Pacifica City Council
July 11, 2022

CO-I-45 ✳Continuation of Agricultural and Related Uses. Where agricultural and related uses exist, allow compatible uses to continue.

CO-I-46 Mineral Resources. If significant mineral resources are discovered with regional agencies to determine a course of action to protect the resources and, if applicable, extract them in an environmentally sensitive manner.

CO-I-47 ✳ Recreational Uses. Promote recreational uses, such as horse boarding and trail riding, which retain open space character while contributing to a visitor-based economy.

7.4 Air Quality
Protecting and improving air quality is important to Pacifica and communities across California, as certain kinds of air pollutants are directly harmful to human health and the health of the natural environment, including water quality, plant and animal life.

Due to its position relative to wind flow patterns and topography, air quality in Pacifica is better than it is in the Bay Area overall. Still, pollutants emitted locally have regional consequences. Since air quality is a regional issue, this General Plan also has referred to Bay Area 2017 Clean Air Plan for guidance.

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CLIMATIC CONDITIONS
Atmospheric conditions, such as wind speed, wind direction, and air temperature interact with the physical features of the landscape to determine the movement and dispersal of air pollutants. Pacifica lies in the northwestern portion of the Bay Area’s peninsula climatological sub-region within this sub-region, air pollution potential is highest in the vicinity of Redwood City, the area most protected from high winds and most susceptible to pollution transported from upwind urban areas. At Pacifica’s location, winds bring air from the ocean and are generally strong enough to carry away local emissions.

INSERT Photo 15
In the Bay Area, winds typically carry marine air inland through the Golden Gate and across the San Bruno gap in the Santa Cruz mountains. The interaction of wind direction, air temperature, and landscape features tend to carry contaminated air eastward.

EXISTING AIR QUALITY
The Bay Area has attained Federal and state standards for carbon monoxide, nitrogen dioxide, and sulfur dioxide but has not met Federal and state standards for California’s standards for annual concentrations of coarse (PM 10) and fine (PM 2.5) particulate matter, as well as the federal 24-hour standard for PM 2.5.

The Bay Area Air Quality Management District operates a regional monitoring network that measures six criteria pollutants. Since the closest monitoring station is approximately ten miles northeast of Pacifica on Arkansas Street in San Francisco, air quality in Pacifica can be inferred but not precisely gauged from BAAQMD’s measurements. Table 7-2 shows measured pollutant concentrations for ozone, PM 10 and PM 2.5 from the Arkansas Street station over the last five years, and ambient air quality standards for these criteria pollutants.

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Table 7-2: Air Quality Data Summary (2016-2020) for the Project Area1 Monitoring Data by Year
Standard 2016 2017 2018 2019 2020
Ozone
Highest 1-hour average (ppm) 0.070 0.087 0.065 0.091 0.088 Days above state 1-Hour Std. 0.9 0 0 0 1 0
Highest 8-hour average ppm 0.057 0.053 0.049 0.073 0.055 Days above state 8-hour Std. 0.07 0 0 0 1 0
Days above federal 8-Hour
Std.

0.075 0 0 0 0 0
Carbon Monoxide
Highest 8-hour average ppm 1.10 1.40 1.60 0.90 1.60
Days above state 8-hour Std. 9.0 0 0 0 0 0
Days above federal 8-Hour
Std.

9.0 0 0 0 0 0
Fine Particulate Matter (PM2.5)
Highest 24-hour average
(µg/m3)
108.0 190.0 241.0 45.0 214.0
Estimated Days above state
Std.2
50 1 9 18 0 20
Estimated Days above federal
Std.
150 0 2 3 0 4
Annual Average 20 7.6 9.6 11.7 7.7 10.5
1 Data for Arkansas Street Monitoring Station in San Francisco 2 Measurements are usually collected every six days. Estimated days over the standard represent the estimated number of days the standard would have been exceeded if measurements were collected every day.

Notes: ppm means parts per million; µg/m3 means micrograms per cubic meter; n/a means insufficient data available
Source: Bay Area Air Quality Management District, https://www.baaqmd.gov/about-airquality/current-air-quality/air-monitoring-data/#/, 2020, accessed June 2021.

Source: California Air Resources Board, Summaries of Air Quality Data, 2015-2019. http://www.arb.ca.gov/adam.

Based on data in Table 7-2, there appears to have been one violation of the state or national ozone standard in San Francisco over the five years between 2015 and 20192016-2020. Because ozone is a regional pollutant and precursors can travel long distances before they react to form ozone, local emissions of reactive organic gases (ROG) and nitrogen oxides (NOx) may contribute to regional ozone levels. The regional monitoring network has recorded ozone levels exceeding the State standard for 15 days per year over the past five years, with fewer violations of the national standards.

In general, particulate levels are relatively low near the coast, and peak in dry, sheltered valleys. Therefore, Pacifica’s air is generally less polluted than the region’s, though local emissions play a role in the region’s air quality issues. Local PM2.5 concentrations have exceeded state 24-hour standards over four of the past five years, and federal 24-hour standards over three of the past five years.

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The BAAQMD maintains an Emissions Inventory, which estimates the total volume of air pollutants generated each day by approximately 100 “areawide” sources, point sources such as factories, gas stations and power plants, and mobile sources (primarily vehicles). In general, the proportion of air pollution generated by different sources varies by pollutant. Cars, trucks, airplanes and boats are responsible for most of the smog-producing pollutants (nitrogen oxides and reactive organic gases) in the air and nearly all of the carbon monoxide. Areawide sources, especially dust from roads, produce most of the particulate air pollutants. Ships account for virtually all of the sulfur dioxide emitted in San Mateo County.

While the region is in compliance for carbon monoxide (CO) emissions, concentrations of CO can still be a local concern. In Pacifica, congestion on Highway 1 has the potential to produce high concentrations, negatively impacting the health of sensitive populations (children, the elderly, etc.).

SENSITIVE RECEPTORS
Some people are more sensitive to air pollution than others. Heightened sensitivity may be caused by preexisting health problems, proximity to the emissions source, and duration of exposure to pollutants. Land uses such as schools, children's day care centers, hospitals, and convalescent homes are more sensitive than the general public to poor air quality because the population groups associated with these uses have increased susceptibility to respiratory distress and other air quality-related health problems. Persons engaged in strenuous work or exercise also have increased sensitivity to poor air quality.

POLICIES
Guiding Policies
CO-G-13 Improve Air Quality. Reduce emissions of ozone-producing pollutants and particulate matter to improve regional air quality and protect the health of Pacifica and Bay Area residents.

Implementing Policies
CO-I-48 Regional Cooperation. Cooperate with the Bay Area Air Quality Management District (BAAQMD) and other public agencies in implementing plans to achieve State and Federal Ambient Air Quality Standards.

CO-I-49 Impact Guidelines. Use the BAAQMD’s Air Quality Guidelines, to determine and mitigate project air quality impacts.

The City consults with the BAAQMD during CEQA review for projects that require air quality impact analysis and BAAQMD is on the distribution list for CEQA documents.

CO-I-50 Sensitive Receptors. Work with BAAQMD to develop and implement a Community Risk Reduction Plan to address the exposure of sensitive populations to toxic air contaminant emissions in Pacifica.

CO-I-51 Construction Equipment. Require all construction equipment to be maintained and tuned to meet appropriate EPA and CARB emission requirements.

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CO-I-52 Dust Abatement. Require contractors to use best management practices to reduce particulate emissions and dust associated with construction activities.

BMPs include, but are not limited to: regular materials and vehicle tire watering; covering of stockpiles; phasing or extension of grading operations; suspension of grading during high wind periods; and revegetation of graded areas.

CO-I-53 Transportation Control Measures. Ensure compliance with the most current Bay Area Clean Air Plan by implementing the Plan’s recommended Transportation Control Measures.

The 20170 Clean Air Plan identifies 17 TCMs aimed at reducing vehicle trips and vehicle miles traveled; increasing access to and support of alternative modes of transportation; promoting compact, walkable land use patterns; and increasing public education and awareness.

7.5 Energy and Greenhouse Gases
Like air quality, greenhouse gas emissions and potential effects of global climate change are environmental issues whose causes and impacts extend far beyond the boundaries of any one city.

However, given its coastal location and fragile environmental assets, the City is acutely aware of the impacts that global climate change may have, and actively engaged in working to reduce greenhouse gas emissions in the Planning Area and adapting to the changing physical environment.

GLOBAL CLIMATE CHANGE
Global climate change (GCC) refers to a change in the average weather of the earth that may be measured by wind patterns, storms, precipitation, and temperature. Historically, the rate of temperature change has typically been incremental, with warming and cooling occurring over the course of thousands of years. In the past 10,000 years the earth has experienced incremental warming as glaciers retreated across the globe.

However, scientists have observed an unprecedented increase in the rate of warming over the past 150 years, roughly coinciding with the global industrial revolution.

Although GCC is now widely accepted as a concept, the extent and speed of change to be expected, and the exact contribution from human sources, remains in debate. Nonetheless, the world’s leading climate scientists, the Intergovernmental Panel on Climate Change (IPCC), have reached consensus that global climate change is “very likely” caused by humans, and that hotter temperatures and rising sea levels will continue for centuries no matter how much humans control their future emissions.23 23 IPCC, 20198

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In its 20189 report, the IPCC predicted that global warming is likely to reach 2.7 degrees Fahrenheit between 2030 and 2052 if it continues to increase at the current rate. Crossing the 2.7 degree threshold could expose tens of millions more people worldwide to life-threatening heat waves, water shortages and coastal flooding. The same report projects a sea level rise of seven to 23 inches by the end of the century, with a greater rise possible depending on the rate of polar ice sheet melting. Observations since then have led to projections for more significant change. A 2009 study done for a consortium of California state agencies has projected a sea level rise of 39 to 55 inches along the California coast by 2100. 24 Locally, a 2016 statewide vulnerability assessment conducted by the California Coastal Commission has projected a sea level rise of 39 to 55 inches along the California coast by 2100.25 Locally, a 2016 statewide vulnerability assessment conducted by the California Coastal Commission 2009 study done for a consortium of California state agencies has projected a sea level rise of 17 to 6639 to 55 inches along the California coast by 2100.26According to the California Climate Action Team (CCAT), accelerating GCC has the potential to cause a number of adverse impacts in California, including but not limited to: a shrinking Sierra snowpack that would threaten the state’s water supply; public health threats caused by higher temperatures and more smog; damage to agriculture and forests due to reduced water storage capacity, rising temperatures, increasing salt water intrusion, flooding, and pest infestations; critical habitat modification and destruction; eroding coastlines; increased wildfire risk; and increased electricity demand. These impacts have and will continue to have considerable costs associated with them.

While all of these impacts may be felt to some extent in Pacifica, of particular concern are coastal erosion, flooding, and habitat modification, as well as water supply issues.

Greenhouse Gases
Gases that trap heat in the Earth’s atmosphere are called greenhouse gases (GHGs). These gases play a critical role in determining the Earth’s surface temperature. Part of the solar radiation that enters Earth’s atmosphere from space is absorbed by the Earth’s surface. The Earth reflects this radiation back toward space, but GHGs absorb some of the radiation. As a result, radiation that otherwise would have escaped back into space is retained, resulting in a warming of the atmosphere. This phenomenon is known as the greenhouse effect.

There are many types of GHGs. The six that are identified explicitly in California legislation as being of primary concern are:
• Carbon dioxide (CO2), emitted as a result of fossil fuel combustion, with contributions from cement manufacture;
24 California Climate Change Center, May 2009.
25 California Coastal Commission, December 2016.
26 California Coastal Commission, December 2016. Climate Change Center, May 2009.

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• Methane (CH4), produced through the anaerobic decomposition of waste in landfills, animal digestion, decomposition of animal wastes, production and distribution of natural gas and petroleum, coal production, and incomplete fossil fuel combustion; • Nitrous oxide (N2O), typically generated as a result of soil cultivation practices, particularly the use of commercial and organic fertilizers, fossil fuel combustion, nitric acid production, and biomass burning;
• Hydrofluorocarbons (HFCs), primarily used as refrigerants; • Perfluorocarbons (PFCs), originally introduced as alternatives to ozone depleting substances and typically emitted as by-products of industrial and manufacturing processes; and • Sulfur hexafluoride (SF6), primarily used in electrical transmission and distribution systems.

GHGs have varying potentials to trap heat in the atmosphere, known as global warming potential (GWP), and atmospheric lifetimes. Often, GWP is expressed in terms of “carbon dioxide equivalents”, or CO2e, which allows emissions of different gases to be summed by a common metric. GWP ranges from one (carbon dioxide) to 23,900 (sulfur hexafluoride). GHG emissions with a higher GWP have a greater global warming effect on a molecule-by-molecule basis. For example, one ton of CH4 has the same contribution to the greenhouse effect as approximately 21 tons of CO2. The parameter “atmospheric lifetime” describes how long it takes to restore the system to equilibrium following an increase in the concentration of a GHG in the atmosphere. Atmospheric lifetimes of GHGs range from tens to thousands of years.

GREENHOUSE GAS EMISSIONS
According to the California Air Resources Board emissions inventory reports for 2000 through 2017, California’s GHG emissions continue to decrease. In 2017, emissions from GHG emitting activities statewide were 424 million metric tons carbon dioxide equivalent. , California’s emissions were the fourth lowest in the United States in 2001. Per capita rates of emissions in the Bay Area and San Mateo County are slightly higher than the California average. According to the California Air Resources Board emissions inventory reports for 2000 through 2019, California’s GHG emissions continue to decrease. In 2019, emissions from GHG emitting activities statewide were 418 million metric tons carbon dioxide equivalent. Per capita rates of emissions in the Bay Area and San Mateo County are lower than the California average.

In 20194, the BAAQMD Climate Center completed a report completed a baseline inventory of GHG emissions for the year 2011, showsshowing that carbon dioxide accounting for 91 percent of greenhouse gas emissions, with methane, nitrous oxide, and other compounds making up the remainder.

Table 7-3: Comparative Greenhouse Gas Emissions
Area Population Emissions (CO2e)
Per Capita Rate
(metric tons/ year/ person)
San Mateo County (20195) 76749,000 3.95.2 million 6.95.9 Bay Area (20191) 7,730218,000 47.386.6 million 6.112.0
California (20197) 39,2808,980,000 418.124 million 10.96

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United States (20197) 3285,3700,000 6,0055,130 million 15.68.4 Note: Emissions are measured in metric tons of carbon dioxide equivalent (CO2e) Sources: Data for San Mateo Count is from Sustainable San Mateo County, 2015. Data for the Bay Area are for 2011, BAAQMD, 2014. Emissions for California from California Air Resources Board; population U.S. Census Bureau, 2013-2017 American Community Survey. Emissions for the United States from U.S. Environmental Protection Agency, Washington, D.C. 2019, population U.S. Census Bureau, 2003-2017 American Community Survey. Data for San Mateo County and Bay Area is from The Climate Center, 2020;. Emissions for California from California Air Resources Board; population U.S. Census Bureau, 2015-2019 American Community Survey.

Emissions for the United States from U.S. Energy Administration, 2019, population U.S. Census Bureau, 2015-2019 American Community Survey.

The Bay Area’s transportation sector is the primary source of Bay Area greenhouse gas emissions, contributing about 40 percent of the region’s CO2e, followed by industrial and commercial sources (36 percent), electricity and co-generation (14 percent), residential fuel usage (8 percent), off-road equipment (2 percent), and agriculture and farming (2 percent). These proportions are illustrated in Figure 7-4.

Figure 7-4: 2011 Bay Area Greenhouse Gas Emissions by Sector Source: California Greenhouse Gas 2000-2017 Emissions Trends and Indicators Report Absent any policy changes, the Bay Area’s greenhouse gas emissions are expected to grow due to population growth and economic expansion (See Figure 7-5). Economic activity variations and the fraction of electric power generation in the region will cause year-to-year fluctuations in the emissions trends. In 2019, the Climate Center completed a report showing that the Bay Area’s transportation sector is the primary source of Bay Area greenhouse gas emissions, contributing about 50 percent of the region’s

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CO2e, followed by natural gas usage (33 percent) and electricity usage (14 percent.) Between 2014 and 2019, the Bay Area reduced its emissions by about 3.6 percent The region made meaningful progress in reducing its electricity emissions, dropping them 52% between 2014 and 2019. This has largely been driven by Community Choice agencies coming online that deliver low-carbon electricity and by a nearly decarbonized PG&E electricity supply in 2019 (due to Community Choice impacts).

In 2014, the City of Pacifica released a Climate Action Plan, which provided a baseline inventory of GHG emissions in 2005. For a similar year, San Mateo County countywide CO2 emissions were 5.91 million metric tons in 2006, averaging 8.1 metric tons per capita. By contrast, emissions in Pacifica were estimated as 4.5 metric tons per capita (See Table 7-4).

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Figure 7-5: Bay Area Greenhouse Gas Emissions Trends by Sector Source: Bay Area Air Quality Management District, Source Inventory of Bay Area Greenhouse Gas Emissions, 2011 San Mateo County countywide CO2 emissions were 5.91 million metric tons in 2006, averaging 8.1 metric tons per capita. By contrast, emissions in Pacifica were estimated as 4.5 metric tons per capita (See Table 7-4).

Table 7-4: 2015 CO2 Emissions in San Mateo County and Pacifica San Mateo % of Total Pacifica % of Total
Transportation 3,165,800 60% 98,000 62%
Energy 1,872,900,000 36% 25,000 35%
Solid Waste 186,800,200 4% 4,000 3%
Wastewater/Water 24,900 0.4% 5,600 4%
Total 5,250,000 159,000
Per Capita CO2 emissions 8.1 4.5
Note: This inventory considers only CO2, and not CO2e emissions Source: Sustainable San Mateo, U.S. Census Bureau, 2011-2015 American Community Survey

ELECTRICITY AND GAS
Pacific Gas & Electric (PG&E) provides gas and electric services to Pacifica homes and businesses. With energy obtained from power plants, natural gas fields, and renewable energy sources in northern California. Peninsula Clean Energy is an alternative renewable-energy electricity provider. Both providers offer clean energy options including significant shares greenhouse gas (GHG) emissions-free power generation. The availability of electricity and gas services is not expected to become an issue during the planning horizon. However, electricity and natural gas use account for 40 percent of greenhouse gas emissions in Pacifica. Thus, while supply is not anticipated to be an issue in Pacifica, reducing demand for these resources will help reduce carbon emissions.

California Green Building Standards
Green building refers to methods in the construction and operation of buildings intended to conserve natural resources, reduce waste from construction and demolition, increase energy efficiency and reduce operating costs, and promote healthy indoor air quality.

The California Building Code (Title 24 of the State Code of Regulations) includes the country’s first Green Building Standards (CalGreen), parts of which became mandatory as of January 2011. Among these are requirements to reduce water consumption, divert construction waste from landfills, and install low pollutant-emitting finish materials. Requirements vary for residential and nonresidential buildings.

The Green Building Standards are a key part of the State’s efforts to achieve the State’s goal of reducing greenhouse gas emissions by 40 percent belowto 1990 levels by 20320, and by 80 percent below 1990 levels by 2050. Future updates are expected to continue to strengthen environmentally responsible building requirements as these practices become widely adopted. Local jurisdictions are responsible for ensuring

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that State standards are met, at a minimum. The 2019 Green Building Standards Code also establishes a system designed to give cities and counties the option of adopting local codes that go beyond the minimum standards.27 Pacifica has adopted CalGreen as well as local “reach codes” that exceed the minimum requirements of CalGreen.

SOLID WASTE COLLECTION AND RECYCLING
Although solid waste accounts for just 2 percent of Pacifica’s carbon emissions, solid waste has the potential to be a much larger contributor to global warming overall because of methane produced byproducts. Solid waste can be reduced through recycling, composting, and reduction and reuse of material goods.

Solid waste collection and recycling services in Pacifica are provided by Recology of the Coast, a division of Recology. Recology, based in San Francisco, operates a number of landfills, waste transfer and materials recovery facilities, including the recycling yard at 1046 Palmetto Avenue in Pacifica. Recology emphasizes waste reduction and diversion, and is the largest compost facility operator by volume in the United States.

In Pacifica, Recology of the Coast currently provides curbside pick-up of garbage, recyclables, and green waste for both residential and commercial customers.

The City has enacted Ordinance No. 838-C.S. regulating plastic beverage straws, stirrers and cutlery, and polystyrene disposable food serviceware. Also, both the City and San Mateo County have recycling divisions that provide information to help residents and businesses reduce and divert waste from landfills.

The City has also adopted Ordinance No. 870-C.S. to comply with SB 1383, California’s Short-lived Climate Pollutant Reduction Strategy, to increase organic waste recycling in an effort to reduce greenhouse gas emissions.

SEA LEVEL RISE
Of the various potential effects of global climate change, sea level rise is particularly relevant to Pacifica because of urban and infrastructure located near the coastline. Areas of the Sharp Park Golf Course, the Rockaway Beach district, and the West Linda Mar and West Sharp Park neighborhoods could be vulnerable to inundation or coastal flooding. Coastal erosion processes that have caused significant damage along the high bluffs of Pacifica’s northern coastal neighborhoods increase in magnitude. In addition to raising the average tide lines, sea level rise has the potential to alter the frequency and magnitude of coastal flood events. The potential for sea level rise to exacerbate coastal flooding and erosion in the Planning Area is discussed in more detail in Chapter 8, Safety. 27 California Building Standards Commission, 2019.

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POLICIES
Policies included in both the General Plan and Local Coastal Land Use Plan are indicated with a ✳.

Guiding Policies
CO-G-14 Renewable Energy. Support the use and development of renewable energy through City purchasing, and facilitation of local renewable energy generation.

CO-G-15 Energy Conservation. Support efforts to reduce energy use by increasing energy efficiency in buildings and promoting awareness of energy use.

CO-G-16 Waste Reduction. Seek to reduce overall solid waste by limiting packaging, controlling construction and demolition waste, and promoting composting and recycling.

Implementing Policies
See Chapter 3, Community Design; Chapter 4, Land Use; and Chapter 5, Circulation for related policies that seek to improve air quality and reduce emissions through urban design, land use, and transportation strategies.

CO-I-54 Climate Action Plan for Greenhouse Gas Reductions. Maintain and update the Climate Action Plan that focuses on feasible actions the City can take to reduce greenhouse gas emissions from government, businesses, and residents in Pacifica.

The CAP should:
• Establish a baseline inventory of all known or reasonably discoverable sources of GHGs that currently exist in Pacifica and that existed in 1990; • Projected GHG emissions expected in 2040 under this General Plan and foreseeable municipal operations;
• Set a target for the reduction of GHG emissions, in line with targets established by the California Air Resources Board;
• Present a list of feasible—and to the greatest extent possible, quantifiable—GHG reduction measures to meet the reduction target, in the areas of energy use (in all sectors), transportation and land use, solid waste, water, and education/outreach; and • Establish an implementation plan, including strategies and funding for monitoring and making improvements..

CO-I-55 Green Building. Monitor the effectiveness of the California Green Building Code in bringing about energy efficiency in architectural design and building construction.

CO-I-56 Solar Orientation. When possible, require buildings to be oriented such that the use of passive and active solar strategies is maximized, in order to promote energy efficiency.

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To achieve ideal solar orientation conditions, the long axis of the building should be oriented east-west, within 15 degrees.

CO-I-57 Encourage Solar Power Generation. Promote use of passive and active solar devices such as solar collectors, solar cells, and solar heating systems in buildings and parking areas by incentive programs and streamlining review.

CO-I-58 Clean City Fleet. Establish City budget for clean fuels and electric or hybrid vehicles to replace and improve the existing fleet of gasoline and diesel powered vehicles.

CO-I-59 City Purchasing of Renewable Energy. Pursue opportunities for the City to lower the cost of purchasing and producing renewable energy, such as through Peninsula Clean Energy or other energy provider at the best value to the City.

CO-I-60 ✳Waste Collection. Periodically evaluate the City’s waste collection contract to ensure that Pacifica residents and businesses receive high-quality and cost effective service.

CO-I-61 Waste Reduction and Diversion. Seek to continually reduce Pacifica’s output of solid waste and increase the proportion of waste diverted from landfills, setting targets and monitoring progress.

CO-I-62 Energy Efficiency in Public Buildings. Prepare and implement a plan to increase energy efficiency in existing public buildings.

Measures may include:
• Conduct energy audits for all municipal facilities;
• Retrofit municipal facilities for energy efficiency where feasible and when remodeling or replacing components, including increased insulation, installing green or reflective roofs, installing automated lighting controls, and retrofitting heating and cooling systems.
• Require that any newly constructed, purchased, or leased municipal space meet minimum standards, such as exceeding Title 24 energy efficiency by 20 percent; • Educate employees on energy conservation.

CO-I-63 Wastewater and Water System Efficiency. Maximize the efficiency of City-operated wastewater treatment, water treatment, pumping, and distribution equipment.

CO-I-64 Outdoor Lighting. Establish outdoor lighting performance standards to minimize energy use while ensuring appropriate light levels. These can be met by :
• Greater use of photocells or astronomical time switches;

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• Directional and shielded LED lights;
• Security lights with motion detectors; and
• Prohibitions against continuous all-night outdoor lighting unless needed for security reasons.

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7.6 Cultural Resources and Historic Preservation
One objective of the General Plan is to protect community assets, including sites with historical and cultural significance. Cultural resources include prehistoric or archaeological sites, properties of cultural or historic significance, or paleontological sites. Pacifica has a rich history with regional and statewide significance, as it was home to several Native American villages as well as the site of the discovery of the San Francisco Bay. The Sanchez Adobe Historical Site along San Pedro Creek, which features physical evidence of several significant periods in California history.

HISTORIC CONTEXT
Native Americans had an extensive presence in the Planning Area. When Europeans arrived, the area was home to persons speaking the Costanoan/Ohlone language, and living in and around two villages:

Pruristac, in San Pedro Valley, and Timiigtac, in Calera Valley persons who spoke the Ramaytush dialect of the San Francisco Bay Costanoan/Ohlone Language, and living in and around two villages: Pruristac, in San Pedro Valley, and Timiigtac, in Calera Valley.. he village at Timigtac is the Ramaytush Ohlone people’s ancestral village of origin within the territorial boundaries of the Aramai, an independent tribe of the Ramaytush Ohlone peoples. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering both Baja and Alta California, first sighted San Francisco Bay from a point on Pacifica’s Sweeney Ridge, and camped in San Pedro Valley. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering California, discovered San Francisco Bay from a point on Pacifica’s Sweeney Ridge, and camped in San Pedro Valley. Not long after, Mission San Francisco de Asis (Mission Dolores in present-day San Francisco) was established, and in 1786 the Mission developed an outpost in San Pedro Valley, alongside Pruristac. The Costanoan Ohlone village was wiped outsignificantly affected2829
Mexican independence from Spain was followed by a “secularization” program, and in 1839 the San Pedro mission outpost and its rancho, covering the majority of the Planning Area, was granted to Francisco Sanchez, who built the adobe house that stands today as the oldest structure in San Mateo County. Following his death, the land was divided and the area developed slowly.

In 1905 construction began on the Ocean Shore Railway, which was to connect San Francisco with Santa Cruz. The line was never completed, but operated as far south as Half Moon Bay until 1921, supporting a string of stops in present-day Pacifica including Edgemar, Salada Beach, Brighton Beach, Rockaway Beach, and Tobin (San Pedro Terrace-by-the-Sea.) Tobin, Salada Beach, and Rockaway Beach. The communities surrounding the railway stops, including Edgemar, Sharp Park, Pacific Manor, Vallemar, Rockaway Beach, and San Pedro Terrace-by-the-Sea, grew slowly until the building boom following 29 California Historical Resources Information System (CHRIS), 202109

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World War II. Pacifica incorporated as a City in 1957, as the union of these unincorporated communitiesneighborhoods.

NATIVE AMERICAN CULTURAL RESOURCES
Five Native American archaeological resources have been found and recorded in Pacifica, all classified as habitation sites. Two additional resources contain both Native American and historic-era archaeological value. The Sanchez Adobe, operated by the San Mateo County Historical Association as a historic site, is listed as a’s State Historical Landmark aandnd Point of Historical Interest is listed on the National Register of Historic Places. and operated by the San Mateo County Historical Association as an historical site. The Sanchez Adobe Park, site of the Pruristac village and the San Pedro mission outpost, or asistencia San Pedro y San Pablo of the Mission San Francisco de Asis (Mission Dolores), also is listed in the National Register of Historic Places and the California Register of Historical Resources. The San Mateo County Historical Association recently dedicated in summer 2021 a new building in Sanchez Adobe Park featuring the history and lifeways of the local ARamai-Ohlone who lived in the village of Pruristac. The facility is specifically designed to accommodate tours of school groups.

The Planning Area is rich with the types of environments where Native American cultural resources have been found: permanent and intermittent streams, productive coastal environments, and sheltered locations for permanent habitations, as well as ridgelines, terraces, spurs and saddles. The Planning Area also includes a significant amount of alluvial soil, which in some cases is overlaid by artificial fill, increasing the probability for buried archaeological deposits. There is considered to be a high likelihood that unrecorded Native American cultural resources are present.

Contemporary Native American Resources
As part of the General Plan update process, the Native American Heritage Commission (NAHC) conducted a record search of the sacred lands file in 20192020. The search indicated the presence of Native American cultural resources within the Planning Area. The NAHC response listed six tribes that may have historic ties to the Planning Area, and letters of inquiry were sent to the six tribal representatives; however, no responses were received.

HISTORIC RESOURCES
The Portola Expedition Camp at San Pedro Creek, the Discovery Site, and the Sanchez Adobe are State Historical Landmarks. Tobin Station, one of two remaining structures from the Ocean Shore Railroad, is a State Point of Historical Interest.

A Master Plan for the Sanchez Adobe Historical Site, completed in 2007 aims to increase visitation and improve visitors’ educational experience while ensuring that the site is preserved for future generations.

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

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In 2005, the Pacifica Historical Society began restoration of the Little Brown Church to establish it as the Pacifica Coastside Museum, which opened in 2015. The Historical Society also owns the last remaining car from the Ocean Shore Railroad, and has stated its interest in moving the railcar alongside tobe close to the Little Brown Church, preferably in the parking lot at Salada Avenue and Francisco Boulevard.. The City considered is considering this as the potential location of the railcar in the City-owned Salada Avenue parking lot as part of a Civic Center master plan discussed by the City Council in 2021. All of theNine different types oflocal historic resources landmarks as specifically designated in the Historic Preservation Ordinance of 1985. They are listed below in Table 7-5 and also shown in in Pacifica are shown in Figure 7-46 and listed in Table 7-5.

INSERT Figure 7-6: Historic and Cultural Resources
INSERT Photo 16
In 1769, an expedition led by Gaspar de Portola discovered sighted San Francisco Bay from a point on Pacifica’s Sweeney Ridge.

INSERT Photo 17
The Sanchez Adobe, built in 1842, is the oldest surviving structure in San Mateo County. The site was once the Costanoan village of Pruristac.

INSERT Photo 18
The Little Brown Church, built in 1910, has been restored by the Pacifica Historical Society.

Table 7-5: Historic Sites in Pacifica
Site Address
Year
Constructed
National Register Historic Landmarks
Little Brown Church 1850 Francisco Boulevard 1910
National Register of Historic Places
San Francisco Bay Discovery Site Sweeney Ridge NA
Sanchez Adobe / Pruristac / San Pedro y San
Pablo
1000 Linda Mar Boulevard 1842
California Historical Landmarks
Portola Expedition Camp at Pedro Creek Southeast of SR 1 and Crespi Drive
NA
San Francisco Bay Discovery Site Sweeney Ridge NA
Sanchez Adobe / Pruristac / San Pedro y San
Pablo
1000 Linda Mar Boulevard 1842
California Point of Historical Interest
Tobin Station-Ocean Shore Railroad Shoreside Drive, Pedro Point Local Landmarks Identified in Pacifica Zoning CodeHistoric Preservation

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Table 7-5: Historic Sites in Pacifica
Site Address
Year
Constructed
Ordinance
Anderson's Store 220 Paloma Avenue 1907
Little Brown Church 1850 Francisco Boulevard 1910
San Pedro Schoolhouse 170 Santa Maria Avenue 1914
Sanchez Adobe / Pruristac / San Pedro y San
Pablo1
1000 Linda Mar Boulevard 1842
Sharp Park Golf Course Clubhouse Sharp Park Road & SR 1 1932 Vallemar Station 2125 Coast Highway 1906
Private residence 165 Winona Avenue 1908
Private residence 185 Carmel Avenue 1910
Dollaradio Station (private residence) 100 Palmetto Avenue 1926 Sources: California Historical Resources Information System, 202109, City of Pacifica, 2020.

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

POLICIES
Policies included in both the General Plan and Local Coastal Land Use Plan are indicated with a ✳.

Guiding Policies
CO-G-17 ✳Historic and Cultural Sites. Conserve designated historic and cultural sites and structures that help define Pacifica’s identity and character and increase public awareness and appreciation of them.

CO-G-18 ✳Ensure Mitigation. Require mitigation for any new development that would adversely affect archaeological or paleontological resources.

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

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CO-I-66 Integration of Historic and Cultural Resources with City Identity. Incorporate historic and cultural resources into the City’s marketing and branding efforts. Specific initiatives might include:
• Identifying historic sites in the City’s wayfinding scheme; • Giving priority to streetscape and public realm improvements around historic structures that are visitor destinations;
• Hosting/supporting events and educational programs that feature Pacifica’s history and promote its relevance; and
• Linking related historical sites through the City’s open space and trail system.

CO-I-67 Public Agency Support for Local Historic Sites. Seek support from public agencies, such as GGNRA, for local historic preservation programs for designated sites.

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

CO-I-68 ✳Resource Impact Mitigation. Ensure that new development analyzes and avoids potential impacts to historic, archaeological, and paleontological resources by:
• Requiring a records review for development proposed in areas that are considered historically, archaeologically or paleontologically sensitive; • Requiring pre-construction surveys and monitoring during any ground disturbance for all development in areas of historical, archaeological, or paleontological sensitivity; and • Implementing appropriate measures as a condition of project approval—such as avoidance, preservation in place, and excavation,—to reduce or avoid impacts.

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

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

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CO-I-70 ✳Native American Sites. Work with local Native American tribes to protect recorded and unrecorded cultural and sacred sites, and educate developers and the community-at-large about the connections between Native American history and the environmental features that characterize the local landscape.

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

ENVIRONMENTAL JUSTICE
The U.S. Environmental Protection Agency (US EPA) defines environmental justice as:
"The fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Fair treatment means that no group of people should bear a disproportionate share of the negative environmental consequences resulting from industrial, governmental, and commercial operations or policies.”
Senate Bill 1000 (SB 1000), the Planning for Healthy Communities Act, mandates that cities and counties prepare an EJ Element or integrate EJ-related policies into other elements when both of the following conditions apply: The concurrent adoption or next revision of two or more other General Plan elements, and when a local jurisdiction identifies one or more disadvantaged communities (DACs) within its General Plan planning area.

SB 1000 specifies the California Communities Environmental Health Screening Tool 4.0 (CalEnviroScreen) as the primary screening method for identifying disadvantaged communities.

Developed by the California Environmental Protection Agency (CalEPA), CalEnviroScreen uses environmental, health, and socioeconomic information to produce scores for every census tract in the state, thereby identifying communities that are most vulnerable to pollution’s effects. The score assigned to each census tract is a product of exposure to pollution, adverse environmental effects caused by pollution, presence of sensitive populations (i.e. those with asthma,cardiovascular disease, or low birthweight infants), and socioeconomic factors that increase vulnerability (i.e. low household income, low educational attainment, and unemployment). A disadvantaged community is defined as one which scores in the top 25th percentile of CalEnviroScreen’s cumulative score.

Using these criteria, there are no census tracts within the Planning Area that are identified as disadvantaged communities.30 All Pacifica census tracts score in the bottom quartile for pollution burden.

However, Census tract 6030, which includes east and west Sharp Park, ranks in a higher statewide percentile (42nd) for sensitive populations relative to other Pacifica census tracts, which rank, on average, 30 CalEnviroscreen 4.0, 2021

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in the 20th to 30th percentile statewide. These populations could be most vulnerable to any exacerbated health effects due to increased pollution burden or climate change.

Although the City is not required by SB 1000 to prepare an EJ Element or integrate EJ-related policies into other elements, the General Plan does integrate EJ related policies in Chapters 7 and.this chapter.

Achieving environmental justice also includes addressing procedural inequities and geographic inequities.

Procedural inequities might include “stacking” commissions or committees with individuals who ignore the interests of minority and low-income residents, holding meetings at times and places that minimize the ability of low-income residents to participate, using English-only communications when non-English speaking populations may be affected by land use decisions, and requiring lower levels of mitigation for projects affecting low-income and minority populations. Geographic inequities might include providing fewer public services, transit services, and parks for minority and low-income residents than for middleand upper-income residents.

Guiding Policy
CO-G-19 Environmental Justice. Strive to implement processes and procedures that promote environmental justice in support of the Coastal Commission’s environmental justice policy.

Implementing Policies
CO-I-71 Inclusive Engagement. Expand notification efforts for major policy documents and projects within Pacifica’s Coastal Zone to underrepresented communities outside of Pacifica.

CO-I-72 Removal of Barriers to Public Participation. Implement efforts to remove barriers that may prevent underrepresented communities from public participation opportunities. Efforts should be made to provide a welcoming, understandable and respectful atmosphere, and to be considerate of the timing, location, and accessibility of any meeting to accommodate the underrepresented communities.

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INSERT Photo 01 DSC_0060
Ensuring the safety of community members through protection from hazards is an essential service of public agencies and a critical priority for maintaining community health and welfare. The purpose of the Safety Element is to establish goals and policies to mitigate the potential impacts from natural and manmade hazards that pose a threat to public health and safety. Specifically, this chapter addresses seismic and geologic hazards, flooding, fire, and other hazards, as well as related aspects of law enforcement, emergency preparedness, and coordinated response measures.

8.1 Seismic and Geologic Hazards
The Planning Area lies within the geologically complex region of California known as the Coast Range geomorphic province. Much of the Coast Range province is composed of marine sedimentary deposits and volcanic rocks that form northwest trending mountain ridges and valleys, running subparallel to the San Andreas Fault Zone. West of the San Andreas Fault lies the Salinian Block, a granitic core that extends from the southern end of the province to north of the Farallon Islands.

SEISMIC HAZARDS
Earthquakes can cause surface rupture from faulting or seismically induced effects, such as ground shaking, liquefaction, and landslides. The challenge is to:
• Minimize Earthquake-Related Hazards, Liquefaction, and Landslides. The San Andreas Fault, which traverses the northeast corner of Pacifica, is active and capable of causing a large earthquake. Areas located on or immediately adjacent to the mapped fault traces must be investigated prior to any development to ensure that fault rupture hazards be avoided or minimized.

Areas located within the alluvial valleys could have a high potential for liquefaction. Site-specific geotechnical investigations can confirm the presence of liquefiable materials and provide foundation design criteria to mitigate the potentially damaging effects of liquefaction.

The Planning Area also includes slopes that are susceptible to landslides, especially areas with greater than 50 percent inclines. Geotechnical engineering can typically overcome the challenges of development on steep terrain through drainage improvements, anchoring foundations in deeper materials, re-grading slopes, and other methods.

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Modern seismic activity within the Coast Range continues to be associated with movement along the San Andreas system of faults. Regionally, this fault system is the boundary between large sections, or plates, of the earth’s crust known as the North American Plate and Pacific Plate. The Bay Area is considered an area of high seismic activity, with an estimated 72 percent probability of an earthquake of magnitude 6.7 or higher occurring in the region over the next 30 years.
1 The San Andreas Fault is the principal strike-slip boundary between the Pacific plate to the west and the North American plate to the east. Its main trace trends northwest through the Santa Cruz Mountains and the eastern side of the San Francisco Peninsula. Between Pacifica and San Mateo, Crystal Springs Reservoir and San Andreas Lake clearly mark the rupture zone. The USGS Working Group on California Earthquake Probabilities indicates there is a 22 percent likelihood of the San Andreas Fault generating earthquakes of M 6.7 or greater in the Bay Area.

The Hayward Fault trends to the northwest within the East Bay, extending from San Pablo Bay in Richmond, 60 miles south to San Jose. Although large earthquakes on the Hayward Fault have been rare since 1868, there is a 14.3 percent chance a large earthquake could occur on the Hayward fault by 2045 .2 The Calaveras Fault, located in the eastern San Francisco Bay region, trends along the eastern side of the East Bay Hills, west of San Ramon Valley, down into the western Diablo Range, and eventually joining the San Andreas Fault Zone south of Hollister. The Calaveras Fault has been the source of numerous moderate magnitude earthquakes but the probability of a large earthquake is much lower (7.4 percent by 2045) than on the San Andreas or Hayward faults.3
Seismic Hazard Zones
The Seismic Hazards Mapping Act (SHMA) established the requirement to identify and map areas prone to earthquake hazards of liquefaction, earthquake-induced landslides and amplified ground shaking. The purpose of the SHMA is to reduce the threat to public safety and to minimize the loss of life and property by identifying and mitigating these seismic hazards. The City is required to use the official California Geological Survey Seismic Hazard Zone Maps in their land use planning and building permit processes.

As shown in Figure 8-1, a majority of the Planning Area is prone to either of these hazards, with liquefaction zones following the alluvial drainage zones and landslide zones following areas with steep slopes. More information on liquefaction and landslides can be found in later sections.

Fault Rupture
Fault rupture is the surface displacement of the earth’s surface due to the movement along a fault associated with an earthquake. Ground displacement is generally experienced on or within the immediate vicinity of the mapped fault trace. The Alquist-Priolo Earthquake Fault Zoning Act of 1972 established the 1 United States Geological Survey (USGS) Working Group on California Earthquake Probabilities (WG07). Fact Sheet 2015- 3009, UCERF3: A New Earthquake Forecast for California’s Complex Fault Systemhttps://pubs.usgs.gov/fs/2015/3009/pdf/fs2015-3009.pdf 2 Ibid.
3 Ibid.

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requirement to regulate development within Earthquake Fault zones associated with active faults.

Development is feasible but requires detailed geologic and seismic evaluations by certified professionals prior to approval of a building permit. An Alquist-Priolo fault hazard zone associated with the San Andreas Fault is located within the Planning Area, as shown in Figure 8-1.

Ground Shaking
Ground movement during an earthquake can vary depending on the overall magnitude, distance to the fault, focus of earthquake energy, and type of geologic material. The composition of underlying soils, even those relatively distant from faults, can intensify ground shaking. The strongest ground shaking anticipated to occur in Pacifica would come from the San Andreas Fault, and could cause strong to very violent ground shaking.

Liquefaction
Liquefaction is a transformation of soil from a solid to a liquefied state during which saturated soil temporarily loses strength resulting from the buildup of excess pore water pressure, especially during earthquake-induced cyclic loading. Soil susceptible to liquefaction includes loose to medium dense sand and gravel, low-plasticity silt, and some low-plasticity clay deposits. Four kinds of ground failure commonly result from liquefaction: lateral spread, flow failure, ground oscillation, and loss of bearing strength.

Liquefaction and associated failures could damage foundations, roads, underground cables and pipelines, and disrupt utility service. The depth to groundwater influences the potential for liquefaction, in that sediments need to be saturated to have a potential for liquefaction.

As shown in Figure 8-1, Liquefaction Zones identify where the stability of foundation soils must be investigated, and countermeasures undertaken in the design and construction of buildings for human occupancy. Statutes require that cities and counties use these zones as part of their construction permitting process.

The Liquefaction map (Figure 8-2) shows further detail. The majority of the Planning Area has a very low potential to experience liquefaction, although areas surrounding some of the alluvial drainages (i.e., San Pedro Creek Valley and Sanchez Creek Valley) contain some areas of very high potential. Medium liquefaction potential exists in many low-lying neighborhoods, including West Edgemar-Pacific Manor, West Sharp Park, Rockaway Beach and Quarry, and parts of Pedro Point, as well as in the valley neighborhoods along San Pedro, Rockaway, and Calera creeks. 4 INSERT Figure 8-1: Seismic Hazards
INSERT Figure 8-2: Liquefaction Susceptibility
4 Association of Bay Area Governments (ABAG). Liquefaction Susceptibility http://www.abag.ca.gov/bayarea/eqmaps/liquefac/liquefac.html. 2003.

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Tsunami and Seiche
A tsunami is a wave generated by abrupt movement of the seabed, which can occur as an earthquake or after a significant landslide. By contrast, seiche is a standing wave in an enclosed body of water. Within Pacifica, only Laguna Salada might be subject to seiche, but the potential for significant risk is low.

Dam Failure
There are no dams within or above Pacifica, and therefore the city is not at risk from a seismically induced dam failure. However, water tanks located in the hills above populated areas could burst and inundate areas below due to a seismic event.

SLOPE FAILURE AND EROSION
Slope Failure
Slope failures, commonly referred to as landslides, include many phenomena that involve the downslope displacement and movement of material, either triggered by static (i.e., gravity) or dynamic (i.e., earthquake) forces. The geology, structure, and amount of groundwater in the slope affect slope failure potential, as do external processes (i.e., climate, topography, slope geometry, and human activity). Slope failure may occur on slopes of 15 percent or less; however, the probability is greater on steeper slopes that exhibit old landslide features such as scarps, slanted vegetation, and transverse ridges. Landslide-susceptible areas are characterized by steep slopes and downslope creep of surface materials, and are more common in zones of active faulting.

Figure 8-1 shows seismically-induced landslide zones in the Planning Area. Landslide Zones identify where the stability of hillslopes must be evaluated, and countermeasures undertaken in the design and construction of buildings for human occupancy. Statutes require that cities and counties use these zones as part of their construction permitting process.

Figure 8-3a shows a summary of the distribution of rainfall-induced landslides evident in the landscape of the San Francisco Bay Region. There are three slope failure threat categories: Mostly Landslides, Few Landslides, and Not Landslide prone.5 Areas identified as “Mostly Landslides” cover areas with the largest and most concentrated landslides; “Few Landslides” indicates smaller, more scattered landslides; and “Not Landslide Prone” indicates flat land or other land unlikely to have a landslide event. Steep slopes on Mori Point, Sweeney Ridge, Cattle Hill, Gypsy Hill, and San Pedro Mountain are identified as likely sites of slope failures, as are small portions of areas in or near development in the Pedro Point and Fairmont neighborhoods and along the west side of Skyline Boulevard. Figure 8-3b shows areas where landslides have previously occurred in the Planning Area.

Subsidence
Subsidence—the sinking of a portion of the ground surface—can occur from immediate settlement, consolidation, shrinkage of expansive soil, and liquefaction. Earthquakes could also cause subsidence and it can also occur due to excess extraction of groundwater. 5 United States Geological Survey (USGS), Open File Report 97-745, San Francisco Bay Landslide Folio, http://pubs.usgs.gov/of/1997/of97-745/. 1998.

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Portions of Pacifica are underlain by relatively clean, poorly consolidated granular material, such as sand.

In places there are perched layers of groundwater so that conditions may exist for liquefaction. Also, where materials are poorly consolidated, there may be ground subsidence or other forms of ground failure. Because the conditions at any particular site control the potential for any type of ground failure, only specific geotechnical investigations, including subsurface testing, can provide a basis for assessing such hazards.

INSERT Photo 02 devils_slide
Devil’s Slide has a long history of slope failures and rock slides that have resulted in the construction of a tunnel bypass.

Soil Erosion
Erosion is the wearing away of soil and rock by processes such as mechanical or chemical weathering, mass wasting, and the action of waves, wind and underground water. Excessive soil erosion can eventually lead to damage of building foundations and roadways. The parts of the Planning Area where soils are most susceptible to erosion caused by wind or rainfall include the northern slope of Mori Point; upper Sharp Park; Shamrock Ranch; and along San Pedro Creek in San Pedro Valley County Park.

Bluff erosion is commonplace along much of the Pacifica coastline. In 2009-10, erosion on the northern coast of Pacifica resulted in the evacuation of two apartment buildings in the 300 block of Esplanade Avenue. Further severe weather in 2015 led to the City-mandated demolition of these buildings in 2016 to prevent their collapse onto the beach below. The property owner demolished a 12-unit apartment building at 330 Esplanade Avenue and City demolished two 20-unit apartment buildings in common ownership at 310 and 320 Esplanade Avenue. Short-term erosion hazards are generally mitigated through best management practices and use of soft stabilization techniques. With sea level rise, there is potential for more serious long-term coastal erosion, which could be a critical challenge within the Planning Area.

Policies supporting coastal resilience against sea level rise impacts are provided later in this chapter.

Within the Coastal Zone, the City requires new development to be set back from coastal bluffs enough to accommodate a 100-year event, whether caused by seismic, geotechnical, or storm conditions (unless this limitation makes a property undevelopable). Areas determined by the study to be unsuitable for development shall be set aside for permanent environmental protection as part of any development.

Similarly, a site stability survey is required for any new development proposed on or adjacent to coastal bluffs or the coastline. New development that would require the use of seawalls or other shoreline alterations for protection either now or in the future shall not be permitted unless this would make the property undevelopable. New coastline alteration is permitted only where necessary to protect existing development or public resources, and must minimize adverse impacts to natural coastal processes.

Increased Coastal Erosion from Potential Sea Level Rise The potential for increased coastal erosion from sea level rise has serious implications for Pacifica. Areas of the Sharp Park Golf Course, the Rockaway Beach district, and the West Linda Mar and West Sharp Park neighborhoods could be inundated. Meanwhile, coastal erosion processes that have caused damage along the high bluffs of Pacifica’s northern neighborhoods would likely increase in magnitude.

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Sea level rise resulting from global climate change is projected to cause more extensive erosion of beaches, dunes, bluffs and cliffs. The 2009 Pacific Institute study of the impacts of sea level rise on the California Coast developed erosion models for dune and cliff/bluff backshore environments. Mean lateral erosion of dunes is estimated at 115 to 116 meters by 2025, 119 meters to 128 meters by 2050. Bluffs, meanwhile, are projected to have eroded by 8 meters to 9 meters by 2025, with geology, wave exposure, and bluff toe elevation all playing important roles in producing variation. 6 These models indicate that there could be
new risks of erosion along the length of Pacifica’s coastline in areas that are not currently exposed to wave action erosion, which could impact all of the coastal neighborhoods and coastal habitats.

POLICIES
Policies included in both the General Plan and Local Coastal Land Use Plan are indicated with a ✳.

Guiding Policies
SA-G-1 ✳Reduce Risk. Minimize risks of property damage and personal injury posed by geologic and seismic hazards.

Implementing Policies
SA-I-1 ✳Fault Zone. New development shall be sited and designed to minimize risks from seismic events. Buildings for human occupancy shall avoid surface traces of active faults, consistent with the Alquist-Priolo Earthquake Fault Zone Act and other relevant state laws. (See the Seismic Hazards map, Figure 8-1).

SA-I-2 ✳Development in Hazardous Areas. Prohibit development in areas of mostly landslides or high or very high liquefaction risk as shown in Figure 8-2, or on slopes steeper than 35 percent, unless detailed site investigations ensure that risks can be reduced to acceptable levels and the structure will be protected for its design life.

SA-I-3 ✳Real Estate Disclosure. Require real estate transactions, development approval processes, and property titles to declare known or suspected seismic or geologic hazards on a property, including Alquist-Priolo Fault Zones and areas suspected of high or very high risk of liquefaction, subsidence, or landslide.

SA-I-4 ✳Code Enforcement. Continue to maintain and enforce appropriate building standards to ensure new development is designed to meet current safety standards associated with seismic activity.

SA-I-5 ✳Seismic Rehabilitation Flagging. Identify and catalogue structures that may be subject to serious structural damage in the event of a major earthquake, and provide information to 6 Heberger, M., H. Cooley, P. Herrera, P.H. Gleick, E. Moore of Pacific Institute. The Impacts of Sea Level Rise on the California Coast. A paper from the California Climate Change Center. May 2009.

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property owners on ways to pay for rehabilitation or retrofit of existing buildings to minimize the potential for damage from an earthquake.

SA-I-6 ✳Restrictions on Mitigation Measures. Prohibit development which would require mitigation measures for potential geotechnical hazards if those measures could adversely affect surrounding property, including the use of public rights-of-way or adversely affect public health, safety, and welfare.

SA-I-7 ✳Erosion Prevention. Require erosion prevention of hillside areas by revegetation or other acceptable methods.

SA-I-8 ✳Geotechnical Studies. Within the Coastal Zone and hillside areas, continue to require geotechnical site investigation for proposed development on sites located in any of the following areas, prior to allowing site development:
• On slopes greater than 15 percent.
• In areas showing evidence of landslides or landslide potential. • In areas showing evidence of ground shaking or earth movement • Within 50 feet of a coastal bluff
• Within sand dune areas.

Geotechnical studies shall identify any geologic hazards affecting the proposed project site, any necessary mitigation measures, and a statement of the site’s suitability for the proposed development and whether or not it will be safe from geologic hazard for its expected life. The study shall identify net developable areas, if any, based on landslide or ground shaking potential and/or erosion risk. Impacts from the development, such as those resulting from increased water runoff, shall also be determined. Such studies must be signed by a licensed Certified Engineering Geologist or Geotechnical Engineer and are subject to review and approval by City staff and/or contracted employees. As detailed in Policy SA-I-2, further technical reports may be required for applicable projects.

SA-I-9 ✳Maintain Restrictions on Hazardous Areas. Continue enforcing the existing Coastal Zone Combining District and Hillside Preservation District regulations that restrict development in hazardous areas where access is impractical and areas prone to hillside and coastal erosion, landslides, seismic shaking, tsunami inundation, or flooding.

SA-I-10 ✳Soil Study. Require any geotechnical studies to include study of expansive and creeping soils, as well as analysis of erosion, seismic, tsunami, and other geotechnical hazards and make recommendations, as warranted.

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SA-I-11 ✳Grading and Drainage Plans. Continue to require a grading and drainage plan for proposed development requiring a coastal development permit and a grading permit. The Plan should demonstrate how the project will maintain natural surface drainage and existing vegetation to the greatest extent feasible, by minimizing alteration of natural topography and removal of existing trees and vegetation; stabilizing cut-and-fill surfaces with native vegetation; restricting the movement of heavy equipment and machinery; and other means.

Prohibit development-related grading and vegetation clearance on slopes steeper than 35 percent. Driveways and utilities may be allowed in the case that there is no less environmentally damaging alternative for providing access to the building site.

SA-I-12 Bluff Drainage and Erosion. The City will pursue feasible funding mechanisms to investigate areas that may be significantly contributing to groundwater flows to the bluffs and determine whether improving drainage and/or reducing irrigation could reduce bluff erosion. Measures to improve drainage and reduce over-watering shall be communicated to the public and property owners as part of existing water conservation outreach programs, and included as conditions on new development where applicable.

SA-I-13 ✳ Water Tank Rupture. Work with the NCCWD to determine areas potentially affected by flooding from ruptured water tanks in the event of a seismic event and inform property owners.

SA-I-14 ✳ Geologic Hazard Abatement District. Amend the Municipal Code to include provisions for formation of geologic hazards abatement district for coastal bluffs and hillside areas at risk of landslides in Pacifica to enable cooperative efforts among property owners for protection of coastal bluffs from erosion and improvement and maintenance of drainage and protective infrastructure.

The Geologic Hazard Abatement District (GHAD) is a potentially useful tool to effectively abate a landslide hazard that crosses property boundaries. It is a mechanism that responds to the physical realities of landslides, and allows property owners to cooperate in solving a common problem. It removes much of the stigma of legal liabilities among adjacent landowners and allows them to cooperate rather than litigate. It also provides for a cost-effective solution, requiring only one geotechnical engineering firm and one plan to solve the problems of several landowners. The City may require the establishment of GHADs as a condition for new development proposed in areas of known bluff erosion or geologic hazard, such as areas identified in Figure 8-3a of the proposed General Plan as "mostly landslides." The City may consider identifying where GHADs are appropriate or necessary.

INSERT Photo 03 DSCN8065
Geotechnical studies are required for proposed development on steep slopes.

INSERT Photo 04 DSCN8076
New development is required to be set back from coastal bluffs enough to accommodate a 100- year event, whether caused by seismic, geotechnical, or storm conditions.

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INSERT Photo 05 IMG_178
New development in the Coastal Zone must not require the construction of riprap or other protective devices that would substantially alter natural landforms.

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

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

SA-I-16 ✳Accessory Structures in Coastal Zone. Amend the Zoning Ordinance to require new accessory structures within the Coastal Zone to be constructed so they can be easily relocated should they become threatened by erosion.

This policy does not apply to accessory dwelling units (ADUs), which are not considered accessory structures as characterized in the City’s Zoning Regulations. ADUs are habitable structures, required to be constructed/installed on permanent foundations, and which are not readily relocated in the same manner as a shed or similar accessory structure.

8.2 Flooding and Drainage
Flooding has been an ongoing issue for low-lying areas of Pacifica, and likely will continue to be a challenge in the future, including possible inundation from a tsunami wave. Strategies to minimize flooding impacts will include limiting development in flood-prone areas and incorporating Federal Emergency Management Agency (FEMA) guidelines and suggested mitigation activities into the City’s plans and procedures for managing flood hazards.

FLOOD ZONES
Flood hazards mapped by FEMA to support the development of Flood Insurance Rate Maps (FIRMs) generally identify areas of greater flood risk (100- and 500-year events) in the lower reaches of the main stream channels, and the risk of coastal flooding along the shoreline. Flood zones based on the FIRMs are

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shown in Figure 8-4. The FIRMs represent the best available maps of flood hazard areas in Pacifica.

Additional maps of flood hazard areas prepared by the U.S. Army Corps of Engineers and the California Department of Water Resources are not available for the city. The City’s annex to the Multi-jurisdictional Local Hazard Mitigation Plan (MJ-LHMP) includes additional information on past flooding events and actions to mitigate flooding risk in Pacifica.

Areas of flood risk include:
• Broad flood inundation in several parts of Sharp Park Golf Course, the Rockaway Beach district, and in the Linda Mar neighborhood along San Pedro Creek. • More narrowly confined flood hazards along the creeks; limiting potential flooding in these areas.

For example, along Milagra Creek mapped flood hazards are typically within the active channel.

INSERT Figure 8-4: Flood Zones
San Pedro Creek has a history of significant flooding in the Linda Mar area. The low area of Linda Mar has pump systems to provide drainage to the ocean, but these systems can be overwhelmed during high flow/tide events. An area of West Linda Mar was removed from high flood risk classification with the completion of the San Pedro Creek flood protection project.

COASTAL FLOODING
Pacifica can also experience flooding from coastal sources, which occurs as some combination of high tides, large wind-driven waves, storm surge, and/or tsunami wave. Areas with the potential for coastal flooding are the low lying areas along the coast, including the Sharp Park Golf Course/Laguna Salada area and the residential and commercial area in West Linda Mar near the mouth of San Pedro Creek.

The only section of coastline protected by levees is the Sharp Park Golf Course area. However, drainage from Sanchez Creek and Laguna Salada to the ocean can be insufficient to prevent lowland flooding during high tide/high flow events. A seawall/revetment structure protects the area north of the Sharp Park Golf Course, generally along Beach Boulevard, including the Pacifica Pier. This structure has required maintenance to repair areas where beach erosion has undermined it.

INSERT Photo 8-06 IMG_0230
Flood hazards in West Linda Mar have been reduced by the San Pedro Creek flood protection project, which included dune restoration and the creation of a drainage swale.

INSERT Photo 8-07 DSCN8226
Sharp Park Golf Course is protected by a levee. Drainage from Sanchez Creek and Laguna Salada to the ocean can be insufficient to prevent lowland flooding during high tide/high flow events.

INSERT Photo 8-08 IMGP2859
A seawall/revetment structure protects the West Sharp Park area. The structure has required maintenance to repair areas undermined by beach erosion.

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Shoreline Protection Programs
In the early 1990s, the City of Pacifica, the California Coastal Conservancy, and the Pacifica Land Trust collaborated to improve steelhead trout habitat and preserve the sandy beach at Pacifica/Linda Mar State Beach, with the removal of vulnerable structures along the shore. The stabilization methods were used to expand and enhance the tidally influenced wetlands at the mouth of San Pedro Creek and restore more than 1900 feet of eroding creek banks. This restoration both enhanced steelhead trout habitat and achieved 100-year flood protection for the nearby community.

To address the remaining flood threat to homes and businesses, the City also removed the most vulnerable structures. In 2002, the City partnered with the Pacifica Land Trust and the California Coastal Conservancy to purchase two homes and their surrounding acreage and delivered 4,000 cubic yards of sand to rebuild dunes and restore four acres of beach and the nearby estuary.

In addition, the City is continuing to maintain and improve the existing seawall and revetment originally constructed in 1962 at Rockaway Beach. Repairs in the past have consisted of retrieval of displaced riprap, importation of additional rip-rap, and repair of the revetment. Other revetments are placed along the beaches of the Planning Area and a seawall has been constructed at Beach Boulevard between Clarendon Road and the northern terminus of Beach Boulevard. Existing shoreline protection structures are shown on the Slope Failure and Coastal Erosion map, shown in Figure 8-3.

In fall 2020, the City of Pacifica initiated the Beach Boulevard Infrastructure Resiliency Project, an infrastructure protection and improvement project that aims replace the current seawall and outdated infrastructure while building climate resilience into the most vulnerable segment of the City of Pacifica’s shoreline. The project is considered critical to the public health and safety of the citizens and visitors in and around the historic West Sharp Park neighborhood and serves to create a multi-benefit solution to protect public infrastructure, recreational activities, numerous homes, businesses, and the community at large, from further impacts due to continued coastal erosion.

Tsunami
A tsunami can occur after an earthquake significant landslide falling into the ocean. Coastal flooding, potentially severe damage, and threats to human health and safety can result from a tsunami. Recorded tsunami runup magnitude is generally lower at Pacifica than other locations from San Francisco to Monterey, likely due to offshore bathymetry and shoreline alterations along the city. Tsunami evacuation zones occur in the West Sharp Park neighborhood and Sharp Park Golf Course/Laguna Salada area, Lower Calera Creek and portions of Rockaway Beach, and the residential and commercial area at Linda Mar near the mouth of San Pedro Creek.

Tsunamis can reach Pacifica from several sources, including ‘far-field’ sources throughout the Pacific Ocean, a substantial earthquake along the Cascadia Subduction Zone in northern California north to Vancouver Island, movement along local fault lines, and local coastal landslides. Travel times, the degree of warning, and the magnitude of the wave will vary depending on the source and initial strength of the tsunami-generating event. Earthquakes along the Cascadia Subduction Zone are likely the most hazardous to Pacifica because of the potential for very large wave generation, and a relatively short travel time (on the order of one to three hours). However, smaller events along local faults could result in a wave that reaches Pacifica with essentially no warning time.

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San Mateo County has an established emergency proposal for tsunamis. As part of this program, the City recently installed a tsunami warning system, consisting of three solar powered alarm towers. One is located in the Sharp Park neighborhood, the second is located in the Rockaway Beach neighborhood, and the third tower stands at Pacifica State Beach. This system links into a San Mateo County alert system that can reach email and cell phones.

Increased Coastal Flooding from Potential Sea Level Rise Sea level rise resulting from global climate change has the potential to alter the frequency and magnitude of coastal flood events in Pacifica. Estimates of sea level rise vary, so trends and potential increases are typically reported in ranges. Present projections used by the State of California are for between 40 and 55 inches by 2100, depending upon the emission scenario used.7 A 2009 report from the Pacific Institute funded by a consortium of California state agencies has developed approximate mapping to indicate potential increases in the 1 percent annual chance of coastal inundation, assuming a 55.1-inch rise in sea level by 2100.
8 This mapping suggests that areas of West Linda Mar, lower Pedro Point, Rockaway Beach, and West Sharp Park neighborhoods, as well as the Sharp Park Golf Course, could be vulnerable to increased coastal flooding.

POLICIES
Policies included in both the General Plan and Local Coastal Land Use Plan are indicated with a ✳.

Guiding Policies
SA-G-2 ✳Development in Hazardous Areas. Protect new development in 100-year floodplains and tsunami hazard zones with flood damage prevention programs.

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

Implementing Policies
SA-I-17 ✳Floodplain Management. Continue to manage floodplains through zoning, development requirements, and ordinances, and take other actions as required by FEMA, in order to remain a participant of the National Flood Insurance Program. 7 Sea-Level Rise Task Force of the Coastal and Ocean Working Group of the California Climate Action Team, State of California Sea-Level Rise Interim Guidance Document, October 2010. 8 Pacific Institute, The Impacts of Sea Level Rise on the California Coast. A paper from the California Climate Change Center.

Available online at: http://www.pacinst.org/reports/sea_level_rise/. 2009.

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SA-I-18 ✳Flood Map Review. Periodically review maps prepared by FEMA and the State Department of Water Resources to identify changes in mapping of areas subject to flooding and amend the General Plan, Municipal Code, or Local Coastal Program as warranted.

SA-I-19 ✳NDPES Enforcement. Enforce NPDES permits, as well as the San Mateo Countywide Water Pollution Prevention Program, to mitigate potential flooding risks by slowing the release of stormwater from development sites into drainage channels..

SA-I-20 ✳Flood Hazard Reduction. Continue to comply with the Flood Damage Prevention Ordinance in the Municipal Code.

SA-I-21 ✳Flood Insurance. Inform households and businesses located in flood-prone areas about opportunities to purchase federal flood insurance.

SA-I-22 ✳Flood Control Maintenance. Regularly maintain flood control structures, including, but not limited to drainage channels, pipes, culverts, and stream beds.

SA-I-23 ✳Flood Control Structures. Require flood control devices that alter streams to incorporate best mitigation measures whenever feasible, and only permit them where no other method for protecting existing structures in the floodplain is feasible and where such protection is necessary for public safety or to protect existing development.

SA-I-24 ✳Storm Drainage Impact Assessment. Require developers to provide an assessment of a project’s potential impacts on the local storm drainage system as part of the development review process.

If development is found to have a negative impact on storm drainage, the City should require applicable and effective mitigation measures, such as the creation of permanent or temporary detention or retention basins, provision of additional landscaped areas and green roofs, installation of pump stations, and the use of permeable paving in driveways, walkways and parking areas.

SA-I-25 ✳No Adverse Impact Approach. Update the Flood Hazard Reduction regulations to establish a “No Adverse Impact” standard to floodplain and coastal development.

In essence, No Adverse Impact floodplain management takes place when the actions of one property owner are not allowed to adversely affect the rights of other property owners. No building permits should be issued for projects that increase the potential for flooding or erosion on- or off-site, degrade water quality, or increase potential public service costs for

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things such as emergency personnel and storm-water management, unless such projects are designed and completed in such a way that they will not:
• pose a threat to public safety; and
• substantially increase flood or storm damage risk to public or private property.

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

SA-I-27 ✳Critical Facilities Location. Site critical public facilities including hospital and healthcare facilities, emergency shelters, police and fire stations, and emergency communications facilities outside of the tsunami evacuation zone and 100-year flood plains.

8.3 Coastal Resilience
Sea level rise resulting from global climate change has the potential to alter the frequency and magnitude of coastal hazards in Pacifica. Sea level rise increases the risk of flooding, coastal erosion, and saltwater intrusion into freshwater supplies, which, if left unmanaged, have the potential to threaten many of the resources that are integral to the California coast, including coastal development, coastal access and recreation, habitats (e.g., wetlands, coastal bluffs, dunes, and beaches), coastal agricultural lands, water quality and supply, cultural resources, community character, and scenic quality. Estimates of sea level rise vary, so trends and potential increases are typically reported in ranges. Present projections used by the State of California estimate between 40 and 55 inches by 2100, depending upon the emission scenario used.

The City of Pacifica received a Local Assistance Grant from the California Coastal Commission (CCC) and California Coastal Conservancy in 2017. The grant provided funding to the City of Pacifica to hire a consultant to conduct technical analyses for the CCC-recommended multi-step process to develop sea level rise and adaptation policies to guide Pacifica in how to prepare for the challenges associated with sea level rise and to reduce risks to people and property.

In 2018, the City prepared a Sea Level Rise Vulnerability Assessment which focused on determining the potential exposure of assets to flooding and erosion hazard under six sea level rise scenarios selected for study. Because future projections of sea level rise along California’s coastline are uncertain (due to uncertainty associated with modeling and the trajectory of global emissions), it was recommended to consider a range of projections to understand the consequences of various decisions, determine the tolerance for risk associated with those decisions, and to inform adaptation strategies necessary to prepare for change in the face of uncertainty. The sea level rise scenarios include no sea level rise (existing conditions) as well as state-recommended scenarios listed in Table 8-1.

Table 8-1: Proposed Future Sea Level Rise (SLR) Amounts for Various Scenarios with Associated Probability of Occurrence (CalNRA & OPC 2017) Year Low (17% Med-High (0.5% Extreme (N/A)

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Chance) Chance)
2050 1 ft. 2 ft.
2100 3 ft. 6 ft. 10 ft.*
*SLR of 6 ft. at 2075 was considered in place of 10 ft. at 2100 to assess potential impacts under the Extreme scenario. This was recommended by ESA because of the lack of erosion and flooding data for 10 ft. of SLR.

The findings of the Vulnerability Assessment were used to inform which adaptation strategies may be appropriate to consider in each subarea and provide the background information for the subsequent study, the Adaptation Plan, a background document that analyzed various adaptation strategies for each subarea, including the costs and benefits of each adaptation strategy, to inform future decisions on adaptation policies. Policies and programs implement the near-term sea level rise adaptation priorities for each sub-area in Pacifica, and identify mid- and long-term adaptation measures, subject to feasibility and monitoring. The Vulnerability Assessment tabulated asset exposures within seven coastal sub-areas to facilitate more focused development of adaptation strategies and policies. These coastal sub-areas represent geographical areas with varied types of development, including public recreation areas, public recreation areas, distinct residential neighborhoods, visitor-serving and neighborhood commercial development, and sensitive wildlife habitats. The sub-areas are shown in Figure 8-5.

The Vulnerability Assessment analysis combines the portion of the West Sharp Park neighborhood along the public sea wall and retaining wall with the Sharp Park Golf Course, West Fairway Park and Mori Point subarea. This decision was made because this entire stretch of shoreline is publicly owned and fully government owned shoreline may have different policy or funding considerations. An additional subarea identified in this planning effort is the West Linda Mar neighborhood, which is not in the Coastal Zone, but may be affected by sea level rise coastal hazards.

Insert Figure 8-5: Subareas

POLICIES
Guiding Policies
SA-G-4 ✳ Key Coastal Act Policies. The City of Pacifica adopts the following key policies derived from the Coastal Act to address coastal resilience:
• PRC 30235. Revetments, breakwaters, groins, harbor channels, seawalls, cliff retaining walls, and other such construction that alters natural shoreline processes shall be permitted when required to serve coastal-dependent uses or to protect existing structures or public beaches in danger from erosion, and when designed to eliminate or mitigate adverse impacts on local shoreline sand supply.
• PRC 30253. New development shall: (1) minimize risks to life and property in areas of high geologic, flood, and fire hazard; and (2) 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; and,

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• The Coastal Resilience policies adopted herein are intended to achieve and are consistent with these key policies, subject to periodic updates as resource and development monitoring and program implementation may dictate.

SA-G-5 ✳ Sea Level Rise and Best Available Science. Planning and development reviews shall use, as applicable, the best available science about projected sea level rise and other climate change-related environmental changes when addressing coastal erosion, bluff failure, flooding, and other coastal hazards.

Implementing Policies
SA-I-28 ✳ Vulnerability Identification and Mapping. The City’s Coastal Vulnerability zones shall be mapped based on the best available science about projected sea level rise, erosion, flooding, and other coastal hazards. Mapping shall be updated as necessary to guide implementation of the LCP’s Coastal Resilience policies. Notwithstanding the Coastal Vulnerability Zone Maps, site-specific hazard mapping and assessment may be required as part of the individual development review process for properties within the City’s Coastal Vulnerability zones.

Coastal Resilience
SA-I-29 ✳ Sea Level Rise Adaptation Plan. The City shall implement its Sea Level Rise Adaptation Plan as expressed in the general and sub-area Coastal Resilience policies. Adaptation alternatives evaluated in the Adaptation Plan that are not specifically expressed in these Coastal Resilience policies shall not be implemented without an amendment to the LCP, public notice, and opportunity for public input. The City shall monitor implementation and, consistent with Coastal Resilience Policy SA-I-31, update the Sea Level Rise Adaptation Plan to strengthen public safety, preserve existing neighborhoods, assure local economic vitality, respond to climate change, promote environmental justice, implement the Coastal Act, and protect the public trust.

Development in Coastal Vulnerability Zones may be approved consistent with the sub-area policies in Section 6.6 if the following findings can be made:

A. The proposed development is sited and designed to avoid, and where unavoidable, to minimize coastal hazards and impacts to coastal resources to the maximum extent feasible, consistent with the Adaptation Plan;
B. All project impacts on coastal resources are mitigated to the maximum extent feasible through the City’s Shoreline Mitigation Program (Coastal Resilience Policy SA-I-32) or consistent with Coastal Resilience Policy SA-I-85.

C. The project will not pose unacceptable risks to life or property or otherwise create a nuisance; and
D. The project will not encroach on public trust lands

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SA-I-30 ✳ Monitoring Shoreline Change. The City shall implement a monitoring program for sea level rise, beach width, bluff offset, flooding and storm damage, and other potential measures or triggers for guiding implementation of the Coastal Resilience policies. The monitoring program shall include yearly (minimum) shoreline and bluff edge surveys and also establish thresholds for reassessing the City’s Adaptation Plan.

SA-I-31 ✳ Sea Level Rise Adaptation Plan Update. The City shall reassess its Sea Level Rise Adaptation Plan as expressed in the general and sub-area Coastal Resilience policies every five years or sooner as required by the shoreline monitoring program (Coastal Resilience Policy SA-I-30). The reassessment shall consider the following:
• Efficacy of Adaptation Plan and implemented measures. • Updated sea level rise projections and risks.
• Potential need to revise adaptation measures or implement new measures, including review of emerging engineering, science, and technologies. • Funding needs and potential funding sources.

The draft findings of the City’s reassessment shall be disseminated to the public for review and comment prior to being finalized.

SA-I-32 ✳ Shoreline Mitigation Program. Within three years of certification of the LCP Land Use Plan update, the City shall adopt a Shoreline Mitigation Program to address the coastal resource impacts of existing and future shoreline protection projects in the City. Special emphasis shall be placed on maintaining beaches and public access to and along the shoreline.

The program will update the public access inventory of the LCP as necessary, include a coastal resource inventory and identify priority improvements for maintaining and enhancing coastal shoreline resources, particularly public access and recreation. The program will include enforceable measures to achieve proportional mitigation of resource impacts identified in shoreline protection projects, including consideration of beach widths, sediment management plan actions, and monitoring. The program will identify potential funding sources for implementation of identified improvements. The program will include provisions for monitoring implementation and program updates as necessary. Until the adoption of a Shoreline Mitigation Program, coastal resource impacts shall be mitigated in accordance with SA-I-86.

SA-I-33 ✳ Adaptation Funding. The City will pursue feasible grant funding sources or new funding mechanisms, such as the formation of Geologic Hazard Abatement Districts (GHADs) as supported by SA-I-14, or securing FEMA and other federal or state adaptation and hazard mitigation funds, to finance adaptation strategies for public infrastructure.

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SA-I-34 ✳ Transfer of Development Rights. Use the City’s transfer of development rights (TDR) ordinance to relocate development rights from Coastal Vulnerability zones (sending sites) to receiving sites outside of Coastal Vulnerability zones. Identify areas where densities and heights may be increased using TDR credits, including to facilitate affordable housing.

SA-I-35 ✳ Critical Transportation Infrastructure. The City will pursue opportunities to preserve, protect, or relocate critical local transportation infrastructure, or provide alternative access, to mitigate against isolation and economic loss, and to ensure public safety.

SA-I-36 ✳ Hazard Prone Infrastructure. The City will preserve, protect, or relocate hazard prone infrastructure to maintain critical services. Preservation/protection in situ with shoreline armoring shall be required to meet the requirements of Policies SA-I-82 and SA-I-83.

SA-I-37 ✳ Business Outreach. The City’s Economic Development Division shall provide nonfinancial assistance to businesses in evaluating options to promote business resiliency.

SA-I-38 ✳ High Water Program. The City will research and evaluate feasible new funding mechanisms to implement a program to record high water marks where feasible following high-water events.

SA-I-39 ✳ Flood Ordinance Consistency. The City will review and amend as necessary the flood damage prevention ordinance to assure consistency with the updated policies and ordinances of the LCP.

SA-I-40 ✳ LHMP Alignment. The City will coordinate its departments and programs to align the Local Hazard Mitigation Plan (LHMP) with the LCP to ensure proactive, coordinated and streamlined adaptation efforts and response to future coastal hazards. The City shall leverage FEMA funding opportunities for hazard mitigation and other related funding mechanisms to implement the Sea Level Rise Adaptation Plan as expressed in the general and sub-area Coastal Resilience policies.

SA-I-41 ✳ Regional Sediment Management. Participate in regional approaches to protecting, enhancing and restoring coastal beaches and watersheds through the California Coastal Sediment Management Workgroup, with a goal of minimizing coastal erosion.

Fairmont West Subarea
SA-I-42 ✳ Shoreline Protection Structures (0-1 foot SLR or 260-foot offset from bluff toe to infrastructure). Shoreline protection structures shall be avoided except that the existing shoreline protection structures may be maintained or new shoreline protection structures constructed to protect existing structures in danger from erosion if found to be the least environmentally-damaging alternative, impacts are fully mitigated consistent with SA-I-32,

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and compliant with any prior permit conditions and/or legal obligations pursuant to the California Coastal Act . Allow shoreline protection structures for the public road and sewer line existing structures if necessary and consistent with Policies SA-I-82 and SA-I-83, other LCP policies, and the Coastal Act. New development on blufftops shall comply will all LCP setback policies, including SA-I-71.

SA-I-43 ✳ Beach Nourishment (2 feet SLR or 260-foot offset from bluff toe to infrastructure).

Evaluate the feasibility of using beach nourishment, in conjunction with sand retention structures (see artificial headlands concept in the Adaptation Plan) as described in SA-I-48, to reduce shoreline protection structure maintenance requirements and maintain beaches of at least 100 feet in width on average. If feasible and approved through a coastal development permit, secure funding and implement as soon as possible. Repeat as necessary. Mitigate all adverse impacts and monitor effectiveness over time.

SA-I-44 ✳ Transfer of Development Rights (ongoing). Provide an option to private landowners to voluntarily transfer development potential as supported by SA-I-61.

West Edgemar and Pacifica Manor Subarea
SA-I-45 ✳ Shoreline Protection Structures (0-1 foot SLR or 220-foot offset from bluff toe to infrastructure or development). Maintain existing or construct new shoreline protection structures to protect existing public infrastructure structures, including between Bill Drake Way and Manor Drive. Allow private property owners to maintain existing or construct new shoreline protection structures if allowed pursuant to Policies SA-I-82 and SA-I-83, and if consistent with prior permit conditions and/or legal obligations pursuant to the California Coastal Act, and require mitigation of beach, public access and recreation and other coastal resource impacts, consistent with SA-I-32 or SA-I-85, as necessary.

SA-I-46 ✳ Beach Nourishment (0-1 foot SLR or 220-foot offset from bluff toe to infrastructure or development). Evaluate the feasibility of using beach nourishment, in conjunction with sand retention structures (artificial headlands concept) as described in SA-I-81, to reduce shoreline protection structure maintenance requirements and maintain beaches of at least 100 feet in width on average. If feasible and approved through a coastal development permit, secure funding and implement as soon as possible. Mitigate all adverse impacts and monitor effectiveness over time.

Northwest Sharp Park Subarea
SA-I-47 ✳ Shoreline Protection Structures (0-1 feet SLR or 70-foot offset from bluff toe to development or infrastructure). Private landowners may maintain, expand, or construct new shoreline protection structures to protect existing structures in danger from erosion, consistent with SA-I-31 and any prior permit conditions and/or legal obligations pursuant to the California Coastal Act.

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SA-I-48 ✳ Beach Nourishment (0-2 feet SLR or 70-foot offset from bluff toe to development or infrastructure). Evaluate the feasibility of using beach nourishment, in conjunction with sand retention structures (artificial headlands concept), to reduce shoreline protection structure maintenance requirements and maintain beaches of at least 100 feet in width on average. If feasible and approved through a coastal development permit, secure funding and implement as soon as possible. Repeat as necessary. Mitigate all adverse impacts and monitor effectiveness over time.

SA-I-49 ✳ Flood Protection (1 feet SLR). Enable property owners to modify development structures (e.g., elevate a residence) to manage impacts of wave run-up and overtopping of bluff face.

Sharp Park, West Fairway Park, and Mori Point Subarea
SA-I-50 ✳ Sharp Park Golf Course. Strongly support the City and County of San Francisco’s maintenance of the Sharp Park Golf Course berm and armoring, consistent with the Coastal Development Permit issued by the California Coastal Commission, including adaptation planning for the course, and protecting public access.

The City of Pacifica shall strongly support the City and County of San Francisco’s ongoing maintenance of the berm even if Coastal Commission termination of authorization is triggered by the conditions of approval, or require construction of flood protection improvements by the City and County of San Francisco.

SA-I-51 ✳ Shoreline Protection Structures (0 feet SLR). Maintain existing or construct shoreline protection structures to protect existing public infrastructure structures if consistent with Policies SA-I-82 and SA-I-83. Extend the Beach Boulevard seawall to the Sharp Park Golf Course berm if consistent with Policies SA-I-82 and SA-I-83.

SA-I-52 ✳ Structure Elevation (0-2 feet SLR). Maintain existing or construct shoreline protection structures if consistent with Policies SA-I-82 and SA-I-83 to limit wave overtopping unless beach nourishment strategies are effective in reducing wave run-up on the backshore. Elevate development structures if consistent with Policy SA-I-87 as necessary to mitigate flood damage, consistent with height limitations. Elevations of wave run-up and associated development thresholds shall be determined via a site-specific study.

SA-I-53 ✳ Beach Nourishment (0-1 feet SLR). Pursue beach nourishment and sand retention structures to reduce shoreline protection structure maintenance requirements and provide beach resources. Encourage the City and County of San Francisco to nourish the beach fronting the Sharp Park Golf Course berm to maintain beach widths.

SA-I-54 ✳ Flood Protection (0 foot SLR). Evaluate and construct appropriate flood protection measures, which may include a Clarendon Road stormwater basin, pump station, and/or

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interior Sharp Park Golf Course levee, to protect homes and businesses from existing fluvial storm flood hazard zone.

SA-I-55 ✳ Flood Protection (3 feet SLR). Evaluate the future need to construct a West Fairway Park stormwater basin, pump station, and interior Sharp Park Golf Course levee to protect western homes from future coastal/fluvial flood hazard zone.

Rockaway Beach, Quarry and Headlands Subarea
SA-I-56 ✳ Shoreline Protection Structures (0 feet SLR). Maintain existing or construct new shoreline protection structures along the north cove for public safety and hazard reduction if consistent with Policies SA-I-82 and SA-I-83.

SA-I-57 ✳ Shoreline Protection (2-3 feet SLR, or when backshore toe is 100 feet from Highway 1).

Coordinate with Caltrans to evaluate the need for a revetment or other appropriate shoreline protection for the Highway 1 embankment.

SA-I-58 ✳ Public Access (0 feet SLR). Plan and provide for enhanced public access, consistent with the City’s Shoreline Mitigation Program (SA-I-32).

SA-I-59 ✳ Beach Nourishment/Public Access (0 feet SLR). Plan and implement beach nourishment for Rockaway Beach. Monitor and measure performance and any reduction of shoreline protection structure maintenance needs. Establish mechanisms through the City’s Shoreline Mitigation Program (SA-I-32) to receive and use beach impact mitigation funds from other sub-areas of the City.

SA-I-60 ✳ Development Setbacks (ongoing). Implement new development shoreline setbacks consistent with SA-I-71.

SA-I-61 ✳ Transfer of Development Rights (ongoing). Provide an option to the private landowners of the Rockaway Headlands to voluntarily transfer development potential as supported by SA-I-34.

Pacifica State Beach and West Linda Mar Subarea
SA-I-62 ✳ Shoreline Protection (2 ft SLR or 100 foot offset from shoreline to infrastructure).

Evaluate beach conditions and consider future shoreline protection to protect existing parking structures and the existing Linda Mar stormwater and wastewater pump station structures as necessary.

SA-I-63 ✳ Highway One Protection. Coordinate with Caltrans to evaluate options for protecting Highway 1, if necessary.

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SA-I-64 ✳ Beach Nourishment (2 ft SLR or 100 foot offset from shoreline to infrastructure).

Evaluate beach conditions and implement beach nourishment as necessary to maintain a 100- foot buffer seaward of the sewer force main and/or Highway 1. Repeat nourishments as needed.

SA-I-65 ✳ Flood Protection (0 feet SLR). Analyze need for floodwall along commercial property to manage flooding from San Pedro Creek under existing conditions with sea level rise allowance. Future flood studies that include climate-driven changes in precipitation should inform any floodwall design. Floodproof Anza pump station (stormwater) to mitigate existing coastal storm flooding vulnerabilities to wave run-up.

SA-I-66 ✳ Flood Protection (2 feet SLR or 100-foot offset from shoreline to infrastructure).

Floodproof the Linda Mar pump stations (sewer and stormwater) to mitigate future coastal storm flooding vulnerabilities to wave run-up as necessary.

SA-I-67 ✳ Groundwater Management (0-2 feet SLR). Begin groundwater monitoring to determine needs for dewatering wells in the lowest portions of the West Linda Mar neighborhood.

Pedro Point and Shelter Cove Subarea
SA-I-68 ✳ Shoreline Protection Structure Upgrades. Allow maintenance of existing or new shoreline protection structures to reduce hazards and resource impacts if consistent with Policies SA-I-82 and SA-I-83. Mitigate impacts consistent with the City’s Shoreline Mitigation Program (SA-I-32) or SA-I-85, as necessary.

SA-I-69 ✳ Shoreline Protection. Allow private property owners to raise homes and other development structures above wave run-up hazards if consistent with Policy SA-I-87, consistent with height limitations.

New Shoreline Development
SA-I-70 ✳ Technical Reports. Development proposed on the shoreline shall include coastal engineering, geomorphology and other relevant technical reports unless on-site hazards already identified in a recent Coastal Vulnerability Zone Map or assessment approved within the last five years are adequate for evaluating and ensuring compliance with the LCP, including through use of permit conditions to address any uncertainty. Reports shall • be prepared by a licensed civil engineer or other suitably qualified professional; • use the best available science;
• consider the impacts from the med-high projection (CalNRA & OPC 2018) of sealevel rise for the anticipated duration of the proposed development;

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• demonstrate that the development will avoid (or if unavoidable, minimize) impacts from coastal hazards to the maximum extent feasible; and • evaluate the foreseeable effects that the development will have on coastal resources over time and mitigate the impacts where they are unavoidable.

Reports may be waived for temporary events, temporary development structures or other minor, short-term development where it is clear there will be no significant hazard risks over the project’s life.

SA-I-71 ✳ Siting and Design. New development on vacant shoreline property shall be sited and designed to be safe from erosion, bluff failure, wave run-up, flooding and other coastal hazards for at least 100 years without shoreline protection, considering projected sea level rise and other climate change effects to be determined from best available science and current guidance at the time of approval of the proposed development. Permit approvals shall prohibit shoreline protection structures for the authorized development, require the property owner to record an acknowledgement that the development does not qualify as an existing structure entitled to construction of a shoreline protection structure under Coastal Act Section 30235 and a waiver of any rights to such protection structures and where necessary require a removal and restoration plan, including bonding for large projects, to avoid future shoreline protection structures or project failure.

SA-I-72 ✳ Assumption of Risk by Private Landowners. Permit approvals of development on the shoreline shall require the applicant to record a deed restriction requiring the owner to assume liability and indemnify and hold the City harmless and make other acknowledgments relating to the risks of development on the property.

SA-I-73 ✳ MHTL and Avoidance of Public Trust Lands. Applications for low-lying development adjacent to coastal waters shall include a Mean High Tide Line (MHTL) survey of the development site prepared by a licensed professional land surveyor based on field data collected within 12 months of the application submittal (may be based on City monitoring survey data if collected by a licensed professional land surveyor). The survey shall be conducted in consultation with and approved by the California State Lands Commission (CSLC) staff. Development shall be sited to avoid public trust lands for the approved duration of the project, unless otherwise authorized by the California State Lands Commission and California Coastal Commission. The City shall conduct new MHTL surveys every ten years or within one year of a new tidal datum epoch (an epoch is a 19-year tidal cycle used to calculate datums), seismic event in the project area greater than 5.5 magnitude, or significant relative rise in annual local mean sea level records.

SA-I-74 ✳ Bluff Face Development. Shoreline protection structures, grading, and landform alteration on bluff faces are prohibited, except for the following:

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• Public access structures where no feasible alternative means of public access exists; and
• Shoreline protection structures if otherwise allowed by the LCP and the public access and recreation policies of the Coastal Act. Such shoreline protection structures shall be designed and constructed to be visually compatible with the surrounding area to the maximum extent feasible, to minimize effects on erosion of the bluff face, and to avoid (and where unavoidable to minimize and to mitigate) coastal resource impacts to the maximum extent feasible.

SA-I-75 ✳ Minor Development in Shoreline Areas. Minor and/or ancillary development, including public trails, benches, gazebos, patios, etc., may be located seaward of a bluff or shoreline setback line provided that development is otherwise consistent with the LCP, does not create a hazard, does not use a foundation that can serve as a bluff retaining device, such as caissons, or that requires landform alteration, and that the development is removed or relocated by the landowner when threatened or in the event that portions of the development fall to the bluffs, beach or ocean.

SA-I-76 ✳ Substantial Modifications to Existing Structures. When a proposed physical improvement to an existing structure would constitute a Substantial Exterior Structural Modification (SESM), as defined, the portion of the project constituting a SESM shall be undertaken consistent with the LCP and, if applicable, the Coastal Act, including but not limited to Policies SA-I-70 and SA-I-71. Any portion of the existing structure that remains and which is determined to be legally nonconforming with an LCP standard, including bluff setbacks or other hazard criteria, shall not be modified to increase the degree of nonconformity.

SA-I-77 ✳ Protection of Private Property in Hazardous Areas. Where full adherence with all LCP policies, including for setbacks and other Coastal Resilience and Natural Hazard avoidance measures, would preclude a reasonable economic use of the property as a whole, the City may allow the minimum economic use and/or development of the property necessary to avoid an unconstitutional taking of private property without just compensation. There is no taking that needs to be avoided if the proposed development constitutes a nuisance or is otherwise prohibited pursuant to other background principles of property law (e.g., public trust doctrine). If development is allowed pursuant to this policy, it must be consistent with all LCP policies to the maximum extent feasible.

SA-I-78 ✳ Habitat Sea Level Rise Migration Buffers. A sea level rise buffer area shall be added to require new development habitat buffers if necessary to allow for the migration of wetlands and other coastal habitats caused by sea level rise over the anticipated duration (i.e., economic life) of the development. Habitats include all wetlands, riparian, intertidal/shoreline and terrestrial environmentally sensitive habitat areas (ESHAs) as defined by the Coastal Act. The sea level rise projection considered shall be determined for the type of development from

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CalNRA and OPC (2018) guidance or the latest update. Except for temporary uses, as described below, uses and development within sea level rise buffer areas shall be limited to minor passive recreational uses, with fencing, de-siltation or erosion control facilities, or other improvements deemed necessary to protect the habitat, to be located in the upper (upland) half of the buffer area. Water quality features such as drainage swales required to support new development shall not be constructed in wetland buffers. Temporary uses may also be placed in the sea level rise buffer area until such time as sea level rise causes the wetlands or other coastal habitat to migrate to within 100 feet of the temporary uses, at which time, they shall be removed. All habitat and buffers identified shall be permanently conserved or protected through a deed restriction, open space easement, or other suitable device.

SA-I-79 ✳ Stormwater and Dry Weather Flows. New development shall provide adequate drainage and erosion control facilities that convey site drainage in a non-erosive manner to minimize hazards resulting from increased runoff and erosion. Runoff shall be directed inland to the storm drain system or to an existing outfall, when feasible. If no storm drain system or existing outfall is present, blufftop runoff shall not be channelized or directed over bluffs and/or to the beach or the ocean.

SA-I-80 ✳ Subdivision Limitations. Update the Zoning Ordinance to prohibit the division of shoreline property that creates hazardous or unbuildable parcels due to erosion, bluff failure, wave run-up, flooding and other coastal hazards for at least 100 years without shoreline protection, considering projected sea level rise and other climate change effects to be determined from best available science and current guidance at the time of approval of the proposed development. Only allow new lots to be created if they can be developed without ever requiring shoreline protection for the development.

Shoreline Protection Structures
SA-I-81 ✳ Soft Shoreline Protection. Encourage the use of soft or natural shoreline protection methods, such as dune restoration and beach/sand nourishment as alternatives to hard shoreline protection structures, such as revetments or sea walls. Soft shoreline protection devices shall be fully evaluated for coastal resource impacts, and shall only be approved if found consistent with the LCP and Coastal Act policies related to shoreline protection.

Consider combining beach replenishment with groin construction to maintain beaches and protect development (see subarea policies).

SA-I-82 ✳ Beach Nourishment. In coordination with the California Coastal Commission and other permitting agencies (e.g., State Lands Commission, U.S. Army Corps of Engineers), the City shall evaluate a beach nourishment program in conjunction with sand retention structures to assist in maintaining beach width and elevations, consistent with sub-area policies. The beach nourishment program will include measures to protect water quality and to avoid (and where unavoidable to minimize and mitigate) potential adverse coastal resource impacts, including

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biological resource impacts, from deposition of material, including measures such as sand compatibility specifications, restrictions on volume of deposition, timing or seasonal restrictions, and identification of environmentally preferred locations for deposits. The City will also consider developing an opportunistic sand program and evaluate how replenishment options may need to change over time with sea level rise.

SA-I-83 ✳ Existing Shoreline Protection Structures. Except as may be otherwise provided in the LCP sub-area policies, legally permitted shoreline protection structures may be repaired and maintained, as supported by Section 30235 of the Coastal Act, subject to all coastal development permit requirements (including those associated with the construction of the structure and/or prior repair and maintenance episodes) until the development they are protecting is removed or no longer requires shoreline protection structures, at which time the shoreline protection structure shall be reevaluated for consistency with the LCP and removed if no longer necessary. Activities considered “repair and maintenance” shall not result in any enlargement or extension of the shoreline protection structure, or any seaward encroachment or impairment of public trust resources, and shall provide mitigation for any new coastal resource impacts not previously or otherwise mitigated, including through the City’s Shoreline Mitigation Program (SA-I-32) and/or Policy SA-I-85. Other modifications to existing shoreline protection structures which fall within the limitations of an exclusion contained in the definition of Substantial Exterior Structural Modification shall be considered to be an existing shoreline protection structure. This policy shall not be applied to justify the removal of a shoreline protection structure which protects any structure authorized to be constructed pursuant to an exclusion contained in the definition of Substantial Exterior Structural Modification.

SA-I-84 ✳ New Shoreline Protection Structures. Shoreline protection structures, including revetments, breakwaters, groins, seawalls, cliff retaining walls, deep piers and caissons, and other such construction that alters natural shoreline processes shall be permitted consistent Section 30235 of the Coastal Act and with the LCP’s sub-area policies only when required to serve coastal-dependent uses or protect existing structures or public beaches in danger from erosion, when designed to eliminate or mitigate adverse impacts on local shoreline sand supply.

SA-I-85 ✳ Authorization Limits of Shoreline Protection Structures. Shoreline protection structures shall only be authorized until the time when the existing structure protected by such shoreline protection structure: 1) is/are no longer present, or 2) no longer require(s) armoring. This policy shall not be applied to justify the removal of a shoreline protection structure which protects any structure authorized to be constructed pursuant to an exclusion contained in the definition of Substantial Exterior Structural Modification.

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SA-I-86 ✳ Mitigating Impacts of New Shoreline Protection Structures. New or reconstructed shoreline protection structures shall be sited and designed to avoid sensitive resources to the maximum extent feasible. Adverse coastal resource impacts shall be avoided, and where unavoidable shall be minimized and fully mitigated, including impacts on sand supply, beach area, public access (vertical access to the shore and horizontal access along the shore and blufftop) and recreational use (surfing, fishing, hiking, etc.), public trust lands and values, ecological function, water quality, shoreline aesthetics, and cultural resources. At a minimum, new shoreline protection structures shall:
• blend with the natural environment;
• avoid significant habitat areas;
• minimize encroachment/footprint;
• protect, and where feasible, provide public access; and • control erosion from surface and groundwater flows.

Mitigation options shall include consideration of providing equivalent new public access, recreation, habitat or other coastal resources in the vicinity of the project, or if such options are not feasible, proportional in-lieu fees that consider and reflect, to the maximum extent practicable, the full value of impacted and/or lost resources for the authorization period of the project. Any fees shall be deposited in an interest-bearing account held by the City of Pacifica for use within the City Limits for mitigation of the specific impact identified in the project approval. This policy may be met through compliance with the City’s Shoreline Mitigation Program (SA-I-32)
SA-I-87 ✳ Monitoring Plan for New Shoreline Protection Structures. Proposals for new, redeveloped/augmented or repaired shoreline protection structures shall include a monitoring plan that evaluates the condition of the shoreline protection structure, conditions at the site and surrounding area, and whether the shoreline protection structure is still needed for protection. The plan shall require an inspection at least every five years to identify:
• Any structural damage and need for repair;
• Environmental impacts, including excessive scour, impacts to shoreline processes and beach width (at the project site and the broader area and/or littoral cell as feasible), and impacts to public access and the availability of public trust lands for public use; and
• The status of the existing structure being protected. • The monitoring plan shall also be updated to at a minimum include any specific requirements associated with coastal permit approval.

At least every 15 years the landowner shall submit a new Mean High Tide Line (MHTL) survey of the subject property based on field data collected within 12 months of the date submitted. Surveys shall comply with Coastal Resilience Policy SA-I-73.

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Coastal Flooding and other Hazards
SA-I-88 ✳ Flood Risk Reduction. The City should, when appropriate, evaluate and pursue, floodproofing of infrastructure and other development in danger from projected flooding by 2050. Allow and facilitate (if feasible) private owners to floodproof development structures, consistent with other LCP policies.

8.4 Hazardous Materials and Operations
A material is considered hazardous if it appears on a list of hazardous materials prepared by a federal, state, or local agency, or if it has characteristics defined as hazardous by such an agency. The California Code of Regulation defines a hazardous material as a substance that, because of physical or chemical properties, quantity, concentration, or other characteristics, may either (1) cause an increase in mortality or an increase in serious, irreversible, or incapacitating, illness or (2) pose a substantial present or potential hazard to human health or environment when improperly treated, stored, transported or disposed of, or otherwise managed. Hazardous materials have been and are commonly used in commercial, agricultural, and industrial applications and, to a limited extent, in residential areas.

Hazardous wastes are defined in the same manner. Hazardous wastes are hazardous materials that no longer have practical use, such as substances that have been discarded, discharged, spilled, contaminated, or are being stored prior to proper disposal. Hazardous materials and hazardous wastes are classified according to four properties: toxic (causes human health effects), ignitable (has the ability to burn), corrosive (causes severe burns or damage to materials), and reactive (causes explosions or generates toxic gases).

Pacifica currently has sites undergoing remediation for contamination with hazardous materials. Some contaminated sites are on vacant parcels or properties with the potential to redevelop. Contamination does not render these sites unusable, but may require time and funding for cleanup.

HAZARDOUS MATERIALS SITES
Releases, leaks, or disposal of chemical compounds, such as petroleum hydrocarbons, on or below the ground surface can lead to contamination of underlying soil and groundwater. Disturbance of a previously contaminated area through grading or excavation operations could expose the public to health hazards from physical contact with contaminated materials or hazardous vapors. Improper handling or storage of contaminated soil and groundwater can further expose the public to these hazards, or potentially spread contamination through surface water runoff or air-borne dust. In addition, contaminated groundwater can spread downgradient (the direction that groundwater flows), potentially contaminating subsurface areas of surrounding properties.

Areas with known or suspected release of hazardous materials to soil and groundwater, and where current clean-up activities monitored by the State Water Quality Control Board or the California Department of Toxic Substances are active, are shown in Figure 8-6 and listed in Table 8-2.

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Three of the four active cleanup sites in Pacifica are classified as Leaking Underground Storage Tanks (LUSTs); most are associated with gasoline. Most of the identified sites are automobile-related: gas stations and auto body or repair shops. The former Sharp Park Rifle Range, identified by both the California Department of Toxic Substances Control and the State Water Resources Board, is undergoing a voluntary cleanup of residual lead from past activities.

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Table 8-2: Contaminated Sites in Pacifica
Map
ID
Site Name Address Site Type Potential
Contaminants
Cleanup
Status
Sites Identified by the California Department of Toxic Substances Control 1 Sharp Park Rifle
Range
Rifle Range Rd. Voluntary
Cleanup
Lead Certified/
Operation
and
maintenanc
e as of
6/30/2011
Sites Identified by the State Water Resources Board
1 Sharp Park Rifle
Range
Rifle Range Rd. Cleanup
Program Site
Lead Open – Site
Assessment
2 Olympic Sharp Park 1518 Francisco
Blvd.

LUST Cleanup
Site
Gasoline Open –
Eligible for
Closure
3 Sunset Garage 2251 Oceana Blvd. LUST Cleanup
Site
Gasoline Open –
Verification
Monitoring
4 Arco #433 498 Palmetto Ave. LUST Cleanup
Site
Benzene,
Toluene, Xylene,
MTBE/ TBA/ Other
Fuel Oxygenates,
Gasoline
Open –
Eligible for
Closure
Sources: California Department of Toxic Substances Control; California Environmental Protection Agency; State Water Resources Control Board, 2020.

REGULATION AND ENFORCEMENT
Various State and federal agencies govern the proper storage, handling, and transport of hazardous materials. San Mateo County handles hazardous waste, organizing both curbside pickup of certain household wastes and appointments at hazardous waste collection events for other items. The County is also responsible for issuing permits for the storage of hazardous waste. The County’s Health System also has a Hazardous Waste Generator Program, authorized by the Department of Toxic Substances Control (DTSC) to inspect and regulate non-permitted hazardous waste generators.

San Mateo County’s Hazardous Materials Emergency Response Program provides a team of trained Hazardous Materials specialists who respond to and manage Hazardous Materials emergencies and potential bio-terrorism threats throughout San Mateo County on a seven-day, 24-hour basis.

POLICIES
Guiding Policies
SA-G-6 Contaminated Sites. Facilitate clean-up programs at contaminated sites, particularly on properties with the potential to develop or be reused for public purposes.

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SA-G-7 Safe Disposal. Continue to promote the reduction, recycling, and safe disposal of household and business hazardous wastes through public education and awareness.

Implementing Policies
SA-I-89 Cleanup of Contamination. Require applicants for development in a potentially contaminated location to perform inspection and cleanup if the site is found to be contaminated with hazardous substances.

The City will require a project applicant to have the site inspected by a registered Environmental Assessor. Reports detailing the results must be submitted for City review, and level of remediation and cleanup must be in compliance with federal and State standards.

SA-I-90 Regional Support. Continue to support the hazardous waste collection, management, and inspection efforts of San Mateo County, the State, and the Water Resources Control Board.

Insert Figure 8-6: Contaminated Sites

8.5 Fire Hazards
Fire hazards in Pacifica include both urban and wildland fires. Urban fires involve the uncontrolled burning of built structures due to human-made causes; wildland fires affect grassland, forest, and brush (and the structures on them), and can result from either human or natural causes. The City’s main challenges regarding these hazards are:
• Actively Managing the Urban-Wildland Interface. Pacifica’s residents enjoy close contact with open ridges and woodlands. This brings with it the risk of proximity to wildland fires.

Preparedness is essential, and the North County Fire Authority’s fire prevention activities, especially its Vegetation Management Program, are important. • Maintaining and Enhancing Evacuation Routes. It is critical that road capacity exists for local residents, workers, and visitors to evacuate in case of an environmental disaster, including fire.

URBAN FIRES
Urban fires are fires that begin in a building in urban centers. They are typically localized but have the potential to spread to an adjoining building. The risk of urban fires is highest where single-family homes, multifamily residences and business facilities are clustered close together, increasing the possibility of rapid spread to an adjoining building. The risk to life and property can be reduced by adopting and funding adequate levels of fire protection and ensuring new buildings are built to include fire resistive features which conform to modern fire and building codes.

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WILDLAND FIRES
Wildland fires are fires that start in a wooded or undeveloped area. Their potential for damage is dependent on the extent and type of vegetation, known as surface fuels, as well as weather and wind conditions. Wildland fires occur infrequently but typically cause more damage than urban fires. About two thirds of Pacifica is undeveloped, and nearly half is protected open space. This undeveloped land is mainly on the rugged ridges that form the City’s western eastern and southern edge and descend down to the ocean between Pacifica’s valley communities. Coastal scrub is the predominant vegetation type, interspersed with annual grassland. Significant areas of eucalyptus forest and mixed woodland are present in eastern Sharp Park and on Cattle Hill and San Pedro Mountain. In California, most wildfire damage occurs in wildland urban interface areas, where homes and woodland vegetation are directly adjacent. The California Department of Forestry and Fire Protection (CAL FIRE) has designated Fire Hazard Severity Zones (FHSZs) throughout the state based on factors such as fuel, slope, and weather to indicate varying degrees of fire hazard (i.e., moderate, high, and very high). FHSZ maps evaluate physical conditions that create a likelihood that an area will burn over a 30- to 50-year period.

CAL FIRE also designates land as either a Federal, State, or Local Responsibility Area (FRA, SRA, and LRA, respectively), based on population density, land use, and land ownership. Portions of the Planning Area within the SOI are designated State Responsibility Areas (SRA), where the State of California is financially responsible for the prevention and suppression of wildfires, while the NCFA has primary responsibility for Local Responsibility Areas (LRA) within the City limit. Lands in Pacifica owned by the federal government and the County, including GGNRA lands,——are designated as a State Responsibility Area (SRA).

Some areas shown on Figure 8-7 along the southwestern perimeter within the Sphere of Influence are designated as Very High FHSZs. Most of this land in the Very High FHSZ zone is an urban reserve or park or other designations where extremely low densities of residential development may be permitted.

Land adjacent to these areas that is within city limits is low- and very-low density residential development.

To address this risk, the City cooperates with CAL FIRE and the North County Fire Authority (NCFA) through cooperative fire protection agreements.

CAL FIRE tracks the deadliest, largest, and most destructive wildfires that have occurred in the state, with the lists last updated in late March 2021. San Mateo County is not included in any of these lists. However, according to the San Mateo County Multijurisdictional Local Hazard Mitigation Plan (MJ-LHMP), it is likely that the risk of wildfires will continue to occur in San Mateo County. Wildfires are influenced by both weather and human activities. Based on its history of past events, San Mateo County has a high chance of a wildfire in any given year. The most common causes of wildfires, based on past events, will be “undetermined,” equipment use, miscellaneous, and power line/electric power.9 However, the
9 County of San Mateo. Multijurisdictional Local Hazard Mitigation Plan, 2021.

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approximately 86,000-acre CZU Lightning Complex wildfire that ignited in August 2020, affecting various locations in San Mateo and Santa Cruz counties, is believed to have been caused by lightning.10 INSERT Photo 8-09 IMGP2969
The interface between wild and urban land in Pacifica presents a potential fire threat.

INSERT Figure 8-7: Fire Hazards

FIRE AND EMERGENCY SERVICES
The cities of Brisbane, Daly City, and Pacifica are contributing members of the North County Fire Authority (NCFA), a Joint Powers Authority established in 2003. The Fire Authority provides both emergency response and non-emergency public safety services to the three cities and their 185,000 residents in its service area. Two of the Authority’s 10 stations are in Pacifica. Fire Station 71, at 616 Edgemar Avenue, serves the north end of Pacifica, while Fire Station 72, at 1100 Linda Mar Boulevard, serves the south end. These locations are shown on Figure 8-7.

Fire and Emergency Response
NCFA has established the following service ratio and response time standards:
• Service ratio standard: one responder per 1,500 population • Response time standards for fire service: Four-minute travel time to 90 percent of calls for fire service, and eight-minute travel time for all apparatus on-scene for fire calls for service. • Response time standard for Emergency Medical Services (EMS): Under seven-minute travel time (6:59) for first response to 90 percent of calls.

Pacifica’s long and narrow geography and its reliance on Highway 1 as the single north-south access route makes the City a challenge for fire response. A 2008 study determined that the Vallemar, West and East Fairway Park, Rockaway Beach, and Rockaway neighborhoods in central Pacifica are beyond four-minute travel distance from northern San Mateo County fire stations, corresponding with the standard response time for first-due fire apparatus. The full assignment response time standard cannot be met in Pacifica from Vallemar south.11
NCFA’s EMS standard is for 90 percent of calls to be reached in less than seven minutes. This standard is met for 97 percent of calls in the zone, including approximately 93 percent of calls in Pacifica. 10 CAL FIRE. Incident page for CZU Lightning Complex fire, https://www.fire.ca.gov/incidents/2020/8/16/czu-lightningcomplex-including-warnella-fire, 2021. 11 Emergency Services Consulting, 2008.

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The NCFA needs additional facilities to meet its fire response standards for Vallemar and areas to the south. A third, mid-point station in Pacifica with a truck and engine company has been discussed for some time. The area that currently does not meet first-response time standards has a low density of development, and so it has fewer persons and structures threatened by fire. A new station would be needed if the central part of Pacifica were to experience significant new development, for example at the Quarry site.

Pacifica has an ISO12 rating of 4. The City’s rating is unlikely to be affected by population growth, but population growth will increase existing deficiencies in service delivery.

Fire Prevention
The NCFA’s Fire Services Prevention Bureau manages code enforcement, plan review and construction inspection, fire investigations, and public education. A key part of the Bureau’s code enforcement activities is the annual safety inspection of every commercial business and multi-family residential property in its service area. The NCFA also conducts a Vegetation Management Program, promoting compliance with vegetation standards to reduce the threat of fire in the urban/wildland interface. The NCFA implements the Vegetation Management Program through public education and by pursuing grant funding to undertake fuel reduction projects.

FIRE ACCESS STANDARDS
Clear emergency vehicle access to buildings is critical for public safety. Such access is regulated by the adopted and amended California Fire Code and Pacifica City Standard Engineering Plans. Under the current California Fire Code (CFC), all portions of a building shall be within 150 feet of a serviceable fire access road, with limited exceptions. The City has adopted the CFC with amendments to address local fire hazard concerns.

Building Signage Standards and Regulations
Pacifica has adopted the latest edition of the CFC, with all appendices, and amended it to address local concerns. The NCFA reviews plans for structures and buildings citywide, including fire-prone areas.

Checklists are used to address fire code requirements, including but not limited to street and building signage, water supply, water infrastructure, fire sprinkler requirements, building requirements (fire sprinklers, smoke detectors, roofing, etc.), access roads, and vegetation management, among others.

The City enforces uniform building address and street sign letters as found in the CFC and California Building Code, which establishes requirements for the design and display of approved address numbers, building numbers, or approved building identification on new and existing buildings to ensure legibility and visibility from the street or road fronting the property. 12 Insurance Service Office (ISO), a private company, has a system for determining the price of fire insurance in a community through a 1 to 10 classification system, with 1 being the highest level of service.

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The MJ-LHMP identifies several mitigation actions for wildland fires in Pacifica, including update of its Emergency Operations Plan; pursuing opportunities to preserve and protect critical transportation infrastructure; and developing and delivering business programs and public outreach programs to promote resiliency and community preparedness.

STATE REQUIREMENTS
In 2005, the California Building Code was amended to require that all new buildings located in any Fire Hazard Severity Zone in SRAs, or any Very High Fire Hazard Severity Zone in LRAs, must use building materials approved for use in wildland/urban interface areas. The code now specifies certain roof coverings, fire resistive wall and ceiling-floor assemblies, wall finish materials, hardware, insulation, and other building materials for use in high fire hazard areas. Also in 2005, the Public Resources Code was amended to expand the defensible space clearance requirement around buildings from 30 feet to 100 feet in any SRA. Building owners must minimize potential fuel around structures, to minimize the risk of loss, and to improve firefighter safety.

INSERT Photo 10 DSCN1220
The City will work with the NCFA toward development of a third fire station in the central part of Pacifica.

POLICIES
Policies included in both the General Plan and Local Coastal Land Use Plan are indicated with a ✳.

Guiding Policy
SA-G-8 ✳Fire Prevention. Protect Pacifica residents and businesses from potential wildland fire hazards.

Implementing Policies
SA-I-91 ✳Response Time. Support efforts by NCFA to meet its response time standards throughout the City.

This effort may include construction of a third fire station in the central part of Pacifica, near the police station or the Quarry site. The City could provide land or shared facilities.

SA-I-92 ✳Adequate Peak Load Water Supply. Work with the North Coast County Water District to maintain adequate water supply for firefighting, including capacity for peak load under a reasonable worst case wildland fire scenario, to be determined by the NCFA.

SA-I-93 ✳Water Storage Locations. In evaluating sites for new water storage facilities, place a priority on locations least subject to impacts from seismic activity and landsliding.

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SA-I-94 ✳Development Review. Review development proposals to ensure that they incorporate appropriate fire-mitigation measures, including adequate provisions for evacuation and access by emergency responders, and vegetation clearances that do not impact ESHAs or wetlands.

SA-I-95 ✳Plan Review in Fire-Prone Areas. Continue to request the NCFA participation in plan review of new buildings in potentially fire-prone areas.

SA-I-96 ✳Fire Prevention Inspections. Continue to require a fire prevention inspection of every permitted business and multi-family development covered by the NCFA.

SA-I-97 ✳Fire Prevention Education. Continue educating the public about local fire hazard prevention programs. Work cooperatively with the NCFA to promote public awareness of fire safety and emergency life support.

SA-I-98 ✳Vegetation Management. Promote and support the NCFA’s Vegetation Management Program to reduce urban/wildland interface fire hazards through public education and fuel reduction projects.

SA-I-99 ✳Multi-jurisdictional approach. Participate in State or regional efforts, to develop a clear legislative and regulatory framework to manage the wildland-urban interface including implementation of MJ-LHMP.

SA-I-100 ✳Rockaway Quarry service. Ensure that any new development at the Rockaway Quarry site is adequately served by public infrastructure, including fire and police services.

8.6 Public Safety and Emergency Management
The City’s public safety and emergency management functions cover several roles that address the time before and during a hazardous event: emergency planning including evacuation routes and emergency response.

EMERGENCY PLANNING
The California Emergency Services Act requires cities to prepare and maintain an Emergency Plan for natural, manmade, or war-caused emergencies that result in conditions of disaster or in extreme peril to life. The City’s Emergency Preparedness and Safety Commission is responsible for disaster preparedness training in Pacifica, and the Police Department and NCFA offer Community Emergency Response Team training. San Mateo County’s Office of Emergency Services provides planning, preparedness, public information, training, and Federal/State intergovernmental emergency services coordination for the cities and unincorporated areas within the county. Pacifica has a member on the Emergency Services Council.

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Pacifica Municipal Code, Title 9, Chapter 2 “Emergency Services” establishes a Director Emergency Services and Emergency Services Council for the purpose of preparing and carrying out plans for the protection of persons and property within the City in the event of an emergency. This PMC provision empowers the City Manager as the Director of Emergency Services to perform various functions to plan for and respond to emergencies in the City, including but not limited to fire emergencies.

Local Hazard Mitigation Planning
The purpose of an LHMP is to reduce or eliminate long term risk to human life and property resulting from hazards, by identifying risks before they occur and putting together resources, information, and strategies for emergency response. An LHMP is required of all cities by federal law. Pacifica’s LHMP is an annex to a regional plan led by the County of San Mateo Office of Emergency ServicesABAG, known as the Multi-Jurisdictional Local Hazard Mitigation Plan (MJ-LHMP) for San Mateo County. The LHMP, originally adopted in 2005 and updated in 2016, and 2021, identifies specific actions the City is taking to mitigate impacts from flooding, earthquakes, wildfires, and other emergency events.The LHMP identifies several issues related to evacuation in case of emergency:

Minimum road widths for emergency response should be 20 feet with an additional 10 feet of clearance on each shoulder. Older roads in the city do not always follow this standard.

A lack of roadways leading to the Shelter Cove neighborhood, with no emergency vehicles able to enter the area currently.

A shortage of educational facilities that can function as temporary medical centers or shelters for people affected by a disaster.

The MJ-LHMP identifies transportation isolation and accessibility as an evacuation vulnerability in case of emergency, including vulnerabilities along arterials, bridges over highways, and single-entry neighborhoods. In the south, Pacifica is connected to the next community via a bridge and a tunnel. In the north, Pacifica is connected to the City of Daly City by Interstate 280 (I-280). The other access points into or out of Pacifica are Manor Drive, Hickey Boulevard, and Sharp Park Road, all of which connect with California State Route 35 (CA-35). There are areas of Highway One which may be susceptible to landslides due to the steep grade. There have been some minor rock slides in the area. If areas of Highway 1 were blocked due to a landslide, the City may be severely limited to access equipment, parts, and materials to fix infrastructure.

EMERGENCY RESPONSE
The City of Pacifica Evacuation Operations Plan provides an overview of steps for necessary evacuation events. Day-to-day emergency responses within the City of Pacifica are governed by the Incident Command System (ICS) and the operational plans and protocols of the responding agencies. Should an emergency go beyond day-to-day response capability, the North County Fire Authority will invoke protocols that allow for the use of automatic-aid and mutual-aid resources within the City. This same process is managed within the Police Department. The fire and police departments will carry out centralized emergency management (Unified Command) to ensure the successful coordination of the response and the initiation of recovery operations.

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During a wildland fire response, the Unified Command (Fire and Police) establishes evacuation decision points which will be executed with the assistance of law enforcement. The City of Pacifica has been divided into zones for purposes of evacuations. Several zones, including those encompassing Pedro Point, inland Rockaway Beach, and the Vallemar neighborhoods have less than twotwo evacuation routes, as shown in Figure 8-8. The City’s evacuation routes in Figure 8-8 would become highly congested during a mass evacuation of the City but would have capacity for an efficient evacuation of smaller portions of neighborhoods. During the event of an evacuation, key intersections would be managed by the Police Department to permit flow of emergency vehicles into the zone and for residential evacuation.

Fire protection and emergency response in Pacifica are handled by the NCFA, cities. The City’s Police Department handles police services. In the event of a major emergency, the Police Station will serve as the command center for the City.

Service standards for fire, police, and emergency response times are generally met or exceeded. However, the city’s geography and circulation system, combined with the current locations of fire stations, mean that neighborhoods in central Pacifica are beyond the NCFA’s standard for response time. This can be resolved, as noted previously with a third, mid-point station with a truck and engine company.

Police Services
The Pacifica Police Department responds to public safety calls, provides traffic safety and security for public events, and handles calls for assistance. The Department handles dispatch services on evenings and weekends for the Department of Public Works and the NCCWD. It participates continuously in the San Mateo County Gang Task Force and provides funding to receive assistance from the San Mateo County Narcotics Task Force. It has officers that establish relationships with school staff to help strengthen the relationship between schools, students, and the police. The Police Department serves the City from its station at 2075 Coast Highway. The station is deemed adequate to support a sufficient level of service for future population growth in Pacifica.

The Police Department staffing level, approximately one officer per 1,000 residents, and response times and levels of service are generally considered good to excellent by residents. However, as recently as the 1990s the Police Department had staffing of approximately 47 officers at a population of roughly 38,000, resulting in a ratio of around one officer per 800 residents. Additional staffing could enable the Police Department to provide additional community policing services.

INSERT Photo 11 DSCN1220
The Police Department serves the City from its station at 2075 Coast Highway, opened in 2004.

Insert Figure 8-8: Pacifica Neighborhoods with Fewer than Two Evacuation Routes.

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POLICIES
Guiding Policies
SA-G-9 Emergency Response. Foster an efficient and coordinated response to emergencies and natural disasters.

SA-G-10 Public Awareness. Support continuing public awareness of hazards, including avoidance, disaster preparedness, and emergency response procedures.

SA-G-11 Disaster Preparation. Make infrastructure investments, enforce regulations, and disseminate information that will improve disaster response and recovery, with the goal of minimizing damage to people and property.

Implementing Policies
SA-I-101 Emergency Operations Plan. Update and maintain the City’s Emergency Operations Plan, which provides adequate response to disasters, including emergency ingress and egress, and defines the expected roles of City, County, and regional agencies.

SA-I-102 Emergency Response Coordination. Develop effective mechanisms for a coordinated response to natural and man-made emergencies by:
• Conducting regular emergency planning meetings and disaster preparedness exercises with City departments, the Fire District, the County, medical centers, and other emergency service providers and relevant public agencies; • Holding emergency drills that require all City staff to be adequately trained to handle different kinds of emergency scenarios; and
• Coordinating with the County on regional emergency communications.

SA-I-103 Emergency Access on New Roadways. Ensure that new roadways are developed in accordance with standards in the Municipal Code. In all new development, require adequate access to be provided for emergency vehicles, including adequate widths, turning radii, hard standing areas, and vertical clearance.

SA-I-104 Areas that Lack Emergency Access. Develop a plan to widen critical rights-of-way that do not provide adequate clearance for emergency vehicles. For areas that are not feasibly accessible to emergency vehicles, develop a contingency plan for reaching and evacuating people in need of treatment.

This initiative should include a plan to open access to or otherwise serve the Pedro Point, inland Rockaway Beach, and the Vallemar neighborhoods.

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SA-I-105 Regulatory Monitoring. Continue to monitor changes in the Federal Disaster Act and applicable State laws, keep City officials and residents aware of the impacts of these changes, and update the City’s Emergency Plan as necessary.

SA-I-106 Public Preparedness. Initiate periodic public information programs that explain the City’s emergency preparedness programs, including the emergency communications system, evacuation routes, and shelter locations.

Each household should be self-sufficient for 72 hours after a disaster. The City will post information on the City’s website and in other visible public locations, such as City Hall about emergency preparedness.

SA-I-107 Local Hazard Mitigation Plan. Continue to maintain and update a Local Hazard Mitigation Plan as an implementation action for the Safety Element.

SA-I-108 Emergency Water Capacity. Work with the Water District to ensure that it has a plan and infrastructure for providing adequate water service and storage during and immediately after an emergency, including a major seismic event.

SA-I-109 Utilities. Require companies providing public utilities in Pacifica to have plans for reestablishing service in the event of a major seismic event or other natural disaster.

SA-I-110 Police Response. Continue to respond without delay to all calls for police assistance as soon as possible consistent with normal safety precautions and vehicle laws. Periodically review procedures and response times to ensure equitable service across the community.

SA-I-111 School Outreach. Continue to partner with schools and youth organizations to conduct outreach and develop conflict resolution, and form pro-active and creative community partnerships to enhance public safety.

SA-I-112 Periodic Evaluation. Periodically, evaluate police and fire services to ensure that the City is providing adequate protection in an efficient, cost-effective manner.

SA-I-113 Critical Facilities Location. Do not locate structures necessary for protection of the public’s health and safety, public assembly, or emergency services in hazardous areas unless no reasonable alternative exists.

SA-I-114 Critical Facilities Operability. Take steps to ensure critical use facilities that are important to protecting health and safety in the community remain operational during an emergency.

SA-I-115 Code Updates. Update City codes and ordinances dealing with public safety to comply with State law and reflect the latest information on hazards and mitigation strategies.

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INSERT Photo 01
The purpose of the Noise Element is to identify the noise sources that exist in the Planning Area, and to establish policies and programs which the City can enact to mitigate potential impacts through both preventative and responsive measures. Noise from motor vehicles and aircraft operations are regulated by state and federal agencies. Noise considerations also inform the location of industrial land uses and transportation facilities, since they are common sources of excessive noise levels, and the location of noise–sensitive uses such as residences, schools, churches, and hospitals, so that they may be less affected by noise.

9.1 Noise Characteristics and Measurement
Noise is commonly defined as undesirable or unwanted sound. Noises vary widely in their scope, source, and volume, ranging from individual occurrences such as leaf blowers, to the intermittent disturbances of overhead aircraft, to the fairly constant noise generated by traffic on freeways.

Three aspects of community noise are used in assessing the noise environment:
• Level (e.g., magnitude or loudness). Sound levels are measured and expressed in decibels (dB) with 10 dB roughly equal to the threshold of hearing. Figure 9-1 shows the decibel levels associated with different common sounds. Transient noise events may be described by their maximum A-weighted noise level (dBA).
• Frequency composition or spectrum. Frequency is a measure of the pressure fluctuations per second, measured in units of hertz (Hz). The characterization of sound level magnitude with respect to frequency is the sound spectrum, often described in octave bands, which divide the audible human frequency range (e.g., from 20 to 20,000 Hz) into ten segments. • Variation in sound level with time, measured as noise exposure. Most community noise is produced by many distant noise sources that change gradually throughout the day and produce a relatively steady background noise having no identifiable source. Identifiable events of brief duration, such as aircraft flyovers, cause the community noise level to vary from instant to instant. A single number called the equivalent sound level or Leq describes the average noise exposure level over a period of time. Hourly Leq values are called Hourly Noise Levels.

INSERT Figure 9-1: Typical Sound Levels

REPORTING NOISE LEVELS
Measuring and reporting noise levels involves accounting for variations in sensitivity to noise during the daytime versus nighttime hours. Noise descriptors used for analysis need to factor in human sensitivity to

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nighttime noise when background noise levels are generally lower than in the daytime and outside noise intrusions are more noticeable. Common descriptors include the Community Noise Equivalent Level (CNEL) and the Day-Night Average Level (DNL). Both reflect noise exposure over an average day with weighting to reflect the increased sensitivity to noise during the evening and night. The two descriptors are roughly equivalent. The CNEL descriptor is used in relation to major continuous noise sources, such as aircraft or traffic, and is the reference level for the Noise Element under State planning law.

Knowledge of the following relationships is helpful in understanding how changes in noise and noise exposure are perceived:
• Except under special conditions, a change in sound level of 1 dB cannot be perceived; • A 3 dB change is considered a just-noticeable difference; • A 5 dB change is required before any noticeable change in community response would be expected. A 5 dB increase is often considered a significant impact; and • A 10 dB increase is subjectively heard as an approximate doubling in loudness and almost always causes an adverse community response.

In establishing noise contours for land use planning, it is customary to ignore noise attenuation afforded by buildings, roadway elevations, and depressions, and to minimize the barrier effect of natural terrain features. The result is a worst-case estimate of the existing and future (projected) noise environment. The purpose of noise contours is to identify the potential need for more detailed acoustical studies, not to predict with certainty the noise level throughout the City. The assumption is that it is desirable to overestimate the potential noise at a future noise-sensitive development site than to underestimate the noise environment and allow for potentially incompatible land-use development.

9.2 Noise Generation in Pacifica
Insert Figure 9-2: Existing Noise Contours
Insert Figure 9-3: Future Noise Contours
The major noise sources in Pacifica are related to roadways and vehicle traffic, particularly along State Routes 1 and 35. Noise produced by industrial or commercial activity has a negligible effect on the City’s residential noise environment. Figure 9-2 maps existing noise contours.

According to common practice, maximum noise levels of 60 dB (CNEL) are considered “normally acceptable” for unshielded single-family residential development. Noise levels from 60 dB to 70 dB fall within the “conditionally unacceptable” range, and those in the 70 to 75 dB range are considered “normally unacceptable.” Noise levels of up to 65 dB are considered normally acceptable for multi-family housing and lodging, while noise levels of up to 70 dB are normally acceptable for most other uses.

TRAFFIC NOISE
The level of traffic noise depends on three factors: (1) the volume of the traffic, (2) the speed of the traffic, and (3) the number of trucks in the flow of traffic. Vehicle noise is a combination of the noises produced by the engine, exhaust, tires, and wind generated by taller vehicles. Other factors that affect the perception

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of traffic noise include: distance from the roadway, terrain, vegetation, and natural and structural obstacles. While tire noise from autos is generally located at ground level, truck noise sources can be located as high as ten to fifteen feet above the roadbed due to tall exhaust stacks and higher engines.

Noise exposure contours for Pacifica’s major roadways were modeled by applying the Federal Highway Administration’s noise modeling procedure. Traffic data representing annual average traffic volumes and truck mix, for existing conditions, were obtained from the engineers working on the General Plan Update and Caltrans. Existing noise measurements were made in March 2009 at four locations, three along SR 1 and one along Sharp Park Road. Using these data and the FHWA methodology, traffic noise levels were calculated for existing traffic volumes.

Based on this analysis, about 1,407 acres or 16.5% percent of the Planning Area were in areas with traffic noise levels greater than 60 dB (CNEL). These areas include approximately 299 acres designated for medium or low density residential development with community noise levels between 60 and 70 dB, considered “conditionally acceptable” for single-family or townhouse development, and 20 acres of medium or low density land with community noise levels over 70 dB, considered “normally unacceptable.” Another 33 acres of high density residential and mixed use land is affected by noise levels of between 65 and 70 dB, considered “conditionally acceptable” for multi-family development, and six acres of land in these categories is currently exposed to unacceptable noise levels over 70 dB. In general, the further development is from Sharp Park Road, SR 35, and especially SR 1, the less noise is likely to be experienced.

Projected Noise Sources and Levels
Future development within the Planning Area will result in increased traffic volumes, thus increasing noise levels in some areas. Future noise contours are illustrated in Figure 9-3. In 2040, an estimated 1,551 acres or 18.2 percent of the Planning Area will be within areas with noise levels greater than 60 dB (CNEL). About 336 acres of low and medium density residential land would be exposed to the “conditionally acceptable” 60 to 70 dB range, up from 299 acres today, while 27 acres would have “unacceptable” noise, up from 20 acres today. Acreage of conditionally acceptable high density and mixed use land would rise from 33 to 38 acres, and land in these categories exposed to unacceptable noise levels would increase from 6 to 8 acres.

Locating noise-sensitive uses away from high-noise areas (e.g. major transportation routes) and buffering noise levels through design features will help minimize future noise-related land use conflicts. Policies in this chapter establish review criteria for certain land uses to ensure that future noise levels will not exceed acceptable levels near noise-sensitive land uses.

INSERT Photo 02
Vehicle noise is a combination of the noises produced by the engine, exhaust, tires, and wind generated by taller vehicles.

INSERT Photo 03
Locating noise-sensitive uses away from high-noise areas and buffering noise levels through design and landscaping features will help minimize future noise-related land use conflicts.

INSERT Photo 04

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Nearby SFO’s noise abatement programs aim to minimize the effects of aircraft noise on communities.

AIRPORT NOISE
The greatest potential for noise intrusion from airports occurs when aircraft land, take off, or run their engines while on the ground. San Francisco International Airport (SFO) is located approximately four miles east of the Planning Area. Based on SFO’s 2019 noise contours, no part of the Planning Area is currently within the 65 dB CNEL noise contour.

SFO’s Aircraft Noise Abatement Office maintains a noise abatement program that integrates parts of the approved Noise Compatibility Plan; City and County of San Francisco resolutions; stated goals of the San Francisco International Airport/Community Roundtable; and air traffic control requirements. The program includes a mix of regulatory and voluntary actions that together minimize the impacts of noise on communities while ensuring safety.

OTHER NOISE SOURCES
General Service Commercial and Light Industrial Uses
Noise sources associated with service commercial uses such as automotive repair facilities, car washes, and recycling yards, are found at various locations in the City. The noise emissions of these types of uses are dependent on many factors and are therefore difficult to quantify precisely. Nonetheless, noise generated by the these uses contributes to the ambient noise environment in the immediate vicinity of these uses and should be considered where either new noise-sensitive uses are proposed nearby or where similar uses are proposed in existing residential areas.

Construction and Other Equipment
Construction can be another substantial, though short-term, source of noise. Construction is most disruptive when it takes place near sensitive land uses, or occurs at night or in early morning hours. The dominant construction equipment noise source is usually a diesel engine without sufficient muffling. In a few cases, however, such as impact pile driving or pavement breaking, process noise dominates.

Other portable or small-scale pieces of equipment may also produce noise. Mechanical equipment such as pumps and fans may produce low noise levels, but continuously and for substantial distances. Rooftop or otherwise exposed mechanical equipment can also produce constant and disturbing noises. Portable power equipment, such as leaf blowers and drills, can produce very high noise levels at the location of the work. Other amplified sounds such as automotive audio equipment or loudspeakers also create noise exposure.

Parks and School Playing Fields
There are numerous park and school uses in the Planning Area. Noise generated by these uses depends on the age and number of people utilizing the respective facility at a given time and the types of activities they are engaged in. School playing field activities tend to generate more noise than those of neighborhood parks, as the intensity of school playground usage tends to be higher.

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NOISE SENSITIVE LAND USES
Noise-sensitive land uses are generally defined as locations where people reside or where the presence of noise could adversely affect the use of the land. Places where people live, sleep, recreate, worship and study generally are considered to be sensitive to noise because intrusive noise can be disruptive to these activities.

9.3 Noise Exposure Standards
City standards established in this General Plan are intended to augment Federal and State standards, and protect community members and sensitive receptors from noise hazards.

FEDERAL REGULATIONS
Federal regulations establish noise limits for airport noise, as well as medium and heavy trucks. Airport noise is predominantly a local issue, but it often involves multiple stakeholders who have distinctive authorities and shared responsibilities with regard to noise abatement and mitigation. The federal government has authority over airspace use and management, air traffic control, aviation safety, aircraft noise emissions, and airport development policy. In addition to its regulatory role and its management of the air traffic control system, FAA provides financial and technical assistance to airports for noise reduction planning and abatement activities.

The federal truck passby noise standard is 80 dB at 15 meters from the vehicle pathway centerline. These controls are implemented through regulatory controls on truck manufacturers. In addition to noise standards for individual vehicles, under regulations established by the Federal Highway Administration, noise abatement must be considered for certain federal or federally-funded projects such as new highways and highway expansions.

STATE REGULATIONS
Title 24 of the California Code of Regulations, the Building Standards Administrative Code, contains the State Noise Insulation Standards, which specify interior noise standards for new hotels, motels, apartment houses, and dwellings other than single-family homes. Such new structures must be designed to reduce outdoor noise to an interior level of no more than 45 dB in any habitable room. They require an acoustical analysis demonstrating how dwelling units have been designed to meet this interior standard where such units are proposed in areas subject to noise levels greater than 60 dB. Title 24 standards are enforced through the building permit application process.

CITY OF PACIFICA REGULATIONS
Title 5, Chapter 10 of the Pacifica Municipal Code makes it unlawful to cause any “loud, disturbing, unnecessary, or unnatural noise” that disturbs persons in Pacifica, and identifies specific types of noises including vehicle horns and amplifiers. It prohibits the use of pile drivers or similar equipment at night, and restricts the hours of solid waste collection. Title 5, Chapter 28 defines the terms for regulating loud parties. Chapter 29 requires general disclosure of the existence of the airport and the potential for noise from overflight, for all property in the City. Special disclosure is required for property within the airport’s CNEL noise footprint as of 1983.

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GENERAL PLAN NOISE STANDARDS
The General Plan establishes thresholds for community noise exposure by land use type in Table 9-1. For proposed land uses in areas where noise exposure may be expected to be greater than the “normally acceptable” threshold, maximum allowable noise exposure with noise mitigation measures is defined in Table 9-2. Table 9-3 provides noise emission standards for new stationary noise sources.

Community Noise Exposure
Table 9-1 presents the community noise exposure matrix, establishing criteria the City can use to evaluate land use compatibility based on noise levels. This matrix is adapted from guidelines provided by the Office of Planning and Research.

Table 9-1: Land Use Compatibility for Community Noise Environments Normally Acceptable Normally Unacceptable
Conditionally
Acceptable Clearly Unacceptable
Noise exposure levels are classified as being “normally acceptable, ” “conditionally acceptable,” “normally unacceptable,” or “clearly unacceptable” for different land use types.

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Normally Acceptable
• Indoor Uses: Either the activities associated with the land use are inherently noisy or standard construction methods will sufficiently attenuate exterior noise to an acceptable level; for land use types that are compatible because of inherent noise levels, sound attenuation must be provided for associated office, retail, and other noise-sensitive indoor spaces sufficient to reduce exterior noise to an interior maximum of 50 dB CNEL.
• Outdoor Uses: Outdoor activities associated with the land use may be carried out with minimal interference.

Conditionally Acceptable
• Indoor Uses: Noise reduction measures must be incorporated into the design of the project to attenuate exterior noise to the indoor noise levels listed in Table 9-2. • Outdoor Uses: Noise reduction measures must be incorporated into the design of the project to attenuate exterior noise to the outdoor noise levels listed in Table 9-2. Acceptability is dependent upon characteristics of the specific use.

Normally Unacceptable
• Indoor Uses: Extensive mitigation techniques are required to make the indoor environment acceptable for indoor activities. Noise level reductions necessary to attenuate exterior noise to the indoor noise levels listed in Table 9-2 are difficult to achieve and may not be feasible. • Outdoor Uses: Severe noise interference makes the outdoor environment unacceptable for outdoor activities. Noise level reductions necessary to attenuate exterior noise to the outdoor noise levels listed in Table 9-2 are difficult to achieve and may not be feasible.

Clearly Unacceptable
• New construction or development should generally not be undertaken.

Allowable Noise Exposure
Table 9-2 indicates acceptable limits of noise for various land uses for both exterior and interior environments. For new development in areas where the community noise environment is not considered “normally acceptable,” noise impacts may be mitigated through use of sound-reducing strategies so that noise levels meet the allowable limits.

Table 9-2: Allowable Noise Exposure

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Noise-Sensitive Land Use
Outdoor Activity
Areas1
Interior Spaces
DNL/CNEL2, dB DNL/CNEL2, dB Leq dB3
Residential 65 45 ---
Transient Lodging (Hotels, Motels) 65 45 ---
Hospitals, Nursing Homes 65 45 ---
Theaters, Auditoriums, Music Halls --- --- 35
Churches, Meeting Halls 65 --- 45
Office Buildings --- --- 45
Schools, Libraries, Museums --- --- 45
Notes:
1 Outdoor activity areas generally include backyards of single-family residences and outdoor patios, decks or common recreation areas of multi-family developments. 2 The CNEL is used for quantification of aircraft noise exposure as required by CAC Title 21. 3 As determined for a typical worst-case hour during periods of use.

Noise Emission Standards for Stationary Noise Sources
The General Plan also provides standards for exposure to stationary (non-transportation) noise sources such as industrial facilities, automotive servicing, or equipment yards, in Table 9-3 below.

POLICIES
Guiding Policies
NO-G-1 Coordination with Other Agencies. Continue to work with other agencies, airports and jurisdictions to reduce noise levels in Pacifica created by their operations.

NO-G-2 Acceptable Noise Environment. Strive to achieve an acceptable noise environment for the environmental, health and safety needs of present and future residents of Pacifica.

NO-G-3 Sensitive Land Uses. Protect noise sensitive land uses, such as schools, hospitals, and senior care facilities, from encroachment of and exposure to excessive levels of noise.

Table 9-3: Noise Level Performance Standards for Stationary Noise Sources1 Daytime
(7:00 a.m. – 10:00 p.m.)
Nighttime
(10:00 p.m. – 7:00 a.m.)
Hourly Equivalent Sound Level (Leq), dBA 50 45
Maximum Sound Level (Lmax), dBA 70 65
Notes:
1As determined at the property line of the receiving noise-sensitive use.

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Implementing Policies
NO-I-1 Community Noise Level Standards. Use the Community Noise Level Exposure Standards, shown in Table 9-1, as review criteria for new land uses. Require all new development that would be exposed to noise greater than the “normally acceptable” noise level range to reduce interior noise through design, sound insulation, or other measures.

NO-I-2 Design Features for Noise Reduction. Require noise-reducing mitigation to meet allowable outdoor and indoor noise exposure standards in Table 9-2. Noise mitigation measures that may be approved to achieve these noise level targets include but are not limited to the following:
• Construct façades with substantial weight and insulation; • Use sound-rated windows for primary sleeping and activity areas; • Use sound-rated doors for all exterior entries at primary sleeping and activity areas; • Use minimum setbacks and exterior barriers;
• Use acoustic baffling of vents for chimneys, attic and gable ends; • Install a mechanical ventilation system that provides fresh air under closed window conditions.

Alternative acoustical designs that achieve the prescribed noise level standards may be approved, provided that a qualified Acoustical Consultant submits information demonstrating that the alternative designs will achieve and maintain the specific targets for outdoor activity areas and interior spaces.

NO-I-3 Best Available Control Technology. Require new, fixed noise sources (e.g. mechanical equipment) to use best available control technology (BACT) to minimize noise and vibration.

Noise from mechanical equipment can often be reduced by applying soundproofing materials, mufflers, or other controls provided by the manufacturer.

NO-I-4 Mechanical Equipment for New Residential Development. Ensure that building regulations require that noise-generating appliances serving new multi-family or mixed-use residential development are located or adequately insulated to protect residents from the noise.

NO-I-5 Noise Criteria for City Equipment. Develop noise criteria for new equipment purchased by the City.

NO-I-6 Construction Noise. Continue to limit hours for certain construction and demolition work to reduce construction-related noises.

NO-I-7 Noise from Highways and Buses. Work with Caltrans and Sam Trans to mitigate transportation-related noise impacts on residential areas and sensitive uses. This may include encouraging installation of sound barriers or bus stop relocation in selected locations.

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NO-I-8 Airport Noise Disclosure Requirements. Update the Municipal Code to ensure that special disclosure requirements concerning airport noise refer to the most current CNEL noise contours developed for San Francisco International Airport.

NO-I-9 Airport Noise Abatement Program. Continue to work with the airport in improving and implementing its noise abatement program.

NO-I-10 Residential Sound Insulation Program. If the airport’s federally-approved 65 dB CNEL annual noise contour is mapped within the City, request that the San Francisco Airport’s Residential Sound Insulation Program allocate available federal and airport funding to sensitive, noise-affected properties in Pacifica.

NO-I-11 Noise Ordinance. Update the noise ordinance to implement General Plan policies and noise standards.

NO-I-12 Noise Enforcement. Ensure staff responsible for noise control and enforcement are trained and equipped to enforce the City’s noise regulations.

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INSERT Photo 01_IMGP2888

10.1 Implementation Process
The 2040 General Plan provides specific policy guidance for the implementation of plan concepts in each of the Plan elements. This framework establishes a basis for coordinated action by the City, adjacent jurisdictions, San Mateo County, and regional and State agencies. This chapter describes the implementation process in general terms and the major actions to be undertaken by the City; the implementing policies in each element of the Plan provide details that will guide program development.

The major implementation process for land use proposals will be updating and administering the Zoning Ordinance and the Zoning Map. The City’s current Zoning Ordinance will need to be updated and amended to be consistent with the General Plan’s policies and to add new zoning districts and modify existing districts to reflect designation on the Land Use Diagram and the density/intensity standards for the land use classifications. The Subdivision Ordinance also should be amended to add additional explicit requirements for solar easements and land dedication for bike paths, trails, coastal access, easements along creeks and waterway corridors, and reservation of sites for the community facilities, consistent with current State law.1 The Capital Improvement Program will be the primary means of scheduling and funding infrastructure improvements of citywide benefit. Based on the recommendations made in the 2040 General Plan for streets, trails, parks, and updates to the City’s master plans for wastewater treatment and recycling and stormwater management systems, the City’s development and impact fees will need to be reviewed in order to determine whether any changes are necessary. Special assessment districts or other means of financing improvements benefiting specific areas may be established.

In many areas, General Plan implementation will depend on actions of other public agencies and of the private sector, which will fund most of the development expected to occur in the Planning Area.

The General Plan will serve a coordinating function for private sector decisions; it also provides a basis for action on project master plans and individual development applications, found to be 1 Government Code §§ 66475. - 66478.

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consistent with the General Plan. The City will adopt procedures for making findings for General Plan conformity decisions prior to adoption of new zoning regulations and an updated Zoning Map. These may take the form of interim zoning regulations.

10.2 Responsibilities
Implementing the General Plan will involve the City Council, the Planning Commission, other City boards, committees and commissions, and City departments. The City also will need to consult with San Mateo County and other public agencies about implementation proposals that affect their respective areas of jurisdiction. The principal responsibilities that City officials and staff have for Plan implementation are briefly summarized below; details on their powers and duties are in the Pacifica Municipal Code.

INSERT PHOTO 02_DSCN1201:

The Capital Improvement Program will be the primary means of scheduling and funding infrastructure improvements of citywide benefit (top).

INSERT Photo 03_DSCN8078:

The Subdivision Ordinance should be amended to add requirements for solar easements and land dedication for bike paths, trails, coastal access and waterway corridors (middle).

INSERT Photo 04_MG_4057_Pacifica-City-Council
Pacifica’s City Council (bottom) is assisted by commissions and advisory committees and task forces.

CITY COUNCIL
The City Council is responsible for the overall management of municipal affairs; it acts as the legislative body and is responsible for adoption of the General Plan and any amendments to the General Plan. The City Council is also responsible for approving and administering the zoning and subdivision ordinances to implement the General Plan. The Council also may adopt area plans and specific plans, as needed for General Plan implementation. The City Council appoints the City Manager who is the chief administrator of the City and has overall responsibility for the day-to-day implementation of the Plan. The City Council also appoints members to the City’s commissions established under the Municipal Code and to advisory committees and task forces. The City Council’s role in implementing the General Plan will be to set implementation priorities; approve zoning map and zoning text amendments, and subdivision maps consistent with the General Plan; and approve a Capital Improvement Program and budget to carry out the Plan.

PLANNING COMMISSION
The Planning Commission is responsible for preparing and recommending adoption or amendment of the General Plan, zoning and subdivision ordinances and other regulations, resource conservation and management plans, and programs and legislation needed to implement the General Plan. The Planning Commission also may prepare and recommend adoption of design guidelines and specific plans, developer-initiated master plans, neighborhood plans or special

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plans, as needed for Plan implementation. Finally, the Commission is responsible for development project review, as specified in the zoning ordinance, and for other implementation actions, as specified in Plan elements or in the zoning ordinance.

PLANNING DEPARTMENT
The Planning Department is responsible for the general planning and development review functions undertaken by the City. It is the lead department for implementation of the Pacifica General Plan, Local Coastal Land Use Plan, Pacifica Zoning Ordinance, Rockaway Beach Specific Plan, Sharp Park Specific Plan, as well as building codes, design guidelines and the Municipal Regional Stormwater Permit. The Building Division of the Department administers the Building Code, issues building and demolition permits and inspects new construction for compliance with Building Code requirements. Specific duties related to General Plan implementation include preparing zoning and subdivision ordinance amendments and design guidelines for Council approval, reviewing development applications, conducting investigations and making reports and recommendations on planning and land use, zoning, subdivisions, development plans and environmental controls. The Department is also responsible for state mandated environmental review related to development in the City and coordinates activities with school districts related to school sites. Finally, the Department has the primary responsibility for preparing the annual report on the General Plan and conducting the five-year review. These reporting requirements are described in Chapter 1 of the General Plan. Parks, Beaches and Recreation Department

PARKS, BEACHES AND RECREATION DEPARTMENT
The Parks, Beaches and Recreation Department is responsible for managing the City’s parks, beaches and recreation services. Specific implementing responsibilities are established in the Open Space and Community Facilities Element of the General Plan. The Department also will be preparing a Parks and Recreation Master Plan to implement the General Plan. The mission of the department is to connect the community and visitors to the natural resources available in the City and provide community programs and events for all ages.

PUBLIC WORKS DEPARTMENT
The Public Works Department is responsible for planning, design and development of public infrastructure projects; traffic and transportation engineering; providing engineering support to the Planning Department for private development project and subdivision infrastructure review, emergency management technical services, and surveying. It maintains parks, playfields, streets and trails; and provides a tree program and clean beaches for community enjoyment as well as safe and reliable transportation and facilities for all city departments. The Department also handles the review of current development applications, subdivision maps, grading permits, public improvement plans, encroachment permits, development in the flood zone, and plumbing permits.

It also inspects construction projects for compliance with encroachment permits it issues and is responsible for the design and construction of capital improvement projects. Specific implementing responsibilities are established in the Circulation; Open Space and Community Facilities; and Safety elements of the General Plan.

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WASTE WATER TREATMENT
The Wastewater Division of the Public Works Department is responsible for the operation and administration of the city’s Calera Creek Water Recycling Plant. The Division will be responsible for implementing aspects of the Conservation Element.

POLICE DEPARTMENT
Within the City, responsibility for public safety is assigned to the Police Department. The Police Department is responsible for preventing crime and maintaining law and order. The Department coordinates with the North County Fire Authority and the County on mutual aid. Specific implementing responsibilities under the General Plan are established in the Safety Element.

The Police Department is made up of the Field Services, Investigative, and Administrative Divisions. Each division carries out specialized duties to ensure the most effective performance by the entire Police Department. Specific responsibilities and programs of the Police Department include, but are not limited to: crime prevention, crisis intervention, safety awareness and natural disaster preparation awareness.

INSERT PHOTO 05_IMGP2948:

The Public Works Department is responsible for street sweeping, rehabilitation, and pavement repair and restoration. (Top)
INSERT PHOTO 06_DisasterFair18:

Disaster exercises are conducted within the city in conjunction with the San Mateo County Office of Emergency Services.

OTHER COMMISSIONS AND COMMITTEES
The City has three standing commissions and four advisory committees to assist in General Plan implementation and other responsibilities assigned to them by the City Council. As of May 2013, these include:
• Beautification Advisory Committee
• Economic Development Committee
• Emergency Preparedness & Safety Commission
• Library Advisory Committee
• Open Space & Parkland Advisory Committee
• Parks, Beaches & Recreation Commission
• Planning Commission
The General Plan does not envision any substantive change in the responsibilities assigned to these committees. The City Council may periodically revise and update the list of commissions, advisory committees, and task forces, as needed.

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10.3 The Plan and Regulatory System
The City will use a variety of regulatory mechanisms and administrative procedures to implement the General Plan. Overall responsibility for plan implementation is vested in the Planning Department, consisting of the Planning Director and staff. Consistency between the General Plan and the zoning ordinance is required to ensure that Plan policies will be implemented and that environmental resources earmarked for protection in the Plan will be preserved. Other regulatory mechanisms, including subdivision approvals, building codes, capital improvement programs, and environmental review procedures also will be used to implement Plan policies. All project approvals should be found consistent with the General Plan.

ZONING REGULATIONS
The City’s Zoning Ordinance will translate plan policies into specific use regulations, development standards, design standards and performance criteria that will govern development on individual properties and development sites. The Zoning Ordinance also includes citywide regulations for landscaping, on-site parking and loading, signs, and a density bonus program among other regulations. The General Plan establishes the policy framework, while the Zoning Ordinance prescribes standards, rules and procedures for development along with criteria and findings required for acting on project applications. The Zoning Map will provide more detail than the General Plan Land Use Diagram.

The General Plan establishes land use classifications that will require new zoning districts.

Regulations for these districts will be established as part of the comprehensive zoning update to be undertaken following adoption of the General Plan. The use regulations and development standards for existing zoning districts will need to be amended to conform to Plan policies. Density and intensity limits, consistent with the Plan’s land use classifications, also will need to be updated.

For purposes of evaluating General Plan consistency, the density of proposed projects will be rounded up or down to the nearest whole number, as appropriate.

The Zoning Ordinance also will be amended to clarify that religious institutions and other protected uses shall be allowed, consistent with federal and State law.

The City will bring both the Zoning Ordinance and the Zoning Map into conformance with the General Plan within a reasonable period of time. When the General Plan is subsequently amended, the Zoning Ordinance and Zoning Map may also need to be amended to maintain consistency between the documents.

During the transition period while new zoning is being developed, the City will use “General Plan Conformity Findings” to provide criteria for determining whether a proposed project is consistent with the General Plan. Factors that will be evaluated to make General Plan Conformity determinations include: site suitability for the proposed use, compatibility with adjacent uses, neighborhood economic vitality and the need for the proposed use; and the proposed density and intensity of development.

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Consistency between the General Plan and the Zoning Ordinance Zoning must be consistent with the General Plan if the City’s land use, housing, and open space policies are to be realized. A fundamental link between the General Plan and zoning is land use/zoning consistency. Table 10-1 shows how zoning districts in Pacifica are consistent with the land use designations of this General Plan. In some areas, new zoning districts are needed (shown in italics). In others, the existing zoning will need to be amended, as prescribed by the implementing policies in this Plan or may be eliminated, such as the M-1 and M-2 industrial districts.

The new districts include RTOS Transitional Open Space Residential, RVLD Very Low Density Residential, CRMU Coastal Residential Mixed Use, MUN Mixed Use Neighborhood, MUC Mixed Use Center, VSC Visitor-Serving Commercial, and VSCS-LI Low Intensity Visitor-Serving Commercial. The City also may choose to create a streamlined procedure for planned development.

The existing lot size overlay and combining districts may also be reviewed and updated. This districting framework will facilitate administration and ensure a closer link with Plan policies because new zones will mirror classifications on the Land Use Diagram. Planned development still would be permitted, but with a more flexible process that would be “findings-driven” and have specific criteria for approval.

Table 10-1: Consistency Between the Plan and Zoning
General Plan Land Use Designations Consistent Zoning District1 Residential
Transitional Open Space Residential RTOS
Open Space
/Agriculture/Residential

A, OS, RM
Very Low Density Residential RVLD, R-1, R-1-H
Low Density Residential R-1
Medium Density Residential R-2, R-3 ,R-3/LD, R-3/G
High Density Residential R-3
Mixed Use
Coastal Residential Mixed Use CRMU
Mixed Use Neighborhood MUN
Mixed Use Center MUC
Commercial
Retail Commercial C-1, C-2
Office/Commercial O, C-1-A
Service Commercial C-3
Visitor-Serving Commercial VSC
Low-Intensity Visitor-Serving Commercial VSC-LI
Public and Community Uses
Public and Semi-Public P-F
Utilities P-F

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Table 10-1: Consistency Between the Plan and Zoning
General Plan Land Use Designations Consistent Zoning District1 Beach and Commuter Parking P
Parks and Open Space
Park A, O-S
Conservation O-S
Urban Reserve A
Source: Dyett & Bhatia, 2021
Notes:
1 Planned Development, Lot Size Overlay, and Combining Districts are not shown here.

SUBDIVISION REGULATIONS
No subdivision of land may be approved under California law and the City’s subdivision regulations unless its design and proposed improvements are found to be consistent with the General Plan. Dedication of land for park facilities will be required for subdivisions above a certain size, consistent with the policies and standards prescribed by the General Plan. The subdivision regulations also can require dedication of land for elementary schools, riparian habitat and reservation of land for fire stations, libraries, bike paths, coastal access, transit facilities, and other public facilities. In addition, it can require easements along creeks and streams.

After adoption of the General Plan, the City’s subdivision regulations will need to be amended to conform to Plan policies. Findings of consistency with the General Plan will continue to be required as a condition of approving parcel maps and tentative maps. Reservation requirements for bus turnout facilities and bike and pedestrian facilities also will need to be added to carry out Plan policies. The subdivision ordinance should require connection between new streets and existing streets and ensure right of way dimensions are provided, consistent with City standards.

Facilitating use of solar energy with north-south lot layouts and roof orientations that enable installation of collector systems will also be encouraged. The subdivision regulations update also should address State requirements for solar access easements as appropriate for Pacifica.

INSERT PHOTO 07_Pacifica 144, 08_DSC_0095, 09_DSCN1317_MalavearCt_cr The subdivision ordinance’s park land dedication requirements, street standards, and other features will be updated to be consistent with the General Plan. The subdivision ordinance should require connection between new streets and existing streets, wherever possible.

BUILDING AND HOUSING CODES
No building permit may be issued under California law (Government Code Section 65567) unless the proposed development is consistent with the City’s open space plan and conforms to the policies of the Open Space and Community Facilities and Conservation Elements.

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To provide an administrative mechanism to ensure consistency with the General Plan, the City should continue its process of performing zoning compliance review of building permit applications for new development.

10.4 Capital Improvement and Programming
The Capital Improvements Program (CIP) includes a list of public works projects that the City intends to design and construct in coming years. Under California law, the Planning Commission, acting as Planning Agency, has responsibility for reviewing the CIP to determine whether it conforms to the General Plan. Specifically, the Government Code requires the Commission to review for conformity with the General Plan CIP projects requiring any of the following actions:
• Acquisition of land for public purposes;
• Disposition of land;
• Street vacations; and
• Authorization or construction of public buildings or structures.

The Planning Commission also has the authority to comment on CIPs prepared by the school districts. These CIPs, and any annual revision proposed to them, are to be forwarded to the City at least 60 days prior to adoption for the City’s review for consistency with the General Plan.

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Packet Pg. 859 Attachment: Attachment D - Redline Edits to Draft General Plan (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to M i l a g r a R i d g e
( G G N R A )
Pacifica
State
Beach
Pacifica
Pier
S h a r p P a r k
G o l f C o u r s e
San Pedro Vall e y
County Par k
S h a r p P a r k
M o r i P o i n t
( G G N R A )
S w e e n e y
R i d g e ( G G N R A )

FASSLER AV E TERRA NOVA BLVD

LINDA MAR BLVD

ODDSTAD BLVD

GRAND AVE

ROCKAWAY BE ACH AVE

REINA DEL MAR AVE

CRESPI DR

CRESPI DR

FAIRWAY DR RIDGEWAY DR

PALOMA AVE

CLARENDON RD

PALMETTO AVE

MANOR DR

AVALON DR

MI LAGR ADR

MONTEREY RD

IVERNESS DR

NELSON AVE

PA ML ETTO AVE

ADOBE DR

BEACH BLVD

HICKEY B LV D
P a c i f i c
O c e a n
Northern
Coastal
Bluffs
(GGNRA)
Sharp
Park
Beach
P e n i n s u l a
Wa t e r s h e d
( S F P U C )
Rockaway
Beach
P e d r o P o i n t
H e a d l a n d s
Devil' s Slide Tunnel

PERALTA RD

ROSITA RD

EVE RGLAD ES DR

M ANZA NI T A DR

LERI D A WAY

R OBERTSRD

SHAR P P A RK R D

BRADFORD WAY

ESPLANADE AV E

E DGEMAR A VE

GAT EWAYDR

FIRECREST AVE

OCEANA BLVD

SHARP PARK RD TALBO T AVE

MOANAW AY
Water
Recycling
Plant
·|þ}35
·|þ}1
MILES
0 1/4 1/2 1 2
Source: Department of Conservation, 2022;
City of Pacifica, 2020; San Mateo County, 2020;
Dyett & Bhatia, 2020.

Figure 8-X:

Mapped Landslides
Planning Area
City Limits
Landslide

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Sharp Park Specific Plan
Final Environmental Impact Report
SCH: 2012022046
May 25, 2022
City of Pacifica

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Packet Pg. 861 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 1 Introduction
This Program Final Environmental Impact Report (EIR) has been prepared by the City of Pacifica (City) in accordance with the California Environmental Quality Act (CEQA). The City is the lead agency responsible for ensuring that the proposed City of Pacifica General Plan Update and Sharp Park Specific Plan (“Plan” or “Proposed Project”) complies with CEQA.

1.1 Purpose
The Final EIR includes the Draft EIR and this document, which includes comments on and responses to comments on the Draft EIR, and minor corrections and clarifications to the Draft EIR.

It is intended to disclose to City decision makers, responsible agencies, organizations, and the general public, the potential impacts of implementing the proposed General Plan and Sharp Park Specific Plan (also referred to as the “General Plan,” “Proposed Plan,” or “Proposed Project”). This program level analysis addresses potential impacts of activities associated with implementation of the General Plan, which are described in Chapter 2: Project Description, of the Draft EIR.

The primary purpose of the Final EIR is to revise and refine the environmental analysis in the Draft EIR, published January 7, 2022 in response to comments received during the public review period.

The extended review period for the Draft EIR (State Clearinghouse No. 2012022046) ran for 58 days, from Monday, January 10, 2022 to March 8, 2022.

This document, combined with the redlined Draft EIR, constitutes the Final EIR on the project.

This Final EIR amends and incorporates by reference the Draft EIR. The Draft EIR, along with the City of Pacifica General Plan, are available at the City’s General Plan Update webpage at the following link:
https://www.planpacifica.org/project-docs
The Draft EIR contains some impacts that are significant and unavoidable despite mitigating policies, specifically impacts to transportation. Irretrievable commitments of non-renewable resources associated with the Project are identified in the Draft EIR for the resource topics of air quality, water consumption, energy sources, and construction-related impacts. Other potentially significant impacts can be avoided or reduced to levels that are less than significant through implementation of the policies identified in the Draft EIR.

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1.2 CEQA Process
Upon publication of the Final EIR, the City Council will hold public hearings to certify the EIR and to consider adoption of the proposed General Plan. Before the City Council may approve the various discretionary actions needed on the proposed Project, it must independently review and consider the information contained in the Final EIR, certifying that the Final EIR adequately discloses the environmental effects of the Plan, that the Final EIR has been completed in conformance with CEQA, and that the decision-making body of the Lead Agency independently reviewed and considered the information contained in the Final EIR. Certification of the Final EIR would indicate the City’s determination that the Final EIR adequately evaluates the environmental impacts that could be associated with the General Plan.

For impacts identified in the EIR that cannot be reduced to a level that is less than significant, the City must make findings and prepare a Statement of Overriding Considerations for approval of the Project if specific social, economic, or other factors justify the Plan’s unavoidable adverse environmental effects.

If the City decides to approve the proposed Project for which the Final EIR has been prepared, it will issue a Notice of Determination.

The City of Pacifica has prepared this document pursuant to CEQA Guidelines Section 15132 which specifies that the Final EIR shall consist of:
• The Draft EIR or a revision of the Draft
• A list of persons, organizations, and public agencies commenting on the Draft EIR • Comments and recommendations received on the Draft EIR • The response of the Lead Agency to significant environmental points raised in the review process
• Any other information added by the Lead Agency
This Final EIR incorporates comments from public agencies and the general public. It also contains the Lead Agency’s responses to those comments. Copies of the Final EIR have been provided to agencies and other parties that commented on the Draft EIR or have requested the Final EIR.

The Final EIR is also available online at:
https://www.planpacifica.org/project-docs.

1.3 New Information in the Final EIR
If significant new information is added to an EIR after notice of public review has been given, but before final certification of the EIR, the Lead Agency must issue a new notice and recirculate the EIR for further comments and consultation. None of the corrections or clarifications to the Draft EIR identified in this document constitutes significant new information pursuant to Section 15088.5 of the CEQA Guidelines.

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The new information added to this EIR merely clarifies and makes insignificant changes to an adequate EIR. Specifically, the new information, corrections, or clarifications presented in this document do not disclose that:
• A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;
• A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance; • A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it; or • The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

As a result, a recirculation of the Draft EIR is not required. Information presented in the Draft EIR and this document support this determination.

1.4 Organization
This document contains the following components:
• Chapter 2 provides master responses to comments raised in multiple comment letters from the Draft EIR. The master responses address comments related to general issues that are common throughout several comment letters. The intent of a master response is to provide a comprehensive response to an issue so that all aspects of the issue are addressed in a coordinated, organized manner in one location and avoid repetition. • Chapter 3 lists all of the agencies, organizations and individuals that submitted written comments on the Draft EIR, reproduces all comments, provides a unique number for each EIR comment in the page margin, and provides numbered responses to comments. • Appendix A contains attachments to the Comments in Chapter 2. • Appendix B contains the redlined DEIR.

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Packet Pg. 865 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 1 2 Master Responses
Numerous comments raised common concerns or questions that are most appropriately answered or clarified in one comprehensive or “master” response. For this Final EIR, the issues listed in Table 2.1-1 are addressed in Master Responses, lettered MR-1 to MR-7. The intent of the Master Responses is to give a single, comprehensive response to the recurring comments to improve readability of the document by avoiding repetition and multiple cross-references. Many of the individual responses refer back to these Master Responses.

Table 2.1-1: Master Response List
Master Response Title Page Number
MR-1 EIR Comments vs. Planning-Related Comments 1
MR-2 Programmatic EIR and Level of Detail Analysis 2
MR-3 Buildout and RHNA 4
MR-4 Undeveloped San Pedro Avenue Sites 5
MR-5 Wildfire 10
MR-6 Environmentally Sensitive Habitat Areas (ESHA) 12
MR-7 Emergency Access 17
MASTER RESPONSE 1: EIR COMMENTS VS. PLANNING-RELATED COMMENTS Some of the comments received during the comment period were expressions of support of or opposition to the content of Proposed Plan, rather than comments on the adequacy of analysis in the draft environmental impact report (DEIR). This response clarifies the City’s legal obligation to address California Environmental Quality Act (CEQA) related comments and describes how the City will respond to General Plan or Specific Plan-related questions or issues raised.

Public Resources Code Section 21091(d) (California Environmental Quality Act (CEQA)) and CEQA Guidelines Section 15088 require that the lead agency evaluate comments received during the noticed comment period and prepare a written response for each comment relating to any significant environmental issues raised in the DEIR. The written responses presented in this final environmental impact report (FEIR) describe the nature of any significant environmental issues raised in the comments and provide a good-faith, reasoned response to each comment. The range of responses includes providing clarification on the DEIR, making factual corrections, explaining why certain comments may not warrant further response, or simply acknowledging the comment for consideration by the decision-making bodies.

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Packet Pg. 866 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 2 At least 10 days prior to certifying an environmental impact report, the City must provide a written proposed response to a public agency on comments made by that agency which conforms with the requirements of CEQA.

As noted above, CEQA only requires responses to comments on the significant environmental issues raised in a DEIR, rather than to comments on the merits of the proposed project or in response to general reference materials submitted in support of comments. However, in recognition of the value of public input and the significant community interest associated with the General Plan update and Sharp Park Specific Plan, City staff will present a summary of General Plan and Specific Plan-related comments received during the public comment period to City decision-makers at public hearings for adoption of the Proposed Plan.

Additionally, to the maximum extent practicable with consideration of the City’s limited staff resources and the timeline for action on the proposed project, City staff will strive to provide thematic responses to all public comments received on issues unrelated to the DEIR. Importantly, all comments received – whether related to the General Plan update and Sharp Park Specific Plan or the DEIR - will be included in the FEIR and become part of the public record.

Consideration of project merits is important and the decision makers in the City of Pacifica will consider all comments regarding the merits as part of deliberations on the proposed project and when making any necessary findings. The Planning Commission and City Council will hold publicly‐noticed hearings to consider action on the project, which will include consideration of the project merits.

MASTER RESPONSE 2: PROGRAMMATIC EIR AND LEVEL OF DETAIL OF ANALYSIS Several comments claim that the DEIR does not provide adequate environmental analysis at the site level.

This master response is prepared to clarify the role of this DEIR and the level of detail of analysis required for a programmatic document.

The Pacifica General Plan EIR is a program EIR, defined in Section 15168 of the CEQA Guidelines as: “[An EIR addressing a] series of actions that can be characterized as one large project and are related either: (1) Geographically; (2) A[s] logical parts in the chain of contemplated actions; (3) In connection with the issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program; or (4) As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental impacts which can be mitigated in similar ways.” The CEQA Guidelines in Section 15618 further provide a discussion of the advantages of a program EIR, which include use as a starting point for environmental review with later activities, use with subsequent EIRs and negative declarations, and noticing for later activities:

Advantages. Use of a program EIR can provide the following advantages. The program EIR can: (1) Provide an occasion for a more exhaustive consideration of effects and alternatives than would be practical in an EIR on an individual action; (2) Ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis, (3) Avoid duplicative reconsideration of basic policy considerations, (4) Allow the Lead Agency to consider broad policy alternatives and program-wide

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Packet Pg. 867 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 3 mitigation measures at an early time when the agency has greater flexibility to deal with basic problems or cumulative impacts, and (5) Allow reduction in paperwork.

Use with Later Activities. Subsequent activities in the program must be examined in the light of the program EIR to determine whether an additional environmental document must be prepared. (1) If a later activity would have effects that were not examined in the program EIR, a new Initial Study would need to be prepared leading to either an EIR or a Negative Declaration. (2) If the agency finds that pursuant to Section 15162, no new effects could occur or no new mitigation measures would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document would be required. (3) An agency shall incorporate feasible mitigation measures and alternatives developed in the program EIR into subsequent actions in the program. (4) Where the subsequent activities involve site specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were covered in the program EIR. (5) A program EIR will be most helpful in dealing with subsequent activities if it deals with the effects of the program as specifically and comprehensively as possible. With a good and detailed analysis of the program, many subsequent activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required.

Use with Subsequent EIRs and Negative Declarations. A program EIR can be used to simplify the task of preparing environmental documents on later parts of the program. The program EIR can:
(1) Provide the basis in an Initial Study for determining whether the later activity may have any significant effects; (2) Be incorporated by reference to deal with regional influences, secondary effects, cumulative impacts, broad alternatives, and other factors that apply to the program as a whole. (3) Focus an EIR on a subsequent project to permit discussion solely of new effects which had not been considered before.

Notice with Later Activities. When a law other than CEQA requires public notice when the agency later proposes to carry out or approve an activity within the program and to rely on the program EIR for CEQA compliance, the notice for the activity shall include a statement that: (1) This activity is within the scope of the program approved earlier, and (2) The program EIR adequately describes the activity for the purposes of CEQA.

A program EIR differs from a project EIR, which is the most common type of EIR and examines the environmental impacts of a specific development project. A project EIR “should focus primarily on the changes in the environment that would result from the development project [and] examine all phases of the project including planning, construction, and operation.” (CEQA Guidelines, Section 15161; In re Bay Delta etc. (2008) 43 Cal.4th 1143, 1169.)
A program EIR can be used as the basic general environmental assessment for an overall program of projects such as the Pacifica General Plan and Sharp Park Specific Plan intended to be developed over a 20-year

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Packet Pg. 868 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 4 planning horizon. A program EIR has several advantages. First, it provides a basic reference document to avoid unnecessary repetition of facts or analysis in subsequent project-specific assessments. Second, it allows the lead agency to look at the broad, regional impacts of a program of actions before its adoption and eliminates redundant or contradictory approaches to the consideration of regional and cumulative effects.

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

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

MASTER RESPONSE 3: BUILDOUT AND REGIONAL HOUSING NEEDS ALLOCATION (RHNA) Several comments claim that the DEIR underestimates the potential environmental impacts of the General Plan because buildout projections do not use estimates of maximum theoretical buildout or provide capacity to address Pacifica’s Cycle 6 Regional Housing Needs Allocation (RHNA). This master response has been prepared to clarify the purpose and uses of buildout projections in the CEQA process and to correct mischaracterizations in the public comments regarding the adequacy of buildout projections in the DEIR.

Buildout projections represent a forecast of the amount of residential and non-residential development likely to result from implementation of the Proposed Plan and they provide a reasonable basis for quantifying potential environmental impacts of the Proposed Plan. In the DEIR analysis, projected 2040 buildout is used as the basis for technical modeling of air quality and GHG emissions, noise, vehicle miles travelled (VMT), and utilities capacity, as well as for an assessment of public services capacity among other topics.

For the DEIR, a projection of likely buildout of the Proposed Plan was developed based on the realistic potential for development in the Planning Area. As noted on DEIR p. 2-20, buildout is calculated based on assumptions about new residential and non-residential development that could be built under the Plan’s land use designations and their respective densities and intensities, adjusted to match expected demand as assessed through an adjusted regional projection from the 2019 Association of Bay Area Governments 2040 growth forecasts. To identify areas of possible change, vacant and underutilized parcels were identified, and capacity was projected based on economic and market conditions, historical growth trends, and approved development in the pipeline.

Buildout projections were calculated on a parcel basis; however, the assumptions for particular sites do not guarantee that any given site will be developed or redeveloped with that use or assumed density during the planning period, as future development will rely primarily on each property owner’s initiative.

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Packet Pg. 869 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 5 Cumulatively though at the citywide level these projections represent a reasonably foreseeable basis for assessing the environmental impacts that could result from Proposed Plan implementation.

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

Consistent with that guidance, DEIR buildout projections do not use the theoretical buildout of each parcel to the maximum extent allowed under zoning because that would not represent a reasonably foreseeable forecast. Parcel dimensions or the existence of environmental constraints will likely preclude many properties from being built out to the maximum intensity allowed and historical trends in the city indicated that developments are typically approved and constructed at densities and intensities below the maximum.

Therefore, it is unreasonable to assume every parcel in the city will be built out at the maximum permitted under the applicable land use designations. Furthermore, using maximum theoretical buildout as the basis for the CEQA analysis would exaggerate impacts and result in mitigation measures requiring the construction of road and utility infrastructure in excess of what is actually needed to support growth resulting from the Proposed Plan. Therefore, the DEIR correctly used a reasonably foreseeable forecast of buildout under the Proposed Plan as the basis for the environmental analysis.

With respect to the second claim that the buildout projections used in the DEIR are inadequate because they do not accommodate Pacifica’s Sixth Cycle RHNA, the City notes that the Proposed Plan is a technical update to the 2014 Draft General Plan Update prepared previously and that the scope of the project did not include substantial land use changes outside of the Sharp Park Specific Plan area or include community engagement to inform such changes. As described on DEIR p. 1-2, the 2014 General Plan update process began with a visioning phase, initiated by the City of Pacifica in the spring of 2009. This project was carried out almost to adoption, and then put on hold in 2014; work resumed on the General Plan update in February 2019, including the addition of a specific plan for the Sharp Park area. In the summer of 2019, a period of community outreach sought to re-familiarize community members with the Plan Pacifica process and work to date and gather more information to reflect more current community priorities.

At a joint study session on September 3, 2019, the City Council reviewed a limited set of land use changes developed on the basis of community outreach conducted in 2019 and directed City staff and consultants to update the 2014 Draft General Plan accordingly and prepare a Draft EIR. Subsequently, in May 2021 the Association of Bay Area Governments (ABAG) released draft RHNA numbers for Pacifica. These draft RHNA numbers were adopted as final RHNA numbers by the ABAG Board in December 2021. To accommodate these new RHNA numbers, it is likely that Pacifica will need to consider additional land use changes; however, such changes were beyond the scope of the Proposed Project. Rather than start the General Plan and EIR process over again and delay adoption by an additional two years, the City elected to proceed with the Proposed Plan knowing that additional land use changes, community engagement and environmental analysis will be needed for the Housing Element. The updated General Plan will provide a better basis for the subsequent Housing Element update. Furthermore, as noted in the master response

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Packet Pg. 870 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 6 “Level of Detail of Analysis and Programmatic Nature of the Draft EIR,” certification of the DEIR will provide a useful programmatic starting point for consideration of any additional land use changes that may be needed to accommodate the City’s 6th cycle Housing Element update to accommodate its RHNA.

Separately, the City is preparing to initiate its 6th cycle Housing Element update. The Housing Element update and development of the required housing sites inventory will involve extensive community input and be subject to separate CEQA review. At this point, the City has not identified the locations of any new housing sites, so they cannot be analyzed as part of this CEQA process. The Housing Element CEQA document will analyze the cumulative effects of implementing the Housing Element Update – including any associated changes to the land use diagram - in combination with the Proposed Plan. Therefore, this approach does not constitute “piecemealing,” or dividing a large project into separate parts, each of which might have individually minimal environmental consequences.

MASTER RESPONSE 4: UNDEVELOPED SAN PEDRO AVENUE SITES
Nearly two-thirds of the overall total public comments on the DEIR related to two undeveloped properties under different ownership, the 0.92-acre 505 San Pedro Avenue site and the approximately 5.5-acre “undeveloped San Pedro Avenue” site. Several of these comments claim that designating the 505 San Pedro Avenue and undeveloped San Pedro Avenue sites as Coastal Residential Mixed Use in the proposed General Plan would result in significantly greater environmental impacts than other land use designations to be applied, such as Low Intensity Visitor Serving Commercial. Further, commenters claim that the designation is not consistent with the Coastal Act, and that the DEIR did not adequately analyze potential biological, geological, and hydrological impacts associated with development on the site pursuant to the Proposed Project. This Master Response has been prepared to clarify what can be developed on this site under the Proposed Project, to address the mischaracterization of Coastal Act inconsistency, and to address perceived inadequacies in analysis of impacts related to biological resources, geological hazards, and coastal flooding on the site.

The site’s proposed designation would allow for development similar to that currently allowed in the 1980 LCLUP and the existing General Plan. Under the current, adopted General Plan, the site has a Commercial land use designation, which “[i]ndicates the variety of potential commercial uses the City might attract, including visitor-serving commercial, retail commercial, office, heavy commercial and light industrial. The type of commercial use recommended for a site is stated in the General Plan Land Use Description” (Pacifica General Plan, p. 33). Residential uses are also permitted above commercial uses, at a density of up to 1 unit per 2,000 square feet of site area, which translates to approximately 22 units per acre. The Proposed Project introduces a new Coastal Residential Mixed Use (CRMU) designation which would apply to the “undeveloped San Pedro Avenue” site. The proposed CRMU designation would establish a set of permitted uses that is more closely tailored to visitor orientation and to the coastal setting, with building form guidance that would result in small-scale buildings more suited to the neighborhood context, as compared to the existing zoning, which permits a wide range of commercial activities from retail shops and fast food restaurants, to home appliance and furniture sales and veterinary hospitals and clinics. As described in the Land Use Framework section of the Proposed Plan, “the Coastal Residential Mixed Use (CRMU)

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Packet Pg. 871 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 7 designation is intended for sites in the Coastal Zone with residential mixed use development potential, including housing at a range of densities, mixed use with housing over retail, and/or small-scale visitororiented commercial uses such as vacation rental or time-share units. Hotels are not permitted. Coastal access and public open space must also be provided, and environmental resources must be evaluated and protected. Sites may be developed up to an overall density of up to 15 units per gross acre, with clustering and sensitive site planning. Non-residential development may have an FAR up to 0.5 FAR. The total FAR (residential and non-residential) cannot exceed 1.0” (proposed General Plan, p. 4-7).

The proposed CRMU designation for the undeveloped San Pedro Avenue site is complemented with proposed Policy LU-I-29, which provides direction for the zoning standards through which it would be implemented:
“Undeveloped San Pedro Avenue Site. Establish a Coastal Residential Mixed Use zoning district to allow small-scale visitor-oriented commercial uses as a stand-alone project without any residential development, or small-scale visitor-oriented commercial uses with residential development at a density range of three to five units per gross acre. Housing may be clustered, and uses may be mixed, vertically or horizontally.

Residential uses may be constructed attached to or detached from commercial uses, provided the overall site contains both commercial and residential uses. Development must include public coastal access and must provide public open space.

A wetland survey conducted according to the requirements of Coastal Commission regulation 13577 (Title 14, California Code of Regulations) is required to delineate potential wetlands on the site as part of the development application and environmental review process. An assessment of potential geotechnical hazards must also be part of the development application and environmental review process, including assessment of the Ocean Shore railroad berm under hazard and vulnerability scenarios consistent with policies in Chapters 7 and 8.”
Therefore, given that the Proposed Project would permit a more circumscribed set of land uses as compared to the current General Plan with less potential for pollution (as compared, for instance, to heavy commercial and light industrial uses) and a reduced development intensity – up to 5 units per acre and 15 units per acre for the undeveloped San Pedro Avenue and 505 San Pedro Avenue sites, respectively, as compared to the current General Plan which would allow up to 22 units per acre – the City notes that the proposed CRMU designation would likely result in reduced environmental impacts on the site. Further, the DEIR considered alternatives to the Proposed Project which could further reduce or avoid environmental impacts on these sites. On pages 4-12 through 4-32, the DEIR analyzes the impacts of Alternative 2: Conservation and Redevelopment under which the 505 San Pedro Avenue site would be designated Conservation, and a portion of the undeveloped San Pedro Avenue site is designated as a park, as shown in Figure 4.2-3. The purpose of this alternative was to create several mixed use nodes between four smaller centers in a sequence along the Coast Highway and a limited amount of development on the Quarry site, with the great majority conserved as habitat or open space. However, as discussed on page 4-32 of the DEIR, while Alternative 2 would result in fewer environmental impacts overall than the Proposed Project, it would not satisfy project objectives for establishment of a strong City center, integration of the Quarry site into the City’s fabric, and

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Packet Pg. 872 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 8 provision of residential development needed for future housing planning, and it was therefore determined to be infeasible.

Several commenters assert that applying a “Conservation” or “Low Intensity Visitor Serving Commercial” designation to the whole of the undeveloped San Pedro Avenue and 505 San Pedro sites would result in lesser environmental impacts. However, designation of the entirety of these sites as Conservation would limit economic use of the property. Also, specific to the 505 San Pedro site in particular, the site does not have the “large land areas” expected to support recreational uses assumed for sites designated as Low Intensity Visitor Serving Commercial. The Pacifica City Council weighed these considerations and adopted the LCLUP on February 24, 2020, which included both San Pedro Avenue sites with a CRMU designation, as well as the implementing policy LU-I-24.

Some commenters assert that the DEIR did not analyze site-specific impacts. As noted in Master Response 2, the DEIR is a programmatic document. It presents a citywide assessment of the potential impacts of the proposed Pacifica General Plan. Given that the specific details of projects pursuant to the Proposed Project cannot be known at this time, the DEIR does not assess project-specific impacts of potential future projects, for which project-level CEQA review will be required to the extent such projects may result in environmental impacts not considered in the DEIR. Additionally, LCLUP updates are exempt from CEQA because the Coastal Commission LCP certification process is “functionally equivalent” to the CEQA process (State Public Resources Code Sections 21080.5 and 21080.9, and State CEQA Guidelines Sections 15250, 15251(f) and 15265). However, as explained in detail below and throughout the DEIR, the DEIR does analyze at a programmatic level the potential environmental impacts resulting from proposed land use changes for the whole of the Planning Area including the Coastal Zone, and considers whether implementation of the Proposed Project could cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect (in this case, the Coastal Act).

Updates to the General Plan and Local Coastal Land Use Plan (LCLUP) have been conducted in tandem.

All policies and land uses in the LCLUP are in the proposed General Plan. To the extent the General Plan Update proposes any policies beyond those which were sent to the California Coastal Commission for review and certification, a subsequent LCP amendment would be necessary to make the LCP consistent with the General Plan. The Coastal Commission has permitting jurisdiction for certain areas within the Coastal Zone and appellate jurisdiction over many other areas in the Coastal Zone, and projects are required to demonstrate compliance with Coastal Act and/or certified LCLUP policies regardless of whether they are located in the Coastal Commission’s permit jurisdiction, its appellate jurisdiction, or within the City’s permit jurisdiction pursuant to the City’s certified LCP. Importantly, the City would be unable to issue any coastal development permits for areas within its permit jurisdiction in the Coastal Zone until the Coastal Commission has certified that the updated LCLUP (reflective of identical policies in the Proposed Project) is consistent with the Coastal Act.

Commenters stated that that the CRMU designation for this area was incompatible with the following Coastal Act policies that are also related to environmental impacts:

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Packet Pg. 873 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 9 • Cal. Pub. Resources Code § 30221: 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.
• Cal. Pub. Resources Code § 30222: 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.
• Cal. Pub. Resources Code § 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.
• Cal. Pub. Resources Code § 30251: 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. • Cal. Pub. Resources Code § 30253: 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.

Regarding land use compatibility and parks services impacts raised in Coastal Act Policy 30221 and 30221, as described on pages 3.1-12 and 3.12-24-25 of the DEIR, the proposed CRMU designation establishes a set of uses that is more closely tailored to visitor orientation and to the coastal setting, and building form guidance that would result in small-scale buildings more suited to the neighborhood context, compared to the existing zoning, while allowing the property owner some economic benefit to their property. Policy LUI-29, along with OC-I-9 (Parks as Part of Future Development, DEIR p. 3.12-40) adequately address these policies and reduce these impacts to the extent feasible for a programmatic document.

As noted in Master Response 6: Environmentally Sensitive Habitat Areas (ESHA), compliance with applicable federal and State regulations, in addition to policies in the Proposed Project, reduce any potential impacts to ESHA to a less than significant level. Policy LU-I-29 also requires delineation of potential wetlands on the undeveloped San Pedro Avenue site as part of the development application and environmental review process. These regulations and policies, taken together, are compatible with Coastal Act policy 30240.

As noted on DEIR p. 3.9-13, the land use changes in the Proposed Project will not substantially degrade the existing visual character or quality of Pacifica and would not conflict with applicable zoning and regulations

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Packet Pg. 874 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 10 governing scenic views. All existing open space areas are preserved and scenic resources are protected under the Proposed Project. Policies and design guidelines included in the Proposed Project will sensitively govern the formal characteristics of new development to ensure they are compatible with existing neighborhood character and quality. The Coastal Act requires scenic and visual qualities of coastal areas to be considered and protected as a resource of public importance; compliance with these policies and with zoning requirements reduce impacts to less than significant and are not in conflict with Coastal Act policy 30251.

Regarding impacts to Coastal Act Policy 30253, the DEIR adequately analyzes impacts that could result from flooding, seismic hazards, and wildfire (Please see Master Response 5: Wildfire).

The DEIR includes a robust analysis of potential liquefaction impacts on p. 3.6-25 and 3.6-26, noting "The impacts from ground failure, including liquefaction, from development of land uses associated with the General Plan would be addressed through site-specific geotechnical studies prepared in accordance with [California Building Code (CBC)] requirements and standard industry practices. Subsequent development would be required to conform to the current seismic design provisions of the CBC to minimize losses from ground failure as a result of an earthquake. These future projects would also be required to adhere to proposed General Plan policies that contain seismic safety requirements and help strengthen existing code requirements such as referencing known hazard areas that must contain measures to resist ground failure through modern construction techniques. Therefore, the potential impact related to seismically related ground-failure including liquefaction is less than significant." The undeveloped San Pedro Avenue site is in a Seismic Hazard Zone for liquefaction, as shown in Figure

3.6-1. The DEIR notes that on p. 3.6-18 and 3.6-19, "Geotechnical investigations conducted within Seismic Hazard Zones must incorporate standards specified by the California Geologic Society (CGS) Special Publication 117, Guidelines for Evaluating and Mitigating Seismic Hazards".

While the undeveloped San Pedro Avenue and 505 San Pedro Avenue sites are not within a FEMA floodplain (as shown in Figure 3.5-1), they could be adversely affected by flooding due to sea level rise. Prior to experiencing inundation hazards from a higher sea level rise, some developed areas are likely to be subject to changes in flooding hazards as stated on page 3.5-28 of the Draft EIR. Low coastal floodzone areas could expand over time as sea levels rise. The use of maps such as those found in the 2009 California Climate Change report (The Impacts of Sea-Level Rise on the California Coast) are not recommended to be used in place of official FEMA FIRM floodzone maps. The FIRM maps are periodically updated and future maps will likely incorporate the latest findings of sea level rise as it becomes more defined. Nonetheless, the Draft EIR on page 3.5-8 and 3.5-11, identifies the areas within the City that could be subject to increased flooding hazards (i.e., areas of West Linda Mar, lower Pedro Point, Rockaway Beach, West Sharp Park and the Sharp Park Golf Course). Further, the proposed policies including SA-G-4 (Key Coastal Act Policies), SA-G-5 (Sea Level Rise and Best Available Science), SA-I-15 (New Development in Coastal Zone), SA-I-28 (Vulnerability Identification and Mapping), and SA-I-30 (Monitoring Shoreline Change) specifically address the potential hazards of sea level rise and provide the flexibility in making the appropriate adjustments as the science improves to ensure that future development is adequately protected.

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Packet Pg. 875 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 11 Overall, the City notes that the CRMU designation envisions development in a manner that is consistent with the objectives of the Coastal Act, and the DEIR adequately analyzes potential impacts to plan compatibility, biological resources, seismic hazards, and coastal flooding, and makes appropriate determinations on the basis of substantial evidence. Further, the City reiterates that any development on the undeveloped San Pedro Avenue or 505 San Pedro Avenue sites pursuant to the Proposed Project will be required to comply with all applicable federal, State and local regulations and policies, including for biological resources (including the Federal Endangered Species Act, California Endangered Species Act, Section 404 of the Clean Water Act, San Francisco Regional Water Quality Control Board, California Coastal Commission) and hydrological or geological impacts (including the National Flood Insurance Act, California Coastal Act, General Construction Permits and Dewatering Permits, San Mateo Countywide Stormwater Pollution Prevention Program (SMCWPPP), the Multi-Jurisdictional Local Hazard Mitigation Plan, and the California Building Code. Compliance with these regulatory frameworks, coupled with the beneficial impacts of the Proposed Plan policies listed above, reduce impacts to less than significant.

MASTER RESPONSE 5: WILDFIRE
Numerous comments expressed concern that the Proposed Project’s analysis of wildfire risk was inadequate, including inadequacies resulting from alleged map errors or from a failure to consider additional data beyond California Department of Forestry and Fire Protection (CALFIRE) Very High Fire Severity Zone maps, such as Wildland Urban Interface (WUI) mapping. This master response has been developed to address comments from the public regarding these perceived inadequacies in mapping and analysis, to clarify the requirements for analysis of wildfire risk pursuant to CEQA and the sources of data used, and to correct factual errors and misrepresentations presented in those public comments.

The DEIR characterizes wildfire hazards within the Planning Area on pages 3.11-4 through 3.11-6 and 3.14- 1 through 3.14-4, making use of data and information from CALFIRE and from the Multi-Jurisdictional Local Hazard Mitigation Plan (MJ-LHMP) for San Mateo County. The characterization in the DEIR includes a description of vegetation in the Planning Area, a history of wildfire occurrence in the Planning Area, the probability of a fire occurring in the future, and identification of Fire Hazard Severity Zones designated by CALFIRE based on factors such as fuel, slope, and weather. Two maps are included:
• Figure 3.11-2, which shows Very High Fire Severity Zones for Local Responsibility Areas (LRAs), State Responsibility Areas (SRAs), and Federal Responsibility Areas (FRAs) as designated by CALFIRE pursuant to Government Code Section 51175. By law CALFIRE is required to designate these Fire Hazard Severity Zones, land within which is subject to various requirements in the California Building Code for the design and construction of new buildings intended to reduce the risk of loss of life and property, including requirements for building materials, defensible space clearance, and other wildland fire safety practices; and • Figure 3.14-1, which shows Fire Threat, a measure of fuel conditions and fire potential in the ecosystem, representing the relative likelihood of “damaging” or difficult to control wildfire occurring for a given area. Fire Threat is not a risk assessment by itself, but can be used to assess

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Packet Pg. 876 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 12 the potential for impacts on various assets and values susceptible to fire. Impacts are more likely to occur and/or be of increased severity for the higher threat classes.

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

WUI maps inform development of Fire Hazard Severity Zones designated by CALFIRE, and the Fire Hazard Severity Zone maps adopted by the State depict only WUI areas that include both a hazard and a housing demographic element (ie an exposure model)[1]. While CALFIRE is currently in the process of updating its mapping to incorporate improved fire science, data and mapping techniques and while that process may ultimately identify new areas where California’s defensible space standards and wildland urban interface building codes are required, updated mapping is not currently publicly available. Therefore, the data and information used in the DEIR represent the latest best available data at time of preparation.

Under CEQA, the DEIR is required to analyze effects from wildfire in two ways. First, the DEIR must analyze if the project would expose people to significant risk of loss, injury, or death involving wildland fires (Appendix G, Criterion IX (g)). Second, if the project is located in or near state responsibility areas or lands classified as very high fire hazard severity zones (Appendix G, Criterion XX(a) through (d)), it must analyze whether the project would impair an adopted emergency response/evacuation plan, exacerbate fire risk, or expose occupants to uncontrolled spread of a wildfire, pollutant concentrations from a wildfire, or post-fire hazards.

Using the latest and best available data, as shown on Figure 3.11-2[2], the DEIR identified that there are no VHFHSZ within the City limit, but that there are Fire Hazard Severity Zones in the Sphere of Influence, which are in areas of State responsibility. Further, using Fire Threat mapping available from CAL FIRE (Figure 3.14-1), as described on p. 3.14-14 of the DEIR, the DEIR identified that beyond CALFIREdesignated Fire Hazard Severity Zones, Pacifica has a substantial risk of wildland fires, with many areas of high threat within the Planning Area. However, as noted in the DEIR, development under the Proposed Plan is expected to occur predominantly in already-urbanized neighborhoods where risk is lower as compared to areas of higher fire threat. While it is possible that development could occur in the proximity of VHFHSZ and in areas that may face higher fire threat shown in Figure 3.11-2 and 3.14-1, there are numerous State regulations – including the requirements of the California Building Code and Public Resources Code - that require landowners to carry out activities such as maintaining defensible space and reducing vulnerability to damage or loss from wildfire, as noted on pages 3.11-11, 3.11-12, 3.14-5, and 3.14- 6 of the DEIR. Any new development occurring in areas that may be designated as VHFHSZ as part of future mapping efforts will be subject to these requirements. Additionally, the MJ-LHMP Annex for Pacifica also includes actions that would reduce the risk of loss or damage due to wildfire in and adjacent to fireprone areas, such as updating its Emergency Operations Plan (Action PAC-8); continuing public education outreach to neighborhoods (Action PAC-14); and Evacuating potential wildfire risk and mitigation strategy

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Packet Pg. 877 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 13 (Action PAC-18) in partnership with North County Fire Authority, as described on DEIR p. 3.14-6. Taken together, these State and local provisions provide a framework for proactively managing and reducing risk associated with wildfire in the Planning Area that is appropriate based on the programmatic nature of the DEIR.

Beyond areas of VHFHSZ, as noted in the DEIR, development occurring in areas of higher fire threat would be also subject to policies in the Proposed Plan that would reduce potential impacts, including development review and consistent inspection (policies SA-I-94 and SA_I-96), public awareness programming (policy SA-I-97), vegetation management policies related to development (policy SA-I-98), plan review in fireprone areas (policy SA-I-95), and coordination with North County Fire Authority and other agencies (SAI-91; SA-I-99; SA-I-102), as described on p. 3.11-24 of the DEIR.

Implementation of these policies together with applicable State and local regulations and measures would minimize fire risk to the maximum extent practicable, and accordingly the DEIR finds that impacts related to wildfire would be less than significant.
[1] Email correspondence with Dave Sapsis, Wildland Fire Scientist, CAL FIRE, dated April 11, 2022 [2] Figure 3.11-2 is based on the “Fire Hazard Severity Zones in SRA” map adopted by CALFIRE on November 7, 2007.

MASTER RESPONSE 6: ENVIRONMENTALLY SENSITIVE HABITAT AREAS (ESHA) Numerous comments expressed concern that the Proposed Project’s analysis of Environmentally Sensitive Habitat Areas (ESHAs) and the potential impacts to the habitat of the California Red-Legged Frog (CRLF), a federally listed Threatened Species, were not sufficiently analyzed or accounted for in the DEIR. These comments are specifically linked to the undeveloped land at/around 505 San Pedro Avenue (“505 San Pedro site” or “site”). This master response has been developed to address comments from the public regarding these perceived inadequacies, and to clarify and correct factual errors, misrepresentations, and assumptions in those public comments.

As defined in Coastal Act Section 30107.5, ESHA is "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." As noted on DEIR Figure 3.7-4, there are known occurrences of the CRLF in Pacifica, including in the vicinity of the 505 San Pedro Avenue site. Additionally, on page 3.7-17 the DEIR notes that portions of the city around Mori Point, coastal bluffs, and Sharp Park Golf Course support both CRLF as well as San Francisco garter snake and likely qualify as ESHA; however, at the time the NOP was released there was no ESHA formally delineated on the 505 San Pedro site. Subsequently, in the course of reviewing whether a Coastal Commission permit was required for development in the Coastal Zone on the 505 San Pedro site, the Coastal Commission conducted a biological study and determined that the whole of the site was ESHA; this information was presented at a hearing on March 2021. Comments allege that the DEIR analysis is inadequate because it did not acknowledge that the Coastal Commission made a determination of ESHA on the 505 San Pedro site; however, the City notes that the property owner has conducted a separate biological study by a qualified expert which concluded

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Packet Pg. 878 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 14 that the development proposed on the site would not result in direct or indirect, temporary or permanent impacts to wetlands, other waters, or any ESHA.1
In any event, irrespective of any prior findings regarding the presence of ESHA on the 505 San Pedro site, any development proposed for the site pursuant the Proposed Plan would be reviewed pursuant to applicable law and required to comply with all applicable federal, state, and local regulations. As noted on pages 3.7-41, these include:
• Federal Endangered Species Act. Pursuant to the requirements of FESA, a federal agency reviewing a proposed project within its jurisdiction must determine whether any federally listed, threatened, or endangered species, or species proposed for federal listing may be present in the project area and determine whether the proposed project will have a potentially significant impact on such species.

In addition, the federal agency is required to determine whether the project is likely to jeopardize the continued existence of any species proposed to be listed under FESA or result in the destruction or adverse modification of critical habitat proposed to be designated for such species (16 USC 1536[3], [4]). Projects that are subject to CEQA and have the potential to significantly impact listed species (as determined in an Initial Study or Environmental Impact Report) must consult with CDFW to get an Incidental Take Permit, without which development cannot legally occur. The permit requires that permit applicants design, implement, and secure funding for a Habitat Conservation Plan or "HCP" that minimizes and mitigates harm to the impacted species during the proposed project.
• California Endangered Species Act. Section 2080 of the California Fish and Game Code prohibits the taking of plants and animals listed under the authority of the California Endangered Species Act of 1984 (CESA). Under CESA, CDFG maintains a list of threatened species and endangered species (California Fish and Game Code 2070). The CDFG also maintains a list of candidate species that CDFG has formally noticed as being under review for addition to either the list of endangered species, the list of threatened species, or the list of “species of special concern,” which all serve as “watch lists.” Pursuant to the requirements of CESA, an agency reviewing a project within its jurisdiction must determine whether any state-listed endangered or threatened species may be present in the project area and determine whether the proposed project will have a potentially significant impact on such species. CESA prohibits the take of any species of wildlife designated by the California Fish and Game Commission as endangered, threatened, or candidate species. CDFW may authorize an Incidental Take Permit of any such species if certain conditions are met, without which development cannot legally occur. Incidental Take Permits allow a permittee to take a CESAlisted species if such taking is incidental to, and not the purpose of, carrying out an otherwise lawful activity. These permits are most commonly issued for construction, utility, transportation, and other infrastructure-related projects. Permittees must implement species-specific minimization and avoidance measures, and fully mitigate the impacts of the project. (Fish & G. Code § 2081 (b); Cal. Code Regs., tit. 14, §§ 783.2-783.8)
1 The Coastal Commission determined that a Coastal Commission permit was required for development at the 505 San Pedro Site, and then denied that permit. The property owner has filed suit to challenge the Coastal Commission’s action. That suit does not affect how the City analyzes the present issues.

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Packet Pg. 879 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 15 • California Coastal Commission. The Coastal Act restricts development within ESHAs to only those uses that are dependent on the resource and requires that ESHAs be protected against significant disruption of habitat values. It also requires that development in areas adjacent to ESHAs and parks and recreation areas be sited and designed to prevent degradation of those areas and to be compatible with the continuance of those habitat and recreation areas. If ESHA is determined to be on a site, the CCC may deny a project’s coastal permit, without which development cannot legally occur.

Further, the Proposed Plan also contains numerous additional policies that in combination with applicable federal, State and local regulations would reduce impacts to special status species and habitat (including ESHA) to a less than significant level. These include policies require written findings that it is consistent with all LCLUP policies (LU-I-3), protecting ESHAs from development (CO-G-11) and requiring sites to conduct a habitat survey to verify ESHA or potential ESHA (CO-I-27; CO-I-31); management of ESHA with specific regulations (CO-I-28) or specific measures (CO-I-26); and protection of California red legged frog during any construction activities (CO-I-35).

Overall, development pursuant to the Proposed Plan would be required to comply with federal and state regulations regarding endangered species, which would require take permits prior to any development occurring. Implementation of Proposed Plan policies listed above would further reduce the potential for impacts to special status species and habitats, and the DEIR correctly determined that associated impacts would be reduced to the maximum extent practicable and would be less than significant. Further, the City notes that there is a disagreement between experts regarding the presence of ESHA on the 505 San Pedro site and the City would have the opportunity to weigh all substantial evidence prior to rendering a future permit decision to authorize development on the site in the future pursuant to the Proposed Project. As such, the Coastal Commission determination of March 2021 does not constitute significant new information which would require recirculation of the DEIR.

MASTER RESPONSE 7: EMERGENCY ACCESS
Several public comments on the DEIR expressed concern that emergency access during a hazard event, especially for wildfire or tsunami evacuation, was not sufficiently analyzed or accounted for in the DEIR or that impact assessment was incorrectly deferred and would be assessed only at a project level. This master response addresses comments from the public regarding these perceived inadequacies, and clarifies and corrects factual errors, misrepresentations, and assumptions in those public comments.

Under CEQA, the DEIR is required to analyze impacts on evacuation in two ways. First, the DEIR must analyze if the project would result in inadequate emergency access (Appendix G, Criterion V (g)). Second, it must analyze if the project would substantially impair an adopted emergency response plan or emergency evacuation plan. The Proposed Project includes policies that complement other existing, adopted plans addressing emergency response and emergency evacuation, including the 2021 Multijurisdictional Local

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Packet Pg. 880 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 16 Hazard Mitigation Plan (MJ-LHMP), the Pacifica All Hazards & Evacuation Plans, and the City of Pacifica Emergency Operations Plan.

As noted on DEIR p. 3.5-45, implementation of the Proposed Project and increases in regional travel passing through Pacifica would increase the amount of vehicular traffic in and around Pacifica and may therefore increase the number of potential emergency access conflicts in the event of a disaster, which could result in a potentially significant impact. However, potential improvements to the roadway network such as the Manor overcrossing project highlighted in proposed policy CI-I-9, would contribute to mitigating the impacts of additional traffic on emergency response times. Furthermore, traffic signal preemption devices on emergency vehicles, as well as emergency sirens, will improve emergency response times in accordance with proposed policy SA-G-9 even in instances of intersection congestion during peak commute periods. Close consultation with Caltrans and the San Mateo County Transportation Authority will help to improve congestion (policies CI-G-7 and CI-G-9) and will ensure that congestion management solutions are implemented with any potential congestion increases. Other Proposed Plan policies improve mobility connections between communities and increase evacuation capacity, such as policy CI-I-1, CI-I-2, CI-I-3, and CI-I-4. The Proposed Project also provides for improved emergency access through policies that provide additional access routes and require new streets and developments meet adopted emergency access standards (CI-I-25, SA-I-94, SA-I-103, and SA-I-104). Policy SA-A-106 also addresses periodic public information programs to raise awareness of the City’s emergency preparedness programs, including evacuation routes. Community evacuation education (SA-I-35) and agency coordination (SA-I-102) also help to ensure inadequate emergency access does not occur. Given the existing framework of adopted plans addressing emergency response combined with the beneficial effects of proposed General Plan policies, implementation of the Proposed Project will ensure that inadequate emergency access does not occur and will result in a less-than-significant impact.

Further, emergency access for individual developments pursuant to the Proposed Project will also be assessed at a project level through the development review process as projects are proposed, consistent with the provisions of the Municipal Code. Project level review required by the City includes site access review for emergency vehicles and traffic control plans as needed that account for emergency vehicles.

The City notes that Proposed Project policies complement numerous other existing plans in place to address natural hazard risk, emergency preparedness, and emergency evacuation. Collectively, these plans together with the proposed General Plan provide an overarching programmatic framework that addresses emergency access and evacuation. These plans include the 2021 Multijurisdictional Local Hazard Mitigation Plan (MJ-LHMP), the Pacifica All Hazards & Evacuation Plan, and the City of Pacifica Emergency Operations Plan. The 2021 MJ-LHMP annex describes important vulnerabilities related to coastal erosion and transportation/accessibility concerns related to landslide along Highway 1. The plan identifies several hazard mitigation action items that will improve emergency access in Pacifica. Such actions include updating the City’s Emergency Operations Plan; taking action to preserve and protect critical transportation infrastructure; considering climate change in infrastructure planning; evaluating potential wildfire risk and mitigation strategies; and developing and delivering business programs and public outreach programs to promote resiliency and community preparedness. The Pacifica All Hazards

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Packet Pg. 881 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 17 and Evacuation Plan grants authority and responsibilities to centralized emergency management and divides the City of Pacifica into 14 evacuation zones, each of which has its own evacuation operations plan, detailing evacuation routes, critical sites, traffic concerns, and refuge areas. This Plan includes specific routes in areas of constrained emergency access. The City’s Emergency Preparedness and Safety Commission is responsible for disaster preparedness training in Pacifica and maintains the Emergency Operations Plan, which ensures an effective and coordinated response to disasters within the city. The City also has a Community Emergency Response Team (CERT) that supplements first-responder police and fire personnel with civilian volunteers to assist with emergency evacuation facilitation in accordance with the City’s existing plans.

Therefore, compliance with the provisions of the Municipal Code and continued implementation of the 2021 Multijurisdictional Local Hazard Mitigation Plan, the Pacifica All Hazards & Evacuation Plans, and the City of Pacifica Emergency Operations Plan in combination with Proposed Project policies would ensure that inadequate emergency access does not occur from the Proposed Project, and that it would not substantially impair an adopted emergency response plan or emergency evacuation plan. As such, the DEIR correctly found that a less-than-significant impact would result.

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Packet Pg. 882 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 1 3 Comments Received
A total of 188 comments, comment letters, and emails were received during the comment period.

Comments and responses to comments are organized by Public Agency comments and responses (section A), Pacifica Organization comments and responses (section B) and Individual/Affiliation comments and responses (section C).

Each letter or summary is identified by a designator (e.g. “Letter A1”). Specific comments within each letter or summary are identified by a designator in the page margin that reflects the sequence of the specific comment within the correspondence (e.g. “A1-1” for the first comment in Letter A1). An index is provided below in Table 3-1. Click the TOC below to jump to a response. (A) Agencies .................................................................................................................................. 15 A1. Amy Dao, BAAQMD, 2/15/2022 ..........................................................................................................16 A2: Will Kanz, CDFW, 3/8/2022 .................................................................................................................21 A3: Dr. Erik Frost, CGS, 2/1/2022 ...............................................................................................................40 A4; Adrianne Carr, NCCWD, 3/8/2022 ......................................................................................................42 A5; Rob Bartoli, San Mateo LAFCO, 3/8/2022 ...........................................................................................44 A6; Julia Koppman Norton, CCC, 3/1/2022 ...............................................................................................46 Pacifica Organizations (B) ............................................................................................................ 47 B1: Judy Heldberg, Pacifica Historical Society, 2/18/2022.........................................................................48 Individuals and Affiliations (C) .................................................................................................... 54 C1: Stan Zeavin, 3/7/2022 ............................................................................................................................55 C2: Maria Martinez-Mont, 2/11/2022 .........................................................................................................62 C3: Lisa Villasenor-Volosing, 3/8/2022 ......................................................................................................63 C4: Remi Tan, 2/26/22 ..................................................................................................................................64 C5: Remi Tan, 2/2/2022 ................................................................................................................................66 C6: Clif Lawrence, 1/30/2022 .......................................................................................................................68 C7: Debra Etienne, 2/14/22 ..........................................................................................................................69 C8: Richard Grassetti, 3/8/2022 ...................................................................................................................72 C9: Bob Boles, 3/7/2022 ...............................................................................................................................73 C10: Christine Boles, 1/27/2022 ..................................................................................................................85 C11: Monica Meagher, 3/8/2022 ..................................................................................................................87

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Packet Pg. 883 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 2 C12: Jewel Walli, 3/5/2022 ...........................................................................................................................89 C13: Christine Boles, 3/8/2022 ....................................................................................................................90 C14: William Leon, 3/3/2022 .....................................................................................................................102 C15: Allison West, 3/8/2022 ......................................................................................................................108 C16: Clifford Lawrence, 2/22/2022 ............................................................................................................111 C17: Deb MacC, 2/14/2022 ........................................................................................................................112 C18: Jim Louderback, 2/28/2022 ...............................................................................................................113 C19: Peter Loeb, 3/5/22 ..............................................................................................................................114 C20: Andre Mettier, 3/8/2022 ....................................................................................................................115 C21: Gary Emich, 3/8/2022 ........................................................................................................................122 C22: Dinah Verby, 3/8/2022 ......................................................................................................................131 C23: Therese Langille, 3/9/2022 ................................................................................................................140 C24: Joanne Gold, 3/9/2022 .......................................................................................................................141 C25: Gary Furlong, 3/7/2022 .....................................................................................................................144 C26: Dina and Robert Horan, 3/7/2022 ....................................................................................................146 C27: Cathy Glenn, 3/7/2022 .......................................................................................................................147 C28: Clif Lawrence, 2/21/2022 ...................................................................................................................149 C29: Nancy Merchant, 3/3/2022 ................................................................................................................150 C30: James Kremer, 2/20/22 ......................................................................................................................151 C31: Bradley Angel, 3/7/2022 ....................................................................................................................167 C32: Andrew Meiman, 3/7/2022 ................................................................................................................172 C33: Richard Campbell, 3/8/2022 ..............................................................................................................173 C34: Richard Grassetti, 3/8/2022 ...............................................................................................................175 C35: Deb Wong, 3/11/2022 ........................................................................................................................206 C36: Patrick Mora, 3/8/2022 ......................................................................................................................208 C37: Allison West, 3/7/2022 ......................................................................................................................210 C38: Peter Loeb, 3/7/2022 ..........................................................................................................................227 C39: Paul Totah, 2/25/2022 ........................................................................................................................229 C40: Adam Mayle, 3/7/2022 .......................................................................................................................230 C41: Adam Mayle, 3/7/2022 .......................................................................................................................235 C42: Sheila Gamble-Dorn, 3/7/2022..........................................................................................................236 C43: Sam Casillas, 3/8/2022 .......................................................................................................................238 C44: Jean Turk, 3/7/2022 ...........................................................................................................................248 C45: Jonathan Cordero, Association of Ramaytush Ohlone, 3/3/2022 ...................................................250

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Packet Pg. 884 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 3 C46: Terrell Watt, 3/8/2022 .......................................................................................................................252 C47: Cindy Abbott, 3/8/2022 .....................................................................................................................318 C48: Paul Tota, 2/25/2022 ..........................................................................................................................323 C49: Christine Boles, 2/28/2022 ................................................................................................................324 C50: Karen Clark, 3/7/2022 ........................................................................................................................365 C51: Gail Benton Shoemaker, 3/1/2022 ....................................................................................................369 C52: Suzanne Moore, 3/3/2022 ..................................................................................................................371 C53: Cherie and Bruce Chan, 3/8/2022 .....................................................................................................374 C54: Christine Boles, 3/6/2022 ..................................................................................................................384 C55: Christine Boles, 3/6/2022 ..................................................................................................................413 C56: Christine Boles, 3/6/2022 ..................................................................................................................414 C57: Christine Boles, 2/17/2022 ................................................................................................................415 C58: Rich Nahass, 2/5/2022 .......................................................................................................................416 C59: Suzanne Moore, 3/5/22 ......................................................................................................................419 C60: Dustin McGahan, 1/18/2022 .............................................................................................................420 C61: Arlene Patton, 3/2/22 .........................................................................................................................421 C62: Clif Lawrence, 1/16/2022 ...................................................................................................................423 C63: Stan Zeavin, 3/2/2022 ........................................................................................................................425 C64: Christine Boles, 1/31/2022 ................................................................................................................427 C65: Patricia McGregor, 1/30/2022 ...........................................................................................................428 C66: Stan Zeavin, 3/8/2022 ........................................................................................................................429 C67: Remi Tan, 1/5/2022 ............................................................................................................................433 C68: Patrick Mora, 3/8/2022 ......................................................................................................................435 C69: Victor Carmichael, 3/8/2022 .............................................................................................................436 C70: Rick Nahass, 2/6/2022........................................................................................................................440 C71: Arlene Patton, 3/2/2022 .....................................................................................................................441 C72: Pete Shoemaker, 2/2/2022 .................................................................................................................442 C73: Erin Macias, 1/20/2022 ......................................................................................................................443 C74: Elizabeth Rubenstein, 1/19/2022 .......................................................................................................447 C75: Peter K, 1/18/2022 ..............................................................................................................................448 C76: David Patton, 2/15/2022 ....................................................................................................................451 C77: Sue Digre, 3/8/2022 ............................................................................................................................452 C78: Sue Digre, 3/8/2022 ............................................................................................................................459 C79: Pete Shoemaker, 2/17/2022 ...............................................................................................................460

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Packet Pg. 885 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 4 C80: Christine Boles, 1/16/2022 ................................................................................................................462 C81: Margaret Goodale, 1/25/2022 ............................................................................................................464 C82: Vicki Sundstrom, 3/8/2022 ................................................................................................................465 C83: Erin Macias, 1/18/2022 ......................................................................................................................472 C84: Rick Nahass, 1/30/2022......................................................................................................................477 C85: Erin Macias, 1/18/2022 ......................................................................................................................482 C86: Christine Boles, 1/20/2022 ................................................................................................................484 C87: Christine Boles, 2/10/2022 ................................................................................................................487 C88: Jim Louderback, 1/16/2022 ...............................................................................................................488 C89: Bill Collins, 2/21/2022 .......................................................................................................................489 C90: Necesse, 1/20/2022 .............................................................................................................................490 C91: Suzanne Buckley, 2/9/2022 ................................................................................................................492 C92: Necesse, 1/20/2022 .............................................................................................................................493 C93: Necesse, 1/19/2022 .............................................................................................................................494 C94: Rick Nahass, 2/20/2022......................................................................................................................496 C95: Mark Hubbell, 3/8/2022 ....................................................................................................................498 C96: Judy Yamahiro, 1/26/2022 .................................................................................................................502 C97: Christine Boles, 1/29/2022 ................................................................................................................503 C98: Christine Boles, 1/7/2022 ..................................................................................................................504 C99: Michelle Pitte, 2/17/2022 ...................................................................................................................505 C100: Shona Keating, 3/8/2022 ..................................................................................................................506 C101: Christine Boles, 1/11/2022 ..............................................................................................................510 C102: Patricia R. McGregor, 2/11/2022 ....................................................................................................511 C103: Alex Strachan, 1/19/2022 .................................................................................................................512 C104: Penelope Keating, 3/8/2022 .............................................................................................................513 C105: Kathi Porter, 1/19/2022 ...................................................................................................................514 C106: Debbie Young Lynch, 1/17/2022 .....................................................................................................515 C107: Ellen Natesan, 3/6/2022 ...................................................................................................................516 C108: John Keener, 2/17/2022 ...................................................................................................................539 C109: Mark Hubbell, 2/21/2022 ................................................................................................................541 C110: Christine Boles, 1/8/2022 ................................................................................................................542 C111: Reina Heinz, 3/8/2022 .....................................................................................................................546 C112: Margaret Goodale, 2/20/2022 ..........................................................................................................552 C113: Margaret Goodale, 2/11/2022 ..........................................................................................................555

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Packet Pg. 886 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 5 C114: Andy Narraway, 3/2/2022................................................................................................................557 C115: Camille Keating, 3/8/2022 ...............................................................................................................558 C116: Henry Ruhnke, 3/8/2022 .................................................................................................................563 C117: Pete Shoemaker, 2/16/2022 .............................................................................................................564 C118: Pete Shoemaker, 1/31/2022 .............................................................................................................565 C119: Michael Vasey, 2/20/2022 ................................................................................................................566 C120: John Sharp, 3/4/2022 .......................................................................................................................570 C121: Margaret Goodale, 3/7/2022 ............................................................................................................571 C122: Stan Zeavin, 3/7/2022 ......................................................................................................................572 C123: Brian Gaffney, ..................................................................................................................................579 C124: Christine Boles, 2/11/2022 ..............................................................................................................613 C125: Nancy Tierney, 3/7/2022 .................................................................................................................618 C126: Lawrence Bothen, 3/7/2022 .............................................................................................................620 C127: Richard Harris, 3/9/2022 .................................................................................................................623 C128: Richard Harris, 3/7/2022 .................................................................................................................625 C129: Jake Scussel, 2/30/2022 ....................................................................................................................627 C130: Laura Sloan, 1/14/2022 ....................................................................................................................629 C131: Danny Estrella, 2/26/2022 ...............................................................................................................630 C132: Kathy Castor, 3/9/2022 ....................................................................................................................637 C133: John Keener, 3/7/2022 .....................................................................................................................638 C134: Breck Hitz, 3/6/2022 ........................................................................................................................641 C135: Christine Boles, 2/11/2022 ..............................................................................................................642 C136: Nick Lusson, 3/8/2022 .....................................................................................................................646 C137: Clifford Lawrence, 3/8/2022 ............................................................................................................647 C138: Andrew, 2/21/2022 ...........................................................................................................................651 C139: Christine Boles, 12/17/21 ................................................................................................................653 C140: Virgilio Jr. L Yap, 1/19/21 ...............................................................................................................654 C141: Remi Tan, 2/26/2022 ........................................................................................................................655 C142: Chuck Gust, 1/21/2022 ....................................................................................................................656 C143: Sue Digre, 3/7/2022 ..........................................................................................................................657 C144: James Kremer, 1/17/2022 ................................................................................................................658 C145: Christine Boles, 2/8/2022 ................................................................................................................659 C146: Christine Boles, 1/31/2022 ..............................................................................................................660 C147: Christine Boles, 2/10/2022 ..............................................................................................................661

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Packet Pg. 887 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 6 C148: Christine Boles, 1/15/2022 ..............................................................................................................662 C149: Christine Boels, 1/13/2022 ..............................................................................................................663 C150: Christine Boles, 1/13/2022 ..............................................................................................................664 C151: Ellen Natesan, 3/7/2022 ...................................................................................................................665 C152: Christine Boles, 1/9/2022 ................................................................................................................666 C153: Mike O’Connell, 1/8/2022 ...............................................................................................................667 C154: Mike O’Connell, 1/10/2022 .............................................................................................................668 C155: Mike O’Connell, 1/11/2022 .............................................................................................................669 C156: Brian Gaffney, 3/8/2022 ...................................................................................................................670 C157: Terry Watt, 3/8/2022 .......................................................................................................................671 C158: Vicki Sundstrom, 2/1/2022 ..............................................................................................................672 C159: Gwendolyn Holden, 2/26/2022 .......................................................................................................673 C160: Ellen Natesan, 1/19/2022 .................................................................................................................674 C161: Arlene Patton, 1/22/2022 .................................................................................................................675 C162: Mark Hubbell, 3/9/2022 ..................................................................................................................676 C163: Paul Totah, 2/27/2022 ......................................................................................................................677 C164: Stan Zeavin, 3/5/2022 ......................................................................................................................679 C165: Christine Boles, 1/10/2022 ..............................................................................................................683 C166: Pez Godsoe, 3/7/2022.......................................................................................................................684 C167: Peter K, 1/16/2022 ............................................................................................................................685 C168: Bill, 1/11/2022 ..................................................................................................................................686 C169: Jackie Rosenheim, 2/21/2022 ..........................................................................................................687 C170: Bryan O’Flynn, 3/9/2022 .................................................................................................................688 C171: Tom Thompson, 3/7/2022 ...............................................................................................................689 C172: Tom Thompson, 3/7/2022 ...............................................................................................................690 C173: Bob Haxo, 3/8/2022 .........................................................................................................................693 C174: James Kremer, 3/8/2022 ..................................................................................................................696 C175: Dan Stegink, 3/8/2022 .....................................................................................................................699 C176: Clif Lawrence, 1/29/2022 .................................................................................................................701 C177: Rick Nahass, 3/4/2022......................................................................................................................702 C178: Christine Boles, 1/11/2022 ..............................................................................................................704 C179: Dawn Zidonis, 1/12/2022 ................................................................................................................705 C180: Irene Davies, 2/14/2022 ...................................................................................................................706 C181: Irene Davies, 1/21/2022 ...................................................................................................................707

2.f
Packet Pg. 888 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 7 Table 3-1: Comment Letter Index
Letter Name Date Agency/ Organization
A1 Amy Dao 2/15/2022 Bay Area Air Quality Management District (BAAQMD) A2 Will Kanz 3/8/2022 California Department of Fish and Wildlife (CDFW) A3 Dr. Erik Frost 2/1/2022 California Department of Conservation, Geological Survey A4 Dr. Adrianne Carr 3/8/2022 North Coast County Water Department (NCCWD) A5 Rob Bartoli 3/8/2022 San Mateo LAFCO
A6 Julia Koppman Norton 3/1/2022 California Coastal Commission (CCC) B1 Judy Heldberg 2/18/2022 Pacifica Historical Society
C1 Stan Zeavin 3/7/2022
C2 Maria Marintez-Mont 2/11/2022
C3 Lisa VillasenorVolosing3/8/2022
C4 Remi Tan 2/26/2022
C5 Remi Tan 2/2/2022
C6 Clif Lawrence 1/20/2022
C7 Debra Etienne 2/14/2022
C8 Richard Grassetti 3/8/2022
C9 Bob Boles 3/7/2022
C10 Christine Boles 1/27/2022
C11 Monica Meagher 3/8/2022
C12 Jewel Walli 3/5/2022
C13 Christine Boles 3/8/2022
C14 William Leon 3/3/2022

2.f
Packet Pg. 889 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 8 Letter Name Date Agency/ Organization
C15 Allison West 3/8/2022
C16 Clifford Lawrence 2/22/2022
C17 Deb MacC 2/14/2022
C18 Jim Louderback 2/28/2022
C19 Peter Loeb 3/5/2022
C20 Andre Mettier 3/8/2022
C21 Gary Emich 3/8/2022
C22 Dinah Verby 3/8/2022
C23 Therese Langille 3/9/2022
C24 Joanne Gold 3/7/2022
C25 Gary Furlong 3/7/2022
C26 Dina and Robert Horan 3/7/2022
C27 Cathy Glenn 3/7/2022
C28 Clif Lawrence 2/21/2022
C29 Nancy Merchant 3/3/2022
C30 James Kremer 2/20/2022
C31 Bradley Angel 3/7/2022
C32 Andrew Meiman 3/7/2022
C33 Richard Campbell 3/8/2022
C34 Richard Grassetti 3/8/2022
C35 Deb Wong 3/11/2022
C36 Patrick Mora 3/8/2022
C37 Allison West 3/7/2022 Pedro Point Community Association C38 Peter Loeb 3/7/2022

2.f
Packet Pg. 890 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 9 Letter Name Date Agency/ Organization
C39 Paul Totah 2/25/2022
C40 Adam Mayle 3/7/2022
C41 Adam Mayle 3/7/2022
C42 Sheila Gamble-Dorn 3/7/2022
C43 Sam Casillas 3/8/2022 Pedro Point Community Association C44 Jean Turk 3/7/2022
C45 Jonathan Cordero 3/3/2022
C46 Terrell Watt 3/8/2022
C47 Cindy Abbott 3/8/2022
C48 Paul Totah 2/25/2022
C49 Christine Boles 2/28/2022
C50 Karen Clark 3/7/2022
C51 Gail Benton Shoemaker 3/1/2022
C52 Suzanne Moore 3/3/2022
C53 Cheri and Bruce Chan 3/8/2022 Pedro Point Community Association C54 Christine Boles 3/6/2022
C55 Christine Boles 2/9/2022
C56 Christine Boles 1/16/2022
C57 Christine Boles 2/17/2022
C58 Rick Nahass 2/5/2022
C59 Suzanne Moore 3/5/2022
C60 Dustin McGahan 1/18/2022
C61 Arlene Patton 3/2/2022
C62 Clif Lawrence 1/16/2022

2.f
Packet Pg. 891 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 10 Letter Name Date Agency/ Organization
C63 Stan Zeavin 3/2/2022
C64 Christine Boles 1/31/2022
C65 Patricia McGregor 1/30/2022
C66 Stan Zeavin 3/8/2022
C67 Remi Tan 1/5/2022
C68 Patrick Mora 3/8/2022
C69 Victor Carmichael 3/8/2022
C70 Rick Nahass 2/6/2022
C71 Arlene Patton 3/2/2022
C72 Pete Shoemaker 2/2/2022
C73 Erin Macias 1/20/2022
C74 Elizabeth Rubenstein' 1/8/2022
C75 Peter K 1/8/2022
C76 David Patton 2/15/2022
C77 Sue Digre 3/8/2022
C78 Sue Digre 3/8/2022
C79 Pete Shoemaker 2/17/2022
C80 Christine Boles 1/16/2022
C81 Margaret Goodale 1/25/2022
C82 Vicki Sundstrom 3/8/2022
C83 Erin Macias 1/18/2022
C84 Rick Nahass 1/30/2022
C85 Erin Macias 1/18/2022
C86 Christine Boles 1/20/2022

2.f
Packet Pg. 892 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 11 Letter Name Date Agency/ Organization
C87 Christine Boles 2/10/2022
C88 Jim Louderback 1/16/2022
C89 Bill Collins 2/21/2022
C90 Necesse 1/20/2022
C91 Suzanne Buckly 2/9/2022
C92 Necesse 1/20/2022
C93 Necesse 1/19/2022
C94 Rick Nahass 1/20/2022
C95 Mark Hubbell 3/8/2022
C96 Judy Yamahiro 1/26/2022
C97 Christine Boles 1/29/2022
C98 Christine Boles 2/7/2022
C99 Michelle Pitte 2/17/2022
C100 Shona Keating 3/8/2022
C101 Christine Boles 1/11/2022
C102 Patricia R McGregor 2/11/2022
C103 Alex Strachan 1/19/2022
C104 Penelope Keating 3/8/2022
C105 Kathi Porter 1/19/2022
C106 Debbie Young Lynch 1/17/2022
C107 Ellen Natesan 3/6/2022
C108 John Keener 2/17/2022
C109 Mark Hubbell 2/21/2022
C110 Christine Boles 1/8/2022

2.f
Packet Pg. 893 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 12 Letter Name Date Agency/ Organization
C111 Reina Heinz 3/8/2022
C112 Margaret Goodale 1/20/2022
C113 Margaret Goodale 2/11/2022
C114 Andy Narraway 3/2/2022
C115 Camille Keating 3/8/2022
C116 Henry Ruhnke 3/7/2022
C117 Pete Shoemaker 2/16/2022
C118 Pete Shoemaker 1/31/2022
C119 Michael Vasey 2/20/2022
C120 John Sharp 3/4/2022
C121 Margaret Goodale 3/7/2022
C122 Stan Zeavin 3/7/2022
C123 Brian Gaffney 3/8/2022
C124 Christine Boles 2/11/2022
C125 Nancy Tierney 3/7/2022
C126 Lawrence Bothen 3/7/2022
C127 Richard Harris 3/9/2022
C128 Richard Harris 3/7/2022
C129 Jake Scussel 2/20/2022
C130 Laura Sloan 1/14/2022
C131 Danny Estrella 2/26/2022 Pedro Point Community Association C132 Kathy Castor 3/9/2022
C133 John Keener 3/7/2022
C134 Breck Hitz 3/6/2022

2.f
Packet Pg. 894 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 13 Letter Name Date Agency/ Organization
C135 Christine Boles 1/10/2022
C136 Nick Lusson 3/8/2022 Protect San Pedro Mountain Operations Team C137 Clifford Lawrence 2/21/2022
C138 Andrew Meiman 2/21/2022
C139 Christine Boles 12/17/202
1 C140 Virgilio Jr. L Yap 1/19/2021
C141 Remi Tan 2/26/2022
C142 Chuck Gust 1/21/2022
C143 Sue Digre 3/7/2022
C144 James Kremer 1/17/2022
C145 Christine Boles 2/9/2022
C146 Christine Boles 1/31/2022
C147 Christine Boles 2/10/2022
C148 Christine Boles 1/15/2022
C149 Christine Boles 1/13/2022
C150 Christine Boles 1/13/2022
C151 Ellen Natesan 3/7/2022
C152 Christine Boles 1/9/2022
C153 Mike O'Connell 1/8/2022
C154 Mike O'Connell 8/3/2021
C155 Mike O'Connell 6/24/2021
C156 Brian Gaffney 3/8/2022
C157 Terry Watt 3/8/2022

2.f
Packet Pg. 895 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 14 Letter Name Date Agency/ Organization
C158 Vicki Sundstrom 2/1/2022
C159 Gwendolyn Holden 2/26/2022
C160 Ellen Natesan 1/19/2022
C161 Arlene Patton 1/22/2022
C162 Mark Hubbell 3/9/2022
C163 Paul Totah 2/27/2022
C164 Stan Zeavin 3/5/2022
C165 Christine Boles 1/10/2022
C166 Pez Godsoe 3/7/2022
C167 Peter K 16-Jan
C168 Bill 1/11/2022
C169 Jackie Rosenheim 2/21/2022
C170 Bryan O'Flynn 3/9/2022
C171 Tom Thompson 3/7/2022
C172 Tom Thompson 3/7/2022
C173 Bob Haxo 3/8/2022
C174 James Kremer 3/8/2022
C175 Dan Stegink 3/8/2022
C176 Clif Lawrence 1/29/2022
C177 Rick Nahass 3/4/2022
C178 Christine Boles 1/11/2022
C179 Dawn Zidonis 1/12/2022
C180 Irene Davies 2/14/2022
C181 Irene Davies 1/21/2022

2.f
Packet Pg. 896 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 15 (A) Agencies

2.f
Packet Pg. 897 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 16 A1. Amy Dao, BAAQMD, 2/15/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A1-1 BAAQMD;
Amy Dao, Sr.

Environment
al Planner
2/16/2
2 The GHG impact analysis should include an
evaluation of the General Plan’s consistency with
the California Air Resources Board’s most recent
Assembly (AB) 32 Scoping Plan and with the
State's 2030, 2045, and 2050 climate goals. The
Air District's current GHG thresholds and CEQA
Guidelines are based on the State's 2020 targets
which are now superseded by the 2030 targets
established in SB 32. The Air District recommends
that cities and counties evaluate such plans based
on whether they would support California’s longterm climate goals of achieving carbon neutrality by 2045, as defined in Executive Order B-55-18,
including reducing GHG emissions in the relevant
jurisdiction to meet an interim milestone of 40
percent below 1990 emission levels by 2030,
consistent with SB 32.

The comment is noted. A clarifying table is thereby
added on DEIR p. 3.4-20 specifying reduction targets
and per capita SB 32 targets. Table 3.4-3 is thereby
added on DEIR p. 3.4-27 to show mass emissions
reductions for each of these targets, as well as the
following clarifying text: "The statewide per capita
goals were developed by applying the percent
reductions necessary toreach the 2030 and 2050
climate goals (40 percent and 80 percent, respectively) to the State’s 1990 emissions limit established under
AB 32. Following this methodology, the table below
shows the maximum mass emissions (i.e., emissions
targets) that the City would need to have to achieve
State reduction targets. As seen in Table 3.4-2, targets for 2040 were calculated based on a linear trajectory
between 2030and 2050, resulting in a target
maximum GHG emissions of 154,433 MTCO2e.In
addition to proving a net reduction in mass emissions
compared to existing conditions, mass emissions
generated by the Project at or below this amount
would constitute a less-than-significant impact on the
environment. Pacifica’s 2014 CAP “assume[ed] that
Pacifica’s emissions have increased since 1990 at the
same rate as for the state of California as a whole,
then Pacifica’s emission levels in 2005 would be
approximately 15 percent above 1990 levels.”
While the Proposed Project falls just short of a 60%
reduction in 2040 without mitigation measures; with
mitigation the Project results in a reduction of 69%
below 1990 levels. Because 2020 existing GHG levels
are approximately 35% below 1990 levels, it can be
reasonably assumed that the Project would meet its
SB 32 target of 40% mass emissions reductions below
1990 levels in 2030.

The following clarifications are added:

DEIR p. 3.4-38: "The Proposed Project would almost
meet SB 32 emissions reduction targets but falls just
short of the 60 percent reduction at 59 percent."
DEIR p. 3.4-52: "Both total and per capita emissions
would achieve the interpolated GHG emissions
reduction target established by the Pacifica CAP and
the AB 32 reduction target of 60 percent mass
emissions reduction below 1990 levels. Because
existing GHG (2020) represents a 35 percent reduction
over 1990 levels, and the Proposed Project is
estimated to result in an approximately 69 percent
reduction of MOTCO2e from 1990 levels, it is
reasonable to assume that Pacifica will meet its 2030
SB 32 goal, and the impact would be less than
significant with mitigation."
DEIR p. 3.4-63: "The Proposed Project would result in
GHG emissions of 1.59 MTCO2e per capita in 2040,

2.f
Packet Pg. 898 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 17 Letter Commenter Date Comment Combined Response
Agencies (A)
which meets the CARB Scoping Plan per capita
reduction targets designed to be consistent with SB
32, which are 6.0 MTCO2e per capita by 2030 and 2.0
MTCO2e per capita by 2050. With mitigation, the
Proposed Project meets its SB 32 reduction target for
2040, and it can be reasonably assumed that it would
also meet its 2030 reduction target for 2030, as
described in Impact 3.4-1. "
A1-2 BAAQMD;
Amy Dao, Sr.

Environment
al Planner
2/17/2
2 CEQA requires local agencies to consider
alignment of local plans with federal, state and
local energy and climate policy; thus, the relevant
plans and programs discussed in the General Plan
and DEIR must reflect the most recent
information. Several references to such goals,
plans, rules, and programs in the General Plan
and DEIR are outdated. Air District staff
recommend that the following references be
updated as follows:
• Revise Air District 2010 Clean Air Plan to the
2017 Clean Air Plan;
• Revise California 2020 GHG reduction goal to
California GHG reduction goals for 2030, 2045
and 2050;
• Revise Low Carbon Fuel Standard (2007) carbon
intensity reduction goals of 10% to 20% per 2018
CARB amendments to the regulation;
• Revise AB 32 (2006) to SB 32 (2016), and the
California Climate Change Scoping Plan 2008 and
2014 versions to the 2017 Scoping Plan;
• Revise EPA GHG Regulation of Cars and Light
Duty Trucks covering model years 2012 through
2016 to the model years 2023 through 2026;
• Revise Executive Order 13154 Federal
Leadership in Environmental, Energy, and
Economic Performance (revoked in March 2015)
to Executive Order 13693 Planning for Federal
Sustainability in the Next Decade;
• Revise Draft Plan Bay Area 2050 to Plan Bay
Area 2050 (adopted by MTC/ABAG in October
2021).

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

DEIR p. 3.4-44, 45, 53, 54: "CO-I-53 Transportation
Control Measures. Ensure compliance with the most
current Bay Area Clean Air Plan by implementing the
Plan’s recommended Transportation Control
Measures. The 2010 2017 Clean Air Plan identifies 17
TCMs aimed at reducing vehicle trips and vehicle miles
traveled; increasing access to and support of
alternative modes of transportation; promoting
compact, walkable land use patterns; and increasing
public education and awareness."
On page 3.14-16, "The Scoping Plan must be updated
every five years to evaluate AB 32 policies and ensure
that California is on track to achieve the 2020 GHG
emissions reduction goal California GHG reduction
goals for 2030, 2045 and 2050. In 2014, ARB released
the First Update to the Climate Change Scoping Plan
(First Update), which builds upon the initial scoping
plan with new strategies and recommendations. The
First Update identifies opportunities to leverage
existing and new funds and drive GHG emissions
reductions through strategic planning and targeted
low-carbon investments. This update defines ARB’s
climate change priorities for the next five years and
sets the groundwork for reaching the long-term goals
set forth in California EO S-3-05. The First Update
highlights California’s progress toward meeting the
near-term 2020 GHG emissions reduction goals
California GHG reduction goals for 2030, 2045 and
2050 in the initial scoping plan."
On page 3.4-18, "The updated Scoping Plan includes
various elements, including doubling energy efficiency
savings, increasing the low carbon fuel standard from
10 to 18 20 percent, adding 4.2 million zero-emission
vehicles on the road, implementing the Sustainable
Freight Strategy, implementing a post-2020 Cap-andTrade Program, creating walkable communities with expanded mass transit and other alternatives to
traveling by car, and developing an Integrated Natural
and Working Lands Action Plan to protect land-based
carbon sinks."
On page 3.4-10, "The Global Warming Solutions Act of

2.f
Packet Pg. 899 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 18 Letter Commenter Date Comment Combined Response
Agencies (A)
2006 (AB 32) 2016 (SB 32) required that the California
Air Resources Board (CARB) determine the statewide
greenhouse gas emissions level in 1990 expanded
upon AB-32 to reduce greenhouse gas (GHG)
emissions. AB-32 required California to reduce
greenhouse gas emissions to 1990 levels by 2020, and
SB-32 continues that timeline to reach the targets set
in Executive Order B-30-15, which requires GHG levels
to be reduced by 40 percent below 1990 levels by
2030. SB-32 provides another intermediate target
between the 2020 and 2050 targets set in Executive
Order S-3-05, which requires reducing GHG emissions
to 80 percent below 1990 levels. Based on its 1990-
2004 inventory work, ARB staff set 427 million metric
tons of carbon dioxide equivalent emissions
(MMTCO2e) as the total statewide greenhouse gas
1990 emissions level, and the 2020 emissions limit.

The CARB approved the 2020 limit on December 6,
2007.25 This would be about 9.7 MTCO2e per capita,
based on the Department of Finance’s state
population projection of 44 million."
On page 3.4-16, "In 2006, the California legislature
passed AB 32 (California Health and Safety Code
Division 25.5, Sections 38500 et seq., or AB 32), also
known as the California Global Warming Solutions Act.

AB 32 requires ARB to implement emission limits,
regulations, and other feasible and cost-effective
measures such that statewide GHG emissions are
reduced to 1990 levels by 2020. SB-32 continues that
timeline to reach the targets set in Executive Order B- 30-15, which requires GHG levels to be reduced by 40
percent below 1990 levels by 2030. SB-32 provides
another intermediate target between the 2020 and
2050 targets set in Executive Order S-3-05, which
requires reducing GHG emissions to 80 percent below
1990 levels.

Pursuant to AB 32 SB 32,..."
On page 3-22, "With the passage of Assembly Bill (AB)
32 Senate Bill (SB) 32, the Global Warming Solutions
Act of 2006, the State of California committed itself to reducing greenhouse gas (GHG) emissions to 1990
levels by 2020."
On page 3.4-12, The standards apply to passenger
cars, light-duty trucks, and medium-duty passenger
vehicles, covering model years 2012 2023 through
2016 2026. The standards are designed to achieve a
national vehicle fleet whose emissions and fuel
economy performance improves year over year. The
goal is to reduce CO2 emissions by 960 million metric
tons and save 1.8 billion barrels of oil over the lifetime of the vehicles sold in model years 2012 2023 through
2016 2026.

2.f
Packet Pg. 900 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 19 Letter Commenter Date Comment Combined Response
Agencies (A)
On page 3.4-13, Header: Executive Order 13154
Federal Leadership in Environmental, Energy, and
Economic Performance Executive Order 13693
Planning for Federal Sustainability in the Next Decade
"On October 5, 2009, President Obama issued
Executive Order 13154, which instructs federal
agencies to set or achieve various emissions reduction
and energy and environmental benchmarks by 2015,
2020, and 2030. The order requires agencies to set
GHG emissions reduction targets for 2020 within 90
days, and requires OMB to set a federal government
target for 2020 within 120 days. The order also sets
out required reductions in vehicle fleet petroleum use
and requires increases in water and energy efficiency
and in recycling and waste diversion rates. The order
also mandates adoption of certain contract and
procurement practices designed to promote energy
and water efficiency and environmentally-preferable
products. Now revoked, Executive Order 13693
introduces new requirements and expands on
requirements established by Executive Order 13154.

Such updates include the establishment of new
reduction targets for Scope 1, 2 and 3 GHG emissions
to be achieved by fiscal year (FY) 2025 compared to an
FY 2008 baseline and report annually a comprehensive
inventory and progress towards GHG emission
reduction goals."
On pages 3.4-21, 3.4-57, 4-17, and 4-18, "Draft Plan
Bay Area 2050" will be revised to "Plan Bay Area
2050".

These reference edits do not change any findings of
significance.

A1-3 BAAQMD;
Amy Dao, Sr.

Environment
al Planner
2/18/2
2 Air District staff recommends that the General
Plan include additional feasible measures to
minimize GHGs within the City. Examples of
potential emission reduction measures that
should be evaluated and considered, include but
are not limited to:
• Including electric infrastructure and fossil fuel
alternatives in the development and operation of
the Plan, such as solar photovoltaic (PV) panels,
renewable diesel, electric heat pump water
heaters, and solar PV back-up generators with
battery storage capacity.
• Expanding the requirements for no natural gas
use to all new residential and commercial
construction, with no exemptions for gas cooking
and residential fireplaces
• Prohibiting or minimizing the use of diesel fuel,
consistent with the Air District’s Diesel Free By
’33 initiative (http://dieselfree33.baaqmd.gov/).
• Meeting the vehicles miles traveled (VMT)
requirement under SB 743 per the Calfiornia
The DEIR includes the effects of all of the
recommended measures in the following ways:

Including electric infrastructure and fossil fuel
alternatives in the development and operation of the
Plan, such as solar photovoltaic (PV) panels,
renewable diesel, electric heat pump water heaters,
and solar PV back-up generators with battery storage
capacity:

Proposed policies CO-G-15 (renewable energy); policy
CO-G-16 (energy conservation); CO-I-59 (updated CAP
that will present list of all feasible GHG reduction
measures); CO-I-62 (encourage solar power
generation); CO-I-63 (clean city fleet); CO-I-64 (City
purchasing of renewable energy); Co-I-67 (Energy
efficiency in public buildings); CO-I-69 (outdoor
lighting); and 7-I-8 (generator retrofitting) all achieve the effect of this recommended measure.

Expanding the requirements for no natural gas use to
all new residential and commercial construction, with

2.f
Packet Pg. 901 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 20 Letter Commenter Date Comment Combined Response
Agencies (A)
Office of Planning and Research (OPR) Technical
Advisory On Evaluating Transportation Impacts In
CEQA (https://opr.ca.gov/docs/20190122-
743_Technical_Advisory.pdf).
• Requiring installation of electric vehicle (EV)
charging infrastructure and capacity to meet
power requirements of future EV charging needs,
per CalGreen Tier 2 charging infrastructure
requirements
(https://www.dgs.ca.gov/BSC/CALGreen#codes).

Planning for and providing funding for zeroemission transportation projects, including a neighborhood electric vehicle program,
community shuttle/van services and car sharing,
and enhancement of active transportation
initiatives, among others.
no exemptions for gas cooking and residential
fireplaces:

The City is exploring this option as part of a parallel Reach Code initiative.

Prohibiting or minimizing the use of diesel fuel,
consistent with the Air District’s Diesel Free By ’33
initiative (http://dieselfree33.baaqmd.gov/).

Proposed General Plan policy CO-I-63 and CO-I-64
would prioritize clean fuels and electric or hybrid
vehicles to replace and improve the existing city fleet of gasoline and diesel-powered vehicles. This policy
would reduce GHG emissions associated with
municipal operations and
Transportation and achieves the effect of the
recommended measure.

Meeting the vehicles miles traveled (VMT)
requirement under SB 743 per the Calfiornia Office of
Planning and Research (OPR) Technical Advisory On
Evaluating Transportation Impacts In CEQA
(https://opr.ca.gov/docs/20190122-
743_Technical_Advisory.pdf):

Please see response to comment C46-30 for more
information on policies that support SB 743
implementation.

Requiring installation of electric vehicle (EV) charging infrastructure and capacity to meet power
requirements of future EV charging needs, per
CalGreen Tier 2 charging infrastructure requirements
(https://www.dgs.ca.gov/BSC/CALGreen#codes):

Mitigation measure GHG-1 includes requirement of
installation of EV charging infrastructure and achieves the effect of the recommended measure.

Planning for and providing funding for zero-emission
transportation projects, including a neighborhood
electric vehicle program, community shuttle/van
services and car sharing, and enhancement of active
transportation initiatives, among others: Policies CI-G18 (transportation demand management), CO-I-68 (clean city fleet); CI-I-51 (transportation demand
management); CI-I-52 (support of expanded funding
for local transportation services); CI-I-42 (bicycle
education); and MM-GHG-1 (EV charging) address and
achieve the effect of this recommended measure.

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Packet Pg. 902 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 21 A2: Will Kanz, CDFW, 3/68/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A2-1 CDFW; Will
Kanz,
Environment
al Scientist
3/8/22 COMMENT 1: Wildlife Connectivity Issue:

Conservation Element CO-G-10 seeks to protect
environmentally sensitive habitat areas, high value
or high habitat value areas, and wildlife movement
corridors from development that would significantly
disrupt habitat values but does not provide a set of
standards for evaluating these impacts and ensuring
the impacts are reduced to less-than-significant. On
page 3.2-20 of the DEIR it states, “While a wildlife
movement corridor is needed somewhere within
the area designated in Figure 3.7-3; the entire area
would not be designated as a wildlife movement
corridor. Corridors typically range from 100 to 400
feet in width, within which habitat is continuous
and suitable for wildlife movements”. Additionally,
Figure 3.7-3 indicates wildlife corridors are only
needed between Milagra Ridge and Sharp
Park/Sweeney Ridge and the need for identifying
wildlife corridors in the other sensitive habitat is not discussed. Development and road construction or
widening has the potential to significantly impact
wildlife movement due to habitat conversion and
built infrastructure such as roads that can cause
habitat fragmentation, and cut off migration
corridors.

The Proposed Project does not include roadway
widening in any sensitive habitat areas, with the
exception of new roadways as part of Quarry
development. Should any future projects be
proposed, they would be required to assess
biological impacts 1) under CEQA and 2) in
accordance with federal, state, and local
regulations, as well as beneficial policies proposed
in the Proposed Project. Please see response to
comment A2-9 for more information. Proposed
policies that reduce the impact include those that
support critical wildlife habitat and special status
species (LU-G-7 and CO-G-8); Protection of
biological resources through new development,
including avoidance of development in critical
habitat, pre-construction surveys and consultation
with CDFW, biological resource assessments
required within any sensitive habitat areas shown
on Figure 7-3, as well as compensatory mitigation
measures (CO-I-27); protection of any species with
defined or potential habitat (CO-I-28) through
specific habitat survey requirements, development
limitations, or other requirements.

The quote on page 3.7-20 of the DEIR is out of
context, the sentence is thereby amended for
clarification:
"Natural wildlife corridors in Pacifica include
riparian corridors and drainages such as San Pedro
Creek, canyons, ridgelines, and corridors across
valley floors where impermeable barriers (such as
dense urban development, exclusionary fencing,
and heavily traveled roadways) have not yet
eliminated options for wildlife movement and plant
dispersal. An area on the south side of Sharp Park
Road functions as a wildlife corridor between
Milagra and Sweeney Ridges. It is a sensitive wildlife
area because of the link it provides between
populations of CRLF, SFGS, and other plants and
animals. This area has also been identified as part of
the Mission Blue butterfly migration corridor
(National Parks Service, Milagra Ridge, Golden Gate
Recreation Area. U.S. Department of the Interior.

Other wildlife corridors could occur in areas of
potentially sensitive habitat, or areas threatened by
habitat fragmentation, areas with high habitat
value, or critical habitat areas, as shown on Figure

3.7-3. This does not change findings of significance.

A2-2 CDFW; Will
Kanz,
Environment
al Scientist
3/9/22 Evidence the impacts would be significant: Road use can result in wildlife mortality, altered abundances
and diversity of wildlife, and modification of animal
behavior (Trombulak and Frissell 2000).

Additionally, wildlife mortality can occur as a result
See response for A2-1 and A2-3

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Packet Pg. 903 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 22 Letter Commenter Date Comment Combined Response
Agencies (A)
of road construction (Trombulak and Frissell 2000).

Road density has been shown to affect habitat
selection in frogs (Vos and Chardon 1998). Both
independently and collectively, these impacts have
the potential to affect public trust resources.

A2-3 CDFW; Will
Kanz,
Environment
al Scientist
3/10/2
2 Recommended Measure 1 – Minimize New Road
Construction:

Limit the construction of new roads and properly
use and maintain existing roads when possible.

When new roads must be constructed or
reconstructed, use practices that minimize
environmental impacts. Restore drainage areas
connected to current roadways to limit
environmental impacts like erosion and diversion of
surface flow. Terrestrial connectivity elements such
as wildlife friendly culverts, directional fencing,
strategically placed median barriers, undercrossings, over-crossings and elevated causeways should be programmed into the Project as design
features or conditions of approval in coordination
with the natural resource agencies.

Site-specific impacts and mitigation measures
would need to be determined during a project EIR
prior to construction. The DEIR includes several
policies that reduce biological impacts from
construction (which also applies to road
construction), including policies that minimize site
disurbance (CO-I-14), protect biological resources
with new development and requirement of preconstruction plan and wildlife surveys, resource assessments, and compensatory mitigation (CO-i26), preconstruction surveys for birds and bats (COI-33 and CO-I-34), and specific measures to protect the California red legged frog and San Francisco
garter snake during construction (CO-I-35). Thus,
the current policies and compliance with existing
regulations reduce impacts to the maximum extent
practicable.

A2-4 CDFW; Will
Kanz,
Environment
al Scientist
3/11/2
2 Recommended Measure 2- Wildlife Connectivity:

The EIR should incorporate a wildlife movement
studies to develop a baseline understanding of the
areas where wildlife movement, crossings, and
mortalities are most prevalent in order to identify
species use and to aid in identifying criteria used to
determine appropriate wildlife corridor widths and
locations where development should not occur. The
studies should be focused in those areas identified
in Figure 3.7-3 as a wildlife movement corridor and
the areas identified as potential environmentally
sensitive habitat areas, and high habitat
value/threatened by fragmentation. CDFW
recommends the study occur over a period of at
least 12 months prior to the approval of any project
relying on the Plan Pacifica Project. The study
should also be utilized to develop project design
and identify areas where wildlife crossing structures
would result in the largest benefit to rare,
threatened, endangered special status, and nonspecial-status species for wildlife connectivity.

Analysis during the 12-month study should also be
utilized to determine the type, size and number of
structures that would be most beneficial to
facilitate wildlife connectivity (new wildlife crossing culverts, modification of existing culverts, elevated
causeways, etc.) in existing developed areas. Upon
completion of any development, wildlife
connectivity structures and movement corridors
should be studied for an additional 6 to12 month
period, at minimum, to determine the effectiveness
of the designs. The protocol for the baseline survey,
post-construction surveys, site selection criteria and
While the importance of identifying and protecting
wildlife migration corridors is recognized in the
Draft General Plan and discussed in the DEIR, the
recommendation to incorporate a longitudinal
study conducted over a period of at least 12 months
into the DEIR is infeasible for two principal reasons.

First, such a study is more appropriately conducted
at a regional or subregional scale and led by an
agency with subject matter expertise such as CDFW,
given that wildlife migration patterns cross multiple
jurisdictional boundaries. Such a study would
necessarily involve coordination between multiuple
jurisdictions and would be beyond the techincal and
financial capabilities of the City of Pacifica to lead.

Second, to implement this recommendation at this
late stage of the multi-year Proposed Project would
require and extensive delay to the timeline and
would incurr significant cost to the City even if the
City had the subject matter expertise to lead such
an effort in the first place. The City notes that CDFW
had multiple opportunities to recommend this type
of study at earlier junctures in the Project -
including most recently during the scoping period
for the DEIR, which ran from August 5, 2020 to
September 14, 2020, but the CDFW did not
previously make this recommendation in their NOP
response.

Nevertheless, the City contiues to recognize the
importance of identifying and protecting wildlife
migration corridors and habitat in and adjacent to
Pacifica and would support regional or subregional
efforts led by an appropriate agency to accomplish

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Packet Pg. 904 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 23 Letter Commenter Date Comment Combined Response
Agencies (A)
design criteria for the development of the wildlife
connectivity structures should follow the protocols
outlined in; The California Department of
Transportation (Caltrans), Wildlife Crossings Design
Manual (Caltrans, 2009) and the Federal Highway
Administration Wildlife Crossing Structure
Handbook – Design and Evaluation in North
America, Publication No. FHWA-CFL/TD-11-003
(FHWA, 2011).
this. To underscore the importance of preserving
and protecting wildlife migration corridors, the
following policy will be added to the Conservation
Element of the 2040 General Plan:

Policy X - The City shall advocate for and participate
in a regional or subregional study to identify areas
where wildlife crossing structures would result in
the largest benefit to rare, threatened, and
endangered special status and non-specila-status
species for wildlife connectivity, to be led and
conducted by an appropriate agency.

A2-5 CDFW; Will
Kanz,
Environment
al Scientist
3/12/2
2 COMMENT 2: Fish Passage Assessment Issue:

Multiple potential fish passage barriers and
unassessed locations exist within the Project area.

The Project contains stream crossings within areas
mapped as historic or current watersheds where
anadromous fish are, or historically were found. The
species include but are not limited to Steelhead –
California Central Valley Distinct Population
Segment (DPS) (BIOS; DS-810), Steelhead – Central
Coast DPS (BIOS; DS-806). Section 156 of the Streets
and Highways Code (Senate Bill (SB)-857), which
amended Fish and Game Code section 5901 and
added section 156 to the Streets and Highways
Code which requires in section 156.3, any project
using state or federal transportation funds
programmed after January 1, 2006, the lead agency
shall ensure that, if the project affects a stream
crossing on a stream where fish are, or historically
were found, an assessment of potential barriers to
fish passage is done prior to commencing project
design. For this Project, the City of Pacifica would
need to submit the assessment to the CDFW and
add it to the CALFISH database. If any structural
barrier to passage exists, remediation of the
problem shall be designed into the Project by the
implementing agency. New projects shall be
constructed so that they do not present a barrier to
fish passage. Evidence the impact would be
significant: The decline of naturally spawning
steelhead trout is primarily a result of the loss of
appropriate stream habitat and the inability of fish
to get access to habitat, according to reports to the
Fish and Game Commission and by the CDFW
(CDFW, 1996). Restoration of access to historical
spawning and rearing areas should be incorporated
into the Project design through barrier modification,
fishway installation, or other means (CDFW, 1996).

Recommendations: The EIR should include technical
evaluation of the current status of each crossing
location noted in the California Fish Passage
Assessment Database within the Project limits that
may be barriers to fish passage. If any barriers or
See response for A2-8

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Packet Pg. 905 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 24 Letter Commenter Date Comment Combined Response
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unassessed barriers noted within the Project limits
are found to be exist, remediation of the barrier
should be designed into the Project by the
implementing agency as a Project feature in
consultation with CDFW and other natural resource
agencies.

A2-6 CDFW; Will
Kanz,
Environment
al Scientist
3/13/2
2 Recommended Measure 1 - Fish Passage
Assessment:

To evaluate potential impacts to native fish species
and fisheries resources, City of Pacifica should
submit any fish passage assessments to the CDFW
and add it to the CALFISH database. If any structural
barrier to passage exists, remediation of the barrier
shall be designed nto the Project by the
implementing agency. New projects shall be
constructed so that theydo not present a barrier to
fish passage. When barriers to fish passage are
being addressed, plans and projects shall be
developed in consultation with the CDFW. CDFW
shall be engaged prior to design in early
coordination and at 30% design at minimum.

See response for A2-8
A2-7 CDFW; Will
Kanz,
Environment
al Scientist
3/14/2
2 Recommended Measure 2 - Fish Passage Design
Coordination:

CDFW recommends incorporation into the EIR a
condition of approval to engage with CDFW in early
and continued coordination before design
commences on any fish passage barrier
remediation.

See response for A2-8
A2-8 CDFW; Will
Kanz,
Environment
al Scientist
3/15/2
2 Recommendation Measure 3 - Bridge and Stream
Crossing References:

CDFW recommends utilizing principles outlined in
the California Salmonid Stream Habitat Restoration
Manual, Part XII (CDFW, 2009) and NOAA Fisheries
Service Guidelines for Salmonid Passage at Stream
Crossings (National Marine Fisheries Service
(NMFS), 2001) into stream crossing designs. CDFW
strongly recommends incorporation of freespan
bridge designs that are at minimum 1.25 times
greater than the channel width. Such designs allow
natural stream flow and sedimentation processes to
continue for long term dynamic channel stability.

The DEIR describes fish passages, coordination with
other agencies, and includes policies that would
reduce potential impacts. As noted on DEIR p. 3.7-
50, "The third special status species which occurs in
Pacifica is steelhead, and is known to spawn along
the main stretch of San Pedro Creek in the area
parallel to Linda Mar Boulevard. As such, there are
several specific areas where proposed buildout
could adversely affect this species and its
habitat....For specific development projects under
the Proposed Project, consultation may be required
with USFWS by FESA, and/or with the California
DFW by CESA. Prior to project construction under
the Proposed Project, the applicant would be
required to conduct biological resource
assessments and pre-construction plant and wildlife
surveys at development sites. Compensatory
mitigation would also be required in order to offset
the loss of or alteration to special status species’
habitat."
Policy CO-I-1 applies explicitly to waterways and fish
passage and includes measures to protect and
restore the creek, including removing obstacles to
fish passages (CO-I-1). Policy CO-I-26 requires
engagement with a qualified biologist to assess

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Packet Pg. 906 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 25 Letter Commenter Date Comment Combined Response
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sensitive species, and engagement and CDFW staff
if special status species are found. The policy also
notes that the City will coordinate with the U.S. Fish
and Wildlife Service, National Marine Fisheries
Service, California Department of Fish and Wildlife,
and Regional Water Quality Control Board in
providing project applicants with the best guidance
to avoid impacts to special status species and
habitat areas including creeks, wetland features,
woodlands, or other sensitive natural features. As
described in Master Response 2: Programmatic EIR,
project-specific impacts and mitigation measures
would be determined for projects prior to approval,
in addition to any needed mitigations or design to
reduce or avoid impacts.

A2-9 CDFW; Will
Kanz,
Environment
al Scientist
3/16/2
2 Issue: The Project falls within the Central Coast
North (CC-N) mountain lion subpopulation. The CCN subpopulation has the potential to be impacted by development facilitated by the Project.

Development within sensitive and critical habitat as
defined in Figure 3.7-3 has the potential to cause
impacts during construction and operation by
increasing human presence, traffic, noise, vibration,
air pollutants and dust, artificial lighting, habitat
removal, severing access to or impacting habitat
resources (e.g. streams, dens site, impacts to preybase, etc.), causing disruption during breeding cycles, impacting den selection, forcing animals into
movement paths and areas that could increase their
vulnerability to vehicle strikes, and has the potential to significantly and permanently reduce or
eliminate the existing wildlife movement corridor
necessary for gene flow. Decreased and impeded
connectivity could increase the decline in genetic
diversity of mountain lions in southern and central
parts of the State (Dellingeret al., 2020).

Evidence the impact would be significant: Mountain
lion (Puma concolor) is a specially protected
mammal in the State (Fish & G. Code, § 4800). In
addition, on June 25, 2019, a petition to list the
mountain lion, Southern California/Central Coast
Evolutionarily Significant Unit (ESU) in Southern and
Central California as Threatened or Endangered
pursuant to CESA (Fish & G. Code §§ 2050 et seq.)
was submitted to the California Fish and Game
Commission. Specifically, the petitioners requested
listing as a “threatened species” for the ESU
comprised of the following recognized mountain
lion subpopulations: 1) Santa Ana Mountains; 2)
Eastern Peninsular Range; 3) San Gabriel/San
Bernardino Mountains; 4) Central Coast South
(Santa Monica Mountains); 5) Central Coast North
(Santa Cruz Mountains); and 6) Central Coast
Central. On April 21, 2020, the Fish and Game
Searches of the California Natural Diversity
Database were conducted in June 2021 at time of
DEIR development, as well as in May 2022 to
confirm presence; the mountain lion was not and is
still not identified in the database for the Planning
Area. According to the United States Fish and
Wildlife Service Critical Habitat for Threatened and
Endangered Species data, there is no designated
critical habitat for mountain lions in the Planning
Area. Further, the bulk of development under the
Proposed Project would occur in urbanized, infill
areas of the City, and there would be relatively little development in areas where mountain lions have
the potential to occur. Please also see response to
comment A2-4 for more information on how the
City would support CDFW study of wildlife
movement corridors.

Proposed policies that reduce the impact include
those that support critical wildlife habitat and
special status species (LU-G-7 and CO-G-8);
Protection of biological resources through new
development, including avoidance of development
in critical habitat, pre-construction surveys and
consultation with CDFW, biological resource
assessments required within any sensitive habitat
areas shown on Figure 7-3, as well as compensatory
mitigation measures (CO-I-27); protection of any
species with defined or potential habitat (CO-I-28)
through specific habitat survey requirements,
development limitations, or other requirements
Given the nature of the General Plan as a longrange planning document, these policies are intentionally crafted broadly so that
implementation will continue to be effective even
as species are added to or removed from special
status lists.

As noted on DEIR p. 3.7-41, "Pursuant to the
requirements of the California Endangered Species

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Packet Pg. 907 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 26 Letter Commenter Date Comment Combined Response
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Commission determined that the petitioned action
“may be warranted” and established mountain lion
within the proposed ESU as a candidate species
under CESA (CDFW 2020). As a candidate species,
mountain lion within the proposed ESU now is
granted full protection of a threatened species
under CESA.

Act, an agency reviewing a project within its
jurisdiction must determine whether any statelisted endangered or threatened species may be present in the project area and determine whether
the proposed project will have a potentially
significant impact on such species." CESA prohibits
the take of any species of wildlife designated by the
California Fish and Game Commission as
endangered, threatened, or candidate species.

CDFW may authorize the take of any such species if
certain conditions are met. Without a take permit,
development may not occur.

Additionally, to clarify that mountain lions are
known to occur in the Planning Area, the following
clarification will thereby added to DEIR p. 3.7-21:

Monarch butterflies
Mountain lion
North American porcupine
However, the findings of the DEIR that compliance
with CESA regulations and implementation of
Proposed Project policies LU-G-7, CO-G-8, CO-I-27,
and CO-I-28, the conclusion that impacts would be
less than significant remain valid.

A2-10 CDFW; Will
Kanz,
Environment
al Scientist
3/17/2
2 Recommendations: It is important that the CC-N
subpopulation remain connected to adjacent
mountain lion populations via suitable habitat and
unobstructed sizeable movement corridors.

Permanently conserving and restoring habitat
connectivity and corridors is essential for
minimizing impacts to mountain lions. Gene flow
through maintenance of existing occupied habitat
within improved and additional wildlife corridors
will promote long-term persistence of isolated
subpopulations (Gustafason et al. 2019). It is
important that the CC-N subpopulation remain
connected to adjacent mountain lion populations
via suitable habitat and unobstructed sizeable
movement corridors. Restrictions to mountain lion
movement between the CC-N and CC-C can further
compound this issue absent conservation strategies
to ensure mountain lion movement opportunities.

Please see response to comment A2-9.

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Packet Pg. 908 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 27 Letter Commenter Date Comment Combined Response
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Opportunities to protect and enhance wildlife
connectivity should be incorporated into the EIR.

A2-11 CDFW; Will
Kanz,
Environment
al Scientist
3/18/2
2 COMMENT 4: Monarch Overwintering
The draft EIR does not include impacts to monarch
butterfly overwintering colonies or suitable
overwintering habitat. CDFW is concerned about
the loss of trees and host plants needed for
monarch butterflies. The loss of suitable
overwintering habitat for monarchs will contribute
to extirpation of western monarch populations. If
projects will remove trees used by over-wintering
monarchs, tree planting alone is unlikely to be
sufficient to mitigate impacts to a less-thansignificant level.

Evidence the impact would be significant:

The data gathered from the Western Monarch
Thanksgiving Count show that western
overwintering monarchs are at an alltime critical
low level and have significantly declined to
approximately two percent of their numbers since
1997 (Xerces Society Western Monarch
Thanksgiving Count, 2019). The decrease in Western
Monarch butterflies may be due to the loss of
overwintering habitat and loss of its host plant
(milkweed) (Pelton et al. 2019). According to the
Xerces Society, “Western monarchs use the same
sites each year, even the same trees, and need
intact overwintering habitat, which provides a very
specific microclimate and protection from winter
storms,” (Xerces Society, 2020).

See response for A2-12.

A2-12 CDFW; Will
Kanz,
Environment
al Scientist
3/19/2
2 Recommendations: The EIR should incorporate
protective measures for western monarch
butterflies that includes protecting trees used for
overwintering.

Recommended Measure 1 -Protect, Manage,
Enhance and Restore Monarch Butterfly
Overwintering Sites:
-Conduct overwintering grove habitat assessment(s)
and develop and implement long-term grove
management plans
(https://www.westernmonarchcount.org/).

Management plan actions for groves may include,
but are not limited to:
o Enhance roosting trees within overwintering
groves and within 1/2 mile of groves by planting
native insecticide-free trees (e.g., Monterey pine
(Pinus radiata), Monterey cypress (Cupressus
macrocarpa), coast redwood (Sequoia
sempervirens), coast live oak (Quercus agrifolia),
Douglas-fir (Pseudotsuga menzesii), Torrey pine
(Pinus torreyana), western sycamore (Platanus
racemosa), Bishop pine (Pinus radiata) and others,
as appropriate for location). Avoid the removal of
trees or shrubs within 1/2 mile of overwintering
The DEIR lists the monarch butterfly in Table C-1:

Special Status Species Considered in the Evaluation
of the Planning Area on page A-104 and states that
the potential for the Monarch Butterfly to occur is
medium and that "suitable habitat occurs at the
sound end of Pacifica, but it is not known to support
migratory monarchs." On DEIR page 3.7-29, the
description of Monarch Butterflies states "In
California, the overwintering grounds are
threatened by coastal development as well as
removal of nonnative eucalyptus trees for
restoration of native habitat." The City notes that
any overwintering sites would be identified in
consultation with CDFW as part of the permitting
and approval process for individual projects
pursuant to the Proposed Project, as noted on DEIR
p. 3.7-50: "For specific development projects under
the Proposed Project, consultation may be required
with USFWS by the Federal Endangered Species Act,
and/or with the California Department of Fish and
Wildlife by the California Endangered Species Act.

Prior to project construction under the Proposed
Project, the applicant would be required to conduct
biological resource assessments and pre2.f
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groves, except for specific grove management
purposes, and/or for human health and safety
concerns. The maintenance of trees and shrubs
within a 1/2 mile of these sites provides a buffer to
preserve the microclimate conditions of the winter
habitat.
o Conduct management activities in groves from
March 16-September 14, in coordination with a
monarch biologist, such as tree trimming, mowing,
burning and grazing in monarch overwintering
habitat outside of the estimated timeframe when
monarchs are likely present.
o Enhance native, insecticide-free nectar sources by
planting fall/winter blooming forbs or shrubs within
overwintering groves and within one mile of the
groves
(https://xerces.org/sites/default/files/publications/
18-003_02_Monarch-Nectar-Plant-ListsFS_web%20-%20Jessa%20Kay%20Cruz.pdf). o Avoid the use pesticides within one mile of
overwintering groves, particularly when monarchs
may be present. If pesticides are used, then conduct
applications from March 16-September 14, when
possible. Avoid the use of neonicotinoids or other
systemic insecticides, including coated seeds, any
time of the year in monarch habitat due to their
ecosystem persistence, systemic nature, and
toxicity. Avoid the use of soil fumigants.
o Consider non-chemical weed control techniques,
when possible (https://www.calipc.org/resources/library/publications/non-chem/). o Remove tropical milkweed that is detected, and
replace it with native, insecticide-free nectar plants
suitable for the location
(https://xerces.org/sites/default/files/publications/
18-003_02_Monarch-Nectar-Plant-ListsFS_web%20-%20Jessa%20Kay%20Cruz.pdf). o To assist in maintaining normal migration
behavior, do not plant any type of milkweed within
five miles of the coast from Mendocino County
south through Santa Barbara County, and within
one mile of the coast south of Santa Barbara
County, unless the species of milkweed is native to
the local area.
o Conduct grove monitoring for butterflies during
the Western Monarch Counts each fall and winter.

When possible, report when monarchs arrive and
depart the groves each year
(https://www.westernmonarchcount.org/).
construction plant and wildlife surveys at
development sites. Compensatory mitigation would
also be required in order to offset the loss of or
alteration to special status species’ habitat." In
addition, the following policies apply specifically to
habitat conservation, including policies to support
open space conservation and habitat protection as
well as wildlife and critical habitat, including
potential ESHA (LU-G-7, CO-G-7, and CO-G-11), to
support habitat preservation through requirement
of habitat survey prepared by a qualified botanist or
biologist for any development in sensitive areas
shown in Figure 7-3 (CO-I-31), coordination with
conservation organizations to optimize habitat
protection for public lands (CO-I-42), and
consultation with the CDFW to protect biological
resources with new development (CO-I-26). Other
policies protect against removal of monarch habitat
and prohibit new development that requires fuel
modification within ESHAs (CO-I-30) and
requirement of a Restoration and Monitoring
Proposal for any proposed habitat restoration that
includes a planting plan (CO-I-32).

Therefore, the findings of the DEIR that compliance
with CESA regulations and implementation of
Proposed Project policies Lu-G-7, CO-G-7, CO-G-11,
CO-I-42, CO-I-26, and CO-I-30 would reduce impacts
to less than significant remain valid.

A2-13 CDFW; Will
Kanz,
Environment
al Scientist
3/20/2
2 COMMENT 5: Setback from Streams, Creeks, Ponds,
Lakes, Wetlands, etc.

Issue: The Project DEIR does not include prescriptive
riparian buffers into its zoning updates. “A riparian
buffer is an area along a shoreline, wetland or
stream where development is restricted or
See response for A2-14

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prohibited. The primary functions of the buffer is to
physically protect and separate a stream, lake,
pond, wetland etc. from future disturbances or
encroachment.” If there are no Project setbacks,
there are no protective measures for environmental
sensitive habitat in these areas.

Evidence: Riparian areas provide important
ecological functions for terrestrial and aquatic
ecosystems. More than 225 species depend on
California’s riparian habitat. These species use
riparian habitat for migrating, nesting, feeding and
rearing young.

Each stream, creek, lake, pond, wetland, etc., is
unique and may require a different buffer or
setback. Riparian areas perform many ecological
functions such as enhancing water quality/quantity,
biodiversity, habitat connectivity, and flood
capacity. The stream, lake, pond, wetlands etc.,
conveys runoff, provides groundwater recharge,
supports aquatic plants and animals, as well as
supplies water to trees and plants that thrive in the
riparian zone. Setbacks or buffers are an effective
tool to physically protect and separate stream or
wetlands from future disturbances. If properly
maintained, setbacks or stream buffers can have
significant opportunities to mitigate some of the
effects of development. Setbacks or stream buffers
protect stream function, protect habitat, and
provide additional capacity for flood flow
conveyance. A summary of impacts to aquatic
features from insufficient riparian setbacks include
the following (San Francisco Bay Regional Water
Quality Control Board (RWQCB), 2004):
· Elimination of natural channel, including loss of
wetlands, wildlife, fisheries and riparian areas;
· Increased sedimentation due to construction
activities and land clearing;
· Unmitigated changes in hydrology that upset the
geomorphic equilibrium of streams, causing
destabilization and erosion of channels, and more
frequent flooding;
· Increased pollutant loads associated with urban
activities;
· Impairment of fish habitat from water diversions
and fish passage barriers due to the construction of
in-channel reservoirs and diversion structures, the
sedimentation of channels, and the removal of
vegetation; and;
· Increased pollutant loads associated with
agricultural activities.

In its Watershed Management Initiative, the State
Water Resources Control Board (San Francisco Bay
RWQCB, 2004) identified the major non-point

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Packet Pg. 911 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 30 Letter Commenter Date Comment Combined Response
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source problems within the San Francisco Bay
Region. “Many of which can be partially or fully
addressed through
establishment of setbacks or stream buffers”. The
San Francisco Bay RWQCB prepared a Stream
Protection Policy with the objective for riparian
buffer zones: “Buffer zones shall be maintained or
enhanced to protect stream functions. Examples of
ways in which buffer zones protect stream functions
include: removing agricultural and urban
stormwater pollutants, reducing sediment from
upland sources, stabilizing stream banks, minimizing
changes to the hydrograph by infiltrating
stormwater runoff, metering stream baseflow, and
supporting vegetation which provides nutrients and
shade.” (San Francisco Bay RWQCB, 2004)
Furthermore, the establishment of buffer zones in
moderate to highly disturbed agricultural areas has
been shown to increase aquatic condition and
habitat value (Teels et al., 2006). Increased buffer
widths have also been shown to have a general
positive relationship with terrestrial species
abundance (Marczak et al., 2010).

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Packet Pg. 912 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 31 Letter Commenter Date Comment Combined Response
Agencies (A)
A2-14 CDFW; Will
Kanz,
Environment
al Scientist
3/21/2
2 Recommendations: CDFW strongly recommends the
City of Pacifica adopt riparian buffer zones into its
zoning to prohibit development adjacent to
streams, creeks, rivers (including perennial,
intermittent, and ephemeral), wetlands, ponds, and
other environmentally sensitive habitat areas.

Additionally, these buffer areas will help to protect
water quality and habitat for aquatic and terrestrial
species. Because the size of a buffer zone may be
dependent on numerous factors including the size
of the watershed, level of disturbance, and species
that occupy the habitat, CDFW recommends the
City of Pacifica coordinate with CDFW to develop a
detailed and descriptive document that lays out the
guidelines for riparian buffers and setbacks. For
agricultural riparian buffers, CDFW has a California
Landowner Incentive Program
(https://wildlife.ca.gov/Lands/CWHP/Private-LandsPrograms/Landowner-Incentive-Program/Phase-2) that is a voluntary, incentive-based program. It
provides funding to restore marginal or flood-prone
farmland to riparian buffers, disburses annual
incentive funding to assist with costs of habitat
management and the loss of income associated
with idling farmland, and provides technical
assistance to restore and manage riparian buffers.

The comment is incorrect, the DEIR clearly describes
and includes riparian buffers, as well the Proposed
Project's potential impacts: On p. 3.7-45, the DEIR
states "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 mean's,
minimizing adverse effects of wastewater discharge
and entrainment, controlling runoff, preventing
depletion of ground water supplies and substantial
interference with surface waterflow, encouraging
wastewater reclamation, maintaining natural
vegetation buffer areas that protect riparian
habitats, and minimizing alteration of natural
streams." Such policies to implement riparian buffer
zones include those to maintain, protect, and
restore Pacifica's creeks, including requirement of
100-foot setbacks from the top of creek banks or
from outer edge of riparian vegetation for
development proposed adjacent to creeks, in
addition to requirement of a biological report
demonstrating hte buffer shall prevent impacts that
significantly degrade the creek (CO-I-1), and
verification and management of ESHA, which would
be establish a minimum of 100 feet from any
sensitive resource (CO-I-27 and CO-I-28). Policy COI-26 addresses consultation with the CDFW if special status species are detected
These conservation buffer policies for sensitive
habitats (including ESHA, wetlands, and other
riparian areas) would apply to new developments
prior to project approval, thus compliance with
these Proposed Plan policies would reduce impacts
to less than significant.

A2-15 CDFW; Will
Kanz,
Environment
al Scientist
3/22/2
2 COMMENT 6: San Francisco Garter Snake
Issue: The DEIR states that there is high potential
for San Francisco garter snake (SFGS; Thamnophis
sirtalis tetrataenia) to be present in the Project area during both the dry and the wet season. However,
the proposed Project does not consider the full
extent of development impacts to upland habitat
for SFGS, a State Fully Protected species.

Construction and maintenance activities in suitable
upland SFGS habitat has the potential to result in
direct and indirect take to SFGS. Indirect take may
occur as a result of upland habitat loss and
degraded site suitability for SFGS to complete all
stages of their life cycle such as through the
construction of roads, installation of fences blocking
suitable habitat and loss of habitat through
development.

See response for A2-16.

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Packet Pg. 913 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 32 Letter Commenter Date Comment Combined Response
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Because of the high probability of presence of the
species within the Project area, the appropriate
avoidance and minimization measures must be in
place to avoid take. As currently stated, CDFW does
not believe the avoidance measures in the DEIR will
avoid all impacts to SFGS. Take of a fully protected
SFGS is prohibited, and CDFW cannot authorize its
take in association with development or
maintenance projects, except under the provisions
of an NCCP.

Evidence the impact would be significant:

Consistent with CEQA Guidelines, Section 15380,
the status of SFGS as an endangered species under
CESA (Fish & G. Code, §2050 et seq.) and as a Fully
Protected species (Fish & G. Code § 5050) qualifies
it as an endangered, rare, or threatened species
under CEQA. SFGS is an endemic snake with a highly
limited range in the San Francisco Peninsula. SFGS
utilize a variety of habitats including upland sites for basking, rodent burrows for shelter and low-lying
marsh for feeding and reproduction (U.S. Fish and
Wildlife Service (USFWS), 1985). In coastal areas,
SFGS may hibernate during the winter in small
mammal burrows (USFWS, 2007). SFGS are
threatened by loss of habitat from agricultural,
commercial, and urban development, illegal
collection by reptile breeders, and decline of their
prey species, California red-legged frog (CRLF, Rana
draytonii) (USFWS, 2007).

Both CRLF and SFGS utilize upland habitat. CRLF can
disperse up to one mile through upland habitat
during the wet season (USFWS, 2002). Habitat loss,
fragmentation, and degradation remain the leading
cause of amphibian and reptile decline (Gallant et
al., 2007; Thompson et al., 2016). Although the
Project proposes to implement avoidance and
minimization measures, it does not avoid the of
potential upland habitat destruction which would
reduce and restrict the range of both SFGS and their
prey species CRLF. Ground disturbing work such as
grading and grubbing necessary for the completion
of development has the potential to result in the
direct take of SFGS utilizing animal burrows and
indirectly impact their habitat availability by
removing the availability of burrows from the site.

2.f
Packet Pg. 914 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 33 Letter Commenter Date Comment Combined Response
Agencies (A)
A2-16 CDFW; Will
Kanz,
Environment
al Scientist
3/23/2
2 Recommendation: CDFW recommends the
following avoidance measures are incorporated into
the EIR and included in all projects that are within
suitable SFGS habitat.

Recommended SFGS Avoidance and Minimization:

All projects shall be designed to avoid all impacts to
SFGS within suitable SFGS habitat including but not
limited to wetlands, streams and waterways as well
as associated upland habitat capable of providing
dens and basking habitat as determined by a
qualified biologist, experienced with SFGS, in
coordination with CDFW. Increased no build buffer
zones around wetland and riparian resources shall
be incorporated and the footprint of any new
structures in upland habitat shall be the minimum
necessary. If take of SFGS is likely then the Project
shall not be approved. The lead agency shall
coordinate with CDFW to ensure the Project is
designed to avoid take of a fully protected species.

The DEIR notes on p. 3.7-31 that "SFGS lives in
marshlands that border ponds and sloughs, riparian
cover along streams, and bordering meadows with
scattered brush, and also uses upland habitat for
overwintering and feeding." All federally and state
threatened, endangered, and candidate wildlife
species are protected under the Federal
Endangered Species Act and the California
Endangered Species Act, respectively; the DEIR
states on p. 3.7-51 that "For specific development
projects under the Proposed Project, consultation
may be required with USFWS by FESA, and/or with
the California DFW by CESA. Prior to project
construction under the Proposed Project, the
applicant would be required to conduct biological
resource assessments and pre-construction plant
and wildlife surveys at development sites.

Compensatory mitigation would also be required in
order to offset the loss of or alteration to special
status species’ habitat." In addition to federal and
State laws which would apply to protect the SFGS,
implementation of the following Proposed Project
policies would reduce potential impacts to specialstatus species to a less than significant level, including protection of open space as well as
important and critical habitat (LU-G-7, CO-G-7);
creek protection and restoration (CO-I-1); wetlands
preservation (CO-I-4); preseving biological
productivity (CO-I-38); protection, verification, and
monitoring of ESHA (GO-G-11, CO-I-27, and CO-I28); habitat preservation requiring special survey in areas delinated in Figure 7-3 (CO-I-31); monitoring
requirements for any proposed habitat restoration
or mitigation (CO-I-32); protection of biological
resources with new development (CO-I-26); specific
protection of SFGS during construction activity (COI-26); and requirement of free passage with any fencing or barriers in riparian ESHA or wildlife
corridor (CO-I-29).

While these above policies would reduce impacts to
less than significant, more specificity around
"upland habitat" is included in the following policy:

CO-I-26 ✳Protection of Biological Resources with
New Development. Protect sensitive habitat areas
and special-status species through implementation
of the following measures:
1) Discourage development and/or buildout in
critical habitat of special status species during the
development review process.
2) Pre-construction plant and wildlife surveys:

Project applicants shall engage a qualified biologist
to conduct presence/absence biological surveys for
sensitive plant and wildlife species prior to

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Packet Pg. 915 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 34 Letter Commenter Date Comment Combined Response
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construction adjacent to or within identified special
status communities and other sensitive areas
identified in Figure 7-3 of the proposed General
Plan. If special status species are identified, the
qualified biologist shall consult with the California
Department of Fish and Wildlife (CDFW) and
establish no-disturbance buffers around special
status species to avoid disturbance and direct
impacts to these resources during construction. If
no special status species are detected during
surveys, then construction-related activities may
proceed. Nesting birds, in particular, are protected
by two means; they receive protection under the
Migratory Bird Treaty Act, and nesting raptors (in
the order Falconiformes or Strigiformes) are
protected under the State Fish and Game Code,
§3503.5.
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, upland habitat,
or other sensitive habitat areas shown on Figure 7-3
of the General Plan.
4) Require on-site monitoring of biological
resources by a qualified biologist throughout the
duration of construction activity.
5) Require compensatory mitigation by means of
habitat preservation, restoration, and
enhancement; for the loss of any critical habitat
and/or special status communities.

The City will coordinate with the U.S. Fish and
Wildlife Service, National Marine Fisheries Service,
California Department of Fish and Wildlife, and
Regional Water Quality Control Board in providing
project applicants with the best guidance to avoid
impacts to special status species and habitat areas
including creeks, wetland features, woodlands, or
other sensitive natural features.

A2-17 CDFW; Will
Kanz,
Environment
al Scientist
3/24/2
2 COMMENT 7: Loss of Pond Habitat Issue:

Development of a golf course to a residential and
commercial development may result in the
destruction of on-site golf course ponds, which
provide habitat for wetland dependent species and
reduce wildlife connectivity. Evidence the impact
would be significant: Manmade ponds on golf
courses can provide food resources for many
species of waterbirds (White and Main, 2005).

Manmade ponds on golf courses can also provide
suitable habitat for wetland dependent wildlife
including semi-aquatic turtles (Price et al., 2013),
amphibians, and macroinvertebrates (Colding et al.,
2009).

See response for A2-18
A2-18 CDFW; Will
Kanz,
3/25/2
2 Recommendations to minimize significant impacts:

CDFW recommends retaining onsite ponds into the
The Proposed Project does not include changing the
designation of a golf course to residential or
commercial development as show in Figure 2.2-1
General Plan Land Use which designates the Sharp

2.f
Packet Pg. 916 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 35 Letter Commenter Date Comment Combined Response
Agencies (A)
Environment
al Scientist
design of the development and incorporating
wildlife corridors with adjacent open space.

Park Golf Course as a Park land use. The DEIR
discusses impacts to ponds specifically at the Sharp
Park Golf Course on p. 3.7-59 and these habitats are
shown in Figure 3.7-2. The DEIR includes multiple
policies to protect sensitive species and habitats
related to the Sharp Park Golf Course and other
sensitive species, including:
(CO-I-4) Wetlands Preservation. Prohibit new
development in existing wetlands except as allowed
under the federal Clean Water Act and the
California Coastal Act. Continue to require formal
delineations wetlands subject to State or federal
regulations prior to any proposed development
project in an area where potential wetlands have
been identified. If impacts on wetlands are
unavoidable, compensation measure should be in
line with the State’s no-net-loss goal regarding
wetlands.
(CO-I-38) Biological Productivity. Maintain—and
where feasible, restore—the biological productivity
and the quality of coastal waters, streams,
wetlands, and lakes in order to maintain optimum
populations of marine organisms and to protect
human health.

Techniques may include:
• Minimizing adverse effects of wastewater
discharge;
• Controlling runoff, preventing depletion of ground
water supplies and substantial interference with
surface waterflow;
• Encouraging wastewater reclamation, maintaining
natural vegetation buffer areas that protect riparian
habitats; and
• Minimizing alteration of natural streams.
(CO-I-27) Verification of ESHA. Prior to any
proposed development in an ESHA or potential
ESHA, require that a habitat survey be conducted by
a qualified botanist or biologist. The habitat survey
will verify whether the site is an ESHA, and
document the extent of the sensitive resources,
document potential negative impacts to the habitat,
and recommend appropriate mitigation measures.

Verification of an ESHA shall be based on the
following considerations:
• Presence of natural communities identified as rare
by the California Department of Fish and Wildlife
(determined by a state rarity ranking of S1 to S3).
• Recorded or potential presence of plant or animal
species designated as rare, threatened or
endangered under State or federal law.
• Recorded or potential presence of plant or animal
species for which there is compelling evidence or
rarity, such as a designation of 1B (rare or
endangered in California or elsewhere) or 2 (rare,
threatened, or endangered in California, but more

2.f
Packet Pg. 917 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 36 Letter Commenter Date Comment Combined Response
Agencies (A)
common elsewhere) by the California Native Plant
Society.
• Presence of coastal waterways.
• Integrity of the habitat and its connectivity to
other natural areas.
(CO-I-31) Habitat Preservation. Require a habitat
survey be prepared by a qualified botanist or
biologist for any development proposed for the
following areas, as shown in Figure 7-3.
• Designated Critical Habitat for Endangered or
Threatened Species;
• Potential Environmentally Sensitive Habitat Area
(ESHA);
• High Habitat Value; and
• Wildlife Movement Corridor.

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

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

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Packet Pg. 918 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 37 Letter Commenter Date Comment Combined Response
Agencies (A)
habitat preservation, restoration, and
enhancement; for the loss of any critical habitat
and/or special status communities.

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

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

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

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

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

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Packet Pg. 919 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 38 Letter Commenter Date Comment Combined Response
Agencies (A)
sheltering habitat such as rocks, small mammal
burrows, logs, densely vegetated areas, and even
man-made structures (i.e., culverts, livestock
troughs, spring-boxes, and abandoned sheds)
(USFWS 2017). CRLF populations throughout the
State have experienced ongoing and drastic declines
and many have been extirpated (Thomson et al.
2016). Habitat loss from growth of cities and
suburbs, mining, overgrazing by cattle, invasion of
nonnative plants, impoundments, water diversions,
stream maintenance for flood control, degraded
water quality, and introduced predators, such as
bullfrogs are the primary threats to the species
(Thomson et al. 2016, USFWS 2017). Development
could injure or kill CRLF if they occur on-site,
resulting in a substantial reduction of the
population.

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

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

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

2.f
Packet Pg. 920 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 39 Letter Commenter Date Comment Combined Response
Agencies (A)
A2-21 CDFW; Will
Kanz,
Environment
al Scientist
3/28/2
2 ENVIRONMENTAL DATA
CEQA requires that information developed in
environmental impact reports and negative
declarations be incorporated into a database which
may be used to make subsequent or supplemental
environmental determinations. (Pub. Resources
Code, §21003, subd. (e)). Accordingly, please report
any special-status species and natural communities
detected during Project surveys to the CNDDB. The
CNNDB field survey DocuSign Envelope ID:

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

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

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

2.f
Packet Pg. 921 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 40 A3: Dr. Erik Frost, CGS, 2/1/2022
A3-1 CGS; Dr. Erik
Frost
Senior
Engineering
Geologist
2/1/22 Earthquake Hazard Zones Numerous potential
earthquake hazards exist within the planning area:
a) Fault Rupture, Liquefaction and Landslide
Hazards The DEIR includes figures depicting the
most up-to-date Earthquake Zones of Required
Investigation produced under the Alquist-Priolo
Earthquake Fault Zoning Act and the Seismic
Hazards Mapping Act. The City may also wish to
provide in the Safety Element links to CGS websites
that will be updated as maps are published and
revised:
https://maps.conservation.ca.gov/cgs/information
warehouse/regulatorymaps/
https://maps.conservation.ca.gov/cgs/information
warehouse/apreports/
https://maps.conservation.ca.gov/cgs/EQZApp/app
/
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response: EIR comments for more
information about GP- or SPSP-related responses.

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

The comment is noted.

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

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

2.f
Packet Pg. 922 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 41 Historical Imagery, and stereo-paired aerial photos.

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

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

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

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

2.f
Packet Pg. 923 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 42 A4; Adrianne Carr, NCCWD, 3/8/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A4-1 NCCWD;
Adrianne
Carr, Ph.D.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2.f
Packet Pg. 924 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 43 Letter Commenter Date Comment Combined Response
Agencies (A)
General
Manager
with decision-makers in that context. Please see
Master Response: EIR comments for more
information about GP- or SPSP-related responses.

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

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

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

2.f
Packet Pg. 925 Attachment: Attachment F - Final EIR (FEIR) Chapters 1-3 (5015 : General Plan Update and Sharp Park Specific Plan Recommendation to City 44 A5; Rob Bartoli, San Mateo LAFCO, 3/8/2022
Letter Commenter Date Comment Combined Response
Agencies (A)
A5-1 San Mateo
LAFCO; Rob
Bartoli
Interim
Executive
Officer
3/8/22 Please clarify the allowed Urban Reserve density.

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

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

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

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