not clearly state the need to ensure that new development and redevelopment be sited and designed to be safe from coastal hazards and to avoid the need for armoring. We also continue to have the same concerns that we have previously relayed to the City regarding how existing development will be addressed going forward in a manner that ensures beaches, habitat, public access, and recreation will be preserved for current and future generations, as required by the Coastal Act. In addition, we previously identified concerns associated with policy preparation based on a lack of technical and feasibility information as the City worked through its Adaptation Plan (including through meeting with you and your staff throughout this year as well as letters dated June 12, 2018 and August 29, 2018). One of our primary concerns was, and remains, ensuring that policies which prescribe specific adaptation measures (like armoring and beach nourishment with the use of sand retention structures) are based on a clear and detailed assessment of the environmental, technical, and economic feasibility of such alternatives. It is not clear that such information has been fully developed.

We do continue to recognize that addressing new and existing development in a place like Pacifica is a complex challenge given the scope of current and future hazards combined with existing patterns of development and shoreline armoring and uncertainties about future sea level rise and future conditions on the ground. As we have previously explained in meetings with and letters to City staff, there are policy approaches that would allow for continued reliance on armoring for certain development over a specified time horizon, including as identified in the City’s current sub-area policies. However, such policy approaches still need to ensure that impacts to other coastal resources would be mitigated, and need to build in an understanding that other adaptation options may be necessary if and when armoring (and/or beach nourishment) can no longer provide adequate protection for both development and coastal resources. Part of the challenge before us is to refine the policies and strike an appropriate balance in order to protect the range of coastal resources and development, while ensuring that short and long term policies interact and seamlessly move towards similar objectives.

In any case, we want to commend the City for tackling difficult sea level rise issues and for starting to identify practical and substantive measures to address such issues moving forward. To be sure, the proposed policies provide many key mechanisms for future steps to take over time as sea level rise advances, including interim protection measures, beach nourishment, monitoring of changing conditions, and periodic updates to the City’s Adaptation Plan to respond to such changes. Although many important coastal hazard planning provisions are addressed in the proposed policies and they provide a good foundation for the LCP update, we also believe that

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Packet Pg. 3763 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 3 many important details will require refinement moving forward, including to ensure that the proposed policies are logical, feasible, realistic, and consistent with the Coastal Act. We continue to look forward to working together with the City to refine this work so that it achieves Coastal Act and City objectives related to minimizing hazards and protecting coastal resources, even as sea level rises.

In terms of some more specific comments on the draft policies in the second memo, here are some preliminary observations:
• The previous memo included a summary with details of how the City has dealt with the impacts of shoreline erosion and coastal flooding for decades. We recommend including a similar setting description in the LUP itself to speak to the broad purpose of the proposed coastal hazard policies and to provide context for their future implementation. • The proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously with City staff, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support it as a primary adaptation strategy through the proposed policies. In short, we think policies that rely so heavily on nourishment, particularly in the shorter term, need to be supported by more thorough data. Similarly, the use of sand retention structures can alter ocean waves, currents and sand movement, potentially exacerbating erosion on one side or the other of the structure (e.g., depending on currents, littoral drift, etc.). These potential impacts should be evaluated accordingly if sand retention structures are planned to be used in conjunction with beach nourishment.
• The proposed policies refer to developing a “Shoreline Mitigation Program” in the future to address impacts associated with hazard response. The policies need be structured to address such impacts now, and many policies seem to imply that is their intent. It may be appropriate to identify development of a future mitigation program as a refinement and a next step, but it needs to be clear that this does not negate the need for mitigation in the interim. Accordingly, given the Shoreline Mitigation Program is not yet complete, we recommend removing reference to implementation of the Program in the policies, instead of referencing only that it will be developed in the future. Until the Program is fully developed, mitigation should be implemented consistent with the type of requirements found in proposed Hazard Policy 60. • It may be appropriate to reformat and reorganize the policies. For example, the “Standard Policies” sections from pages 12-16 account for the overarching approach for new development in all areas throughout the City, and in both the short- and long-term. It may make better logical, and document-flow sense to move these, along with the definitions section, to the beginning of the document. Additionally, although we understand the policy construct that suggests that general policies may be superseded by more specific policies for each sub-area, we are concerned that some of the more specific policies appear to be making prescriptions for outcomes that are not based on analysis (e.g., allowed armoring). It is not

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Packet Pg. 3764 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 4 appropriate, in our view, to have policies state conclusions that have not yet been supported by analysis, and it may be that the overarching policies are required to take precedence in that regard unless and until more definitive conclusions can be drawn. • It appears that some critical policy language is missing from some of the proposed draft policies. Please ensure that the following are addressed:
o Please provide design standards for the construction of allowable shoreline protection devices (e.g., they must: blend with natural environment; avoid significant habitat areas; minimize footprint; protect, and where feasible, provide public access; control erosion from surface and groundwater flows; etc.).
o Please identify specific details regarding how proportional mitigation for all unavoidable impacts of shoreline protection devices to coastal resources (e.g., shoreline sand supply, beaches, public recreational access areas and amenities, public views, water quality, etc.) is to be measured and applied. Please ensure that the policies require removal of shoreline protection devices when they are no longer required to protect existing structures in danger from erosion (including when structures are demolished and then rebuilt, or redeveloped) when such removal and restoration can be accomplished without endangering existing principal structures or existing public facilities on adjacent sites. o Please discuss how height limitations will be accounted for if/when structures need to be elevated to meet FEMA base flood levels in some areas.
o The siting and design policies for hazard areas no longer address substantial improvements to existing development (or ‘redevelopment’) in the second memo. We recommend the City develop specific language for how the siting and design of structures will be addressed when they are redeveloped in situations where there is existing, legally authorized shoreline protection and in cases where there is a natural bluff or shoreline fronting the proposed development. In addition, we recommend including separate policies to address new development on vacant lots that are fronted by existing, legally authorized shoreline armoring and in places where there is a natural bluff or shoreline. In cases where new development/redevelopment cannot be located safe from hazards without reliance on existing and/or new armoring or cannot meet the required setbacks, any approval for such development should include triggers for eventual removal in response to coastal hazards (e.g., when declared unsafe for occupancy and/or use; when the development encroaches onto current or future public trust land and the State Lands Commission denies a grant, lease, or other legal mechanism to allow the development to remain in place; when access and utilities are no longer available to serve the development and cannot be restored; when the blufftop edge erodes to the minimum setback line; when removal is required by subsequent adaptation planning; etc.), as well as propose ways in which the new and redeveloped structures will mitigate for that armoring’s impacts to coastal resources.
o Please provide a policy that outlines how the City will address development that becomes unsafe for occupancy and a public nuisance due to coastal hazards.

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Packet Pg. 3765 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 5 • Certain themes, concepts, and terms used throughout the draft policies need to be better defined or explained in order for us to better evaluate the intent and application of the proposed policies, including as follows:
o Please define “existing structure,” as it is used often in the policies in relation to shoreline armoring. We recommend that it be defined as a structure legally authorized prior to the effective date of the Coastal Act on January 1, 1977, including as is identified in the Commission’s Sea Level Rise Policy Guidance.
o Instead of only a reliance on “new development”, please also define “redevelopment” to ensure that current development is brought into compliance with the policies as it is substantially changed over time. Please establish clear thresholds for when repair, maintenance, improvement, or other work is conducted to the extent that a structure needs to be reviewed against all current standards, including for coastal hazards.

Typically, such thresholds would at the least include alteration (including demolition, renovation or replacement) of 50% or more of major structural components. o Please further describe what constitutes current “best available science” and whether there is a different standard for what amount of sea level rise should be evaluated in geotechnical studies versus what amount of sea level rise new development must be sited/designed to be safe from. For example, consider specifying that all new development must evaluate, at a minimum, the medium-high projection scenario (from the 2018 OPC Sea-Level Rise Guidance and in line with the Draft 2018 Science Update to the Commission’s Sea Level Rise Policy Guidance) over its anticipated lifetime, but that if new development cannot be sited to avoid impacts over that time period certain minimum standards must be met (similar to the policies related to takings). We would be happy to work with the City on this topic.
o Please explain how the hazard areas referenced in the policies will be defined, including the coastal hazard zones, coastal hazard maps, flood hazard zones, and tsunami run-up zones. The current definition of hazard zone refers to the City’s current maps, but it is not clear to what maps that refers. Any maps referred to in the policies should be included as part of the LCP. In addition, for particular hazard areas that will be mapped, we recommend that the City add timeframes for how often these maps must be updated and include contingencies in the event that they are not updated by the prescribed deadline. o Proposed Hazard Policy 5 states that the City will implement a monitoring program for sea level rise to establish thresholds for reassessing the City’s Adaptation Plan. Please describe the type of thresholds that will be identified. Additionally, the current sub-area policies refer to triggers, but do not explain how the triggers would be implemented. For example, clarify whether armoring/nourishment etc. would be implemented when the bluff offset reaches the specified distance, or whether the specified distance triggers a new approach. Please also explain how beach width and bluff offsets will be measured. o Proposed Hazard Policy 7 states that the Shoreline Mitigation Program will identify priority improvements for maintaining and enhancing coastal shoreline resources, particularly public access and recreation. Please further describe what types of

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Packet Pg. 3766 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 6 improvements the City is contemplating in this regard and provide relevant examples. o Proposed Hazard Policy 8 refers to funding for “adaptation strategies”. Please outline what kind of strategies this refers to, and specify if this will include voluntary removal or relocation of development.
o Proposed Hazard Policy 9 calls for identifying areas where densities and heights may be increased using TDR credits, including to facilitate affordable housing. Please describe how such determinations will be made, including which specific criteria will be evaluated.
o Proposed Hazard Policy 11 states that the City will preserve, protect, or relocate hazard prone infrastructure to maintain critical services and the environment. Given that these two goals will often conflict, please specify what criteria will be evaluated in determining the preferred option for infrastructure projects. Also, given similarities and overlap, please consider combining with proposed Hazard Policy 10. o Please clarify the intent of proposed Hazard Policy 50. Presumably redevelopment of existing development will require the entire structure to conform to applicable LCP standards, but the policy is not clear on this point.
o Proposed Hazard Policy 52 requires sea level rise buffer areas be added to new development if necessary to allow for the migration of wetlands and other shoreline habitats. Please describe how such buffer areas will be delineated, applied, and protected as same.
o The definition of shoreline within the hazard policies appears to exclude shoreline properties adjacent to rivers, streams and creeks, as well as properties that will be impacted by erosion and/or flooding by large storm events or over longer time periods due to rising sea levels. We recommend that the policies instead refer to coastal hazard areas so that properties that are potentially subject to coastal flood and erosion hazards both now and in the future will be reviewed for consistency with the hazard policies.

Again, we appreciate and commend the City on developing these draft coastal hazard policies and the related policy framework, and look forward to helping to refine the policies and approach through our ongoing collaboration on the City’s LCP update. It is clear from these policies that the City is taking the issues and problems associated with coastal hazards seriously, and in a way that advances the City’s approach to sea level rise and LCP planning. We hope these comments help move us forward in that regard. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me or Patrick Foster of my staff. Again, we greatly appreciate the ability to be a part of this important planning process and look forward to continued coordination and discussion of this important effort.

Sincerely,

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Packet Pg. 3767 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 7 Jeannine Manna
North Central Coast District Manager
California Coastal Commission
cc: Bonny O’Connor, City of Pacifica Planner
Attachments:

Attachment 1 – ESA memo to the City dated August 24, 2018 (memo 1) Attachment 2 – CCC comments on memo 1 dated August 31, 2018 Attachment 3 – ESA memo to the City also dated August 24, 2018 (memo 2)

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Packet Pg. 3768 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW.COASTAL.CA.GOV
November 22, 2019
City of Pacifica Planning Department
Attn: Tina Wehrmeister
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Consultation Draft Local Coastal Program Land Use Plan Update Dear Ms. Wehrmeister:

Thank you for the opportunity to review and comment on the City’s proposed draft update to the Local Coastal Program (LCP) Land Use Plan (LUP). As you know, the LUP is a key regulatory tool that implements the statewide goals and policies specified in the California Coastal Act to protect, restore, and enhance coastal resources at the local level, including by specifying the kinds, locations, and intensities of allowed development and applicable coastal resource protection requirements. Once the LUP and an accompanying Implementation Plan (IP) are certified by the Coastal Commission,1thus certifying an updated LCP overall, the updated LCP forms the basis and standard of review for future development within the City’s Coastal Zone.

Accordingly, the City’s current LCP update process offers an exciting opportunity to holistically and comprehensively envision Pacifica’s future and craft the process for how to achieve that vision. Given that importance, Commission staff has been actively and directly engaged with you and your staff to identify issues early and provide recommendations on how to approach the many complicated coastal resource policy decisions facing the City. We acknowledge the substantial time and energy the City has invested in developing this draft document and we greatly appreciate the efforts to coordinate and discuss with Commission staff.

In that vein, we are hopeful that these comments are understood in the manner in which intendednamely to provide as much helpful guidance from our perspective as possible at this juncture. As such, this letter provides a summary of some of the key issues we’ve identified thus far in our review of the draft document, as well as some broad recommendations for how to address these issues. Some of these issues we have discussed with you to-date, while others will be introduced for the first time in this letter.

Specific comments, as well as some line-edits, have been provided on each of the draft LUP chapters in the attached documents. However, given our limited review time, these comments and edits should not be considered final or comprehensive. Lastly, this letter is intended to respond to the City’s letter dated October 31, 2019 to clarify Commission staff’s general perspective regarding the consultation process thus far.

1 The standard of review for an LUP is Chapter 3 of the Coastal Act, and for an IP is the certified LUP.

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Packet Pg. 3769 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
2 Consultation Process
With regard to the letter sent to Commission staff regarding the LCLUP consultation process, we note that the City of Pacifica originally initiated the LCLUP Update process by developing a Consultation Draft in 2014. While this draft document was transmitted to Commission staff for initial review, the City halted the LCLUP process due to time and budgetary constraints. As a result, Commission staff did not conduct a thorough review nor provide written comments to the City at that time. The City began to reengage in the LCLUP update process again in 2018 through the development of an administrative draft of the LUP Coastal Hazards Chapter in conjunction with the development of a vulnerability assessment and adaptation plan. Throughout the multiple rounds of review prior to City action, Commission staff sent three comment letters (dated August 29, 2018, August 31, 2018, and October 19, 2018) on the Hazard Policy Update, all within the abbreviated timeframes requested by City staff, as well as attended a number of public meetings. Through all of these communications, Commission staff noted a willingness to work with the City to identify alternative, context-specific approaches to resolve significant concerns with the hazard policies as drafted (see included attachments). Other than a few coordination calls, Commission staff did not receive specific requests from the City to meet staff-to-staff to further engage at that juncture. Following action by the City Council approving the draft hazard policies for incorporation into the full LCLUP update, no further progress was made on the LCP update, as reflected in LCP grant progress reports received from the City during early 2019.

In summer and early fall of 2019, the City began to recirculate a new LCLUP Consultation Draft, starting with the version originally developed in 2014, incorporating the latest draft Hazards Policy Chapter approved by the City Council. While the City initially emailed Commission staff in August regarding their plans for revising the draft LCLUP recirculation schedule, there was no further discussion with Commission staff regarding the revised timeline to ensure it would be workable and provide for adequate review and staff to staff coordination prior to the draft going before the City Council and Planning Commission for feedback. In an effort to improve coordination on the LUP update process to ensure adequate and meaningful consultation could occur, Commission staff reached out to the City about the anticipated schedule and how to accommodate essential timeframes for both agencies.

At that time, the City relayed that they were sticking to an accelerated timeline to meet grant requirements, but did agree to modify the deadline for comments so as to provide Commission staff with 30-working days to review the draft document as opposed to 30-calendar days. During this review period City and Commission staff have met various times, both in-person and over the phone, and agreed the meetings have been productive. Commission staff continues to commend City staff for the hard work and coordination to-date, and it is our hope this cooperative process can continue. In our experience, this type of early coordination helps to ensure a smoother LCP certification process, including streamlining review and resolution of issues upon ultimate submittal to the Coastal Commission. As such, we will continue to honor our commitments to provide feedback to the City as requested, as we have previously done, regardless of existing workload constraints and staff turnover.

Draft LCLUP Update Feedback and Recommendations
First, in general, the proposed LUP update provides a good starting point by which the City can evaluate development in the coastal zone through assessing up-to-date information and revised policies that address current issues facing the City and reflect the City’s present day vision. However, at a broad level, the document requires numerous clarifications and details added to the policy language to make

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Packet Pg. 3770 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
3 the LUP as user-friendly as possible, manage development expectations in certain areas of the City with known constraints, and ensure consistency with the resource protection policies of the Coastal Act.

Additionally, there is significant overlap between policies in different chapters that creates redundancy, most notably between the Natural Hazards and Coastal Resilience Chapters. In our view, with added refinements and focus, the LUP will offer more clarity and ease of use, ensure adequate protections for sensitive habitats and public access to the beach, and minimize hazard risks to new development. We strongly recommend that the document be reviewed to add detail and clarify language where needed, eliminate policy redundancies, both within and among chapters, and to group related policies accordingly, as discussed in meetings and addressed in this letter and in the attached document edits.

Additionally, in 2019, the Coastal Commission unanimously adopted its first environmental justice policy to provide guidance for Commissioners, staff, and the public on how the Commission will implement its environmental justice authority and integrate the principles of environmental justice, equality, and social equity into all aspects of the Commission’s program and operations. While the current draft LUP mentions environmental justice in terms of the City Council’s Goals and in policy CR-I-2, we recommend the City consider adding additional policies that will more fully address environmental justice issues that pertain to coastal resources as well as participation in the decision making process to help to reduce disparate impacts on vulnerable communities resulting from new development.

In terms of the Land Use and Development chapter, we recommend: 1) ensuring that all figures, numerical references, and maps regarding existing and proposed land use patterns are accurate and upto-date; 2) adding language regarding maps/diagrams to indicate that they are illustrative and for planning purposes only; 3) adding directive policies requiring new development to demonstrate that there are adequate public services to serve such development, examples of which were previously provided to the City; 4) adding up-to-date neighborhood-specific traffic, hazard, visual character, and coastal planning constraints as outlined in the 1980 version of the LUP; 5) including further detail about sites with known development constraints (i.e. the Quarry and Pedro Point field); 6) prohibiting increases in density of land use in hazard and sensitive resource areas; 7) redesignating areas with severe development constraints to the Conservation land use designation, including lots adjacent to the bluff edge where homes and apartments were recently removed; and 8) providing a figure that indicates all proposed changes to existing certified land use designations. With regard to the Public Access Chapter, we recommend: 1) adding more policies that specifically bolster and speak to coastal access, as opposed to public access more generally; 2) ensuring that coastal access will be able to adapt in response to coastal hazards including in areas with and without shoreline protection; and 3) including all existing coastal access points throughout the City including lateral and vertical trails required as CDP requirements, and public parking lots.

Within the Environmental and Scenic Resources Chapter, in general, more recent sources and information should be referenced, and internal references should only be made to maps and documents that are part of the LUP rather than to other City documents. More specifically, the relationship between wetlands and environmentally sensitive habitat areas (ESHA) warrants further discussion. For example, while not all wetlands are ESHA, wetland policies are applied to all wetland areas, which should be stated explicitly. Further, the draft LUP should cite and recognize Coastal Commission regulations that

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Packet Pg. 3771 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
4 more clearly articulate the requirement for a one-parameter criteria for wetland delineations which is applied in the coastal zone, contrasting this with the USACE three-parameter approach. It should also be noted that because the National Wetlands Inventory (and similarly, any map provided or prepared by the City) are not all comprehensive, on-the-ground conditions will prevail. Discussions on ESHA should also: 1) include policies on ‘especially valuable habitat’ as defined by the Coastal Act, which captures natural resources not considered rare but that have some other particular value (e.g. unusually pristine conditions, vegetation supporting other sensitive species, wildlife corridors, etc.); 2) remove references to degrees of habitat value without definition, as an area can be severely degraded and still constitute ESHA if it can be restored and/or is supporting sensitive resources; 3) categorically designate dune habitats as ESHA; 4) reorganize and bolster the ‘Plant Communities and Wildlife Habitats’ section for consistency in terms of vegetation types and levels of specificity and relevance; 5) consider habitat not defined by vegetation communities including bluff faces, offshore rocks and islets, and dunes; 6) articulate why seasonal wetlands are included under ESHA; and 7) explain that all riparian habitat should be treated as ESHA, while clearly articulating the differences between streams, creeks, riparian vegetation, and riparian corridors.

In addition, minimum buffer requirements should be established for sensitive habitat areas including wetlands and ESHA, including streams, and any uses allowed within such buffers should be specified.

Moreover, a defined limit should be established for any exceptions to such minimum buffer requirements resulting in a buffer reduction. 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 wetland and/or ESHA and will be compatible with the continuance of the wetland and/or 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 wetland and/or ESHA. For both perennial and intermittent streams, buffers should be measured from the outer edge of riparian vegetation where it exists; if it does not, the buffer should be measured from the edge of the bank; and if there is no bank, the buffer should be measured from the mid-line of the watercourse. With respect to impacts and mitigation, impacts to coastal resources must always first be avoided to the maximum extent feasible, then minimized, then mitigated for. As such, compensatory mitigation requirements for impacts to sensitive habitats that cannot be avoided should be addressed in this document. Further, the City should consider defining temporary versus permanent impacts- where temporary impacts are those that would be resolved within 12 months, and do not include earthwork or other significant disturbance, with impacted vegetation restored to equal or better including that similar age/size structure of the community is restored.

The Environmental and Scenic Resources Chapter should also reference both perennial and nonperennial resources in any discussion on creeks and other waterways, should further develop the discussion and policies on marine resources (including beaches, rocky intertidal and reef habitats, softbottom habitats, and offshore rocks), and should avoid referencing “restoring” beaches unless it is intended to include ecological, as well as mineral and physical, resources. Additionally, instead of referencing restrictions on invasive plant species, we recommend prohibiting the use of any California Invasive Plant Council (Cal-IPC)-listed species with a status of high or moderate, or identified as locally-threatening under the limited alert or watch status, and to establish requirements for their

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Packet Pg. 3772 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
5 abatement from sites on a project-by-project basis as well as through broader restoration efforts. Lastly, there is the potential to frame some of the issues in the chapter under a theme of ‘water security,’ including concepts such as groundwater recharge, use of recycled water, etc.

As mentioned above, there are numerous redundancies between the “natural shorelines” section in the Environmental and Scenic Resources chapter and the content of the Natural Hazards and Coastal Resilience chapters. We recommend instead framing the protection of natural shorelines as “preservation of natural shore dynamics.” In addition to these redundancies, feedback on adaptation and hazard policies expressed in the aforementioned comment letters in 2018 (enclosed) was not incorporated into the draft policies, and as such the main themes are reiterated here. Specific details on policy language that should be incorporated can be found in the enclosed letters, including topics such as design, mitigation, and removal of shoreline protection structures, as well as triggers for removal of threatened development.

In general, the hazard and coastal resilience policies seem to recommend an approach for protecting development throughout the City with hard armoring, supplemented by potential beach nourishment, with no policies that would allow the City to prepare to relocate structures out of hazardous areas. The emphasis on armoring would likely result in the loss of beaches and their associated public access, recreation, economic, and habitat benefits as sea levels rise, and would leave the City unprepared for sea level rise in the long term. While armoring may protect existing development in the short- to mediumterm, such an approach may not be technically or economically feasible in all areas and/or over longer timeframes, and would not, by itself, be consistent with Coastal Act requirements to ensure protection of coastal resources. Policies should be framed to better balance the dual Coastal Act goals of ensuring safe development and protecting coastal resources such as beaches, habitat, and public access and recreation, as sea level rises over time. As discussed in our previous comment letters and in recent coordination calls, Commission staff would be happy to work with City staff in developing a more appropriate balance of short- and long-term approaches, including those that would consider the use of shoreline armoring.

Additionally, the proposed policies rely heavily on beach nourishment as a key adaptation strategy.

Although we believe that nourishment is an appropriate strategy to evaluate and pursue if technically feasible, we also believe that the information that could underpin such a strategy needs to be further fleshed out. As we have discussed previously, the technical analysis and supporting information regarding potential feasibility and effectiveness of beach nourishment (and also sand retention structures) needs to be better developed (including in relation to different grain sizes and the effects of sand retention structures on erosion in other areas), particularly to support such an approach as a primary adaptation strategy in this proposed LCP update. In short, we think that policies that rely so heavily on nourishment, particularly in the shorter term, need to be supported by more thorough quantitative data.

In addition, we have previously identified appropriate definitions of “redevelopment” and “existing structures” or “existing development” that should be incorporated into the draft. “Existing development” should be defined as a structure legally authorized prior to the effective date of the Coastal Act, i.e.- January 1, 1977, including as it is identified in the Commission’s Sea Level Rise Policy Guidance.

Instead of defining redevelopment, the draft defines ‘new development’ as development on a previously

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Packet Pg. 3773 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
6 vacant parcel, which would mean no current structures would ever have to be brought into compliance with policies if substantially redeveloped and as such does not align with the Coastal Act or the Commission’s guidance on sea level rise planning.

Finally, as discussed above, we have reviewed each of the draft LUP chapters and provided City staff with our suggestions and recommendations via in person meetings and phone calls on each chapter. In closing, we again thank you and your staff for the thoughtful and collaborative work done to date, and appreciate and commend the City for moving forward with the sometimes difficult, but important, task of updating the LCP’s LUP. We also very much look forward to continued collaboration, and helping the City to refine the draft LUP, and a future draft IP, including in the ways identified in this letter. We hope these comments help move us forward to this end. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me.

Sincerely,
Julia Koppman Norton
Coastal Planner
North Central Coast District Office
California Coastal Commission
cc: Kevin Woodhouse, City of Pacifica City Manager
Encl.: CCC Letter to City, dated August 29, 2018
CCC Letter to City, dated August 31, 2018
CCC Letter to City, dated October 19, 2018
LCP Draft Update, Ch. 1-6 & Appendices, with edits

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Packet Pg. 3774 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY GAVIN NEWSOM, GOVERNOR

CALIFORNIA COASTAL COMMISSION

NORTH CENTRAL COAST DISTRICT OFFICE
45 FREMONT STREET, SUITE 2000
SAN FRANCISCO, CA 94105
PHONE: (415) 904-5260
FAX: (415) 904-5400
WEB: WWW.COASTAL.CA.GOV
February 19, 2020
City of Pacifica Planning Department
Attn: Tina Wehrmeister
1800 Francisco Blvd.

Pacifica, CA 94044
Subject: City of Pacifica Post-Consultation Draft Local Coastal Program Land Use Plan Update Dear Ms. Wehrmeister:

Thank you for the opportunity to review and comment on the City’s Local Coastal Program Land Use Plan (LCLUP) post-consultation draft. We would like to commend you for the hard work that went into preparing this draft and acknowledge the effort made to respond to comments we submitted in our previous letter to you dated November 22, 2019 (attached). We recognize that the City has carefully gone through the aforementioned comments and line-item edits and has modified the draft LCLUP to accept some of our recommendations. This letter is intended to provide a summary of the remaining key issues we’ve identified in the post-consultation draft. The items discussed below should not be considered final or comprehensive given our limited review time, but are meant to provide guidance on the more challenging topics at this point in the process of our ongoing effort to coordinate with the City.

It is our understanding that the City Council will be considering the post-consultation draft at the public hearing on February 24, 2020. As such, please deliver this comment letter to the City Council for consideration prior to the hearing in question.

As indicated above, we understand City staff has incorporated some, but not all, of Commission staff’s edits and feedback into the LCLUP post-consultation draft. We continue to recommend that any additional outstanding edits and comments provided in our November letter be incorporated and/or addressed in the final draft LCLUP approved by the City Council. In particular, recommendations and specific language provided on the Environmental and Scenic Resources Chapter should be used to further modify the information and policies as currently drafted. Specifically, we recommend that the City include the more nuanced language we recommended regarding the following topics: recognition of non-perennial resources within the creeks, wetlands, and coastal waters implementing policies, riparian buffers (ER-I-1), potential environmentally sensitive habitat area (ESHA) designation (Section 4.3, “Plant Communities & Wildlife Habitat”), intermittent creeks and streams (ER-G-7), verification of ESHA (ER-I-23), and management of ESHA (ER-I-24) to ensure protection of sensitive habitats and species throughout the City consistent with the Coastal Act resource protection policies.

With regards to the natural hazards and coastal resilience policies (Chapters 5 & 6), the City has modified and/or added new definitions for “new development,” “existing structure,” “substantial exterior structural modification (SESM)” (the City’s proposed definition to qualify the concept of “redevelopment”), and “shoreline.” The application of these new definitions throughout the proposed policies raises inconsistencies with Coastal Act hazard policies 30253 and 30235 which require new

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Packet Pg. 3775 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
2 development to ensure long-term structural integrity, minimize future risk, and to avoid landform altering protective measures; and, with the exception of coastal-dependent uses, limit the construction of shoreline protection structures to that required to protect existing structures or public beaches in danger from erosion when designed to eliminate or mitigate adverse impacts to shoreline sand supply.

Specifically, these new definitions limit application of the City’s hazard policies depending on the nature and location of the proposed development, and expand allowances for shoreline protection as further described below.

First, the definition of “shoreline” as currently presented would only include bluff edges and beach areas at the intersection of the ocean or sea with land. As such, policies that reference “development on the shoreline” (CR-I-42: Technical Reports) or “shoreline development” (CR-I-43: Siting and Design and CR-I-44: Assumption of Risk by Private Landowners) would be limited to shoreline protection structures or similar development located in this very narrowly defined area. However, as we understand through discussions with you and your staff, the City intends for these policies to apply to development located on any parcels that have a shoreline frontage, and as such, we recommend the City modify the definition and the corresponding policies to better reflect this intent. However, even with such clarifications, CR-I-42 would not apply to development located on low-lying shoreline or blufftop land inland of shorefront parcels even if the development would be subject to coastal hazards over its anticipated life. Therefore, development proposals in these areas would be permitted without adequately accounting for potential coastal hazards through a technical evaluation, demonstrating such development will avoid and minimize hazards, and mitigating for any effects the development may have on coastal resources over time, inconsistent with Coastal Act hazard policies. We continue to recommend that any development proposed in coastal hazard zones, defined as anywhere mapped by the City’s coastal vulnerability maps, evaluate such hazards consistent with the requirements of CR-I-42. Further, this policy should be expanded so that the required evaluation examines hazards posed to the development with and without any existing shoreline protection structures.

Second, we commend the City for including language in CR-I-43 requiring that new development be sited and designed safe from coastal hazards for 100 years without shoreline protection structures, and include conditions waiving rights to shoreline protection, and where necessary, removal and restoration.

However, as drafted, this policy would only apply to new development on vacant shoreline properties, which are extremely limited in Pacifica. In addition, similar to CR-I-42 discussed above, this policy would not apply to new development on vacant land just inland of shorefront parcels if separated by a public road, or other lands, even if the development would be subject to known hazards over its anticipated life, inconsistent with Coastal Act hazard policies. Further, the definition of “new development” specifically excludes structures authorized pursuant to the SESM exclusions such as nonstructural improvements to existing structures, any development already protected by an existing shoreline protection structure, existing structures replaced pursuant to Section 30610, and complete demolition and rebuild of single family residences. Thus, this policy would not apply to improvements or redevelopment of existing structures in the majority of the City. This will essentially result in a continued pattern of development and redevelopment in hazardous areas both with and without existing shoreline protection.

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Packet Pg. 3776 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
3 Even if it is the City’s intent to continue to allow existing development to redevelop in hazardous areas, the assumption of risk policy (CR-I-44) similarly only applies to development on shorefront lots. Thus, redevelopment of and improvements to existing structures will continue in hazard areas without the property owners being required to accept the full risk of such development and without providing for adequate mitigation to ensure the development will not impact coastal resources over time. Thus, we continue to recommend that CR-I-43 and CR-I-44 apply to all development proposed in coastal hazard zones. If the City would like to allow for exceptions to setbacks, we recommend accomplishing this goal by first evaluating the hazard, examining siting and design options to avoid or minimize the hazard, allowing for exceptions pursuant to CR-I-49 (Protection of Private Property in Hazard Areas), and then including adequate mitigation for impacts to coastal resources over time by requiring an expanded version of CR-I-44 (Assumption of Risk by Private Landowners) that recognizes the development is located in a hazardous area, or in an area that may become hazardous in the future, assumes the risks of injury and damage from such hazards in connection with the permitted development, unconditionally waives any claim of damage or liability against the City, indemnifies and holds the City harmless with respect to approval of the project, recognizes the property owner has no rights under Coastal Act Section 30235 and related LCP policies to shoreline armoring in the future, that sea level rise could render it difficult or impossible to provide services to the site, that the boundary between public tidelands and private land may move inland causing the structure to be located on public land and thus subject to removal, that any future encroachment must be removed unless determined legally permissible pursuant to the Coastal Act, and that the structure may need to be removed or relocated if it becomes unsafe or substantially damaged.

Third, the definition of “existing development” refers to development constructed or permitted prior to the certification date of this LCLUP and the definition of “SESM” measures modifications to existing structures cumulatively from the same date. In addition, the exclusions provided in the definition of “SESM” and the reference to these exclusions in both the “existing structure” and “new development” definitions in effect allow the vast majority of development in the City a new or expanded entitlement to shoreline protection, including reconstruction of existing protection, and preclude such development from the need to mitigate for unavoidable coastal resource impacts caused by new construction or perpetuation of shoreline protection structures. Lastly, the City has included an exclusion for shoreline protection itself within the SESM definition which allows for reconstruction, repair, and maintenance of shoreline protection structures as long as the height and length are not expanded more than 10 percent.

As we understand, under these proposed definitions and associated policies, the City would allow for unlimited redevelopment on sites built or permitted prior to certification of this drafted LCLUP that are protected by an existing shoreline protective structure. Further, the proposed policies would allow new, redeveloped and augmented shoreline protection structures for all existing development defined as those structures constructed or permitted prior to the certification date of the LCLUP or authorized pursuant to the SESM exclusions. Lastly, the policies would allow for full reconstruction of existing shoreline protection in perpetuity without conforming to the proposed hazard policies as long as it does not increase the height or length by 10 percent.

These definitions and associated policies are inconsistent with the goals of the Coastal Act, which, as discussed in the Commission’s adopted Sea Level Rise Policy Guidance, provide that new development or redevelopment constructed after January 1, 1977 is not entitled to shoreline protection and must be

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Packet Pg. 3777 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
4 built safe from coastal hazards for its anticipated life. As such, Commission staff continues to recommend that the City define existing structure for the purpose of shoreline protection as a structure legally authorized prior to the effective date of the Coastal Act (i.e. January 1, 1977). In addition, existing structures redeveloped since that date should not be entitled to shoreline protection themselves, even though they may de facto be protected by an existing shoreline protective device.

As has been discussed throughout this process, Commission staff is open to discussing options for exceptions to allow for continued reliance on shoreline armoring for structures built or redeveloped after 1977 in certain circumstances. However, such exceptions will require a case by case evaluation considering factors such as: up and down coast patterns of development and existing shoreline protection, existing public infrastructure, access to support the development, alternatives to address the hazards including relocation, options for short and long term planning, and takings of private property.

Further, any exception would be contingent upon specific adaptation and policy options that ensure that coastal resources would be protected over time. These include at a minimum, an expanded assumption of risk, waiver of liability, and disclosures that shoreline armoring may not be able to provide safety in perpetuity, that the City may not be able to continue to provide services to hazardous locations, and that development may need to be removed at some point in the future to ensure safety and/or to meet other adaptation goals. Additional options may include requirements for continued planning, development of specific phased adaptation approaches along with necessary funding mechanisms, and requirements for alternative public access (e.g., integrating lateral access with shoreline armoring).

Additional comments on the revised Natural Hazards and Coastal Resilience Chapters include:
 Accurate neighborhood-specific hazard information should be incorporated into each neighborhood section, as indicated in our previous November comment letter. While some information was added to this end, additional details regarding erosion rates and patterns as demonstrated in the 1980 version of the LUP should be incorporated and updated, where necessary.
 Section 6.6. The sub-area policies and programs include triggers by which each of the policies are intended to be implemented. The introductory statement indicates that the triggers do not account for regulatory permitting, approvals, or financing, and that planning should be conducted in advance of the triggers. Alternatively, Commission staff recommends this document include triggers for planning purposes.
 CR-I-8, CR-I-9, CR-I-55. All policies should stipulate that the “least environmentally damaging alternative” be implemented, as indicated in prior edits. While some policies refer back to Coastal Act Section 30235 which stipulates the least environmentally damaging alternative is preferred, not all do, so Commission staff recommends each of these policies explicitly state as much.
 CR-I-2. The City intends to implement its Sea Level Rise Adaptation Plan through the policies in this chapter. Part c) of this policy stipulates that development in Coastal Vulnerability Zones may be approved consistent with the sub-area policies if the “project will not pose unacceptable risks to life or property.” Commission staff recommends that Part c) be amended to state that the “project will not pose unacceptable risks to life or property for the anticipated life of the development.” In addition, Commission staff recommends removing the italics as they constitute the bulk of this policy.

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Packet Pg. 3778 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
November 22, 2019
5  CR-I-3. Thresholds for reassessing the City’s Adaptation Plan through monitoring shoreline change should account for adequate setbacks from inland development based on erosion rates and a factor of safety.
 CR-I-5. The City intends to adopt a Shoreline Mitigation Program to address the coastal resource impacts of existing and future shoreline protection projects in the City within three years of LCLUP certification. Input from the Commission and the public will be important for the development of this program consistent with Coastal Act requirements and the public’s vision.

Please amend this policy to indicate the Shoreline Mitigation Program shall be reviewed and certified by the Commission through an LCP amendment. We also recommend that the City consider requiring the development of public access facilities or in-lieu fees as mitigation for approval of new, reconstruction, and repair and maintenance of shoreline protection structures, as part of the proposed Program.
 “Sharp Park, West Fairway Park and Mori Point” sub-area & CR-I-22. Commission staff notes that the levee that protects the Sharp Park Golf Course was built in the 1940’s, rather than the 1980’s as indicated in this draft. In addition, policy language should not reference specific permit provisions, but rather should speak to compliance with prior permit conditions and/or existing legal obligations pursuant to the California Coastal Act as is more generally done in Policy CR-I14.  CR-I-14. Please note there are two versions of CR-I-14. The policy on regional sediment management should indicate who will participate (i.e. The City).  CR-I-44. The majority of the edits made to the “Assumption of Risk by Private Landowners” were struck out by the City. Commission staff continues to recommend the City broaden the assumption of risk and waiver of liability per prior edits.  CR-I-49. Commission staff understands the City’s intent to protect private property in hazardous areas to allow for the minimum economic use of a property so as to avoid an unconstitutional taking of private property, but recommends adding that this is subject to development maintaining safe access and assuring there is infrastructure to serve it for the anticipated life of the development.
 CR-I-52. This policy should also apply to condominium development.  CR-I-54. This policy states that existing shoreline protection structures may be repaired and maintained until the development they are protecting is removed or no longer requires shoreline protection. Please amend this to account for redevelopment/substantial exterior structural modification. In addition, Commission staff notes this policy language is internally inconsistent, as it references Section 30235 of the Coastal Act, in which “existing structures” is evaluated as prior to January 1, 1977 rather than prior to certification of this LCLUP.  CR-I-57. Edits to this policy direct that new or reconstructed shoreline protection structures fully mitigate for coastal resource impacts where impacts are unavoidable. However, reconstruction of shoreline protection structures is included in the exceptions clause of the “substantial exterior structural modification” definition. Please ensure that both new and reconstructed shoreline protection is mitigated for by removing reconstruction of shoreline protection structures from the list of exceptions.
 Definitions. The City should clarify whether or not the exceptions in SESM definition apply throughout the City or just in coastal hazard areas.

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Packet Pg. 3779 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan City of Pacifica
Comments on the City’s Draft LUP Update
February 19, 2020
6  NH-I-10. Requires geotechnical studies for areas within 50 feet of a coastal bluff, but this should be clarified and expanded to account for increased erosion from sea level rise both with and without existing shoreline protection for development within 300 feet of a bluff edge.  NH-I-17. More generally includes similar requirements to the Coastal Act, but again, with the proposed definition of “new development” would limit application of this policy to areas where there is no existing development.

Lastly, it has come to our attention that there are numerous shoreline protection structures in the City, both publicly and privately owned, that are unpermitted and/or have existing permits that have since expired. Please take note of this in considering policies regarding shoreline protection structures that provide allowances for active, permitted shoreline protection structures specifically.

As discussed above, this letter is not an exhaustive list of comments on the post-consultation draft of the LCLUP, but rather provides an overview of overarching feedback at this time. We again thank you and your staff for the thoughtful and collaborative work done to date, and appreciate and commend the City for moving forward with the sometimes difficult, but important, task of updating the LCP’s LUP. We look forward to continued collaboration, and helping the City to refine the draft LUP, and a future draft IP, including in the ways identified in this letter. We hope these comments help move us forward to this end. If you have any questions or would like to discuss these matters further, please don’t hesitate to contact me.

Sincerely,
Jeannine Manna
District Manager
North Central Coast District Office
California Coastal Commission
cc: Kevin Woodhouse, City of Pacifica City Manager
Encl.: CCC Letter to City, dated August 29, 2018
CCC Letter to City, dated August 31, 2018
CCC Letter to City, dated October 19, 2018
CCC Letter to City, dated November 22, 2019

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Packet Pg. 3780 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: KoppmanNorton, Julia@Coastal
Sent: Tuesday, March 1, 2022 4:42 PM
To: [email protected]
Cc: Rexing, Stephanie@Coastal
Subject: General Plan Update & Sharp Park Specific Plan - DEIR Comments Attachments: FW: NOP - Pacifica GP Update & Sharp Park Specific Plan - Comments; CCC Comment Letter 2018.08.31.pdf; CCC Comment Letter 2018.10.19.pdf; CCC Comment Letter 2019.11.22.pdf; CCC Comment Letter 2020.02.19.pdf; CCC Comment Letter 2018.08.29.pdf; Pacifica LCP Post-Consultation Draft Letter 2020.02.19.pdf
Hello,
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.

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.

Please let me know if you have any questions.

Best,
Julia
_______
Julia Koppman Norton
North Central Coast District Supervisor
California Coastal Commission

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Packet Pg. 3781 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 2.k
Packet Pg. 3782 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: KoppmanNorton, Julia@Coastal
Sent: Friday, November 13, 2020 9:12 AM
To: Rexing, Stephanie@Coastal
Subject: FW: NOP - Pacifica GP Update & Sharp Park Specific Plan - Comments Attachments: City Council 7/20 - Sharp Park Specific Plan Guiding Policy Framework Discussion From: "KoppmanNorton, Julia@Coastal" <[email protected]> Date: Wednesday, September 9, 2020 at 1:07 PM
To: "Murdock, Christian" <[email protected]>
Subject: NOP ‐ Pacifica GP Update & Sharp Park Specific Plan ‐ Comments Hi Christian,
Please add this email to the record for comments on the NOP for the General Plan Update and Sharp Park Specific Plan.

As noted in the attached email dated July 16, 2020 on the City Council’s framework discussion regarding the Sharp Park Specific Plan, as the Sharp Park Specific Plan proposes to increase height and density allowances within the Sharp Park neighborhood, the CEQA analysis should thoroughly analyze potential visual impacts of development as provided through the Specific Plan on the character of the surrounding area and on views through the neighborhoods of the ocean, impacts to community character as designated and provided in the LCLUP, impacts on public access and recreation, and impacts of potential geotechnical and coastal hazards on development that per the current proposal would be of increased height and density than currently allowed. More specifically, the analysis should include visual simulations, height and density alternatives, explanations of the hazards within this particular neighborhood, and the benefit to the public with regard to priority uses in this coastal area, and should consider:
 Potential impacts if the proposed maximum height is reduced in areas in which tall buildings (up to 55 feet in height) will impact the visual character of surrounding areas as well as public views to and from the ocean in visually sensitive areas, and
 Performing a thorough geotechnical analysis, including an evaluation of the potential hazards to this neighborhood (landslides and shoreline erosion) as well as a wave uprush study for the area. Such a wave uprush study should include an assessment of the potential hazards caused by 100‐year storm events (cumulative with high tide events, as well as projected sea level rise impacts and given a typical eroded beach condition).

In addition, any new General Plan and Sharp Park Specific Plan policies will need to be consistent with the LCP, and should not lessen protections or conflict with policy protections for coastal resources in the LCP. Please let me know if you have any questions. We look forward to continuing to work with the City on this CEQA process.

Thanks,
Julia
____________
Julia Koppman Norton
Coastal Planner

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Packet Pg. 3783 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 North Central Coast District
California Coastal Commission
(415) 904‐5292

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Packet Pg. 3784 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: KoppmanNorton, Julia@Coastal
Sent: Thursday, July 16, 2020 2:59 PM
To: Murdock, Christian
Cc: Tina Wehrmeister
Subject: City Council 7/20 - Sharp Park Specific Plan Guiding Policy Framework Discussion Hi Christian,
Please add the following to the record for the Sharp Park Specific Plan Guiding Policy Framework Discussion that is on the City Council agenda on Monday, July 20th. The comments reiterate concerns and comments raised by Commission staff during a phone call with Commission and City staff on April 3, 2020.

As the Sharp Park Specific Plan proposes to increase height and density allowances within the Sharp Park neighborhood, a thorough analysis should be conducted in terms of visual impacts of development as provided through the Specific Plan on the character of the surrounding area and on views through the neighborhoods of the ocean, impacts to community character as designated and provided in the LCLUP, and impacts of potential geotechnical and coastal hazards on development that per the current proposal would be of increased height and density than currently allowed.

Any allowed uses in the Specific Plan should prioritize low‐cost visitor‐serving, recreational uses and public access. In addition, the Specific Plan would need to provide for increased coastal resource protections in order to ensure consistency with the Coastal Act, and documentation should be provided including visual simulations, height and density alternatives, explanations of the hazards within this particular neighborhood, and the benefit to the public with regard to priority uses in this coastal area. More specifically, the City should consider:
 Reducing the proposed height in areas in which tall buildings (up to 55 feet in height) will impact the visual character of surrounding areas as well as public views to and from the ocean in visually sensitive areas, and  Performing a thorough geotechnical analysis, including an evaluation of the potential hazards to this neighborhood (landslides and shoreline erosion) as well as a wave uprush study for the area. Such a wave uprush study should include an assessment of the potential hazards caused by 100‐year storm events (cumulative with high tide events, as well as projected sea level rise impacts and given a typical eroded beach condition).

We look forward to continuing to work with the City on this Specific Plan throughout the City’s drafting and review process. Thank you.

Best,
Julia
____________
Julia Koppman Norton
Coastal Planner
North Central Coast District
California Coastal Commission
(415) 904‐5292

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Packet Pg. 3785 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: Mike O'Connell < >
Sent: Thursday, May 26, 2022 8:58 AM
To: Murdock, Christian
Subject: General Plan Comments
[CAUTION: External Email]

Christian
On Clarendon Road, why are you changing it to very low density residential when the subdivision was recently completed with a GP of low density residential? This should be low density residential.

The high density residential designation at the rehabilitation center should be low density residential like the adjacent sites. The land the city owns where the trail is located is high density residential but I understand that when it was granted to the city from the state it may only be used for flood control purposes and so should have a public/semi-public designation or utilities.
900 Rosita and the adjacent lots still have a public designation even though they are not owned nor have ever been owned by the school district. I changed the GP on 900 rosita already and do not want to see it inadvertently reverted to public. I've made this request several times - how do we get resolution on it? You should change the adjacent lots too since they are not owned by a public agency.

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Packet Pg. 3786 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 Thanks,
Mike O'Connell, PE
DRE #02114316
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3787 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 3 Murdock, Christian
From: Christine Boles < >
Sent: Thursday, May 26, 2022 10:06 AM
To: Murdock, Christian
Cc: Bier, Mary; Bigstyck, Tygarjas; Public Comment
Subject: Trouble accessing General Plan documents
[CAUTION: External Email]

Good morning Christian,
I see the revised GP documents were released early this morning through the staff report for Wednesday, but I cannot seem to download Attachment G, comment letters. I assume responses to comments are in this document too? Can you send it to me some other way, or will it be posted on the Plan Pacifica website this morning? Here is the error message I keep getting. I'm leaving on a trip tomorrow morning and I need to download these now if the meeting is really still happening on Wednesday.

And will you be answering my other questions or has the City Manager limited your ability to respond to me as he did earlier with Public Works staff about the sewers?
Thank you for including my recent emails in the agenda packet. I know you are extremely overworked and I am not blaming you personally, but this whole process continues to be a royal mess. I'm already drafting my response about the continued inadequate landslide maps. Even landslides that I learned about from Public Works are still not mapped! Is this Dyett and Bhatia's work? Who is supervising their work and why do we continue to pay for poor quality work that will delay this process?
Christine Boles, Architect
Beausoleil Architects

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Packet Pg. 3788 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 4 Pacifica, CA 94044
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3789 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 5 Murdock, Christian
From: Mike O'Connell < >
Sent: Thursday, May 26, 2022 12:14 PM
To: Murdock, Christian
Subject: Re: General Plan Comments
[CAUTION: External Email]

Christian
I found the section in staff report on Rosita. I appreciate that it is in the staff report but it is half wrong. The report should state that 900 Rosita already changed the GP to LDR. It is important to make that distinction. Also, how do we get the mapped changed? Will that be done before Council? I'm just trying to avoid a bunch of confusion 10 years from now if the color on the map is wrong.

Thanks,
Mike O'Connell, PE
DRE #02114316
On Thu, May 26, 2022 at 8:57 AM Mike O'Connell wrote:

Christian
On Clarendon Road, why are you changing it to very low density residential when the subdivision was recently completed with a GP of low density residential? This should be low density residential.

The high density residential designation at the rehabilitation center should be low density residential like the adjacent sites. The land the city owns where the trail is located is high density residential but I understand that when it was granted to the city from the state it may only be used for flood control purposes and so should have a public/semipublic designation or utilities.

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Packet Pg. 3790 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 6 900 Rosita and the adjacent lots still have a public designation even though they are not owned nor have ever been owned by the school district. I changed the GP on 900 rosita already and do not want to see it inadvertently reverted to public. I've made this request several times - how do we get resolution on it? You should change the adjacent lots too since they are not owned by a public agency.

Thanks,
Mike O'Connell, PE
DRE #02114316

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Packet Pg. 3791 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 7 CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3792 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 8 Murdock, Christian
From: Pete Shoemaker < >
Sent: Thursday, May 26, 2022 4:51 PM
To: Murdock, Christian
Subject: Let's be friends
[CAUTION: External Email]
Christian,
You and Bonny and the Staff have done an incredible amount of good work on the GP and EIR, both initially and responding to comments. Yet here we are in battle mode again! It’s so frustrating.

You do all this great work and then give us no time to look it over and appreciate it. Sure, we’ll be checking for things we don’t like, but most of it is just fine. All we need is a reasonable amount of time to review, talk in a civilized manner, and we can get this done.

You of course realize that dropping a 3,670-page agenda, which includes a link to another 1,125-page document (EIR redline) for a total of 4,795 pages, and expecting the Planning Commission, and everyone else, to review this in 6 days, three of which are holidays, is beyond absurd. How could we not be pissed off? Why do this? You’re just setting yourself up for acrimony, and all your great work will be overshadowed.

Just for context: If the Planning Commissioners worked full 8-hour days on Thursday (today), Friday, Tuesday and Wednesday, like you will probably do, they would have to go over, in some manner, 150 pages per HOUR, every hour, nonstop, to get through this. This would be absurd to ask full-time paid employees to do, and these people are unpaid volunteers with most of them having other full-time jobs.

We don’t have to live like this. Let’s make it better, please.

Pete
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Packet Pg. 3793 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan From: Pete Shoemaker < >
Sent: Friday, May 27, 2022 10:37 AM
To: Beckmeyer, Sue <[email protected]>
----------
Commissioner Wright,
We the undersigned are Pacificans who love our community and have given many volunteer hours to serve it for many years. We understand and appreciate your service on the Planning Commission. We are writing to urge you, during the upcoming meeting on June 1, to ask for more time to review the General Plan, Sharp Park Specific Plan and EIR submitted to you by City Staff.

We would like to recommend that the Planning Commission work with staff to partition these documents into manageable sections and develop a timeline for a series of separate public meetings on each section. Public comment should be included as part of each meeting regarding these important documents that will guide our city for decades.

There is no reason to rush through this process that began in 2009, and was delayed for a number of reasons until now; if there is such a reason, the city should divulge the urgency to you and to the public. The current approach being suggested by City staff is counter to the principles of democratic process where citizens actively participate in the decision-making of government.

We know you want to do the best job possible as Commissioner, and you need to be given a reasonable opportunity to do so. To ask you to review these very long technical documents, along with the numerous comments that were submitted asking for changes, in a six-day period, three days of which are holidays, is more than challenging. It puts you in an impossible position, which is completely unfair to you, the people of Pacifica, and the City Council who appointed you to provide your recommendations to them.

As a Planning Commissioner, you have the authority and duty to ask for what you need to do your job. The City of Pacifica's lively history of robust public engagement shows that Planning Commissioners have on many occasions held off on making decisions that needed more time to fully understand and deliberate over. While Staff has provided you summaries and recommendations, City Council and the public rely on you as one of the steps to ensure a full and robust vetting of critical planning documents.

As individuals who spent many hours reviewing the draft GP, Sharp Park Specific Plan and DEIR, and have found serious errors and omissions that were documented during the initial (also expedited) public comment period, we believe these should be given due time and consideration for review and inclusion in this process.

Like you, we are in the process of reviewing the new releases to see what changes have been made. We will be preparing a summary with prioritized recommendations. We commit to getting this to you as soon as possible, so that you have this additional information to guide you in your due diligence review.

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Packet Pg. 3794 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan Again, we thank you for your service and urge you to ask for more review time at the June 1 meeting.

And just for context: The agenda is 3,670 pages with a link to another 1,125-page document, for a total of 4,795 pages. If you worked full 8-hour days on Thursday, Friday, Tuesday and Wednesday before the June 1 meeting, you would have to go over, in some manner, 150 pages per hour, every hour nonstop, to get through it all.

Sincerely,
The undersigned…
Allison West Dinah Verby Mark Hubbell
Barbara Lubben Erin Macias Nancy Tierney
Bill Collins Gary Emich Patricia R. McGregor
Bob Boles James Kremer Pete Shoemaker
Cherie Chan Jim Heldberg Peter Loeb
Christine Boles JoAnne Arnos Sue Digre
Cindy Abbott John Keener Summer Lee
Clif Lawrence Karen Clark Susan Miller
Danny Estrella Leo Leon Suzanne Moore
David Hirzel Lisa A. Warns Victor Carmichael
Deb Wong Margaret Goodale William C. Trichon
Debra Etienne Marjorie Davis

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Packet Pg. 3795 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 9 Murdock, Christian
From: D Gold < >
Sent: Friday, May 27, 2022 5:11 PM
To: Public Comment
Subject: General Plan -- Highway 1 onramp at Milagra
[CAUTION: External Email]

I was very concerned to find in the General Plan update the following on page 5-12 (page 33 of the pdf file):
"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. "
The community has strongly opposed this new on-ramp for traffic safety, public safety and its environmental impact.

This opposition was reflected at two public meetings, and at a recent city council meeting. At that meeting, the city council stated that their vote to explore the manor overcrossing improvements was not a vote to construct the highway 1 on ramp, and the two projects could be split.

Therefore the general plan should be amended to remove this linkage. The onramp is a bad idea that will damage the surrounding neighborhood.

Thank you for your attention.

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

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Packet Pg. 3796 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 10 Murdock, Christian
From: Julie Starobin < >
Sent: Sunday, May 29, 2022 2:51 PM
To: Public Comment
Subject: General Plan Update
[CAUTION: External Email]

I read the General Plan Update and there's a lot there to be concerned with. One particular item should definitely be changed before the plan is approved.

On page 5-12 (page 33 of the pdf file): "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. " The proposed new on-ramp at Milagra has been discussed at several City Council meetings and at least two public hearings. At all of them, the majority of community speakers were from the Pacific Manor neighborhood and emphatically opposed the on-ramp. Several Council people expressed concern that the community was so opposed and said the two projects should be separated. They stated, on record, that their vote for the overcrossing was not a vote for the on-ramp.

Several alternatives were proposed and need to be considered. The General Plan should be amended to remove the assumption that these two projects are linked. The on-ramp is a terrible idea that will negatively affect the surrounding neighborhood.

Thank you,
Julie Starobin. Pacific Manor
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Packet Pg. 3797 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 11 Murdock, Christian
From: Dustin M
Sent: Sunday, May 29, 2022 3:49 PM
To: Murdock, Christian
Subject: Pacifica General Plan deserves more time for review by the Planning Commission [CAUTION: External Email]

Dear Deputy Planning Director Murdock,
I am writing to express to you my concern as a local homeowner, active City volunteer and local business owner regarding the accelerated review process of the newly proposed General Plan, the Sharp Park Specific Plan and the EIR recently submitted to the Planning Commission.

Your work as Deputy Planning Director plays a vital role in our local governance, particularly since the General Plan is a guiding document that will shape Pacifica’s future for decades.

It is my understanding that the Planning Commission has been requested to review these documents over a 6 day period, yet the documents total an incredible 4,795 pages.

I feel that this places too heavy a burden on the Planning commission to execute with the prudence and detail necessary to properly fulfill its function.

Furthermore, I believe that these documents should be broken into sections for the Planning Commission to review in parts and include opportunities for further public comment. To date, there have been few opportunities with very little advertising, for the public to engage in this process.

The future of Pacifica deserves the care and attention of the Planning Commission and the voices of Pacificans should be represented.

I am asking you to consider a more reasonable formal timeline for the Planning Commission to review the General Plan, the Sharp Park Specific Plan and the EIR. June 1st is not reasonable for the Planning Commission to be effective in it’s function.

Sincerely,
Dustin McGahan
President
Little Feet Renovation Inc.
“visionary sculptural transformations”
www.littlefeetrenovation.com
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Packet Pg. 3798 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 12 Murdock, Christian
From: Remi Tan < >
Sent: Tuesday, May 31, 2022 6:19 AM
To: Public Comment; Murdock, Christian; _City Council Group; Woodhouse, Kevin; Wehrmeister, Tina; Berman, Lauren; Hauser, Samantha; Nibbelin, John; Leal, David; Godwin, James; Domurat, George; Ferguson, Alex; O'Connor, Bonny Subject: Comments on May 2022 Draft General Plan (GP) revise – Prominent prominent ridge lines and prominent landforms
[CAUTION: External Email]

2022-05-31
Re: Comments on May 2022 Draft General Plan (GP) revise – Prominent prominent ridge lines and prominent landforms Dear Planning Staff, Commission, and City Council,
Reviewing the new Draft General Plan and noticed that there are prominent ridge lines (noted in red) and prominent landforms (noted in purple) missing from this Figure 3.3:

1. Gypsy Hill - Gypsy Hill Rd. There are developable lots on this. GP should state that all new homes in this area must be located well below the ridge line and screened by new trees and existing homes add tree screening and offer landowners salable transfer development rights to keep as open space (removing existing buildings and improvements) and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

2. Fassler Hill - Ohlone Dr. Harmony @ 1 Development was recently approved disregarding this ridgeline. GP should state that all new homes in this area must be located well below the ridge line and screened by new trees and existing homes add tree screening and offer landowners salable transfer development rights to keep as open space (removing existing buildings and improvements) and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

3. There is a proposed development at the end of Higgins Rd on this ridge line. Due to access and infrastructure issues and active recreation trail this development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

4. Pedro Point – end of Grand and Belfast Aves. Individual lots - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

5. Behind Park Pacifica and Frontierland Park - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

6. South of San Pedro Valley - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

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Packet Pg. 3799 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 13 7. Rockaway Quarry Headlands is missing. GP should state that any part of the future Quarry development that is trying to get ocean views needs to be not visible from these prominent points, and in exchange development in the flatlands of the Quarry should be densified.

8. Mussel Rock – this starts at the north end of town at the end of this beach. No developments are currently proposed here. Due to access and infrastructure issues and coastal erosion, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

For all of the prominent ridgelines and prominent landforms shown on the map (including Aramai Pt.) No development should be allowed and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

Please make all the corrections noted above to the General Plan.

Thank you and Best Regards,
Remi Tan,
Architect, Pacific Manor

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Packet Pg. 3800 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 14 2.k
Packet Pg. 3801 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 15 CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3802 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 16 Murdock, Christian
From:

Sent: Tuesday, May 31, 2022 4:11 PM
To: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: YES Adopt the current GPU and EIR that is being presented on June 6 [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,

We are writing to urge you TO ADOPT the current GPU and EIR that is being presented for your consideration at the upcoming June 6 public hearing, which proposes to change the Land Use Designation of the five-acre Pedro Point Field.

We DO NOT support comments previously submitted by PPCA President Allison West on March 7, 2022 and related letters submitted by the PPCA’s CEQA consultant Richard Grassetti, attorney Brian Gaffney, and consulting Coastal Ecologist, Dr. Peter Baye.

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

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Packet Pg. 3803 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan

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Packet Pg. 3804 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 18 Murdock, Christian
From: Remi Tan < >
Sent: Wednesday, June 1, 2022 1:58 AM
To: Public Comment; Murdock, Christian; _City Council Group; Woodhouse, Kevin; Wehrmeister, Tina; Berman, Lauren; Hauser, Samantha; Nibbelin, John; Leal, David; Godwin, James; Domurat, George; Ferguson, Alex; O'Connor, Bonny Subject: Re: Comments on May 2022 Draft General Plan (GP) revise – Prominent prominent ridge lines and prominent landforms
[CAUTION: External Email]

Dear Planning Staff, Commission, and City Council,
Regarding my comment yesterday on 2022-05-31, I forgot to note on the map on Figure 4-3 Land Use Diagram that all the areas circled in red and purple below should be made Park or Conservation. Please add this map markup to my comment.

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Packet Pg. 3805 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 19 2.k
Packet Pg. 3806 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 20 Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Manager and Member
S.A.A. Equities, LLC
Architecture, Green/Sustainability Consulting, and Real Estate Investment On Tuesday, May 31, 2022, 06:18:33 AM PDT, Remi Tan wrote:
2022-05-31
Re: Comments on May 2022 Draft General Plan (GP) revise – Prominent prominent ridge lines and prominent landforms Dear Planning Staff, Commission, and City Council,
Reviewing the new Draft General Plan and noticed that there are prominent ridge lines (noted in red) and prominent landforms (noted in purple) missing from this Figure 3.3:

1. Gypsy Hill - Gypsy Hill Rd. There are developable lots on this. GP should state that all new homes in this area must be located well below the ridge line and screened by new trees and existing homes add tree screening and offer landowners salable transfer development rights to keep as open space (removing existing buildings and improvements) and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

2. Fassler Hill - Ohlone Dr. Harmony @ 1 Development was recently approved disregarding this ridgeline. GP should state that all new homes in this area must be located well below the ridge line and screened by new trees and existing homes add tree screening and offer landowners salable transfer development rights to keep as open space (removing existing buildings and improvements) and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

3. There is a proposed development at the end of Higgins Rd on this ridge line. Due to access and infrastructure issues and active recreation trail this development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

4. Pedro Point – end of Grand and Belfast Aves. Individual lots - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

5. Behind Park Pacifica and Frontierland Park - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

6. South of San Pedro Valley - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

7. Rockaway Quarry Headlands is missing. GP should state that any part of the future Quarry development that is trying to get ocean views needs to be not visible from these prominent points, and in exchange development in the flatlands of the Quarry should be densified.

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Packet Pg. 3807 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 21 8. Mussel Rock – this starts at the north end of town at the end of this beach. No developments are currently proposed here. Due to access and infrastructure issues and coastal erosion, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

For all of the prominent ridgelines and prominent landforms shown on the map (including Aramai Pt.) No development should be allowed and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

Please make all the corrections noted above to the General Plan.

Thank you and Best Regards,
Remi Tan,
Architect, Pacific Manor

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Packet Pg. 3808 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 22 2.k
Packet Pg. 3809 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 23 CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3810 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 24 Murdock, Christian
From: Remi Tan < >
Sent: Wednesday, June 1, 2022 2:10 AM
To: Public Comment; Murdock, Christian; _City Council Group; Woodhouse, Kevin; Wehrmeister, Tina; Berman, Lauren; Hauser, Samantha; Nibbelin, John; Leal, David; Godwin, James; Domurat, George; Ferguson, Alex; O'Connor, Bonny Subject: Re: Comments on May 2022 Draft General Plan (GP) revise – Prominent prominent ridge lines and prominent landforms
[CAUTION: External Email]

Dear Planning Staff, Commission, and City Council,
And diagrams 4-4 through 4-9 should be updated accordingly with the ridgline properties designate as park or conservation land
Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment Pacifica Manor
On Wednesday, June 1, 2022, 01:58:30 AM PDT, Remi Tan < > wrote:

Dear Planning Staff, Commission, and City Council,
Regarding my comment yesterday on 2022-05-31, I forgot to note on the map on Figure 4-3 Land Use Diagram that all the areas circled in red and purple below should be made Park or Conservation. Please add this map markup to my comment.

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Packet Pg. 3811 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 25 2.k
Packet Pg. 3812 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 26 Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment Pacific Manor
On Tuesday, May 31, 2022, 06:18:33 AM PDT, Remi Tan < > wrote:
2022-05-31
Re: Comments on May 2022 Draft General Plan (GP) revise – Prominent prominent ridge lines and prominent landforms Dear Planning Staff, Commission, and City Council,
Reviewing the new Draft General Plan and noticed that there are prominent ridge lines (noted in red) and prominent landforms (noted in purple) missing from this Figure 3.3:

1. Gypsy Hill - Gypsy Hill Rd. There are developable lots on this. GP should state that all new homes in this area must be located well below the ridge line and screened by new trees and existing homes add tree screening and offer landowners salable transfer development rights to keep as open space (removing existing buildings and improvements) and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

2. Fassler Hill - Ohlone Dr. Harmony @ 1 Development was recently approved disregarding this ridgeline. GP should state that all new homes in this area must be located well below the ridge line and screened by new trees and existing homes add tree screening and offer landowners salable transfer development rights to keep as open space (removing existing buildings and improvements) and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

3. There is a proposed development at the end of Higgins Rd on this ridge line. Due to access and infrastructure issues and active recreation trail this development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

4. Pedro Point – end of Grand and Belfast Aves. Individual lots - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

5. Behind Park Pacifica and Frontierland Park - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

6. South of San Pedro Valley - No developments are currently proposed here. Due to access and infrastructure issues, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

7. Rockaway Quarry Headlands is missing. GP should state that any part of the future Quarry development that is trying to get ocean views needs to be not visible from these prominent points, and in exchange development in the flatlands of the Quarry should be densified.

8. Mussel Rock – this starts at the north end of town at the end of this beach. No developments are currently proposed here. Due to access and infrastructure issues and coastal erosion, future development should be halted and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

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Packet Pg. 3813 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 27 For all of the prominent ridgelines and prominent landforms shown on the map (including Aramai Pt.) No development should be allowed and GP should offer landowners salable transfer development rights to keep as open space and transfer their development rights to lot owners in the flats near transit to densify those lots near transit.

Please make all the corrections noted above to the General Plan.

Thank you and Best Regards,
Remi Tan,
Architect, Pacific Manor

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Packet Pg. 3814 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 28 2.k
Packet Pg. 3815 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 29 CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3816 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 30 Murdock, Christian
From: Remi Tan < >
Sent: Wednesday, June 1, 2022 2:24 AM
To: Murdock, Christian; _City Council Group; Woodhouse, Kevin; Wehrmeister, Tina; Public Comment; Berman, Lauren; Hauser, Samantha; Nibbelin, John; Leal, David; Godwin, James; Domurat, George; Ferguson, Alex; O'Connor, Bonny Subject: 2022-05 Pacifica General Plan - Public Comment Draft - Comments - DEIR Housing [CAUTION: External Email]

Dear City Council and City Planning Staff and Commission: It looks like my comment from 2022-02-26 on the DEIR and on 2022-01-08 on the Draft GP has not been addressed. Not sure why this is so. The 990 net new residential potential is still way under the RHNA numbers of 1,892 To be compliant with RHNA, this General Plan must be updated to account for the RHNA numbers. As mentioned before, we need to densify zoning on all sites near transit lines in the flats and not on the hillsides. Please see my original comments below Please have Dyett and Bhatia work this out and present a new draft to the public.

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Packet Pg. 3817 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 31 Thank you and Best Regards,

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Packet Pg. 3818 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 32 Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment Pacific Manor
On Saturday, February 26, 2022, 04:39:20 PM PST, Remi Tan > wrote:

Dear City Council and City Planning:

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.

Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment Pacifica, CA
From: Remi Tan < >
To: [email protected] <[email protected]>; o'[email protected] <o'[email protected]> Sent: Saturday, January 8, 2022, 11:47:52 AM PST
Subject: 2022-01 Pacifica General Plan - Public Comment Draft - Comments - Housing Chris and Bonnie: I have the following comments on the draft public comment General Plan 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.

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 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.

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.

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Packet Pg. 3819 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 33 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
Please advise on next steps plans to take in incorporating increased housing and the above measures into the new General Plan.

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Packet Pg. 3820 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 34 2.k
Packet Pg. 3821 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 35 2.k
Packet Pg. 3822 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 36 Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment . Pacifica, CA 94044

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Packet Pg. 3823 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 37 M
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CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3824 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 38 Murdock, Christian
From: Richard Clark <r >
Sent: Wednesday, June 1, 2022 9:37 AM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: Land Use Designation of the 5 acre Pedro Point Field [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,
I am writing to urge you not to adopt the current GPU and EIR that are being presented for your consideration at the upcoming the June 6th public hearing, which proposes to change the Land Use Designation of the five-acre Pedro Point Field, a recognized wetlands and EnvironmentallySensitive Habitat Area (ESHA) and a center of our community, from Commercial-Recreational uses to Commercial Residential Mixed Use. What I’m most concerned about the field being developed is the high volume of traffic this will incur and the burden/effect these additional cars will have on the surrounding residential San Pedro area. Any given weekend, there is a high load of parked cars along San Pedro Avenue. There is only one way in and one way out. With the proposed changes, a minimum of 85 single family residences and up to 800 homes could be built on this field. That could increase the amount of vehicles from 85 to 1600 on any given day (most residences have a 2 or more cars).

I fully support comments previously submitted by PPCA President Allison West on March 7, 2022 and related letters submitted by the PPCA’s CEQA consultant Richard Grassetti, attorney Brian Gaffney, and consulting Coastal Ecologist, Dr.

Peter Baye, and am disturbed that this testimony was rejected without adequate analysis. Their comments documented known DEIR deficiencies and reasonably foreseeable adverse impacts of the proposed GPU that are in violation of CEQA and Coastal Act policies. Please do not dismiss these expert opinions and instead take steps to address the noted deficiencies and violations before adopting these important guiding documents for our city.

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

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Packet Pg. 3825 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 39 Murdock, Christian
From: Mark Musselman < >
Sent: Wednesday, June 1, 2022 10:14 AM
To: Public Comment
Cc: Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg; Murdock, Christian
Subject: Land Use Designation of the five-acre Pedro Point Field [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,

I am writing to urge you not to adopt the current GPU and EIR that are being presented for your consideration at the upcoming June 6 public hearing, which proposes to change the Land Use Designation of the five-acre Pedro Point Field, a recognized wetlands and Environmentally-Sensitive Habitat Area (ESHA) and a center of our community, from Commercial-Recreational Use to Commercial Residential Mixed Use. I have been living on Pedro Point for 5 years now - first renting and now owning on Livingston Avenue, looking down on the Field. I see this Field as being an amazing part of the community that is totally unique to any other place I've lived in the Bay Area. This field should be developed as a Park, not more housing. This field needs to be protected from current and future development.

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

Sincerely,
Mark Musselman
Pacifica, CA 94044
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3826 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 40 Murdock, Christian
From: David Costa < >
Sent: Wednesday, June 1, 2022 11:09 AM
To: Public Comment; Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg Subject: Subject: Proposal to change land use designation in the GPU and EIR [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,
I am writing to object to the proposal in the GPU and EIR that would change the Land Use Designation of the five-acre Pedro Point field from Commercial-Recreational Use to Commercial Residential Mixed Use. I find it difficult to believe that this proposal is once again being considered over the near universal objection of the residents of Pedro Point and the numerous reasons that argue against this being anything but a good idea.

This parcel is in a recognized wetlands and Environmentally-Sensitive Habitat Area (ESHA) and when it rains, it becomes swamp like. There are photos of people using row boats on it. There has been no discussion of how this can be mitigated to allow mixed commercial-residential use.

Changing the land use designation of this parcel would also significantly alter the basic nature/environment of this neighborhood. Since the City has failed to provide any park or open space for the community, this parcel has become a recreational/gathering spot, where people can exercise their pets and congregate. It is without question that a Prescriptive Easement has already been established for the residents of Pedro Point and, if the proposed change of land use is adopted, it will incite litigation to formally establish this Prescriptive Easement.

Given your position, I'm sure that you already the requirements for a Prescriptive Easement, so I won't bother to recite them here.

Of even greater concern, are the safety issues presented by adding numerous additional housing units to a neighborhood which has only one access road and which is in a high-risk fire area. On weekends and holidays, Pedro Point is crowded with people using its streets for parking (many illegally) and many of these streets are substandard and difficult to navigate. With global warming, it is only a matter of time before Pedro Point is subject to a significant fire, requiring its residents to evacuate as quickly as possible. This will be difficult as is and a potential disaster if seventy or more additional housing units are allowed to be built on the parcel in question. This email should serve to put the City on notice of its potential liability.

I have been a resident of Pedro Point for over thirty-six years and have witnessed the neglect of this neighborhood by the City first hand, from the failure to properly maintain its streets to the failure to enforce parking and illegal fireworks regulations. The current owner of the property purchased it with full knowledge of the environmental, safety and zoning issues, as well as the concerns of the neighborhood. His sole purpose seems to have been to develop the property in disregard of these issues. I fail to see why his desire to make a profit should take precedence over these issues and concerns.

I have reviewed the the comments previously submitted by PPCA President Allison West on March 7, 2022, as well as the letters the submitted by the PPCA’s CEQA consultant Richard Grassetti, attorney Brian Gaffney, and consulting Coastal Ecologist, Dr. Peter Baye. I believe that the city and the Planning Committee need to

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Packet Pg. 3827 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 41 carefully examine these documents before making changes that will almost certainly open them up to both moral and legal issues.

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

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Packet Pg. 3828 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 42 Murdock, Christian
From: Suzanne Moore < >
Sent: Wednesday, June 1, 2022 11:13 AM
To: Berman, Lauren; Hauser, Samantha; Domurat, George; Godwin, James; Ferguson, Alex; Leal, David; Wright, Greg; Public Comment
Subject: Comments on the DEIR, GP, and SPSP
[CAUTION: External Email]

TO: Pacifica Planning Department
Pacifica Planning Commission
FROM: Suzanne Moore, Manor District
RE: Final DEIR, GP, SPSP and the Housing Element to come Hello staff and commissioners,
Thank you, staff, for your evident hard work at creating and incorporating community responses to the DEIR, GP, and SPSP.

And thank you, commissioners, for taking up the task of reviewing these documents for City Council.

I am confused on how best to communicate my concerns pertaining to these documents. Since the documents are interconnected and you will be making recommendations on all three, I will refer to the designations supplied by the documents.
3-G-12, Housing Opportunity, is referenced in both the GP and SPSP. 3-J-37, Supportive Housing
3-I-35, Preserve Affordability
All of these demonstrate City goals for projects and preservation of affordable housing that serve the homeless, special needs, and opportunities suitable for all incomes, abilities, and stages of life. The City seems to focus heavily on relationships and incentives geared to for-profit contractors. To utilize the services of non-profit contractors, many communities rely on monies from a dedicated housing fund, - which we could create through a title transfer fee, vacancy fee, landlord tax, and commercial linkage fee. I would like to see this language be incorporated in our plans. 3-I-36, Displacement Indicators. This is seen in the SPSP and refers to change in the share of low-income households, average rent and sale price, supply of affordable units, evictions and foreclosures within SPSP. Concord gathers this data through a registry, and they have hired someone to set up the system.

It could be invaluable information for Pacifica: the number of Air B&Bs/conversions, condos and conversions, unit availability and current rents - all data helpful to the real-time picture of displacement risk factors. I would like to see a registry be incorporated into our City plans.

I understand that Pacifica’s Housing Element will be addressed separately. I want to voice my concern that Pacifica is far behind other communities in the development of our Housing Element, and time is running out for development of this important document. I understand necessary steps include a needs assessment, site inventory, and public engagement. Can we immediately start this process?

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Packet Pg. 3829 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 43 I admit I am not well educated in this process of communicating my ideas about the GP, SPSP, DEIR. I found the document difficult to understand. I have no doubt, however, of its importance - and the importance of community engagement. Please continue efforts to engage the public.

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

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Packet Pg. 3830 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 44 Murdock, Christian
From: Louderback, Jim < >
Sent: Wednesday, June 1, 2022 12:46 PM
To: Public Comment
Cc: Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg; Murdock, Christian; Berman, Lauren
Subject: GPU and Pedro Point
[CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners:

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

I’m very concerned about the flood-plain aspect of this land, particularly as sea rise continues. The Pedro Point Field is a known wetlands which would be inappropriate for high-density (overwhelmingly) residential, and according to the county maps will be inundated with water over the next 20-30 years as sea levels rise. This would lead to an inordinate expense to the city to manage the retreat from land that should never be built on (see the crazy costs to keep the sea wall intact up by the pier and multiply by ten).

And as a neighborhood with only one road in and out, I’m also concerned about potential bottlenecks if the Pedro Point headlands caught fire, which is increasingly likely in our dry, dry times. Almost doubling the size of the neighborhood will turn San Pedro Avenue into a dangerous bottleneck if we have to evacuate quickly.

In addition, as a Pedro Point resident, I look out over the field and regularly use it for recreation and gathering with neighbors. It would totally change the character of the neighborhood if this plan moves forward. Please don’t ruin this amazing part of the world with untrammeled development that is wrong for Pacifica, wrong for Pedro Point, and wrong the environmentally changing world we live in.

Let’s instead turn this into an amazing place for the community, the neighborhood, and visitors to come enjoy our amazing city. The growth of the Pedro Point shopping center and use of Pacifica State Beach show that we have an amazing opportunity to appeal to more day trippers and overnight guests. Let’s turn this field into something we can all be proud of and that continues to highlight the amazing strength Pacifica has as a destination for local, regional, and global guests. This can be accomplished without changing the zoning, and with intelligent development that supports the wetland, the rising seas and the ecology and the community.

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

Sincerely,

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Packet Pg. 3831 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 45 Jim Louderback, Sam Louderback, Kimberly Risk
Pacifica, CA
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3832 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 46 Murdock, Christian
From: Melinda Clar < >
Sent: Wednesday, June 1, 2022 12:57 PM
To: Public Comment; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: Open Field at Pedro Point
[CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners:

As a 25-year resident of Pedro Point, we highly object to the proposed changes to the open field at Pedro Point. Besides all of the effects to the local environment, the roads cannot support the huge influx of cars coming onto Pedro Point.

On any given weekend, the parking is so bad that it is difficult for two cars to pass each other on San Pedro Avenue. Think of what the traffic would be in this limited space with the additional cars associated with new housing built on the field. There is only one road into Pedro Point, therefore the additional traffic would be a hazard to emergency vehicles.

Pedro Point is the Gem of Pacifica. Its unique nature is extremely rare in the Bay Area. Building on the field would destroy its charm and history. It would also have the effect of lowering property values and quality-of-life for the Pedro Point residents, many of whom have been here for over fifty years.

To turn the field into a Foster City and destroy the Jewel of Pacifica is unacceptable! It's obvious to us that this plan is being pushed by folks who don't live on Pedro Point and could care less about its residents or the City of Pacifica.

We urge you to abandon this plan. There has got to be a better idea.

Sincerely,
Pat and Mindy Clar

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

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Packet Pg. 3833 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 47 Murdock, Christian
From: Melinda Clar < >
Sent: Wednesday, June 1, 2022 1:00 PM
To: Public Comment; Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg Subject: Open Field at Pedro Point (additional email address added) [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners:

As a 25-year resident of Pedro Point, we highly object to the proposed changes to the open field at Pedro Point. Besides all of the effects to the local environment, the roads cannot support the huge influx of cars coming onto Pedro Point.

On any given weekend, the parking is so bad that it is difficult for two cars to pass each other on San Pedro Avenue. Think of what the traffic would be in this limited space with the additional cars associated with new housing built on the field. There is only one road into Pedro Point, therefore the additional traffic would be a hazard to emergency vehicles.

Pedro Point is the Gem of Pacifica. Its unique nature is extremely rare in the Bay Area. Building on the field would destroy its charm and history. It would also have the effect of lowering property values and quality-of-life for the Pedro Point residents, many of whom have been here for over fifty years.

To turn the field into a Foster City and destroy the Jewel of Pacifica is unacceptable! It's obvious to us that this plan is being pushed by folks who don't live on Pedro Point and could care less about its residents or the City of Pacifica.

We urge you to abandon this plan. There has got to be a better idea.

Sincerely,
Pat and Mindy Clar

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

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Packet Pg. 3834 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 48 Murdock, Christian
From: Gary Furlong < >
Sent: Wednesday, June 1, 2022 1:20 PM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: San Pedro Ave field proposed land use designation change [CAUTION: External Email]

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

Frankly, it is almost beyond believing that this issue is still being actively considered. I have written about this matter before but am happy to do so yet again. I have lived here for more than 20 years and my husband has lived here for more than 30 years, so we do have some history here.

Please keep in mind these points:

1. there is ONE ROAD in and out of this neighborhood. On a pleasant day our neighborhood is already swamped with cars, many of them illegally parked as there is no legal parking left anywhere; these "extra" cars are due to beach goers, shoppers, hikers, people going to restaurants, people attending events at the community center, people visiting friends who live here, etc. Lots that are already zoned for residential use are still in the process of being built out so there will be more cars, more traffic. If there is an emergency that requires an evacuation of this neighborhood (i.e. a fire sweeping through the neighborhood) it is already impossible to quickly and safely evacuate this area. The city planning committee already bears a moral (and possibly legal) responsibility for creating a situation that may well prove to be deadly in the event of an emergency. The thought that some are considering adding even more possible housing (and not just a few but a great many) to this mix staggers the imagination. Again, ONE ROAD.

2. The field is environmentally sensitive. This has been shown over and over again. Documentation has been provided showing this to be true so I won't belabor that point here. However, I will point out that this field is being considered in its current condition during an extended, multi-year drought. One day the drought will end and that field will revert to its previous condition, which means a soggy mess during the wet season. It is the legal duty of the committee to exam the documents that have been presented to them in this regard.

3. The appearance is being given that the Planning Commission is creating a special zoning provision so that the owner of the property can make a profit at the cost of the neighborhood. I'm all for people making a profit but I also recognize that the field was bought with zoning that does not allow residential development. The current owner bought it knowing that and I resent that my neighborhood is being sacrificed so that a profit can be made. I believe it is the duty of the city and the Planning Commission to look out for its established neighborhoods adopting this change will do just the opposite.

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Packet Pg. 3835 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 49 4. Cramming houses into field will change the basic nature of our neighborhood. That field currently serves as a open space where neighbors can have casual encounters, where people exercise their pets, etc. For many years now there has been unchallenged access to that field and it has thus developed into the heart of the community. This designation change will ruin my decades long enjoyment of that field and will certainly do so for many others.

I am in agreement with the comments previously submitted by PPCA President Allison West on March 7, 2022. I fully support the letters the submitted by the PPCA’s CEQA consultant Richard Grassetti, attorney Brian Gaffney, and consulting Coastal Ecologist, Dr. Peter Baye, I remain deeply concerned that this testimony was evidently rejected without adequate analysis and assume that at some point this is going to be examined more closely. Their comments documented known DEIR deficiencies and reasonably foreseeable adverse impacts of the proposed GPU that are in violation of CEQA and Coastal Act policies. I believe that the city and the Planning Committee need to carefully examine these documents before making changes that will almost certainly open them up to both moral and legal issues.

Regards,
Gary Furlong
.

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

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Packet Pg. 3836 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 50 Murdock, Christian
From: Beth Brann < >
Sent: Wednesday, June 1, 2022 1:36 PM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: San Pedro Avenue Field Property and proposed change of land use designation [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,

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

I have been a Pedro Point resident since 2000 (22 years), and purchased my home with the view it had of the open field and the beach. The density of housing being proposed in changing the usage is preposterous if you look at the number of people currently living in Pedro Point and observing the traffic, the condition of our streets, the weekend touring and daily traffic, and the realization that we only have 1 ROAD IN AND 1 ROAD OUT in case of emergency. We cannot fathom what the additional number of vehicles, residences, and people would contribute to changing the safety and our coastal vibe of our little enclave in Pedro Point, Pacifica.

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

Sincerely,
Beth Brann
Pacifica, CA 94044
phone
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Packet Pg. 3837 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 51 Murdock, Christian
From: Anne Evers Hitz < >
Sent: Wednesday, June 1, 2022 2:29 PM
To: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: San Pedro Avenue Field Property and proposed change of land use designation [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,
We are writing to strongly urge you NOT to adopt the current GPU and EIR that are being presented for your consideration at the upcoming June 6 public hearing, which proposes to change the Land Use Designation of the five-acre Pedro Point Field, recognized wetlands and EnvironmentallySensitive Habitat Area (ESHA) and a center of our community, from Commercial-Recreational Use to Commercial Residential Mixed Use.

We have been Pedro Point residents since 1990 (32 years). The density of housing being proposed by changing the usage does not make any sense if you look at the number of people currently living in Pedro Point and observe the condition of our streets, the weekend touring and daily traffic, and the realization that we only have ONE ROAD IN AND ONE ROAD OUT in case of emergency. We cannot fathom what the additional number of vehicles, residences, and people would contribute to changing the safety and the coastal vibe of the neighborhood.

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

Sincerely,
Anne and Breck Hitz
Pacifica, CA 94044
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Packet Pg. 3838 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 52 Murdock, Christian
From: Andy Narraway < >
Sent: Wednesday, June 1, 2022 3:19 PM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: GPU comment re Calson Field, Pedro Point
[CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,

I am a resident of Pedro Point for the last 9 years. I moved here after 25 years living in SF and moved here for the small town community feel I was lacking, living in SF. I have attended numerous planning commision and council meetings over the years voicing my opposition to changing the Calson field in Pedro Point from Commercial into a Residential zoning. Even a small number of developments will completely change the nature of our neighborhood and will diminish the quality of life for everyone surrounding any development. We have been continually ignored by the real estate interests on city council and real estate lobbying dollars for the last 9 years I have lived here (and apparently for even longer than that by residents who have spent the last 20+ years here) and Im sick and tired of the VAST majority of the community's wishes being railroaded and IGNORED. I won't even go into Federal species regulation, climate change, wetland preservation, sea rise etc as it's been repeated ad nauseum over many, many years with NO action by the members of city council.

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

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

Sincerely,
Andy Narraway
Grand Avenue
Pacifica

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Packet Pg. 3839 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 53 CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3840 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 54 Murdock, Christian
From: Lori Martin < >
Sent: Thursday, June 2, 2022 9:16 AM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg; Home
Subject: General Plan & Pedro Point
[CAUTION: External Email]

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Packet Pg. 3841 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan

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Packet Pg. 3842 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 56 CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3843 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 57 Murdock, Christian
From: Mlcalifdreaming < >
Sent: Thursday, June 2, 2022 9:27 AM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: General Plan & PEDRO POINT
[CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,

I am writing to urge you not to adopt the current GPU and EIR that are being presented for your consideration at the upcoming June 6 public hearing, which proposes to change the Land Use Designation of the five-acre Pedro Point Field, a recognized wetlands and Environmentally-Sensitive Habitat Area (ESHA) and a center of our community, from Commercial-Recreational Use to Commercial Residential Mixed Use. I have lived on Pedro point for 13 years and have never once used this field for my personal use. My concern is that a planned development such as this would dramatically change the Pedro Point community which is becoming an upscale jewel of Pacifica (with an ever increasing tax base for the city), add an additional traffic and parking burden to an already over-burdened area, cause flooding and potentially destroy the wetlands.

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

Sincerely,
Michael Martin
Pacifica, CA 94044
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3844 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan

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Packet Pg. 3845 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 59 Murdock, Christian
From: Jennie Lill (JLILL) < >
Sent: Thursday, June 2, 2022 11:25 AM
To: Public Comment; Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg Subject: San Pedro Avenue Field proposed land use designation changes [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,
I hope you are doing well.

It recently came to my attention that a couple of proposals I thought have been dismissed recently have reemerged that will directly affect myself, my family and my neighbors within the Pedro Point community.

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

Firstly, the traffic in and out of Pedro Point is already congested particularly during commute times and on sunny days when we suffer from parking due to beach traffic overflow. Many times it has been impossible to even park outside my own home and I often have to place traffic cones outside to ensure my family and tenants can park safely near our residence (140 Blackburn Terrace which I have been the owner of for the past 9 years). We already have many vacant lots that are already zoned for residential use which are still being built out which means that in a year or so time, the traffic will increase.

We often discuss that it will be hard to safely evacuate via our one exit road during a Tsunami, Earthquake or Fire evacuation.

We simply cannot add multiple additional houses in this area.

Secondly, the field where the new zoning is being proposed if often flooded in the rainy season, but is also a habitat to certain types of wildlife (we often see garter snakes there) but is also the central hub of our community for dog walkers, our residences who can't walk too far and for our young children. How would we be compensated for this if it becomes built out?
I am in agreement with the comments previously submitted by PPCA regarding this matter and implore that the city and the Planning Committee very carefully examine these documents before making changes that will almost certainly open them up to both moral, legal and societal issues.

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Packet Pg. 3846 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 60 In brief, this is a beautiful neighborhood that is already stretched to capacity & where it really makes no sense to build things up further.

Please contact me with any questions
Sincerely,
Dr. Jennie Lill
Jennie R Lill Ph.D. Senior Fellow & Executive Director.

Department of Proteomics, Lipidomics and Next Generation Sequencing Genentech, A Member of the Roche Group
On Campus on Mon, Tues, Wed, WFH Thurs Fri
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Packet Pg. 3847 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 61 Murdock, Christian
From: Peter Loeb >
Sent: Thursday, June 2, 2022 12:10 PM
To: Bier, Mary; Bigstyck, Tygarjas; O'Neill, Mike; Beckmeyer, Sue; Vaterlaus, Sue; Woodhouse, Kevin; Berman, Lauren; Hauser, Samantha; Domurat, George; Godwin, James; Ferguson, Alex; Leal, David; Wright, Greg; Murdock, Christian Cc: Summer Lee; JoAnne Arnos; Pete Shoemaker; Mark Hubbell; Clif Lawrence; Cherie Chan; Christine Boles; Stan Zeavin; Suzanne Moore; Nancy Tierney; Sue Digre (Contact); Cindy Abbott; James Kremer; Marj Davis; Paul Chervatin; Carolyn Jaramillo; Dinah Verby; Sam Casillas; Victor Carmichael
Subject: When will comments on General Plan be addressed? [CAUTION: External Email]

Perhaps the most frequent response to comments in the FEIR is:
“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." Will the comments about the General Plan be shared in the June 6, 2022 Planning Commission meeting? The recommended action on that agenda is:

Adopt the attached resolution to recommend City Council approval of the General Plan Update and Sharp Park Specific Plan.

Members of the public have made many comments on the General Plan. That will be a large number of comments to summarize and discuss. The Planning Commissioners will be unable to consider them all in the meeting, prior to acting on the recommended action. All of the comments on the General Plan need to be presented to the Planning Commission before they take the recommended action. Some of the comments may result in recommended changes to the General Plan. These comments and the General Plan recommendation action item deserve a separate meeting to consider all these comments and the recommendation.

Peter Loeb
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Packet Pg. 3848 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 62 Murdock, Christian
From: Christine Boles < >
Sent: Thursday, June 2, 2022 1:31 PM
To: Clif Lawrence
Cc: Peter Loeb; Bier, Mary; Bigstyck, Tygarjas; O'Neill, Mike; Beckmeyer, Sue; Vaterlaus, Sue; Woodhouse, Kevin; Berman, Lauren; Hauser, Samantha; Domurat, George; Godwin, James; Ferguson, Alex; Leal, David; Wright, Greg; Murdock, Christian; Summer Lee; JoAnne Arnos; Pete Shoemaker; Mark Hubbell; Cherie Chan; Stan Zeavin; Suzanne Moore; Nancy Tierney; Sue Digre (Contact); Cindy Abbott; James Kremer; Marj Davis; Paul Chervatin; Carolyn Jaramillo; Dinah Verby; Sam Casillas; Victor Carmichael; Public Comment
Subject: Re: When will comments on General Plan be addressed? [CAUTION: External Email]

Thank you Peter, this is a very important point as the Planning Commission is also being asked by staff and state agencies to consider making some changes to the GP as well.

It would be really helpful to know how this meeting will be structured so that the public can prepare comments for the various topics. Certainly we won't be limited to one 2-3 minute comment on all three incredibly complex documents, will we? My main comments will focus on the still deficient landslide and fire maps in both the General Plan and EIR as those are critical to life safety, but I just noticed some new horizontal discrepancies in the General Plan while reading the revisions on the plane yesterday that should be fixed too.

I plan to spend this weekend writing up ahead of time what I can in this short time period, but oral comments should be allowed after the staff presentation/initial planning commission discussion on each separate item at a minimum (GP, SPSP, EIR) as we have no idea what staff will be presenting and what may be accidentally left out or misinterpreted from our comments that need additional attention.

Again, please allow us to be your partners in this update. Many of us have spent many hours reviewing and analyzing these documents and the background scientific data. We want to be helpful so together we can ensure Pacifica has a really good General Plan to guide us through the next 20-40 years.

Thank you!
Christine Boles
On Thu, Jun 2, 2022 at 12:32 PM Clif Lawrence < > wrote:

Very good catch.

Clif
On Thu, Jun 2, 2022 at 12:10 PM Peter Loeb < > wrote:

Perhaps the most frequent response to comments in the FEIR is:
“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. 3849 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 63 Will the comments about the General Plan be shared in the June 6, 2022 Planning Commission meeting? The recommended action on that agenda is:

Adopt the attached resolution to recommend City Council approval of the General Plan Update and Sharp Park Specific Plan.

Members of the public have made many comments on the General Plan. That will be a large number of comments to summarize and discuss. The Planning Commissioners will be unable to consider them all in the meeting, prior to acting on the recommended action. All of the comments on the General Plan need to be presented to the Planning Commission before they take the recommended action. Some of the comments may result in recommended changes to the General Plan. These comments and the General Plan recommendation action item deserve a separate meeting to consider all these comments and the recommendation.

Peter Loeb
--
Christine Boles, Architect
Candidate for Pacifica City Council, District 2
Caring for the People and Environment of Pacifica
www.ChristineforPacifica.com
M m m
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Packet Pg. 3850 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 64 Murdock, Christian
From: Debi Hirshlag < >
Sent: Thursday, June 2, 2022 3:16 PM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: Concerned Citizen - Proposed land use designation change for the San Pedro Ave field in Pedro Point
[CAUTION: External Email]

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

I am a fairly new resident, having moved to Pacifica about a year ago and being so smitten with the field's open space allowing coastal access for Pedro Point residents and visitors and providing a safe place for families and dogs to meet, exercise and roam, especially given so many of us have no yard or a highly sloped one, and the area has few protective sidewalks. It is also a natural adjunct to the historic Pedro Point Firehouse, a community center for residents and others who lease it out, including a small playground for kids behind it.

Development of this field will fundamentally alter the charm, peace and safety of this neighborhood. I don't know if any of you live in or spend time in Pedro Point but the beauty of this neighborhood comes with several downsides, of which the development of dense housing will only serve to make it worse.

1. During the busy weekends and throughout the summer, beachgoers and patrons of businesses like Soul Grind and Humble Sea park up and down our streets after facing full lots or seeking to avoid paying for parking. And the recently enacted large vehicle parking ordinance will probably reduce legal parking by another 6 or so spaces here. As a result, we face a gauntlet of illegally and/or poorly parked cars as we try to get into and out of our neighborhood. This is not only a driving hazard but potentially a safety hazard should an emergency vehicle try to get in/out or, heaven forbid, we need to evacuate in an emergency. I have had to slam on my brakes for children running across streets from behind parked cars excited to go to the beach, an unleashed dog jumping out of an open Jeep and generally "oblivious" tourists on the phone crossing the road. If you add another 70 units with all their residents, cars and visitors, this becomes a real hazard for ingress and egress, not to mention how traffic will flow from the housing area onto San Pedro (street light, or every man for himself trying to dart into traffic).

2. For whatever reason, Pacifica seems to have forgotten about street quality in Pedro Point. We have pot holes and edges of streets that are deteriorated and crumbling away. This is made worse by so many people parking along the edges, the narrowness of our streets and the water drainage during rainy seasons which chips away at blacktop quality. Again, visitors and residents have already taxed the infrastructure of Pedro Point. How can we keep adding onto it?

3. Lastly, acoustics in Pedro Point are a bit unique due to the bowl-shape of our hillside. Every emergency vehicle, car with a loud muffler and revving motorcycle is heard loud and clear in our homes, at all hours of the day and night. Even construction on a single home is loud. If you take construction on 70 homes that will take a very long

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Packet Pg. 3851 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 65 time, not to mention the resulting noise of 70 families, their cars, their kids and their dogs, all of us who are living here will have their quality of life reduced greatly.

I understand and support progress, and realize the pressure towns are under given California's housing push, but isn't a Planning Commission also supposed to look out for the safety and well-being of existing, tax-paying residents - not just hypothetical new ones? Aren't there safer places to build where a new neighborhood can be established, rather than altering an existing one? Or, can't existing cleared land be added onto/built up? And, if the safety and well-being of existing residents isn't enough of a factor to NOT accept this proposed change, I urge you to revisit in detail the environmental considerations of this piece of land. Not only does it support endangered species and provide drinking water for wild animals in our area, it is also an important drainage basin for the hillside of Pedro Point. You see a grassy field right now (in a multi-year drought) but even in the most modest one-day rain, all the criss-cross drainage of Pedro Points flows to that field.

I conclude by saying I am in agreement with the comments previously submitted by Pedro Point Community Association (PPCA) President Allison West on March 7, 2022. I fully support the letters submitted by the PPCA’s CEQA consultant Richard Grassetti, attorney Brian Gaffney, and consulting Coastal Ecologist, Dr. Peter Baye, and I remain deeply concerned that this testimony was evidently rejected without adequate analysis and assume that at some point this is going to be examined more closely. Their comments documented known DEIR deficiencies and reasonably foreseeable adverse impacts of the proposed GPU that are in violation of CEQA and Coastal Act policies. I believe that the city and the Planning Committee need to carefully examine these documents before making changes that will almost certainly open them up to both moral and legal issues, and jeopardize the safety and well-being of the existing residents of Pedro Point - both human and wildlife.

Thank you.

Regards,
Debi Hirshlag
Pacifica, CA 94044
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Packet Pg. 3852 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 66 Murdock, Christian
From: Christine Boles < >
Sent: Thursday, June 2, 2022 6:21 PM
To: Murdock, Christian; _City Council Group; Woodhouse, Kevin; Public Comment Subject: URGENT - city calendar on Meeting Portal site for Planning Commission hearing has not been updated!
[CAUTION: External Email]

I am getting questions from other members of the public because the city meeting portal website shows the GP hearing already happened on 6/1. The agenda itself also says 6/1 and there is no agenda posted for the 6/6. This is so confusing. Does this meet the legal requirements of notifications? Please confirm and fix it asap.

Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3853 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 67 Murdock, Christian
From: Suzanne Moore >
Sent: Thursday, June 2, 2022 7:02 PM
To: Bier, Mary; Bigstyck, Tygarjas; Murdock, Christian; Berman, Lauren; Domurat, George; Ferguson, Alex; Godwin, James; Wright, Greg; Hauser, Samantha; Woodhouse, Kevin; Leal, David; Beckmeyer, Sue; Vaterlaus, Sue
Cc: Christine Boles; Clif Lawrence; Mark Hubbell; Nancy Tierney; Pete Shoemaker; Suzanne Moore
Subject: Public questions to prepare for the 6/6/22 Planning Commission meeting [CAUTION: External Email]

Community members have been intent on providing thoughtful and meaningful comments to the GP, SPSP, and DEIR.

We have some common questions to best prepare for the 6/6/22 meeting with the Planning Commission.

1. Will there be public presentations? These documents are complex, and for many of us, difficult to understand. Could the City provide a brief presentation on the proposals to increase density and height, especially in Sharp Park where the neighborhood could be completely transformed?

2. Will the public be allowed time to speak to each of the three documents? It is unclear from the agenda.

3. If the public disagrees with a City reply to a previous comment on the DEIR, what process has been created?

4. Can you clarify when staff will present public comments on the General Plan and Sharp Park Specific Plan at public hearings per Master Response 1 on packet page 751? Some comments remain unaddressed.

5. The Housing Element process has not been initiated, will require significant public engagement, has a January deadline, will require CEQA work, and needs to be consistent with the LCLUP and the GP. Further changes to the GP, LCLUP and EIR may be needed. Can we immediately, with the dedicated outside consultants the city has already hired, start work on the Housing Element in parallel with the GP review and approvals process? What are the repercussions if the State fails to certify our Housing Element?
--
Suzanne Moore
Home
Cell
--
Suzanne Moore
Home
Cell
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Packet Pg. 3854 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan

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Packet Pg. 3855 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 69 Sent from my iPhone
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Packet Pg. 3856 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 70 Murdock, Christian
From: Emil Mitev < >
Sent: Thursday, June 2, 2022 8:39 PM
To: Public Comment
Cc: Murdock, Christian; Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg
Subject: Opposition to adopt current GPU and EIR
[CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,

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

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

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

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Packet Pg. 3857 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 1 Murdock, Christian
From: Joanne Gold
Sent: Thursday, June 2, 2022 9:53 PM
To: Public Comment
Cc: Berman, Lauren; Hauser, Samantha; Domurat, George; Ferguson, Alex; Godwin, James; Leal, David; Wright, Greg; Murdock, Christian; Murdock, Christian Subject: Comments on GPU and EIR for June 6th Planning Commission Hearing [CAUTION: External Email]

Dear Mr. Murdock and Planning Commissioners,
I am a resident of Pedro Point and am writing to urge you not to adopt the GPU and FEIR in their current form which are being presented for your consideration at the upcoming the June 6th public hearing.

There is no question that the City of Pacifica needs a new General Plan. But the GPU and FEIR being put in front of you contain errors and omissions that will have significant negative consequences if not addressed and will leave the city vulnerable to future challenges and/or lawsuits – something no one wants, and the city can’t afford.

The area of my greatest concern - and the one that prompted more than two-thirds of overall public comments on the DEIR - is the proposed Land Use Designation change from Commercial-Recreational (CR) to Commercial Residential Based Mixed Use (CRMU) for the five-acre undeveloped San Pedro Avenue site (ie: the Pedro Point Field - the center of my neighborhood, a seasonal wetlands and EnvironmentallySensitive Habitat Area) I am among those who had personally submitted comments on the DEIR citing issues with this proposed Land Use change noting negative impacts, deficiencies, and ways in which the proposed Land Use would be out of compliance with CEQA and Coastal Act policies.

I also fully support comment letters previously submitted on behalf of the Pedro Point Community Association on March 7, 2022 by the PPCA’s CEQA consultant Richard Grassetti, attorney Brian Gaffney, and consulting Coastal Ecologist, Dr. Peter Baye. Their comments also documented known deficiencies in the Draft EIR and reasonably foreseeable adverse impacts of the proposed GPU.

Please do not merely dismiss these expert opinions and common-sense comments from concerned residents like me in a rush to approve the EIR and GPU in their current form. These are long and complex documents – more than 4,000 pages in all! You must take the time needed to adequately review and consider their content and all the comments submitted.

We’ve waited this long to update the General Plan… don’t sacrifice quality and the careful consideration needed that will give us a plan for the future of Pacifica we can be proud of. I implore you to take steps to address the noted deficiencies, errors and omissions – especially those related to the Pedro Point field - before adopting these important guiding documents for our city. It will not only help to avoid drawn out challenges and potential litigation, it is simply the only responsible thing to do.

Respectfully,
Joanne Gold
Pacifica

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Packet Pg. 3858 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan 2 CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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Packet Pg. 3859 Attachment: Attachment K - Public Comments Received Prior to Agenda Publication (5015 : General Plan Update and Sharp Park Specific Plan