Attachment F - Final EIR (FEIR) Chapters 1-3 — Pacifica City Council, July 11, 2022 (part 4 of 5)

Coastal Access Trail, and Page 6-28 Fig 6-4
Schools and Community Facilities Shows
“GGNRA” as owner of the Pedro Point
Headlands (and shows GGNRA as the owner of
the city-owned Catlle Hill property).

Proposed Changes: Delete “GGNRA” under
Pedro Point Headlands on this and other maps
throughout the Draft General Plan and DEIR. The
property is owned by the City of Pacifica and the
State of California (California Coastal
Conservancy). It is uncertain whether GGNRA
will take title. Separate the cityowned Cattle Hill
property from GGNRA property on Sweeney
Ridge.

C108-3 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-15 OC-I-15 Pedro Point Headlands.

Complete the planned transfer of City-owned
land on Pedro Point Headlands to an
appropriate public or private land steward, and
pursue land and/or trail easement acquisition if
necessary to connect Headlands trails with the
Coastal Trail in Pacifica.

Proposed Change: OC-I-15 Pedro Point
Headlands. Complete the planned transfer of
City-owned land on Pedro Point Headlands to an
appropriate public or private land steward.
(Delete the rest of the sentence, as the
necessary parcels have been acquired,
as noted on Pages 6-9 and 6-17).

C108-4 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-16 Fig 6-2 Trail System Shows "Pedro
Point Trail” as a proposed trail or trail
improvement
Proposed change: The restoration efforts of the
Pacifica Land Trust Stewards have completed the
trails as mapped, and they should be shown as
"Existing Trails" (Also, the Devil's Slide Trail
should be shown as an "Existing Trail")
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C108-5 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-18 Trails at Pedro Point bring hikers from a trailhead on Highway 1 to an overlook point
and to Pedro Summit. They are minimally
improved, although the trailhead created with
the opening of the Devil’s Slide Tunnel in 2014
has created a new public parking lot.

Proposed change: Trails at Pedro Point bring
hikers from a trailhead on Highway 1 to an
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses. Please see
540
Letter Commenter Date Comment Combined Response
Individuals (C)
overlook point and to Pedro Point Summit. The
trailhead created with the opening of the Devil’s
Slide Tunnel in 2014 has created a new public
parking lot. (Delete "They are minimally
improved, although".)
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.

C108-6 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-19 OC-I-25 Pedro Point Headlands Trails.

In coordination with GGNRA and the California
Coastal Conservancy, support trail
improvements on Pedro Point Headlands, and
extension of these trails to the new trailhead at
the north end of Devil’s Slide.

Proposed change: Pedro Point Headlands Trails.

In coordination with GGNRA and the California
Coastal Conservancy, support connection with
the proposed Coastal Trail between Pedro Point
Shopping Center and the Devil’s Slide.

C108-7 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-21 Fig 6-3 Coastal Access Trail and access improvements expected under land steward
management; new trails should provide coastal
views from Pedro Beach
Proposed change: Trails provide coastal views.

Access improvements expected upon
completion of Coastal Trail segment from Devil's
Slide to Pedro Point Shopping Center.

C108-8 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-23 Table 6-5: Coastal Access Points Item 27 Pedro Point Headlands Detail: Headlands
with steep cliffs. Limited trail access exists from
trailhead at Highway 1. Proposed Improvement:

Trail and access improvements expected under
land steward management; new trails should
provide coastal views.

Proposed changes:

Detail: Headlands with steep cliffs. Trails on the
headlands provide coastal views. Informal trails
provide access from the north end of the Devil's
Slide Trail and from south end of Pedro Point
Shopping Center. Proposed Improvement:

Access improvements expected as a result of
proposed construction of the Coastal Trail
between Pedro Point Shopping Center and the
Devil's Slide north trailhead.

C108-9 John
Keener,
Pacifica
Land Trust
(President)
2/17/22 Page 6-29 OC-I-52 Pedro Point Headlands.

Extend trails on Pedro Point Headlands to a
coastal overlook point. (See Point 27 on Figure
6-3.)
Proposed change: Pedro Point Headlands.

Improve access to trails on Pedro Point
Headlands by supporting the Coastal Trail
segment from Devil's Slide to Pedro Point
Shopping Center. (See Point 27 on Table 6-5.)
[[Note - Incorrect location for Point 27 - should
be Table 6-5]]
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content
of the Proposed Plan and will be shared with
decision-makers in that context. Please see Master
Response 1: EIR Comments for more information
about GP- or SPSP-related responses. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.
541
C109: Mark Hubbell, 2/21/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C109-1 Mark Hubbell 2/21/2
2 How can I view public comments already submitted on the General Plan DEIR?
All submitted comments will
become part of the public
record.
542
C110: Christine Boles, 1/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C110-1 Christine
Boles
1/8/22 I was finally able to download the general plan
documents after receiving several error
messages about the city's lack of bandwidth.

The first thing I wanted to do was look at the
landslide/coastal erosion map.

I am copying the Council and Planning
Commission as this relates to an article I wrote
in the Tribune this week as well as private
discussions I have had recently with two
council members. It also relates to a project on
the Planning Commission agenda for Monday
the 10th on Talbot Avenue.

The comment is noted.

C110-2 Christine
Boles
1/8/22 I have apparently been screaming into the void
for over a year now...my letters, public
comments, expert reports from scientists I sent
you, mostly ignored. The Esplanade bluffs and
Oddstad Boulevard where the kids died are still
shown in white as not landslide/coastal erosion
prone. I appreciate the new map of debris flow
slides, but it does not reference the HDAI
report that the city commissioned after the 475
landslides that winter of 1982 or consider all of
these historic landslides. Even some of the 9
major slides studied, like the one between
Moana and Talbot are not included on either
map.

The recent landslide on Highway One is
missing, which is a blockage of a major
evacuation route. You have these records in
your files; I just saw them recently as part of a
document request. And the new 2021 USGS
maps, which I also shared with planning staff
recently, shows most of Pacifica in landslide
prone zones. Your document page 8-5
references USGS maps from 19888 (yes 3, 8s)
by the way.

There is some discussion of bluff erosion in the
written text, but again the map does not
match. And there have been many more
properties that were forced to be removed in
proximity to the shoreline than are mentioned,
including at Linda Mar Beach, Rockaway and
Manor that I know of.

I am so disappointed, and frankly, angry that
the city after 40 years is apparently still not
seriously considering our greatest
environmental hazards. We must do better.

The DEIR chapter related to Seismic Hazards uses two
maps to characterize landslide threat in Pacifica: The
Seismic Hazard Zone map, which shows landslide
prone areas that are required to undergo geotechnical
investigation and appropriate mitigation measures
incorporated into the project design. The Landslide
Zone data was released by the Department of
Conservation in 2021, the authoritative source for
mapping Zones of Required Investigation. As noted in
the map methodology, "As a part of the geologic data
compilation, an inventory of existing landslides in the San Francisco South Quadrangle, San Mateo County
was prepared by analysis of shaded relief maps
(various illumination directions) and contour data,
limited field reconnaissance, and a review of
previously published (Harding-Lawson, 1983; Bonilla,
1988; Jacobs Associates, 1999; Brabb and others,
2000; Wentworth and others, 1998) and unpublished
geologic-landslide mapping. Landslides were reviewed
using the lidar shaded-relief map (USGS, 2005), Google
Earth Pro DigitalGlobe and Historical Imagery, and
stereo-paired aerial photos. For each landslide
included on the map several characteristics
(attributes) were collected and compiled in a
geodatabase. These characteristics include recency of
activity, type, thickness, associated geologic unit(s), and the confidence of interpretation (definite,
probable, or questionable). The completed landslide
map was digitized, and the attributes were entered
into a database. Landslides rated as definite or
probable were carried into the landslide zone..."
Methodology for the Montara Mountain Quadrangle is
as follows: "As a part of the geologic data compilation, an inventory of existing landslides in the Montara
Mountain Quadrangle was prepared by analysis of
lidar-derived shaded relief maps (various illumination
directions) and contour data, 3D Google Earth Pro
DigitalGlobe and historical imagery, limited field
reconnaissance, and a review of previously published
(Brabb and others, 2000; Wentworth and others,
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Letter Commenter Date Comment Combined Response
Individuals (C)
1998) and unpublished geologic-landslide mapping.

Landslides were mapped using the 2005 USGS lidar
shaded relief images as base map. 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 and questionable). The completed landslide
map was digitized, and the attributes were entered
into a database..." As such, all relevant historical
landslides should be captured in Landslide Zone maps
released by the Department of Conservation.

The Slope Failure Threat and Coastal Erosion map,
Figure 3.6-3, shows areas of slope failure threat
categories. Risks due to landsliding are described in
detail on p. 3.6-8, and 3.6-13. Descriptions of coastal erosion and past events are described on p. 3.6-14,
and critical coastal erosion is also shown on Figure 3.6-

3. Projections of coastal erosion were studied as part
of the 2018 Sea Level Rise Vulnerability Assessment
(referenced on p. 3.6-1), which used best available
data to provide projections of future coastal erosion.

Taken together, this analysis adequately characterizes
risks due to landslides and coastal erosion in the
Planning Area. As noted in Impacts 3.6-1, the impacts
from landslides on development of future land uses
associated with the Proposed Project would be
addressed through site-specific geotechnical studies
prepared in accordance with CBC requirements and
standard industry practices, which would specifically
address landslide hazards located in landslide hazard
areas. Development would conform to the current
design provisions of the CBC to mitigate losses from
landslides. Proposed developments would also adhere
to the hillside development requirements contained in
the proposed policies below, as well as the existing
regulations in the Hillside Preservation District to
resist landslides through modern construction design
and slope stabilization techniques. General Plan
Policies SA I-2 and I-9 maintain restrictions on
hazardous areas including those in the hillside
Preservation District, while Policy SA I-8 requires that proposed development in hillside areas undertake
geotechnical studies which analyze erosion and
landslide potential. Policy LU-I-14 extends the Hillside Preservation District on the zoning map to ensure that
all steep and sensitive terrain is subject to these
regulations. Given State and local regulations,
including those in the Proposed Project, the potential
for adverse landslide impacts due to the
implementation of the Proposed Project at the
regional and local level is considered less than
significant.
544
Letter Commenter Date Comment Combined Response
Individuals (C)
As noted in Impact 3.6-2, 1982–1983, the entire
coastline of San Mateo County contains areas
susceptible to severe erosion and slope failure.25
Coastal areas within the Planning Area include
locations that the USGS have determined to have
critical erosion hazards and unstable segments where
the sedimentary rocks are susceptible to failure from
heavy wave action. Areas within the Coastal Zone are
vulnerable to coastal erosion. Proposed development
within the Coastal Zone would be regulated by the
Coastal Act and certified Local Coastal Plans. The
proposed General Plan shares policies with the LCP,
including policies SA I-28 and SA-I-29, which commit to mapping areas vulnerable to coastal erosion and other
coastal hazards on a regular basis, and to
implementing a Sea Level Rise Adaptation Plan to
safeguard against coastal hazards, including coastal
erosion. Policy SA-I-70 requires geo-technical reports
for new development on the shoreline, and SA-I-71
requires that new development be sited and designed
to be safe from erosion for at least 100 years without
shoreline protection. Therefore, the potential for
adverse erosion impacts related to land use changes
from implementation of the proposed General Plan is
less than significant with implementation of the
proposed policies.

C110-3 Christine
Boles
1/8/22 The Planning Commission is again reviewing
the project on Talbot at their next meeting,
which is asking for variances from HPD on up to
100% slope, near this historic landslide. How
can Commissioners possibly do their jobs if we
haven't given them accurate tools?
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response 1:

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

C110-4 Christine
Boles
1/8/22 Speaking of HPD, let me leave you with a
couple of quotes I found recently in digging
through newspapers from the 1970s when the
HPD ordinance was being drafted and
reviewed. There were 15 public hearings just
for this one ordinance by the way, with a ton of
community engagement and public comments.

The ordinance was approved unanimously by
both the Planning Commission and City
Council.

11.17.71 Tribune
"Les Clark, Director of Community
Development estimates that there are about
5400 acres of untouched land in Pacifica, 2800
of which are developable. The balance is on
hillsides of 35% grade or more - too steep to
develop....Preservation of steep land in excess
of 35% grade is a top priority, said Clark. Such
land should not be developed."

6.7.72 Tribune
The comment is noted.
545
Letter Commenter Date Comment Combined Response
Individuals (C)
At a Planning Commission hearing on June
1,1972, a developer complained about the
proposed ordinance saying," 70 percent of the
remaining land in Pacifica will have to remain
undeveloped if this ordinance is approved."
Planning Commissioner Lee Forster
replied,"You are finally getting the point. That
is exactly what the citizens of Pacifica expect
from this ordinance."
546
C111: Reina Heinz, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C111-1 Reina Heinz 3/8/22 The Environmental setting for the DEIR incomplete and out of date. Please
update using the best available data
and current technological practices.
- In particular, there seems to be
omitted and/or outdated biological
data – regarding species and
vegetation.
- Hydrology and watershed maps are
not up to date/not utilizing using best
available tools (i.e. GIS layers).

The commment is noted. Please see response to comments 14- 2, 163-3, 37-21, and C112-15 for more information on the adequacy of data informing biological settings. The DEIR uses the latest and best available data from FEMA to map areas of flooding on the Hydrology map, Figure 3.5-1 (National Flood Hazard Layer for San Mateo County, FEMA, 2019).

C111-2 Reina Heinz 3/8/22 Many policies in the DEIR do not match the correspondingly numbered
policies in the GP. Please update the
DEIR to track with the GP for
recirculation.

These inconsistencies are corrected in errata. These
clarifications do not change findings of significance in the DEIR.

C111-3 Reina Heinz 3/8/22 Land use maps in both the GP and DEIR are difficult to distinguish
variation in color coding.

Indicate potentially fire prone areas,
highlighting those in the urbanwildland interface when new information becomes available.

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 (i.e. an exposure model) . 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. Please see more information in Master Response 5: Wildfire.

C111-5 Reina Heinz 3/8/22 This fire risk topic also relates to wildlife corridors and the need to
maintain habitat connectivity as
related for viable mammal
populations. Looking ahead climate
change will affect changes in the way
we view land. In this time of “extreme
wildfires” (where one in 100-year fire
burns out of control for more than
several weeks) - set to increases by
50% by the middle and end of this
century, we need to better plan for
land use and development, especially
with regards to protecting sensitive
wildlife habitat. Please consider the
following with respect to development
and puma habitat:
o Wildlife zones are something we
The comment is noted. Impacts of wildfire on animal
populations is not a required topic of analysis under CEQA, thus no further response is required. However, the comment
addresses the content of the Proposed Plan and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments for more information about GP- or SPSP-related responses.
548
Letter Commenter Date Comment Combined Response
Individuals (C)
should be more concerned about.

Particularly in a time when globally
California is now one of the most fire
prone places in the planet.
o Unlike the areas of Hillsborough and
neighboring cities in the northern
region of the Santa Cruz mountains,
Pacifica has better potential habitat
sites for the Santa Cruz puma
population which is the population we
see here.
o It is well established that
development affects habitat quality,
habitat connectivity and reproductive
behavior of pumas1,2 and the
subpopulation in Pacifica is genetically
isolated and a provisionally listed
species.
o Further development may force
dispersal aged males to live in
subquality habitat/zones.

C111-6 Reina Heinz 3/8/22 7. Conservation (GP)
• Surface
water/Groundwater/Wetlands pp.7-2
to 7-6
Why are minor creeks (such as Big Inch
creek) omitted from the report? Big
inch creek is an ephemerally flowing
creek, serving as a potential seasonal
wetland and source of season surface
water, from the upslope watershed.

Thus, I suggest including this example
as a minor creek by indicating a creek
icon in the hydrology map in Figure 7-
3, especially as there is clear evidence
bolstered by local knowledge that this
creek supports wildlife such as deer.

Alternatively, this example might be
included as a seasonal wetland in the
wetland section of water resources.
• Figure 7-1: Hydrology Map p.7-3
It seems that the analysis of water
resources could use more current and
locally updated datasets as well as
more up to date available technology.

See prior question about minor creek
inclusion. This hydrology and
watershed map fails to use the most
accurate and up to date data available.

Suggestions include updating
watershed data delineations and
drainage points using best practice
techniques, the best available and
appropriate technology on a regional
or more granular level such as updated
The comment is noted. Figure 3.5-1, Hydrology and Flood Zones Map, will be amended to add Big Inch Creek to the map. This amendment represents a minor clarification and does not affect the findings of the DEIR.

Water resources analysis uses the most recent available data including from the National Flood Hazard Layer for San Mateo County, FEMA, 2019; Tsunami Hazard Area for San Mateo
County, Department of Conservation, State of California, 2020; U.S. Fish & Wildlife Service, National Wetlands Inventory, 2011; FEMA, 2008; ESA, 2009; City of Pacifica, 2020; San Mateo County, 2020.

In regards to wetlands, proposed policy CO-I-4 prohibits new development in existing wetlands except as allowed under the federal Clean Water Act and the California Coastal Act. It continues 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-netloss goal regarding wetlands.

The recommended citation is not available freely or publicly online. The DEIR uses the best available public information; please see response to comment C122-9 and C1-7.

The stormwater citation is from the City of Pacifica website, 2021. This information will be updated in the General Plan.

In addition, the typo "“Areas with riparian mixed hardwood habitat occur Areas with riparian mixed hardwood habitat occur” on page 7-18 of the General Plan will be amended. 549
Letter Commenter Date Comment Combined Response
Individuals (C)
GIS layers - watershed boundary or
hydrography dataset - from the US
Geological Survey (USGS). There
should be a note about potential
watersheds in this map or in the
wetlands section.
• Wetlands p.7-5
The National Wetlands inventory does
not take into account actual wetlands
that have not been delineated. It
should be required that pre-project
approval as required by CEQA, in areas
indicating potential habitat for unique
flora or fauna a delineation be
completed by a qualified biologist.
• Stormwater 7-6
Where is the citation for this
statement? ‘Overall, the City maintains
290,000 linear feet of storm drain
pipes and 986 inlets.’
• 7.2 Biological Resources Section. p.
7-16 to 7-24 of GP and corresponding
sections in DEIR.

Suggested edits: Utilize this citation to
update all fields with relevant
information, especially plant
communities and Wildlife Habitat
descriptions. Mooney, H., & Zavaleta,
E. (2016). Ecosystems of California.

Univ of California Press.
• Riparian Mixed Hardwood p. 7-18
(18 of PDF)
Fix typo, (delete double line of the
same text): “Areas with riparian mixed
hardwood habitat occur Areas with
riparian mixed hardwood habitat
occur”
C111-7 Reina Heinz 3/8/22 CO- I-3 Funding for Creek
Maintenance. Establish funding
mechanism to require property
owners with land adjacent to creeks to
pay proportionate share of creek
improvement maintenance. Should a
funding mechanism require property
owners with land adjacent to creeks to
pay proportionate share? Creeks are a
common pool resource and creative
solutions are available that would
allow the City of Pacifica to support
property and landowners through cofinancing such maintenance projects.

For instance the city might qualify for
(or support acess for owners to apply
for) Payment for Ecosystem Service
(PES) programs as well as federal and
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR. However, the comment addresses the content of the Proposed Plan and will be shared with decision-makers in that context. Please see Master Response 1: EIR Comments for more information about GP- or SPSP-related responses.
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Letter Commenter Date Comment Combined Response
Individuals (C)
state grant programs that are
currently increasing in availability. See
https://www.landcan.org/Grant-andAssistance-Programs/.

Suggested edit: CO- I-3 Funding for
Creek Maintenance. Establish a
mechanism supporting collaborative
funding solutions between the city and
property owners with land adjacent to
creeks to distribute the share of creek
improvement maintenance.

Alternative edit: CO- I-3 Funding for
Creek Maintenance. Establish a
mechanism to support property
owners with land adjacent to creeks to
pay proportionate share of creek
improvement maintenance.

C111-8 Reina Heinz 3/8/22 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 (of)
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 nonet-loss goal regarding wetlands.

Suggested edit: 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 wetland delineations subject to
State or federal regulations prior to
project approval for any proposed
development project in an area where
potential wetlands have been
identified. Delineations should be
completed in areas with indicator
species presence (i.e. Arroyo willow)
or any riparian zones where potential
wetlands are present, and required
prior to any permit or modification to
property. If impacts on wetlands are
unavoidable, compensation measure
should be in line with the State’s nonet-loss goal regarding wetlands.

C111-9 Reina Heinz 3/8/22 CO-G-7 – Wildlife and Critical Habitat.

Conserve and protect indigenous
threatened, endangered, and other
special status species by preserving
critical habitat.

Suggested Edit: CO-G-7 Protect Habitat
for Special Status Wildlife and
Vegetation. Conserve and protect
native threatened, endangered, and
other special status species by
preserving suitable habitat important
for the protection and persistence of
these species. Habitat can be
protected by allowing very limited or
no development, by identifying habitat
areas as top priorities for permanent
conservation, and by managing public
land to ensure species protection.

C111-10 Reina Heinz 3/8/22 CO-I-26 –Protection of Biological Resources with New Development.

Protect sensitive habitat areas and
special-status species through
implementation of the following measures: Suggested Edit: CO-I-26 –Protection of Biological Resources with New
Development and other earth
disturbing site modifications. Protect
sensitive habitat areas and specialstatus species through implementation of the following measures:
*This CO-I-26 policy should be added
to the DIER.

The comment is noted; it is included on DEIR p. 3.7-53. The policy modification affects the General Plan and would be considered in part with other General Plan-related issues as part of decisionmaker hearings. Please see Master Response 1. 552
C112: Margaret Goodale, 2/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C112-1 Margaret
Goodale,
Naturalist
2/20/22 1. Remove inappropriate title “Annual Grasslands” and replace with the more accurate
“Grasslands/Prairie”
This comment is noted. The following edit has been
made for clarity:

DEIR p. 3.7-2: "Annual Grasslands Grasslands/Prairie
Annual grasslands in Pacifica occur most often in a
mosaic pattern with coastal scrub and are
dominated by non-native annual grass species and a
variety of other non-native weeds. The presence of
these grasslands in Pacifica is limited and generally
occurs in highly disturbed areas. Damage to
grasslands is a result of unauthorized vehicle
activity, which resulting in off-road trails on
hillsides. Common dominants of grasslands include
ripgut brome (Bromus diandrus), rattail fescue
(Festuca myuros), and wild oat (Avena barbata).

Associated forbs include filaree (Erodium botrys),
sweet clover (Melilotus indicus), plantain (Plantago
lanceolata), and wild radish (Raphanus sativus).

Weedy species include foxtail (Hordeum murinum
ssp. leporinum), Italian ryegrass (Festuca perennis),
French broom (Genista monspessulanus), pampas
grass (Cortaderia selloana), cape ivy (Delairea
odorata), Bermuda buttercup (Oxalis pes-caprae),
black mustard (Brassica nigra), and sweet alyssum
(Lobularia maritima). Native species include
wild iris (Iris douglasiana), blue-eyed grass
(Sisyrinchium bellum), and California poppy
(Eschscholzia californica).4,5"
This is a minor correction made to clarify and does
not affect the findings of the DEIR.

C112-2 Margaret
Goodale,
Naturalist
2/20/22 2. Describe as follows:

Grasslands/Coastal Prairie in Pacifica occur at
Milagra Ridge, Sweeney Ridge, Cattle Ridge, Mori
Point, Aramia Point (formerly Rockaway
Headland), San Pedro Valley Park, the San Pedro
Mountain hills and Pedro Point Headlands and
often grow in a mosaic with coastal scrub.

Over the past thirty years extensive work has been
accomplished to protect, preserve and restore
native, perennial grasses and forbs at Pedro Point
Headlands (PPH), Aramai Point, Mori Point and
Milagra Ridge. The Pedro Point Headlands
restoration was supported by a grant awarded by
California State Parks and Recreation Division to
the Pacifica Land Trust to repair off- highway
vehicle damage. Grassland and prairie are being
protected in other publicly managed lands as well.

Unprotected grassland/prairie remnants continue
on Harmony 1, Rockaway Rock, the Quarry, Cattle
Hill, along Fassler, Esplanade, Palmetto, and Fish
and Bowl.

The comment is not related to the adequacy of the
DEIR, therefore no further response is required in
the FEIR. However, the comment addresses the
content of the Proposed Plan and will be shared
with decision-makers in that context. Please see
Master Response 1: EIR Comments for more
information about GP- or SPSP-related responses.
553
C112-3 Margaret
Goodale,
Naturalist
2/20/22 3. The following policy should be added: "With
climate change, it is important to maintain both
genetic diversity and carbon sequestration by
protecting grassland/prairie remnants." That policy
should be implemented by "Any grassland/prairie
or scrub edge must be surveyed at the correct time
of year by a botanist prior to any disturbance."
The following species are ranked as California Rare
Plants in CalFlora and are present or likely to be
present in Pacifica:

1. Centromadia parryi ssp. parryi, a dicot, is an
annual herb that is native to California, and
endemic (limited) to California. California Rare
Plant Rank: 1B.2 (rare, threatened, or endangered
in CA and elsewhere). Present Mori Point, Aramai
Point

2. Chorizanthe cuspidata var. cuspidata, a dicot, is
an annual herb that is native to California, and
endemic (limited) to California.

California Rare Plant Rank: 1B.2 (rare, threatened,
or endangered in CA and elsewhere).

3. Leptosiphon rosaceus, a dicot, is an annual herb
that is native to California. California Rare Plant
Rank: 1B.1 (rare, threatened, or endangered in CA
and elsewhere).

4. Silene scouleri ssp. scouleri, a dicot, is a
perennial herb that is native to California, and also
found elsewhere in western North America.

Present PPH California Rare Plant Rank: 2B.2 (rare,
threatened, or endangered in CA; common
elsewhere)

5. Arabis blepharophylla, a dicot, is a perennial
herb that is native to California, and endemic
(limited) to California. California Rare Plant Rank:

4.3 (limited distribution).

Present PPH* and Milagra Ridge

6. Erysimum franciscanum, a dicot, is a perennial
herb that is native to California, and endemic
(limited) to California. California Rare Plant Rank:

4.2 (limited distribution)
Present PPH* and Milagra Ridge

7. Piperia michaelii, a monocot, is a perennial herb
that is native to California, and endemic (limited) to
California. California Rare Plant Rank: 4.2 (limited
distribution).

Present PPH* and Aramai Point
The comment is noted. All species are found in
Appendix C, with the exception of Piperia michaelii,
which will be added in Appendix errata. This plant is
not federally or state listed, and it does not appear
in the CNDDB. Thus, it does not change findings of
significance in the EIR.

C112-4 Margaret
Goodale,
Naturalist
2/20/22 3. Additional native species below are confirmed in Pacifica’s grassland/prairie communities according
to inaturalist, Calflora and as compiled by *Kramer
Botanical, Vascular Plant Species within the Pedro
Point Headlands Trail Improvement and
Restoration Project Area, February 2016.
https://www.calflora.org//app/ipl?vrid=ce891&blo
om=t
https://www.inaturalist.org/check_lists/3273-
Mori-Point-CheckList?iconic_taxon=47126&without%5B%5D=page& The comment is noted. As noted on DEIR p. 3.7-49,
the DEIR used the California Native Plant Society
Inventory of Rare and Endangered Plants (online
edition, v8-02). California Native Plant Society.

Sacramento, CA. This database was accessed on
June 11, 2021 to identify plants in the Planning
Area. This data source represents the best available
data from an established source of CEQA
information. As the comment does not address the
adequacy of the environmental analysis contained
in the DEIR, no further response is required.
554
without%5B%5D=q
https://www.inaturalist.org/check_lists/5529-
Milagra-Ridge-CheckList?iconic_taxon=47126&without%5B%5D=page& without%5B%5D=q
555
C113: Margaret Goodale, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C113-1 Margaret
Goodale,
Naturalist
2/11/22 While our State certified LCP is sadly out of date, it remains our only real guide to coastal development.

Please see response to comment C30-8.

Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan
Update to ensure coordination between the
two documents. The City has prepared a
draft of the LCP Update in 2019, approved
by the City in 2020, and which is currently
under review for certification by the
California Coastal Commission. To the extent
the General Plan Update proposes any
policies beyond those which were sent to
the California Coastal Commission for review
and certification, a subsequent LCP
amendment would be necessary to make
the LCP consistent with the General Plan.

C113-2 Margaret
Goodale,
Naturalist
2/11/22 1. The new General Plan and DEIR must be consistent with Pacifica’s STATE CERTIFIED LCLUP.
• COASTAL ZONE LAND USE PLAN POLICIES of Pacifica’s
State certified LCLUP specify the following:

Page C-8

23. New development … shall· be located … where it wi11 not have significant adverse effects, either individually or cumulatively,. on coastal resources.

26. New development shall:

2. (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.

Page C-19
GEOLOGY (Fairmont West)
A Seismic Safety and Safety Element policy prohibits the approval of new developments which require seawal1s as
a mitigation measure. The· policy also states that projects should not be approved which eventually will need
seawalls for the safety of the structures and residents.

Page C-25 (WEST EDGEMAR-PACIFIC MANOR., ,(AMENDED
OcTOBER,24., 1984., #1-84).) GEOLOGY
As with bluff:-top lands to the north of the "Dollar Radio Station" residence, coastal bluffs in this area are subject to a high· rate of wave erosion. This average rate is exceeded during winter storm conditions when high wave run up and heavy rains are present. During these periods, sloughage of the face of bluffs occurs typically in the form of vertical slabs. The City's Seismic Safety and Safety Element requires the bluff setback to be adequate to accommodate a
minimum 100-year event, whether caused by seismic,
geotechnical, or storm conditions. The setback should be adequate to protect the structure for its design life. A Seismic Safety and Safety Element policy prohibits the
approval of projects which require seawalls as a mitigation This policy is consistent with PRC Div 20. Ch
3, article 4:. Marine Environment [30230 -
30236] ( Article 4 added by Stats. 1976, Ch.
1330. )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 coastaldependent 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. Existing marine structures
causing water stagnation contributing to
pollution problems and fishkills should be
phased out or upgraded where feasible.

Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan
Update to ensure coordination between the
two documents. The beneficial impacts of
these shared policies as they relate to
reduction of potential impacts required
under CEQA, such as impacts related to
geology or hydrology, are analyzed in the
DEIR. The City has prepared a draft of the
LCP Update in 2019, approved by the City in
2020, and which is currently under review
for certification by the California Coastal
Commission. To the extent the General Plan
Update proposes any policies beyond those
which were sent to the California Coastal
Commission for review and certification, a
subsequent LCP amendment would be
necessary to make the LCP consistent with
the General Plan. The DEIR does include
556
measure. The policy also states that projects should not be approved which eventually will need seawalls for the
safety of the structures
and residents.
• The new DEIR directly contradicts policy in the certified LCLUP as well as Coastal Act guidelines:

Doc p. 9 &10
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.
• The above two consecutive sentences contradict each
other.
• MUST ALSO DEFINE AND SPECIFY DATE OF EXISTING
DEVELOPMENT!
ALLOWS ANY NEW DEVELOPMENT TO BUILD A WALL.

Current Coastal Act specifies only development existing at the time of its adoption.

Page C-105
SHORELINE PROTECTION .AN) DRAINAGE STRUCTIRES
Erosion is a primary problem along the Pacifica coast.

Studies by the U. S. Anny Corps of Engineers indicate that in many cases shoreline structures are not economically justified. (See LCP Background Report, Geology; General Plan Background Report,
Geology). There are, however, ·a few areas in the City
where shoreline protection may be necessary to protect
major beach access or highly sensitive habitat. (See LCP Access Component Report, Local Beach Resources and
Management). For these areas, and other areas where
protection from hazards may be needed in the future,. the following conclusions are suggested:

Dumping and other unengineered erosion protection
sha11 be prohibited. Existing unauthorized rubble or
protective devices shall be removed prior to any additional development in such areas. A qualified expert shall be
engaged to analyze the impacts -0f proposed structures
and prescribe appropriate mitigation, if necessary, prior to issuance of a,permit. Impact evaluation shall include
methods to minimize alteration of natural migration' and ~eposition of sand on shorelines within the 1ittoral cell, sufficient engineering to protect threatened area, latera1 and (if appropriate) vertical beach access, and structures as well
• THE MITIGATION DETAILS FOR THE EXCEPTION
MENTIONED ON PAGE 9 OF THE NEW DEIR MUST BE
INCLUDED.
discussion of the Coastal Commission
requirements; please refer to response to
comment C123-42 for more information.

Please see Master Response 1.
557
C114: Andy Narraway, 3/2/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C114-1 Andy
Narraway
3/2/22 I am writing to comment and to inform you that I vociferously oppose the rezoning of the Calson Field from Commercial Recreation to Commercial Residential Mixed Use.

We, the majority of residents of Pedro Point, have for over a decade insisted that any residential buildings on this site would be both illegal and deleterious to the current residents of Pedro Point and Pacifica as a whole.

The various politicians over the last decade we entrusted with listening to us, their so-called constituents, have consistently shown a complete disregard for OUR opinions and have ignored us. Well, we have had ENOUGH. If you, the current members of the Council, will not listen to the residents, the taxpayers, the voters and even environmental experts then it will have to be resolved by litigation. We will not go away quietly and will fight this until you relent and confirm the wishes of the people involved and NOT one owner who wishes to profit at our expense.

In 2014, the residents of Pedro Point, hired experts and an attorney and they cited deficiencies in City's General Plan Update and Draft Environmental Impact Report (DEIR). The Proposed Land Use change did not pass, and the approved Land Use Designation remained Commercial Recreation. The DEIR (then) and now, fails to comply with the California Environmental Quality Act. Errors found by experts materially tied to the legal adequacy of the plan. The general plan land use designations are the heart of the plan; once a site is designated, applicants have certain development rights. Therefore it is essential that the City fully consider site values and constraints prior to re-designating sites, not after the site is redesignated. This GPU fails to do that, and the EIR fails to adequately or accurately assess impacts of the proposed re- designation of the Pedro Point Field site.

The Draft Environmental Impact Report in 2014 (and NOW) fails to recognize the parcels as an Environmentally-Sensitive habitat for Endangered Species.

In 2019, the neighborhood of Pedro Point asked for (and never received) a Neighborhood-Specific Study to consider the robust community input and evidence presented thus-far. This request was denied. Why? If as you say, the vision and goals recommended in the GPU for a sustainable economy in Pacifica are to better leverage its coastal location and establish itself as a more successful tourist destination and call for more tourist-oriented retail districts… similar to other beachside communities along the Pacific coastline, well we have it: The Pedro Point field is directly adjacent to Linda Mar State Beach, wetlands and floodplains of San Pedro Creek (including endangered species habitat). It is also adjacent to a coastal visitor-serving commercial center (inclusive of multiple unique restaurants, surf shop, grocery store, coffee shop, etc.).

Therefore, low-intensity “visitor-serving commercial” land use is an obvious alternative that the DEIR AND council should and MUST enact.

A “Conservation” (C) land zone would be the simplest solution for rectifying these previous errors and to avoid future litigation I would urge the council to KEEP the current CR zoning or change the land use to Low-Intensity Visitor-Serving Commercial but to change to a CRMU will mean years of lawsuits.

Please see Master
Response 6: ESHA and
Master Response 4:

Undeveloped San Pedro
Ave Sites for more
information. The comment
addresses the content of
the Proposed Plan and will
be shared with decisionmakers in that context.

Please see Master
Response 1: EIR Comments
for more information about
GP- or SPSP-related
responses.
558
C115: Camille Keating, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C115-1 Camille
Keating
3/8/22 Page153 Figure 6.2/ page 157 Figure 6-3 Coastal Access and page 84 Fig 4-8
Pacifica Southwest
The wording on #25 MAP OF COASTAL ACCESS, AS WELL AS THE MAP 6-2 IS UNCLEAR AND LEADS TO FUTURE CONFUSION.

The maps and figures of the above pages have some discrepancy and do not clearly identify where the plan is "Improve segment of Coastal Trail along former Railroad berm" The proposal shows a trail, continuing from the current beach trail ending at the bridge of San Pedro Creek, towards and behind the Pedro Point Shopping Center, parallel with both the shopping center and the East side of "The Calson field" passed the narrow portion of San Pedro ave. in front of Anchor Inn, and linking to a public trailhead at the Devils Slide trail near Ace Hardware. There is no need to encourage trail goers into several private properties, and away from the actual trail direction straight ahead of the San Pedro Bridge. Its mention to "Alongside the old railroad berm", alongside the (Calson) field property and continue towards the Pedro Point Headlands through an area "know as the Colt property" (pg. 84)
This seems like the continuation of an old plan that needs tightening up. The wording of "alongside the old Railroad berm" which is actually Shoreside drive, a private driveway should not be included at all.

Rather, the safest and most effective way to continue the trail IS TO PUT A SMALL CROSSWALK ON SAN PEDRO AVE. WEST TO

EAST, JUST PASSED THE BRIDGE, ALOWING TRAIL-GOERS TO
EITHER: 1)CONTINUE TOWARDS ACE HARDWARE AND ACCESS
THE PUBLIC TRAILHEAD TO DEVILS SLIDE, OR 2)GO UNDER THE

OLD HIGHWAY ALONG THE CREEK TO ENTER LINDA MAR

SHOPPING CENTER OR
CONTINUE TO OLD COAST ROAD. This provides the most options, for a safe and easy straightaway crossing, with a clear view of cars, directly to the access point of Devils Slide trail with adequate for pedestrians. This section is already a "No parking" zone and has enough space to accomodate a clear pedestrian or bike lane to the trail.

As well, the segment under highway 1, is already used by many residents, from the south Linda mar area, connecting them from the L.M shopping center, Old Coast road, and Higgins trails.

Therefore, it makes no sense to point trail-goers throughmultiple private properties in Pedro Point, and into cramped
neighborhood area with limited sidewalks, to then cross the street near a blind turn @ Ace hardware.

Who would be responsible for the liability and maintenance of this proposed trail segment through multiple private properties? Providing a cross walk area at the bridge at San Pedro allows for more safe connection to other trails and neighborhoods without impeding on private property owners, or pushing more
unnecessary foot traffic into an already congested area. It keeps The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.
559
Letter Commenter Date Comment Combined Response
Individuals (C)
a continuity of Public City trail, on Public property, which can be more safely maintained and insured by the city. Both visually, and strategically, its pedestrian connectivity and straight away, makes more sense to any hikers looking to get from point A to point B.

Please see attached photo of (My) Proposed crossing area on San Pedro ave. (My proposed crosswalk area; safe straight away, clear sight, plenty of pedestrian access, options for continued connection to Linda Mar or Devils slide, out of Private Property.) C115-2 Camille
Keating
3/8/22 Page 97 LU-I-28
"Maintain Access beach along Shoreside drive"
It seems that the access point that is mentioned in LU-I-28 is actually referring to the San Pedro Creek Public access at Coast Hwy in the Pedro Point Shopping center. This is the safest, most convenient, least impactful, and only public access south of the San Pedro Creek. Therefore, the public (especially visiting Public) should have clear signage directing them towards this access at the Creek .

Shoreside Drive is a privately owned driveway that enables it’s resident’s to access their homes by car and foot. Any access points from Shoreside drive, or houses to the beach are also private, and run closely along side the homes, for the use of the residents and are not to meant to handle public use. Throughout the years, and especially negatively impactful during Covid, Shoreside residents were bombarded with an influx of beach goers, unclear of how or where to park and access the beach.

People climbed up and between houses, used residents' private decks and paths as bathrooms, allowed kids and dogs to run THROUGH our homes and yards, left litter on the property and dangerously parked and blocked the one way narrow dirt
driveway preventing ingress/egress. We were vocal of our concerns to the city during that time, and were given cones and temporary signage to alert visitors and protect our property with. We were also asked by Pacifica PD during beach closures to try and eliminate any arteries of access that might be used to get to the beach. It is a constant struggle.

C115-3 Camille
Keating
3/8/22 This is a sensitive area vulnerable to the elements, lack of parking and to overuse.

Lack of signage near the Shopping center, and negligent trampling by visitors looking for access, adds increased liability and maintenance to our private driveway, not to mention creates hostile conflict between resident property owners, and beach visitors trying to find their way.

This is supported on Table 6-5; Coastal Access Points as "Private property with no access" but unclear on LU-I-28. I am glad to see that in OC-I-40 "Until such an entity agrees to be responsible for liability and maintenance of such access ways, they are not to be open for public use"
Please help clear up any future confusion by adding proper The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.
560
Letter Commenter Date Comment Combined Response
Individuals (C)
signage to the safely maintained and convenient Public Access at the Creek in the PP shopping center at COAST HIGHWAY
C115-4 Camille
Keating
3/8/22 PG. 97 LU-I-29 Undeveloped San Pedro ave.

I am opposed to any rezoning of this property at this time, without further study, updated EIR and traffic reports, and without broader neighborhood feedback. Until the safety (or lack of) for ingress and egress by current Pedro Point residents is addressed, the development of any portion of the "Calson Field" must be thoughtfully considered.

In March of 2014, a resident, Errol Chang was fatally shot on San Pedro ave by swat teams. For the entirety of the day, Pedro Point residents were stuck on either side, unable to access their homes or leave the point by car. This was a terrible scene on many levels. It also heightened our awareness, as to what happens in an emergency. Whether it be a road blockage, or worse, a Fire, Tsunami, or earthquake evacuation, where all residents need to leave Pedro Point via San Pedro Ave, we are held hostage to our one way in and out neighborhood. Until such considerations are met, I do not feel that the rezoning of "the Calson Field" to CRMU is acceptable with the number of homes/units it allows for. Nor do I feel it should become such a commercial draw, that exacerbates current traffic and parking on the point. We already have tight roads with little to no sidewalks facing overuse.

The comment is noted. Congestion is
not a required topic for CEQA analysis
and the DEIR analyzed and mitigated
VMT impacts on pages 3-40 to 3-43.

Comments regarding land use
designations do not pertain to the
adequacy of the DEIR, thus no further
response is required. However, the
comment addresses the content of the
Proposed Project and will be shared
with decision-makers in that context.

Please see Master Response 1: EIR
Comments for more information about
GP- or SPSP-related responses. See
response to comment C15-2 and
Master Response 7: Emergency Access
regarding emergency access.

C115-5 Camille
Keating
3/8/22 PG. 97 LU-I-29 Undeveloped San Pedro ave.

Whatever goes in at the field property should be small scale, and allow for a majority of open space to preserve the safety, and look and feel of Pedro Point, and have the least impact on Please see more information on
evacuation routes in Master Response
7: Emergency Access. Please see
Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.
561
Letter Commenter Date Comment Combined Response
Individuals (C)
current Pedro Point residents, as well as in the south end of Pacifica, to where the traffic bottlenecks along HWY1.

C115-6 Camille
Keating
3/8/22 Pg. 159, Coastal Access #24 North Side PedroPoint Shopping Center #25 Ocean Shore Railroad Berm
This coincides with my concerns stated above regarding
Shoreside drive
#24 It is stated “ Improve new segment of Coastal Trail along former railroad berm”. To where exactly are you referring? The berm once ran the length of the beach, and parts were taken down in the upgraded beach trail between Taco Bell and the old "Fassler house." Is this the area you are referring? It is unclear, though maps and some wording point to north of the Pedro Point Shopping Center.
#25, "Ocean Shore Railroad Berm", also referred to as "Shoreside Drive" in other segments of this plan, are one in the same, so interchanging the names is confusing and lacks continuity and clarity. This is a privately owned DRIVEWAY with resident access only, but because of the wording of “Old Railroad berm”, the exact location and section of trail you are referring to is murky.

This leaves room for interpretation, confusion, and sometimes anger from the frustrated public who lacks proper direction, signage, and etiquette, regarding treading through private property.

C115-7 Camille
Keating
3/8/22 Lastly, On page 82 Figure 4-8 it lists two areas listed as either "View Corridor" or "Bluff top view points" in Pedro Point, that are both sensitive areas vulnerable to overuse, or on private property near eroding or unsafe bluffs. Both Shoreside drive/ Shelter Cove road, and Kent road / Blackburn Terrace. These areas when pointed out become an attractive nuisance to the already congested neighborhood, and liability to private property owners as people "searching for a view" tread over private property or sensitive habitat. On Shelter cove road and Shoreside drive about 10 years ago, a woman fell off of the cliff and died while overlooking the view. More recently, in June of 2021, a young woman drove passed the resident safety cones placed at the end of Danmann, alerting of residents' parking area, in an attempt to drive her car off the cliff. When unsuccessful, due to hitting a fence put up by residents to protect this area, the woman jumped off of the cliff in the dark of night, a second attempt at suicide. Residents found her damaged car, and later, her near lifeless body at the bottom of the cliff. I was one of those residents. I along with my family stayed with the woman, and after rescue firefighters arrived and brought her broken body up the cliff after lying helpless for over 12 hours as the tide crept up to her. It was a haunting scene that will stay with me.

When you "advertise viewpoints" especially in areas that are private, and or not maintained by the city, you are inviting more attention to sensitive areas that would be better left unbroadcasted. With that said, I am glad to read that on Page 162 Policies OC-I-38-41 Impediments to Public Access, it states "prohibit restrictions on public parking that would adversely affect public access to beaches, trails, or other recreational lands along the coast, EXCEPT WHERE NECESSARY TO PROTECT PUBLIC SAFETY" and that "THE CITY MAY GRANT EXCEPTIONS TO THIS The comment is not related to the
adequacy of the DEIR, therefore no
further response is required in the
FEIR. However, the comment
addresses the content of the Proposed
Plan and will be shared with decisionmakers in that context. Please see Master Response 1: EIR Comments for
more information about GP- or SPSPrelated responses.
562
Letter Commenter Date Comment Combined Response
Individuals (C)

REQUIREMNET WHERE PUBLIC ACCESS WOULD POSE A SAFETY

RISK, OR THREAT TO FRAGILE RESOURCES, OR WHERE
ADEQUATE ACCESS EXISTS NEARBY"
Please take this into consideration when choosing to include privately owned, or sensitive or potential dangerous areas, and listing them unnecessarily as "View Corridor" or Bluff top Views." Again, No private entity should be made liable for maintenance or dangers caused by unwanted invitations to the public in the form of signage or listings and these areas SHOULD NOT BE PROMOTED.
563
C116: Henry Ruhnke, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C116-1 Henry
Ruhnke,
Architect
3/8/22 Our office is working with the owner of the 3.48 acre undeveloped parcel (number 018-140-670) which fronts on the west side of Highway 1 situated between the Our Savior’s Lutheran Church and the Pacifica Pet Hospital. The current zoning of this parcel is C-2 and the 1980 General Plan identifies this parcel along with neighboring parcels to the north and south as commercial land use designations.

We have reviewed the Draft General Plan update and have noticed that parcel 018-140-670 is now shown as a “service commercial” land use while the other parcels to the north and south have been shown as “mixed use neighborhood 16-26 units per acre.” The “service commercial” land use is actually a downzoning of my client’s parcel since the existing C-2 zoning allows for more uses than the “service commercial” land use category. It seems inconsistent to keep parcel 018-140-670 as a commercial use while changing surrounding land-uses to mixeduse neighborhood. Furthermore, looking at the figure 4-3 in the Draft General Plan my client’s parcel appears to be a “spot zone” around mixed-use uses.

This letter is to request parcel 018-140-670 be changed in the Draft General Plan from “service commercial” use to “mixed-use neighborhood 16-26 units per acre.” Considering the City’s and State’s need for housing, identifying this parcel as mixed-use makes much more sense than the commercial “spot zone” as currently proposed.

In summary, I looked at all 522 Policies, both Guiding and Implementing, in the DGP and checked their occurrences in the DEIR. I found that 168 of them were listed in error at least once in the DEIR, and many multiple times. By “error” I mean that the text does not match that of the same-numbered Policy in the DGP. That is an error rate of at least 32%, about one out of three.

Tracking the Consistency of Policy Numbering between the DGP and There are 522 policies (Guiding and Implementing) listed in the General Plan, I checked every one of them against their counterpart in the DEIR, in all of the I found that 168 of them were listed incorrectly at least once in the DEIR, many That is an error rate of at least 32%.

The data is listed here in the two following worksheets, one with all the raw data This video explains my process in detail.

The comment is noted. These
policies will be renumbered in
errata. They do not change
findings of significance.
565
C118: Pete Shoemaker, 1/31/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C118-1 Pete
Shoemaker
1/31/2
2 The below video shows how I discovered 15 errors in policies between the GP and the EIR in 90 samples: 17% error rate.

There are 530 such policies, which projects to about 90 potential errors. The attached files are my documentation.

Policy errors: https://www.screencast.com/t/8rog4I2erC
The comment is noted. Policy
numbering will be clarified in a
redline version.
566
C119: Michael Vasey, 2/20/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C119-1 Michael C
Vasey, PhD
2/20/22 ln reviewing the draft Plan Pacifica, the following comments will mostly be focused on the property identified as "Undeveloped San Pedro Avenue Site" in Fig.4-B: Pacifica Southwest. ln all of the maps in the document, the Undeveloped San Pedro Avenue Site is shown to have three roads going through it. ln fact, no roads actually go through this - 5 acre property. Rather, these reflect "paper streets". This is important because this relatively large, flat property is still relatively intact and provides numerous local community, public, and natural resource services to Pacifica. I will elaborate further below^
The comment is not related
to the adequacy of the
DEIR, therefore no further
response is required in the
FEIR. Maps will be modified
to remove paper streets;
this does not change any
findings of significance.

C119-2 Michael C
Vasey, PhD
2/20/22 Section 1
Referring to this property, pages 4-25 & 4-27 state that the "Plan retains flexibility for any future development on the vacant site west of the shopping center, identified as the Undeveloped San Pedro Avenue Site, which could have residential and small-scale commercial and visitor-oriented uses.

Development of the site will require detailed evaluation of coastal hazards/vulnerabilities and biological resources to ensure that any sensitive habitat and wetlands that may exist on the site are protected; thus, the footprint of development could be smaller than the area designated. Future development should include a small park and access to the berm and the beach beyond. Completion of the Devils Slide Tunnel project has provided the opportunity to create a new trailhead and trails through open space land on the headlands" (my emphasis, and similarly throughout the remainder of this comment). This important language is highlighted because it effectively summarizes the potential for this site to serve Pacifica residents, the broader public, and the conservation of diminishing coastal biodiversity in important ways.

The following guiding policies and implementing policies highlight some of these key points (P.4-31), for
example:
"LU-G-1 Coastal Development. Ensure that development maximizes beach and coastal open space access and is oriented as much as possible to each particular coastal environment in use, design, and intensity.

LU-G-7 Open Space Conservation and Habitat Protection. Protect beaches, oceanfront bluffs, ridgelines, hillside areas adjacent to existing open space, and areas that support critical wildlife habitat and special status species.

LU-G-9 Citizen Participation . Continue broad-based citizen participation in the planning process."
LU -l-2 Land Divisions in the Coastal Zone. "Continue to require coastal development permits for all land divisions within the Coastal Zone. Land divisions in the Coastal Zone shall be: Prohibited on properties that include any areas that ore within or adjacent to an Environmentally Sensitive Habitat Area (ESHA) unless the resulting parcels can be developed without building or requiring vegetation clearance in the ESHA or ESHA buffer, or unless the resulting parcels are set aside for conservation. Any land division that would result in a parcel that could not be developed in accordance with the policies of this LCLUP is not allowed."
LU-l-3 Coastal Development Permit Findings. "For all development that requires a coastal development permit, continue to require written findings that it is consistent with all LCLUP policies and implementation Plan provisions of the City's certified Local Coastal Program. If there is a conflict between a provision of this LCP and a provision of the General Plan, or any other City-adopted plan, resolution, or ordinance not included in the LCP, The comment is not related
to the adequacy of the
DEIR, therefore no further
response is required in the
FEIR. However, the
comment addresses the
content of the Proposed
Plan and will be shared
with decision-makers in
that context. Please see
Master Response 1: EIR
Comments for more
information about GP- or
SPSP-related responses.
567
and it is not possible for the development to comply with both the LCP and such other plan, resolution or ordinance, the LCP shall take precedence and the development shall not be approved unless it complies with the LCP provision.

LU-l-29 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 smallscale 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 73577 (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"
This series of guiding and implementing policies well defines both the significant challenges of developing this site, the potential that represents for the community, and to some degree the potential that the best solution may be to make all or a significant portion of it public open space. I will elaborate on these ideas below.

C119-3 Michael C
Vasey, PhD
2/20/22 Section 2
To begin, most significantly, in the Draft Plan Pacifica, the issue of Environmentally Sensitive Habitat Areas (ESHA) is defined as: "any area in which plant or animal life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and which could be easily disturbed or degraded by human activities and developments." "These areas are to be protected against any significant disruption of habitat values, and only uses dependent on these resources are to be allowed within these areas. Development in areas adjacent to environmentally sensitive habitat areas must be sited and designed to prevent impacts which would significantly degrade those areas, and be compatible with the continuance of those habitat and recreation areas." (P.7- 22).

This is particularly relevant to the Undeveloped San Pedro Avenue Site because of a clear case that this site is ESHA based on the occasional presence of the California Red-Legged Frog (CRLF) in the drainage channel that borders the eastern edge of the property. Several CRLF were present at this site in 2021 and there is evidence that the population laid eggs and produced juveniles (tadpoles)" The drainage canal collects all the natural runoff from Pedro Point Headland to the south and runs in storm water drains below the residential community down to another open drainage channel along the north side of the junction of San Pedro Road and Grand Avenue. It then pools on the other side of Grand Avenue and continues intermittently north to another culvert which empties into an arroyo willow thicket and, then, through another culvert into the mouth of San Pedro Creek. This seasonal breeding population is now well validated (for example, by California Department of Fish and Wildlife). The population waxes and wanes depending on the year. Most likely, it is an important breeding site in dry years because natural breeding pools become fewer. Because of neighborhood runoff, the pool system at the foot of Grand Avenue is Please see Master
Response 6: ESHA and
Master Response 4:

Undeveloped San Pedro
Ave Sites for more
information
568
hypothetically a refuge during dry years.

Another feature of this site that benefits the CRLF is the adjacent field. At night, CRLF individuals access the field and forage for invertebrates that are abundant during the spring and summer breeding season. This abundance of invertebrate forage is also of value to a variety of other species in the neighborhood that depend on the field for food resources. For example, a variety of different rodent species live in the field and these, in turn, provide foraging resources for nearby raptors and owls that live in the forest that is abundant on Pedro Point Headland above the residential area. There is no analogous foraging site in the neighborhood for these avian predators.

Hence, a variety of hawks, owls, and other species (for example, violet green sparrows sometimes during the year) rely on this habitat to support their breeding sites in the nearby forest. This, in essence, underscores the value of the "field" as an ESHA supporting the biodiversity of the area.

One reasonable criticism of the Draft Plan Pacifica report is that it does not recognize this drainage site on Pedro Point. For example, in Figure 7.3, it is not illustrated. Also, despite the well-reported CRLF population present at this site, the red hatched area indicating Critical Habitat for CRLF that should extend to the Undeveloped San Pedro Avenue Site does not. It is important to highlight this potential development conflict so that the property is not zoned inappropriately inviting unrealistic real
estate investment in property that is likely to be determined to be ESHA by the Coastal Commission.

C119-4 Michael C
Vasey, PhD
2/20/22 Section 3
Aside from these fundamental natural resource constraints to getting project approval for the Undeveloped San Pedro Avenue site, there are also a number of geophysical considerations that are important for permitting any future development at the site.

For example, the Undeveloped San Pedro Avenue Site was formerly an extension of the tidal wetland known as Lake Mathilda that extended far into Linda Mar Valley. This wetland was partially cut off from the field by the construction of the Ocean Shore Railroad but was still linked to the mouth of San Pedro Creek via the seasonal stream that drained Pedro Point Headland into San Pedro Creek. During the mid- 20th Century, fill from development in the back of Linda Mar Valley was placed over these wetland sediments to raise the surface of the site. Nevertheless, mucky, wetland soils lie beneath this fill and these unconsolidated soils are well known to he seismically unstable. Accordingly, Figure 8-1 identifies the Undeveloped San Pedro Avenue Site as being at high risk for liquefaction. Further, because the site is low in the tidal frame, it is well recognized as vulnerable to future Sea-Level Rise (SLR). These two factors alone, particularly along the northeast area of the Undeveloped San Pedro Avenue Site, are
sufficient to detract from any development in this area. For example, as spelled out in SA-l-78, "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." ln summary, development on this former wetland is risky both at present, due to seismic instability, and in the future due to potential vulnerability due to SLR.

Please see Master
Response 4: Undeveloped
San Pedro Avenue Sites for
more information about
how proposed projects will
be required to demonstrate
compliance with Coastal
Act policies to receive a
coastal permit; and how
compliance with federal,
state, and local regulations
will reduce potential
impacts to less than
significant.

C119-5 Michael C
Vasey, PhD
2/20/22 Section 4
ln Section 6 {Open Space and Community Facilities), Fig. 6.l identifies the Undeveloped San Pedro Avenue Site as a potential "Park Opportunity Site" The comment is not related
to the adequacy of the
DEIR, therefore no further
569
even though it is not generally recognized elsewhere in the narrative from this section. ln fact, the Undeveloped San Pedro Avenue Site has great potential as a trail connection for hikers linking Pacifica State Beach, across the Undeveloped San Pedro Avenue Site the field along an existing trail alongside the wetland drainage area on the east side of the property, and then crossing San Pedro Avenue to enter the existing trail that goes from behind the Ace Hardware up to Pedro Point Headland. Currently, this trail, and a trail to the old Ocean Shore levee a set of stairs up and down, lead one across the field from San Pedro Road to the Beach. Despite the fact that the Undeveloped San Pedro Avenue Site is private, the Coastal Commission has found that there is a constructive easement across the property.

Further, along the lines of the Pocket Parks mentioned in Section 6, the Undeveloped San Pedro Avenue Site already serves as a major gathering place for residents of Pedro Point. Working with the neighborhood and other Pacifica citizens, it would be excellent to create a pocket park for this part of Pacifica. On the ocean side of the highway and the south side of San Pedro Creek, this is the only level, relatively large area where people from the neighborhood and elsewhere can gather. It would be great to fold this area into the pocket park planning process.
response is required in the
FEIR. However, the
comment addresses the
content of the Proposed
Plan and will be shared
with decision-makers in
that context. Please see
Master Response 1: EIR
Comments for more
information about GP- or
SPSP-related responses.

C119-6 Michael C
Vasey, PhD
2/20/22 Section 5
A final but related issue is the support of recreation for the neighborhood and other people who visit the coast for a variety of reasons. Again, presumably as a result of the closure of beach parking areas 5 during early Covid times, many people began to park along San Pedro Road and use the Undeveloped San Pedro Avenue Site as an access for surfing, fishing, and other shoreline recreation. This supports the OC-G-6 Coastal Areas Suited for Water-Oriented Recreation goal. Beyond coastal access, this site is also used in essence as a dog friendly space and place for various residents to play. It has great potential become an important recreational resource for Pacifica.

C119-7 Michael C
Vasey, PhD
Summary
ln summary, the Undeveloped San Pedro Avenue Site is somewhat mischaracterized by the Draft Plan Pacifica document. Most importantly, it fails to recognize the wetland value of this site, the importance of the site to ESHA considerations, and its potential for linking Pacifica State Beach with Pedro Point Headland. Further, by identifying this site as one for future development and drawing in the paper streets in all the figures in the document, it is easy to assume that this property does not have the natural and cultural values that, in reality, it clearly presents. While it is possible that some limited development might take place, it would be essential for this development to be as far as possible from the biologically sensitive habitat at its eastern end. This would then entail a number of problems within the neighborhood, such as too much traffic to get to the western part of the field without negative inpats and intense local opposition. ln my view, the Plan Pacifica draft would be far improved if it included these considerations in the final document so that future people interested in potential development would not be misled by the current treatment of this site in Draft Plan Pacifica.

Please see Master
Response 6: ESHA and
Master Response 4:

Undeveloped San Pedro
Ave Sites for more
information.
570
C120: John Sharp, 3/4/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C120-1 John E.

Sharp
3/4/22 Housing Element
Owner notes that the City of Pacifica ("the City") is, as is the case with all jurisdictions of the State of California, undergoing affordable housing review consistent with, without limitation, the multiple affordable housing bills recently signed into law, including Senate Bill 9, Government Code Sections 65915, 65852.2, 6582.22 and related statutes. In addition, pursuant to the requirements of the Association of Bay Area Governments, (ABAG), Regional Housing Needs Allocation ("RHNA) goals must be met. In or about December 2021, ABAG adopted Final Regional Housing Needs for the San Francisco Bay Area which applies to all jurisdictions, including the City.

Among the multiple references in the City's Draft Housing Element for 2015-2023, adopted by City Council Resolution No. 13-2015 on May 11, 2015, the Draft Housing Element references ABAG's RHNA allocations as applied to the City. The table at page 29 (Table II-12), relying on RHNA mandates shows planning requirements for housing units affordable to a range of income levels and goes on to state:
"In practical terms, it means a mix of housing types may be necessary to meet future housing needs, to include low-density single-family housing and higher-density housing in mixed used developments." At page 45, the land use element, under "Land Use Controls" references the Land Use Element of the General Plan as providing "overarching guidelines for land categories and includes a map of assigned land uses". That map contains the owner's property, as identified above.

At page 46, table II-27 and paragraph 3, the various residential zoning districts in the City are described. On page 4 7, the Housing Element states, at paragraph 1:
"Tradeoffs among zoning districts, notwithstanding, the internal consistency that exists between General Plan Densities and Zoning Code Standards results in a situation where it is feasible for developers to achieve maximum allowable residential densities within each respective zoning district. Furthermore, in certain cases, the Density Bonus Ordinance (discussed later) may allow density up to 50% beyond the district allowance."
At paragraph 7, on page 47, a description of multiple-family residential development in the various R districts and C districts is described.

Further, at page 86, the Housing Element identifies "approximately 95 acres of vacant or underutilized land in the C 1, C2 and CR districts." It is further stated that these commercial zoning districts provide an opportunity for affordable housing".

On behalf of Owner, we note in the context of the Housing Element, General Plan Update and General Plan EIR, that zoning of the abovedescribed parcel for high-density residential use provides the City with affordable housing opportunities as contemplated in the many recent state affordable housing mandates and the City's own policy document.

Owner thus requests that, the land use designation for Parcel 018-140- 670, currently zoned C-2, be zoned for high-density residential zoning, which would contribute to the City's housing requirements.

The owner's preference
for high density housing
is noted. As this
comment does not relate
to the analysis of the
DEIR, no further
response is required.

However, the comment
addresses the content of
the Proposed Plan and
will be shared with
decision-makers in that
context. Please see
Master Response 1: EIR
Comments for more
information about GP- or
SPSP-related responses.
571
C121: Margaret Goodale, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C121-1 Margaret
Goodale,
Naturalist
3/7/22 SA-I-14 Geologic Hazard Abatement District
>> No coastal property that is unsafe to build on without first “altering the shoreline,” building a seawall, or allowing future “Shoreline Protection” should be developed according to the currently State certified LCLUP.

A Seismic Safety and Safety Element policy prohibits the approval of projects which require seawalls as a mitigation measure. The policy also states that projects should not be approved which eventually will need seawalls for the safety of the structures and residents.

The new GP/SPSP/DEIR documents in review propose to:

SA-I-9 Maintain Restrictions on Hazardous Areas.
“Continue enforcing the existing Coastal Zone Combing (sic.) District and Hill- side 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. “ >> Note that “restrict” does not prohibit.

SA-I-14 Geologic Hazard Abatement District
Amend the Municipal Code to include provisions for formation of geologic haz- ards 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 improve- ment and maintenance of drainage and protective infrastructure. The Geologic Hazard Abatement District (GHAD) is a potentially useful tool to effec- tively 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.

SA-I-33 Adaptation Funding allows property owners in
hazardous areas to
“…pursue…new funding mechanisms…”
SA-I-68 Shoreline Protection Structure Upgrades
Allow maintenance of existing or new shoreline protection structures to reduce hazards and resource impacts…
>> The three entries facilitate violation of the California Coastal Act. Every implication that indefinite new and improved walls are encouraged MUST be removed.

This comment is related to the
LCLUP. These policies have been
reviewed in a consultation draft
with the CCC, and any final
changes will be made consistent
in an update to the GP.
572
C122: Stan Zeavin, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C122-1 Stan Zeavin
& Linda Mar
3/7/22 1. Our GP is filled with short term planning. Higher costs and duplication will follow.

Obsolescence is the bed partner of short-term planning for long term issues. See Example 1 below for dangers of short-term planning with respect to traffic and transportation.

C122-2 Stan Zeavin
& Linda Mar
3/7/22 2. The major question on many projects in the GP: What is best for development, not what is best for Pacifica’s citizens and what is the most up-to date information (see also #3)
To be fair, the science is considered when it doesn’t interfere with planning development. However, there are several
examples of the city rubber stamping developer’s reports in spite of multiple engineering errors and misinformation. Failure to do due diligence by choosing to ignore the most up-to-date information available is bad for Pacifica. For examples of the city’s lack of due diligence resulting in citizen safety concerns, see Example 2 below.

C122-3 Stan Zeavin
& Linda Mar
3/7/22 3. GP’s lack of information updating makes it impossible to formulate a realistic(?) new(updated?) GP plan. The GP has almost no contingency plans for major projects, and without accurate information to begin with, contingency planning is meaningless. Even the proposed contingencies, such as they are, do not plan for what would happen if the money dries up nor does it explain who would then pay. What if SLR accelerates faster than currently anticipated, which at this point seems a distinct possibility? Without reasonable alternatives in the plan, there could be up to years of delay for a situation that might call for an immediate response. See Example 3 below.

The comment is noted. Policies
within the LCLUP related to
effects of climate change and sea
level rise are addressed in the
LCLUP. Please see also See
response to comment C13-3 for
more information about coastal
flooding and sea level rise.

C122-4 Stan Zeavin
& Linda Mar
3/7/22 4. The GP will not have a completed LCP and the June date for the completion of the GP is both arbitrary and artificial. The GP is not close to having an acceptable LCP. This process has been going on for years. It appears that the city is attempting to get an incomplete GP on record that will take years to correct rather than take the time to do a thorough and complete GP that would minimize the risk of litigation challenging the GP. A proper GP would also minimize the risk to citizens from poorlydocumented hazards such as fire, flooding, landslides, erosion, and sea level rise. See Example 4 below for how and why the city could go broke without resilient/adaptation alternatives and long-term planning that is not now included in the GP/DEIR.

ALERT: Read Pacifica’s responses to the CCC’s suggestions. Our city council shows no intention of following the California Coastal Commission’s (CCC) guidance.

Hazards are adequately
documented in the DEIR, please
see response to comment C22-10
for adequacy of mapping.

C122-5 Stan Zeavin
& Linda Mar
3/7/22 Example 1 of short-term planning Traffic and Transportation Pacifica can only handle so many car trips in a day. Yet, the The comment is noted.

Congestion and transit adequacy
573
Letter Commenter Date Comment Combined Response
Individuals (C)
previous GP draft had a potential of up to 750 new units up for development, including hotel rooms, condos, apartments, and homes. Now, the Quarry has been added and one can assume that others spots will be. There could be between 800-900 or more possible new units. While the city has a formula for how many car trips there are in a day per type of unit, I couldn’t find a discussion about what the number of units should be to be able to keep congestion at certain levels. This would allow the city to stop development at a preferable level of traffic control.

NOTE: It should be noted that appreciably improving the traffic patterns won’t be possible. A few years ago, a previous city council attempted to widen Highway 1 between
Rockaway/Fassler and Reina Del Mar/Vallemar from four lanes to six. CalTrans wrote the plan. The bottom line was that even with a $60M grant, there would be about 1.5 minutes saved in the morning rush and around 2.5 minutes at night --rush hour traffic wouldn’t change much, no matter how many lanes that part of Highway 1 was widened. A federal court decision resulted in CalTrans shelving the plan.

Pollution levels rise as traffic level rises. Let’s remember that most of us live in valleys. That means that we will be breathing more CO2 the more cars we have sitting at stop lights. The ocean winds will simply push the CO2 back into the valleys.

We need a sane limit on the building height. The city currently has a height limit of 35 feet. The Sharp Park Specific Plan has provisions for 5-story buildings. How high does the city want new buildings to go? More height means even more units.

More units equals more traffic. Most people in Pacifica would prefer to keep the small town feel that we have now. That means real height limits.

With SB9 and SB10 the future shows less local control on the number of units. This is a wildcard at this time but it bodes ill for traffic control. This legislation needs to be addressed in the GP and DEIR.

Having a first class bus system for Pacifica is necessary but it is not enough. The city is saying more people will use a good bus system. But we don’t know what the percentage might be. This improved bus system has to be in place before any large-scale development takes place so that the city can manage any growth through observing the actual number of people using the bus system.
are not required topics for CEQA
analysis. Buildout under the
Proposed Plan, including visitor
serving commercial buildout at
the Quarry, is included in VMT
analysis and GHG emissions in Ch

3.4, and with less than significant
impacts with mitigations
concluded.

Highway 1 remains under the
jurisdiction of Caltrans, which is
beyond the City's sole scope of
authority to mitigate. As noted
on DEIR p. 3-29, C/CAG is
primarily responsible for
administering the Statemandated Congestion
Management Program (CMP).

The C/CAG-designated CMP
roadway system components in
Pacifica include Highway 1 (SR 1)
and Skyline Boulevard (SR 35).

C/CAG’s LOS standard for
roadway segments on these
roadways is LOS E or better. With
buildout of the General Plan,
none of the intersections along
these two CMP roadway
segments would operate at LOS E
or LOS F. Congestion threshold
are not yet exceeded right now,
therefore it is appropriate to
monitor and proactively
coordinate with Caltrans until
thresholds could potentially be
reached. Potential improvements
to the roadway network could
contribute to mitigating the
impacts of GHG and air quality, as
described in Table 3.4-3,
including policies listed on 3.4-31
and 3.4-32 related to pedestrian
improvements and increased
connectivity, streetscape
improvements and traffic calming
measures, transit service, trip
reduction programs, a clean city
fleet, increased density and
affordability, reduced parking,
water conservation, and waste
reduction.

The comment also refers to
height limits and increased
traffic; height is not directly
574
Letter Commenter Date Comment Combined Response
Individuals (C)
associated with density, and units
that could reasonably be
expected to develop in these
areas are included in buildout
projections. 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.

C122-6 Stan Zeavin
& Linda Mar
3/7/22 Example 2: The GP is putting the desires of the developers above safety of its citizens.

The GP is putting the desires of the developers above safety of its citizens. The CCC upheld an appeal to a nine-unit project the city approved at 1567 Beach Blvd. This is one of several successful appeals. The commonality among these appeals is the city’s rubber stamping the developer’s reports which contained misinformation and faulty science. Just a few further examples:
• claiming the retaining wall had 40 more years of life when a simple visual of the wall showed advanced fissures;
• claiming it will be years before the overtopping by waves will reach 70 feet inland while the locals had many photographs of several storms with overtopping already at the 70-foot mark; • not even following the 1980 LCP (the active LCP at this time).

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

Potential impacts and regulations
and policies that reduce impacts
from hazards are found in DEIR
chapters 3.5, 3.6, and 3.11.

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.

As the commenter notes, the
Coastal Commission has
permitting jurisdiction for areas
in the Coastal Zone. Please see
Master Response 1: EIR
comments for more information
575
Letter Commenter Date Comment Combined Response
Individuals (C)
about GP- or SPSP-related
responses.

C122-7 Stan Zeavin
& Linda Mar
3/7/22 Example 3: GP’s lack of information updating makes fact-based planning impossible
The use of obsolete studies and information can be found throughout the GP. One person who has been taking a close look at our GP stated that he couldn’t find any studies dated later than 2013. The lack of updating is inexcusable.

The latest Climate Change information is being ignored. The proposed armoring in front of Beach Blvd. is based on outdated information. The newest studies show: Rising temperatures are accelerating water movement between land, ocean and clouds.

Water moves from dry regions to wetter ones with 2-4 times the speed of what models had projected. This movement
creates both more storms and stronger storms (Nature).

Therefore, the old 100- year storm concept is obsolete.

NOTE: Among many relevant current studies that any due
diligence would have turned up, the latest NOAA/USGS
predictions have SLR up to 7 feet by 2100 Both the Pine Island and neighboring Thwaites Glaciers in Antarctica are speeding up due to the melting of the ice shelf that supports them
(Washington.edu/news, Hannah Hickey). Methane gas has been photographed leaking into the atmosphere in the melting northern tundra (Nova).

The DEIR uses the latest and best
publicly available information for
analysis. While coastal storms are
not a required topic for CEQA
analysis, flooding is a required
topic. Coastal flooding is
described on DEIR p. 3.5-8. In
2018, the City of Pacifica
prepared a Sea Level Rise
Vulnerability Assessment using
the best available science. The
2021 MJ-LHMP, incorporated by
reference, contains updated
information about climate
change.

C122-8 Stan Zeavin
& Linda Mar
3/7/22 Risk of extreme wildfires will increase 14% by 2030 and 30% by 2050 (U.N. Environment Program report). This report also states the U.S. has invested $50 billion over the next decade to aggressively thin forests around “hot spots” where nature and neighborhoods collide. If grants are available, Pacifica should apply for one. Also, the latest West Coast Plover Conference has reported that coastal fog has decreased 30%. We can’t expect fog protection for our highly burnable Eucalyptus trees as we go into the future. We need serious wildfire alternatives AND escape routes other than Highway 1.

The comment is noted. Analysis
and policies related to
impairment of an adopted
emergency response plan or
emergency evacuation plan
evacuation are described in
Impact 3.11-1. Please see also
Master Response 5: Wildfire and
Master Response: Evacuation.

C122-9 Stan Zeavin
& Linda Mar
3/7/22 Habitat studies in the GP are poorly done with most being outdated. As an example, the grasslands study in the GP was completed in 1992! There is no way to make any serious
decisions using this type of data.

The DEIR uses the best and latest
available data from credible
government sources, such as
from the California Department
of Fish & Game; California
Department of Forestry; National
Wetlands Inventory, U.S.; and
Fish and Wildlife Service National
Wetlands Inventory and the U.S.

Fish & Wildlife Services, at the
appropriate scale of a
Programmatic EIR for a General
Plan. Please also see response to
comment C1-7. The basis for the
vegetation classification system
utilized in this analysis relies on
the currently accepted California
Department of Fish and Wildlife
576
Letter Commenter Date Comment Combined Response
Individuals (C)
List of Vegetation Alliances and
Associations (also known as the
Natural Communities List). Plant
communities generally correlate
with wildlife habitat types, and
these typically are classified and
evaluated using CDFW’s
California Wildlife Habitat
Relationship classification
system. The supplemental
grasslands data from 1992
represents a relevant,
comprehensive study conducted
by a biologist for the purposes of
the City's trail master planning
effort at a scale appropriate for a
programmatic DEIR.

C122-10 Stan Zeavin
& Linda Mar
3/7/22 Example 4: The city could go broke without resilient/adaptation alternatives and long-term planning included in the GP/DEIR The cost of armoring is prohibitive. Who pays the difference if the grants don’t cover the cost? Initial prices range from $48M to $111M with expected costs through the 50-year life running from $102M to $235M. Anyone who has dealt with these kinds of numbers knows that by the time final cost is computed, it could well be double the original figures. If you consider the GP’s business plan which includes growth in the coastal zone including flood zones, Pacifica will need a beach for tourism to thrive. With armoring, our present beach will disappear, which will create a need for sand nourishment and possibly groins.

There was a sediment study, authorized by the state, which included Pacifica about 6-7 years ago headed by the Army Corps of Engineers and included various local scientists and engineers.

The study concluded that, depending on the angle of the tide, sand nourishment would need to be replenished every 5 to 18 years and groins would be out of Pacifica’s price range. What this implies is that for a 50 year wall, you would have to replenish the sand, at a minimum, three times. The price would be prohibitive and it will continue to go up. Under the circumstances, can Pacifica afford more than one
replenishment.? Will the tourists come without a beach? Where are the alternatives, or will the citizens of Pacifica end up shouldering a large part of the cost surrounding the proposed wall/hybrid system?
With over 4000 miles of coastline in the U.S., Pacifica is nowhere near the top of the climate change food chain when it comes to grants. Even with the majority of hurricanes, along with serious SLR issues on the east and south coasts, Pacifica can certainly still get some grants at this time. But, even in our own county, we on the coast
take second place to the bigger population on the bayside. It seems unlikely that Pacifica can get the number of grants to survive the cost of the GP’s plans.

The comment is noted. Coastal
armoring is addressed in the
LCLUP and not required for
analysis under CEQA. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR, no
further response is required.

C122-11 Stan Zeavin
& Linda Mar
3/7/22 Experts say the key to long term planning is a functional Resiliency Policy. There is no actual Resiliency Policy in the This comment is related to
policies in the LCLUP. The LCLUP
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GP/DEIR. A Resiliency policy infers a certain flexibility, such as managed retreat (landward relocation if you prefer) and other adaptations. However, , most of the alternatives in what is called the GP/DEIR Resiliency Policy fall into the Resistance category, e.g., walls, etc. The major reason for this manipulation is to prevent lowering the value of existing structures, i.e., privately owned residences?, in the flood zone. What this means is the LCP will not be acceptable to the CCC; all the alternatives are expensive; and there are no fiscally reasonable contingencies in place.
is not addressed as part of this
DEIR.

C122-12 Stan Zeavin
& Linda Mar
3/7/22 Sea Walls are Not the Answer:
• Given the latest Climate Change information, a good case can be made that the Beach Blvd. wall will not be effective for its expected lifetime. The wall is built to last 50 years, but this assumes that the SLR stays below 2.5 feet and one 60- year storm. But by not considering other, less optimistic scenarios, the people on Beach Blvd. could be put in a position of extreme danger. Though there are trigger points in place, it is inexcusable not to have a fallback plan in place that won’t cost an arm and a leg in case of an emergency. And who will pay? • The wall can’t be built to protect new development. The wall is being rebuilt to protect the Sharp Park sewer system. But the CCC has stated that all new development along the coast will be considered as if there is no sea wall. In the Sharp Park workshops the vast majority of the time was not spent on aspects of the sewer system and other issues, but on the desire for development. What if the development plan runs into approval problems? Pacifica will, in all probability, be responsible for all future upgrades to the infrastructure (not necessarily the original build) and removal of the new buildings when the time comes (it’s probable that businesses will dare Pacifica to sue them, even if it’s written into the contract with the city that the business is responsible for the building’s removal). It could be big money for the real estate industry and disaster for Pacifica.

NOTE: The DEIR, Doc p. 9 & 10 – 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..

Notice that the above two sentences are contradictory.

It is unclear which sentence this
comment refers to. If commenter
is referring to "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)" (DEIR
p. 3.6-17). This statement comes
from Pacifica's currently certified
LCP.

C122-13 Stan Zeavin
& Linda Mar
3/7/22 The Sharp Park sewer system services 40% of Pacifica, the proposed sea wall will protect around 5% of Pacifica’s
population. The plan is to do the upgrade to the sewer system during the life of the wall with most of the work being done near the end of the wall’s existence. With SLR there is a possibility of a storm emergency at any time, including wall failure. With a pump failure, waste backup could reach every corner of the sewer system. Even with triggers and a plan in place by that time, it would take years to add details to finish the plans, raise the money, and actually complete moving the The comment is noted. See
response to comment C9-2.
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sewer system landward. By waiting so long to complete the rebuild the cost could double or triple what it would cost if done in the near future.
o ALERT: The CC is going to vote on using increased fees from the sewer system. It is not clear where the money will go.

C122-14 Stan Zeavin
& Linda Mar
3/7/22 The Linda Mar sewer and storm water drain systems are being refitted with pipes recommended in a ten year plan that is now eleven years old. The people who live on Anza, the first street east of Highway 1, have experienced sewage bubbling up from the sewers several times in the last 15 years. We can agree that this is unacceptable. After the storm, late last year, it was reported that there was close to 7” of rain in a 24 hour period.

The 17 million gallons processed plus the 2.9 million gallons dumped into the ocean essentially, the 20 million gallons of the projected capacity of the Calera Creek water recycling plant AFTER the larger pipes are installed. The Master Plan uses the same design rainfall event as used in the 2011 Master Plan, with a 24 hour total of 3.74”. Last year’s rainfall is close to double the design rainfall event of the Master Plan. With the latest Climate Change information, we can assume that the
probability of other storms this big or bigger is high.

Recalculating the numbers before installing pipes that might have to be replaced sooner rather than might have saved the city serious money.

The comment is noted. See
response to comment C9-2.

C122-15 Stan Zeavin
& Linda Mar
3/7/22 CONCLUSION:

The GP/DEIR/SPSP needs a refocusing of its economic priorities.

Most of the visible economic energy in the GP/DEIR is aimed at financing the sea wall and development. As mentioned earlier, there are serious potential roadblocks to both. With very little discretionary money available in our city, the losers are other big ticket issues such as the Sharp Park sewer system and help for the increased wildfire dangers. The longer these items are ignored, the higher the price for a fix gets for Pacifica. Other issues, such as the Linda Mar sewer and rainwater systems could cost Pacifica serious added expense due to
mismanagement and duplication. Building in a flood zone will, again, cost Pacifica dearly in the long run. Without
contingencies based on resiliency, Pacifica’s choices are very limited, and the ability to react quickly and correctly in an emergency decline. I recognize that there is a strong
commitment to the priorities as they stand in the GP/DEIR, so I ask that if the city do nothing else, please add in the appropriate places (I’d be glad to help) alternatives based on real resiliency solutions. This would make life much easier and, hopefully, cheaper for the coming generations. Lastly, if money is not there for serious armoring, should the city put up a retaining wall north of the pier and use the money saved and refocus the grant search to start/complete the Sharp Park Sewer System reconfiguration?
The comment is not related to
the adequacy of the DEIR,
therefore no further response is
required in the FEIR. However,
the comment addresses the
content of the Proposed Plan and
will be shared with decisionmakers in that context. Please see Master Response 1: EIR
Comments for more information
about GP- or SPSP-related
responses.
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C123: Brian Gaffney,
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C123-1 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 This office represents the Pedro Point Community Association and its members in regards to the City
of Pacifica’s General Plan Draft January 2022 (“2022
GP Update” or “Project”) and the Pacifica General
Plan Update Draft Environmental Impact Report
(“2022 Draft EIR” or “DEIR”). Attached hereto
please find specific comments about the 2022 Draft
EIR’s compliance with CEQA (the California
Environmental Quality Act), Public Resource Code
§§ 21000 et seq. and the CEQA Guidelines, and
inadequacies in the 2022 GP Update.

The 2022 Draft EIR falls short of CEQA’s
requirements as it
(1) fails to include an adequate project description,
(2) improperly segments the project,
(3) fails to include an adequate environmental
setting description, (4) fails to adequately analyze
Project impacts,
(5) fails to adequately analyze mitigation measures,
and
(6) fails to integrate required Coastal Act and other
statutory environmental analysis with this CEQA
process.

Thus, the 2022 Draft EIR does not include sufficient
information to foster informed public participation
and to enable Pacifica decision makers to consider
the environmental factors necessary to make a
reasoned decision about the proposed 2022 GP
Update.

Because the 2022 Draft EIR is fundamentally
inadequate, meaningful public review and comment
are precluded. Once the DEIR is fixed it must be
recirculated for further public and agency review
and comment.

Please include this office in further communications
regarding this proposed project and environmental
review. Please provide us with copies of a
Recirculated Draft EIR and the Final EIR for this
proposed Project.

The commenter's assertion the project fails to
include an accurate project description is
incorrect. Section 15124 of the State CEQA
Guidelines defines the types of information
that should be included in a project
description, including a map of location and
boundaries (Figure 2.1-1, 2.1-2 and Figure 2.1-
3); statement of objectives (DEIR p. 2-2, 2-9
through 2-11); a general description of the
project’s technical, economic, and
environmental characteristics (DEIR p. 2-1, 2-2,
2-6, and 2-7); and a statement briefly
describing the intended uses of the EIR (DEIR p.
1-5). The project description includes an
estimate of how much buildout is expected to
occur as result of implementing the Proposed
Project (DEIR p. 2-22 and 2-23 ) and where this
development would likely occur, as much of
the residential and nonresidential
development would occur, corresponding to
Figure 2.2-1. Project-specific detail is not
required for descriptions of general plans and
other high-level programs as details about
specific subsequent projects typically are not
known and will be addressed in future projectspecific CEQA documents. Thus, the project description is adequate. Please also see
response to comments 123-2, 3, 4, 5, and 6.

The commenter's assertion that the DEIR
segments the project is incorrect. The DEIR
does not segment the project; it analyzes the
effects of implementation of the land uses and
buildout estimate under the Proposed Plan.

Please see Master Response 3: Buildout and
RHNA for more information. See also
responses to C123-3, and 4.

The commenter's assertion that the DEIR
environmental setting description is
inadequate is untrue. The DEIR includes an
adequate environmental setting description. It
describes the existing local and regional
physical environment, as it existed when the
notice of preparation of the EIR was published
in September 2020. This specific comment
does not highlight any specific examples of
inadequate environmental settings. Please see
response to comments 123-7 through 123-13.

The commenter's assertion that the DEIR does
not address Project impacts is untrue. The DEIR
adequately addresses Project impacts for each
of the required topics under CEQA. The DEIR
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analyzes the impact of the policies by focusing
on where and what type of development the
plan would allow. The DEIR adequately
analyzes how compliance with State, regional,
and local regulations, as well proposed policies
under the Proposed Project, may or may not
reduce CEQA impacts of significance. Then it
also considered the beneficial impacts of the
policies and the extent to which they would
reduce or avoid impacts in conjunction with
existing regulations. As a programmatic
document, this EIR presents a citywide
assessment of the potential impacts of the
proposed Pacifica General Plan. It does not
assess project-specific impacts of potential
future projects under the proposed Plan, all of
which are required to comply with CEQA as
applicable. Please also see response to
comments C123-14 through 33.

The commenter's assertion that the project
does not adequately analyze mitigation
measures is untrue. Please see response to
comments C34 through 40.

The commenter's assertion that the DEIR fails
to integrate required Coastal Act and other
statutory environmental analysis is untrue. The
DEIR analyzes potential impacts due to sea
level rise, coastal erosion, sensitive habitat,
and other impacts and identifies regulations
and policies that could reduce any potential
significant impacts. Coastal Commission
permitting authority is referenced in
subsequent chapters. As noted on p. 2-7, Local
Coastal Plans (LCPs), which include Local
Coastal Land Use Plans (LCLUPs), are not
subject to CEQA. LCP amendments 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). Therefore, the LCLUP for
Pacifica is not analyzed under this EIR. Please
see response to comments C123-41 through

59. This information, coupled with the extensive
number of public comments on the DEIR,
indicate that there has been sufficient
information to foster informed public
participation. Responses to these comments
and subsequent DEIR clarifications will enable
decisionmakers to make reasoned decisions.
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C123-2 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 The 2022 Draft EIR’s Project Description is
Inadequate.
"[A]n accurate, stable and finite project description
is the sine qua non of an informative and legally
sufficient EIR." (San Joaquin Raptor Rescue Center v.

County of Merced (2007) 149 Cal.App.4th 645, 655
quoting County of Inyo v. City of Los Angeles (1977)
71 Cal.App.3d 185, 199.) The project description
must include a general description of the project’s
technical, economic and environmental
characteristics, considering principal engineering
proposals and supporting facilities. (CEQA Guideline
15124, subd. (c).) The EIR must include detail
sufficient for evaluation and review of
environmental impacts. (CEQA Guideline 15124.)
Even where an EIR is adequate in all other respects,
a “truncated project concept” violates CEQA. (San
Joaquin Raptor/Wildlife Rescue Ctr. v. Cnty. of
Stanislaus (1994) 27 Cal. App. 4th 713,730; County
of Inyo, supra, 71 Cal.App.3d at 200.)
An EIR project description should include all project
components. All phases of a project must be
considered in the EIR as the “whole of the action,”
so that “environmental considerations do not
become submerged by chopping a large project into
many little ones, each with a potential impact on
the environment, which cumulatively may have
disastrous consequences.” (Bozung v. Local Agency
Formation Commission of Ventura County (1975) 13
Cal.3d 263, 283–284; Burbank-Glendale- Pasadena
Airport Authority v. Hensler (1991) 233 Cal.App.3d
577; CEQA Guideline 15126.)
The 2022 Draft EIR’s Project Description is flawed in
the following ways:
1) The 2022 Draft EIR at p. 2-14 states that “Figure

2.3-1 shows the General Plan Land Use Diagram.”
However, the 2022 Draft EIR does not contain a
Figure 2.3-1. Given that the 2022 Draft EIR provides
that the Land Use Diagram will be used “to review
and approve, modify or deny proposed
development projects” (DEIR, p. 2-14), the absence
of a Land Use Diagram at Figure 2.3-1 makes the
2022 Draft EIR’s project description uncertain and
thus invalid under CEQA.

The General Plan Land Use Diagram is shown in
Figure 2.2-1; the following clarification is
made: “Figure 2.32-1 shows the General Plan
Land Use Diagram.”
C123-3 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 2) There is an underlying uncertainty regarding how many new units will be allowed to be developed
under the proposed 2022 GP Update. The 2022
Draft EIR defines “buildout” as development
resulting from application of land use designations
and assumed densities under the General Plan.1
DEIR, p. 2-20. “Buildout is calculated based on
assumptions about new residential and nonresidential development that could be built under Please see response to comment C4-1 and
Master Response 3: Buildout and RHNA for
more information on adequacy of buildout
projections. Please also see response to
comment C123-22.
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the Plan’s land use designations and their respective
densities and intensities, adjusted to match
expected demand. Id. The 2022 Draft EIR provides
that “implementation of the Proposed Project is
projected to result in an additional 990 units.” DEIR
p. 2-21.

Yet the 2022 GP Update provides that only a few
months from now, by January 31, 2023, the City will
update the General Plan Housing Element to
accommodate 1,892 housing units in compliance
with the 6th Cycle Regional Housing Needs
Allocation (RHNA 6). 2022 GP Update, p. 1-6. Nor
does the DEIR project description consider ADUs,
ministerial development allowed by SB 9, or lot
splits. The 2022 Draft EIR does not acknowledge
these additional housing units, nor attempt to
harmonize or explain these widely variant housing
unit assumptions. Given these discrepancies, the
Project description is not finite and stable.

Further, as discussed below, this uncertainty in the
number of housing units under Project buildout
results in a flawed analysis of Project impacts.

C123-4 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 3) The City of Pacifica appears to be impermissibly segmenting the Project and its analysis of Project
impacts by separating the General Plan Housing
Element from the General Plan Update released to
the public in January 2022.

The City’s August 5, 2020 Notice of Preparation of a
Program Environmental Impact Report for the
General Plan Update stated that “the Statemandated Housing Element will be updated as part of a separate process as part of the next Housing
Element cycle (2023).” The January 5, 2022 Notice
of Availability of a 2022 Draft EIR and Draft 2040
General Plan states that “While a part of the
General Plan, the Housing Element will be updated
separately in compliance with state law and is not a
part of the Plan Pacifica Project.” The 2022 Draft EIR
states that “the current Housing Element was
adopted on May 11, 2015 as a separate volume,”
and that “SB 375 requires regional housing
elements and transportation plans to be
synchronized on 8-year schedules.” DEIR, pp. 2-1 &
3-22.

Not evaluating any GP Housing Element as part of
the 2022 Draft EIR impedes understanding of the
proposed Project, and therefore Project impacts.

Review of past Pacifica Housing Elements shows
that issues discussed include population, population
growth trends and housing units, information that is
germane and crucial to understanding buildout
Separately, the City is preparing to initiate its
6th cycle Housing Element update. The
Housing Element update and development of
the required housing sites inventory will
involve extensive community input and be
subject to separate CEQA review. The Housing
Element CEQA document will analyze the
cumulative effects of implementing the
Housing Element Update – including associated
changes to the land use diagram - in
combination with the Proposed Plan.

Therefore, this approach does not constitute
“piecemealing,” or dividing a large project into
separate parts, each of which might have
individually minimal environmental
consequences. Please see Master Response 3:

Buildout and RHNA for more information.
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Individuals (C)
under the 2022 General Plan and its long term
environmental impacts. Given that the City has not
updated its General Plan in over 40 years, and that
the Housing Element must be produced in nine
months - by January 31, 2023 – both the public and
Pacifica decision makers would benefit from an
analysis that includes the Housing Element. By
segmenting the 2022 GP Update from the General
Plan Housing Element, the City is impermissibly
segmenting the Project. Further, the 2022 Draft EIR
does not analyze the consistency of the Housing
Element with the rest of the General Plan.

C123-5 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 4) The 2022 Draft EIR omits any narrative
explanation or graphic representation which parts
of the City of Pacifica are proposed to be changed
under the Project.

Further, reference to Figure 2.1-2 is insufficient as
the size of the map and the similarity of colors
prevent the public from determining whether sites
are Coastal Residential Mixed Use, or Office
Commercial, or Service Commercial, or Low
Intensity Visitor-Serving Commercial. While the
March 2014 Pacifica General Plan Draft
Environmental Impact Report (“2014 DEIR”) showed
the area around the undeveloped San Pedro
Avenue site in pink as bounded generally by
Danmann Ave and San Pedro Ave, the 2022 Draft
EIR does not even include this general information
about the area in pink at the south west portion of
Figure 2.1-2.2
Without this specific information of what areas will
be re-designated or changed under the proposed
Project, public disclosure is impeded as it is
impossible to assess the conclusion that Coastal
Residential Mixed Use will result in 70 new units.
2022 Draft EIR Table 2.4-2. Further, the 2022 Draft
EIR does not disclose if all of these 70 units will be
at the undeveloped San Pedro Avenue site, or how
many new units could be permitted at this
particular site. It is not the public’s role to connect the dots; this is the City’s duty under law in
preparing an adequate environmental impact
report. Thus, the 2022 Draft EIR falls short of
CEQA’s requirement for a finite project description.

The commenter's assertion that the DEIR does
not include narrative explanation on where
land uses change is incorrect. As noted on DEIR
p. 3.1-20, the “Proposed Project includes new
land use designations that replace older and
more generic land use designations in the
same or nearby areas; the new land use
designations accommodate more diverse
housing types, densities, and commercial
developments, primarily in already-developed
areas. There are three mixed use classifications
to create areas where housing and active
commercial uses may be integrated.” As shown
in Table 2.4-2, approximately 76 percent of
new units are projected to occur in these new
mixed use classifications, shown in Figure 2.2-

1. Thus, these new land use categories clearly
designate where new development will occur.

The remaining units would be accommodated
in smaller vacant “infill” lots found primarily in
the West Sharp Park, East Sharp Park,
Westview-Pacific Highlands, Rockaway, and
Pedro Point neighborhoods; these vacant
parcels are shown on the existing land use
map, Figure 3.1-1. Given environmental factors
such as slope and sensitive species, there are
some constraints on the development
potential of these sites.

Further, the City notes that buildout
projections were calculated on a parcel basis to
provide a reasonable estimate of the location
and extent of growth under the Proposed
Project for the purpose of evaluating
environmental impacts; however, the
assumptions for particular sites do not
guarantee that any given site will be developed
or redeveloped with that use or assumed
density during the planning period, as future
development will rely primarily on each
property owner’s initiative. Cumulatively
though at the citywide level these projections
represent a reasonably foreseeable basis for
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assessing the environmental impacts that
could result from Proposed Plan
implementation. Therefore, the DEIR correctly
used a reasonably foreseeable forecast of
buildout under the Proposed Plan as the basis
for the environmental analysis.

As shown in the Land Use Diagram, the Coastal
Residential Mixed Use Designation is only
shown in southern Pacifica for undeveloped
San Pedro Avenue site and adjacent parcel.

This classification permits 10 to 15 du/ac, as
described in the land use classifications. 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.

Please see Master Response 4: Undeveloped
San Pedro Ave Sites.

C123-6 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 5) The 2022 Draft EIR project description fails to provide a list of related environmental review and
consultation requirements, including but not limited
to compliance with the Coastal Act.

This comment is untrue, Coastal Act
compliance is described on DEIR p. 2-6 and 2-7.

C123-7 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 The 2022 Draft EIR’s Environmental Setting is
Inadequate.

An EIR must present an accurate and complete
description of the environmental setting in the
vicinity of the project as it existed before
commencement of the project. (San Joaquin Raptor
I, supra, 27 Cal.App.4th at 722.) A city “should
normally limit its examination to changes in the
existing physical conditions in the affected area as
they exist at the time the notice of preparation is
published.” (CEQA Guideline 15126.2.) The
environment consists of the “physical conditions
The DEIR includes an adequate environmental
setting description. It describes the existing
local and regional physical environment, as it
existed when the notice of preparation of the
EIR was published in September 2020. This
specific comment does not highlight any
specific examples of inadequate environmental
settings or comparisons to the 1980 plan.
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Individuals (C)
which exist within an area which will be affected”
by a project. (Pub. Res. Code § 21060.5.) A complete
description of the “preexisting environment” (San
Joaquin Raptor I, supra, 27 Cal.App.4th at 723) is
critical to establish a baseline for analyzing whether
the project’s impacts are significant. (County of
Amador v. El Dorado County Water Agency (1999)
76 Cal.App.4th 931, 952; CEQA Guidelines 15125 &
15126.2(a).) The environmental setting must be
sufficiently comprehensive to allow the impacts “to
be considered in the full environmental context.”
(CEQA Guideline 15125, subd (c).) As the County of
Amador court stated, “ the question is whether the
EIR contains a sufficient description of the baseline
environment to make further analysis possible.” (Id.
at 954.)
The 2022 Draft EIR’s Environmental Setting is
flawed in the following ways:
1) In analyzing potential Project impacts, the 2022
Draft EIR frequently does not compare the Project
to existing environmental conditions. In many
instances, the 2022 Draft EIR compares the 2022 GP
Update to development permissible under the 40-
year old Pacifica General Plan. Repeatedly the 2022
Draft EIR fails to justify its decision to use a baseline consisting of environmental conditions projected to
exist in the future. Further, the 2022 Draft EIR has
failed to demonstrate that an existing conditions
baseline would be misleading or without
informational value – as CEQA requires.

C123-8 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 2) Simply identifying the undeveloped San Pedro
Avenue site at Figure 3.1-1 as
“vacant/undeveloped” utterly fails to adequately
describe the site such that the 2022 Draft EIR can
evaluate the direct, indirect and secondary effects
of the proposed Project. The absence of a more
detailed description of the undeveloped San Pedro
Avenue site at Figure 3.1-1 could be excused if the
2022 Draft EIR elsewhere described the rich
biological and recreational resources of this site, but the 2022 Draft EIR makes no attempt to provide this
baseline.

Please see response to comment C34-8.

Vegetation and habitats at the Pedro Point site
are shown in figures 3.7-1 and 3.7-3,
respectively.

C123-9 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 3) The EIR’s description of the environmental
setting is insufficient to provide adequate analysis
of flooding and tsunami impacts. There is no
mention of baseline conditions in the undeveloped
San Pedro Avenue site.

Also, Figure 3.5-1 is flawed; while it shows the San
Pedro Avenue site as a Tsunami Evacuation Area, it
fails to show the site as subject to flooding. This
affects the EIR’s analysis of impacts including, inter
alia, whether reasonably foreseeable development
pursuant to the 2022 GP Update will substantially
See Master Response 2 regarding the
programmatic nature of the DEIR. Existing
baseline hydrology and flooding conditions are
also described under the Environmental
Setting section starting on page 3.5-1 of the
DEIR.

As shown on Figure 3.5-1, page 3.5-3 of the
DEIR, the site is not in a FEMA identified special
flood area, however it is subject to localized
floods as noted on page 3.5-8 ‘The broadest
mapped flood hazard areas are located along
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alter the existing drainage pattern of the San Pedro
Avenue site resulting in substantial erosion and/or
flooding, or place future housing within a 100-year
flood hazard area and/or redirect flood flows.

San Pedro Creek, covering much of the Linda
Mar area north of the creek extending down to
the coast. A broad 0.2 percent annual chance
flood area is mapped at the confluence of the
main stem with the North Fork of the San
Pedro Creek.’
Figure 3.5-1 was created based on the
following sources:
-The latest tsunami evacuation zone data
which is available at the City's website
(https://www.cityofpacifica.org/civicax/fileban
k/blobdload.aspx?BlobID=2499),
-As well as the National Flood Hazard Layer for
San Mateo County mapped by the Federal
Emergency Management Agency (FEMA).

As noted on DEIR p. 3.5-20, "potential impacts
associated with implementation of the
Proposed Project include increased rates of
storm water runoff and subsequent flooding
hazards, erosion, increase in nonpoint source
pollutants affecting receiving water quality,
and coastal erosion and flooding that may be
intensified by sea level rise. These impacts
would be reduced to less-than-significant
levels through regulatory compliance and with
implementation of proposed policies." The
DEIR describes how "adherence to the
Construction General Permit under the NPDES
program would require that a SWPPP with best
management practices (BMPs) be prepared for
construction sites; it would include measures
to protect water quality of stormwater that is
discharged offsite and practices to limit erosion
or unintentional releases of hazardous
materials used during construction.

Additionally, any development that would
occur under the Proposed Project would be
subject to the erosion and runoff control
provisions described in the regional Basin
Plan." Based on analysis under Impact 3.5-3
starting on page 3.5-29, implementation of
existing local regulations and compliance with
the following proposed General Plan policies,
the impacts of the Proposed Project related to
the alteration of drainage patterns, flood flow,
stormwater runoff, and exceeded capacity of
stormwater drainage systems would be less
than significant. See policies CO-G-1, CO-G-2,
CO-G-3, CO-G-4, CO-G-6, CO-I-1, CO-I-2, CO-I-4,
CO-I-5, CO-I-7,CO-I-9 through CO-I-16, CO-I-23,
CO-I-24, CO-I-25, CO-I-38, CO-I-46, CO-I-47, COI-58, CO-I-63, SA-G-4, SA-G-5, SA-I-11, SA-I-12, SA-I-15, SA-I-17, SA-I-18, SA-I-19, SA-I-20, SA-I-
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22, SA-I-23, SA-I-24, SA-I-25, SA-I-28, SA-I-30,
SA-I-79, and SA-I-86.

C123-10 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 4) Average household size is used by the 2022 Draft EIR to determine population at “buildout” under the
proposed General Plan update. Table 3.1-3 of the
2022 Draft EIR shows that average household size is

2.86 persons per household. However the 2014
DEIR stated an average household size of 2.6
persons or 2.7 persons. (Compare 2014 DEIR pp.

3.1-6 & 3.13-13.) The 2022 Draft EIR does not
acknowledge or explain these differences.

Average household size uses updated data
from 2014-2019 American Community Survey.

C123-11 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 5) The 2022 Draft EIR’s conclusions about the
increase in population is inconsistent, and it is
unclear if this is a flaw in the description of the
existing environmental setting or inconsistency in
the Project impact analysis.

The Executive Summary of the 2022 Draft EIR states
the Project will result in a population of 41,280 at
buildout, referencing Table ES-1. See 2022 Draft EIR
at p. E5. However, Table ES-1, Table 2.4-1 and
Section 5.1 of the 2022 Draft EIR state a population
of 41,050. If the Executive Summary is correct, it is
unclear if the higher population number in other
parts of the 2022 Draft EIR is due to the Project
causing a further increase in population or if the
existing population setting is inaccurate.

Thank you for this comment. The correct
number, 41,050, was used as part of project
analysis. The buildout population is amended
on p. E-4 as follows to reflect the buildout
number: 41,28041,050. This does not change
findings of significance.

C123-12 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 6) CEQA requires the lead agency to use a baseline that represents real conditions on the ground at the
time of CEQA review. The DEIR relies on traffic data
from 2010, 2011 and in the case of potential VMT
thresholds of significance, 2015. (DEIR, pp. 3-28, 3-
40).

Traffic counts from pages 3-12 to 3-21 were
conducted in 2018 and 2019, and analysis from
Table 3.2-7 on page 3-41 was conducted in
2020 and 2021, in accordance with the table
references in the DEIR.

As noted on DEIR p. 3-28, VMT calculations
rely on the most recent version of the tripbased travel demand model jointly maintained by C/CAG and the Santa Clara County VTA
(C/CAG 2020, published February 2021.) The
latest C/CAG model does not have a 2020
scenario; the 2015 baseline represents the best
available information at the time of the study.

C123-13 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 7) Certainly more was possible from this EIR’s
description of existing conditions.

The 2022 Draft EIR at p. 1-3 references the Existing
Conditions and Key Issues Report (July 2010)
(hereinafter GP Existing Conditions). Review of this
other document reveals discussion of neighborhood
character, including Pedro Point (GP Existing
Conditions p. 2-160), discussion of historical
development (GP Existing Conditions p. 2-5),
housing density by neighborhood (GP Existing
Conditions p. 2-26), existing zoning and zoning maps
(GP Existing Conditions pp. 2-48 to -53), and sites
available for potential housing development of 405
The environmental baseline information in the
DEIR represents an adequate assessment of
environmental settings for CEQA-required
topics. Each of these topics mentioned does
not relate to required topics of CEQA analysis.

Please also see Master Response 2:

Programmatic EIR for more information about
the scope and requirements of a programmatic
EIR.
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units (GP Existing Conditions p. 3-12). In contrast,
the 2022 Draft EIR omits this critical background
information, despite that the information is readily
available. The environmental baseline information
must be in the EIR not solely in some other
referenced document.

C123-14 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 The 2022 Draft EIR’s Analysis of Impacts Is Flawed.

An EIR must evaluate all significant environmental
effects of a proposed project. (Pub. Res. Code §§
21100(b) (1), 21061; CEQA Guidelines 15126(a),
15143.) Both direct and indirect impacts must be
analyzed, in the short term and the long term.
(CEQA Guideline 15126.2.) “Significant effects
should be discussed with emphasis in proportion to
their severity and probability of occurrence.” (CEQA
Guideline 15143.) EIRs “should be prepared with a
sufficient degree of analysis to provide decisionmakers with information which enables them to make a decision which intelligently takes account of
environmental consequences.” (Galante, supra, 60
Cal.App.4th at 1123; CEQA Guideline 15151.)
Bare conclusions without explanation of the factual
and analytical basis is not sufficient analysis of an
environmental impacts. (Laurel Heights I, supra, 47
Cal.3d at 404; City of Maywood v. Los Angeles
Unified (2012) 208 Cal.App.4th 362, 393.) Further,
failure to adequately explain the reasons why an
impact is insignificant violates CEQA. (Protect The
Historic Amador Waterways v. Amador Water
Agency (2004) 116 Cal.App.4th 1099, 1111-12.)
The EIR must include analysis of how adverse the
Project’s adverse impacts will be. (Galante
Vineyards v. Monterey Peninsula Water
Management Dist. (1997) 60 Cal.App.4th 1109,
1123.) Without this analysis, the EIR does not
provide decisionmakers with information to make a
decision which “intelligently takes account of
environmental consequences.” (Ibid.)
Designating an EIR as a program EIR does not by
itself decrease the level of analysis required in the
EIR. (Friends of Mammoth v. Town of Mammoth
Lakes Redevelopment Agency (2000) 82 Cal.App.4th
511.) A program EIR must evaluate the broad policy
direction of a general plan, even though an EIR on a
specific construction project will necessarily be
more detailed. The sufficiency of the information
contained in an EIR is reviewed in light of what is
reasonably feasible. (CEQA Guideline 15151; Kings
County Farm Bureau v. City of Hanford (1990) 221
Cal.App.3d 692, 733.) At minimum, an EIR “must
include detail sufficient to enable those who did not
participate in its preparation to understand and to
This background information is noted. Please
see responses to comments 123-15 to 123-40.
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consider meaningfully the issues raised by the
proposed project.” (Laurel Heights, supra, 47 Cal.3d
at p. 405.) Tiering does not excuse the City from
adequately analyzing reasonably foreseeable
significant environmental effects of the Project, and
does not justify deferring such analysis to a later tier EIR or negative declaration. (CEQA Guideline
15152(b).)
The 2022 Draft EIR’s discussion of Project
environmental impacts is flawed in the following
ways:

C123-15 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 1) The City has long known that analysis of impacts from redesignating the San Pedro Avenue property
was important to the public. The 2014 DEIR
included scoping comments raising issues which are
still relevant in 2022: viable land use designations
for the San Pedro Avenue (Calson) site;
incorporation of most recent Coastal Commission
guidance; the relationship between preserved open
space and biological resources, and barriers to
wildlife movement. (2014 Draft EIR, p. E-5 & E-6)
Despite these public concerns raised eight years
ago, the 2022 Draft EIR does not mention these
2014 concerns in this DEIR. See DEIR, p. E-8 & E-9.

Nor does the 2022 Draft EIR discuss viable land use
designations for the San Pedro Avenue (Calson) site,
incorporation of most recent Coastal Commission
guidance, hydrology and flooding at the San Pedro
Avenue site, or interference with California redlegged frog movement from reasonably foreseeable Project development at the San Pedro Avenue site.

Concerns about impacts to biological resources
are mentioned in Areas of Known Controversy,
Biological Resources, DEIR p. E-8. While
findings from the Coastal Commission were not
a matter of public record until after publication
of this DEIR's NOP, Master Response 6: ESHA
for more information, as well as Master
Response 4: Undeveloped San Pedro Ave Sites,
describes the disagreement among experts
about this site, as well as any policies, coupled
with Coastal Act, FESA, and CESA, would
reduce potential impacts to less than
significant.

C123-16 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 2) The 2022 Draft EIR does not analyze the impacts of changing land use classifications. For example,
while the Coastal Residential Mixed Use (“CRMU”)
designation is noted in the 2022 Draft EIR’s Project
Description (p. 2-16) and included in Figure 2.1-2,
the 2022 Draft EIR includes no discussion of impacts
from this CRMU land use designation, modifications
to the proposed Project which would lessen
impacts, or assess alternatives in comparison.

As noted on DEIR p. E-1, "This EIR is a program
EIR that examines the potential effects
resulting from implementing designated land
uses and policies in the proposed General Plan.

The impact assessment evaluates the General
Plan as a whole and identifies the broad,
regional effects that may occur with its
implementation. This EIR presents a citywide
assessment of the potential impacts of the
proposed Pacifica General Plan."
"Implementing designated land uses" includes
CRMU. For all sections of analysis, the DEIR
considers where existing vacant land uses
would change. As described in DEIR p. 2.1-18,
the DEIR "compares the Proposed Project land
use diagram to existing land use conditions to
determine whether implementation of the
Proposed Project would trigger any impacts."
For example, as noted on DEIR p. 3.7-61,
"Development at the undeveloped San Pedro
site could potentially result in indirect impacts
to the wildlife utilizing nearby creek habitat.

This includes the possibility of fuel spills and/or
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Letter Commenter Date Comment Combined Response
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leaks which could make their way into the
riparian corridor of San Pedro Creek." Please
see Master Response 4: Undeveloped San
Pedro Avenue Sites for more information
about impacts of CRMU, in addition to how
different land uses on the site were compared
in the Alternatives.

C123-17 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 3) The 2022 Draft EIR’s project description includes “guiding policies” for each of the proposed Pacifica
General Plan elements. See Section 2.5 Key Plan
Guiding Policies at DEIR, p. 2-24 et seq. Yet, these
guiding policies themselves are not analyzed in the
DEIR for their potential impacts.

For example, one guiding principle is SA-I-104
(Areas that Lack Emergency Access) which purports
to develop a plan to widen critical rights-of-way that
do not provide adequate clearance for emergency
vehicles. This initiative would include a plan to
“open access to or otherwise serve” the Pedro Point
neighborhood. DEIR, p. 3-47. There is no analysis of
the direct, indirect or secondary traffic, stormwater,
air quality or any other impact of this guiding policy
in the Pedro Point neighborhood.

Guiding principles most similar to the CRMU
designation proposed for the San Pedro Avenue
field would appear to be “Compact Mixed Use
Development” (LU-G-6) and “Coastal
Development.” DEIR, pp. E-13 & 2-26. “Compact
Mixed Use Development” (LU-G-6) is claimed to be
a General Plan policy that would reduce various
land use and air quality impacts, but there is no
explanation of how or why this would reduce
impacts.

The 2022 Draft EIR’s project description states that
the policy regarding Coastal Development (LU-G-1)
is to “Ensure that development maximizes beach
Guiding policies are analyzed to the extent that
they may reduce impacts of required CEQA
topics.

CEQA analysis must occur for any known
improvements; the arrangement of any road
widening is not known at this time, and a
contingency plan for alternative access already
exists as part of the All Hazards and Evacuation
Plan. 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. The DEIR adequately
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and coastal open space access and is oriented as
much as possible to each particular coastal
environment in use, design, and intensity.” DEIR, p.
2-26. This proposed Coastal Development policy is
not mentioned except as a purported “mitigation”
to visual impacts, but without explanation of how or
why coastal development will reduce visual impacts.

DEIR, p. 3.9-28.
addresses impacts to VMT, air quality, and
stormwater at the programmatic level.

Description of how Compact Mixed Use
Development (LU-G-6) would not physically
divide an existing community is described on
DEIR p. 3.1-20, "the Proposed Project provides
concentrated and compact development
primarily in already developed areas, with
policies to provide more linkages and
enhanced connectivity within and between
those areas."
Compact, Mixed Use Development is also a
strategy used to reduce greenhouse gas
emission and VMT. As described in DEIR p. 3.4-
57, "Sustainable Communities Strategies
policies include a mix of strategies that
encourage compact growth patterns, mixeduse design, alternative transportation, transit, mobility and access, network expansion,
transportation investment, and environmental
justice." As noted on the same page,
"Consistent with MTC goals, the Proposed
Project would... increase mixed-use
development. The land use design,
transportation
network promotion, and transit facility
enhancements would help reduce vehicle trips
and support alternative transportation."
As noted in the DEIR p. 3.9-14, Policies in the
Proposed General Plan that ensure that new
development achieve a high standards of visual
quality consistent with existing regulations
governing scenic quality include use of the
City’s Design Guidelines in evaluating proposals
(CD-I-4) and providing updated, illustrated
Design Guidelines for multifamily and senior
housing (CD-I-5) and for commercial and
mixed-use building form (CD-I-7).

C123-18 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 4) The 2022 Draft EIR identifies Pedro Point as
“vulnerable to increased coastal flooding.” DEIR, p.

3.5-11. It also acknowledges that undefined
“sections of the City are susceptible to flooding
during heavy storm events. The Proposed Project
allows for development in areas that may be
located within 100-year flood zone areas. Siting
structures in flood zones can result in direct impacts
…; the frequency of flooding events may increase,
and there may be an increase in the amount of area
that is considered prone to a 100-year flood event.”
DEIR, p. 3.5-38.

Yet, the 2022 Draft EIR under Impact 3.5-3 (New
The fifth paragraph on page 3.5-21 of the DEIR
states that existing local stormwater
management plans and policies, and State
Water Board regulations, which implement
federal Clean Water Act requirements, would
prevent these potential impacts from rising to
a level of significance under CEQA through
requirements that minimize the creation of
pollution generating surfaces. Clean Water Act
Section 402 NPDES MS4 Permit, which covers
many Bay Area jurisdictions including the City
of Pacifica, requires stormwater management
plans, which in turn require source and
treatment control measures. In many cases, as
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Individuals (C)
development alter existing drainage patterns,
through stream alteration or addition of impervious
surfaces, increases stormwater runoff or redirects
flood flows) concludes – without adequate
explanation - that this impact is less than significant.

DEIR, p. 3.5-29. It asserts that compliance with the
Project general policies would ensure the impact to
water quality is less than significant. DEIR, p. 3.5-32.

No mitigations are discussed. DEIR, p. 3.5-37. Again,
the 2022 Draft EIR is flawed by not explaining the
analytic route it followed to reach its conclusion, by
not explaining how general policies would “ensure”
the impacts is insignificant, by combining the
analysis of impacts with mitigations, and by not
discussing mitigations at all.
part of the NPDES program to reduce the
severity of impacts, stormwater drainage
control/Low Impact Design (LID) measures may
be required as standard conditions of approval
and building permit application submittals,
along with compliance with RWQCB Municipal
Regional Stormwater Permit Order No. 2011-
0083 Provision C.3 (Provision C.3).

As required by Provision C.3, for new
development that would introduce 10,000
square feet of new impervious surfaces, a
project applicant would incorporate LID
strategies, such as stormwater reuse, onsite
infiltration, and evapotranspiration as initial
stormwater management strategies.

Ultimately, adherence to stormwater control
measures as part of the Municipal Regional
NPDES stormwater permit, a SWPPP prepared
as part of the General Construction Permit, and
improvements under the Proposed Project
would minimize the water quality impact to a
less-than-significant level. The Proposed
Project strengthens these provisions through
policies in the Safety Element requiring grading
and drainage plans for proposed developments
requiring a grading permit, minimizing erosion
risk, and enforcing NPDES permits. In addition,
compliance with the Proposed Project policies
set would ensure the impact to water quality is
less than significant. Please also see Master
Response: Undeveloped San Pedro Avenue
Site.

C123-19 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 5) While the 2022 Draft EIR acknowledges the need for analysis of indirect and secondary impacts which
are caused by the Project and occur later in time or
farther removed in distance (DEIR, p. 1-8), the EIR’s
discussion of such indirect Project impacts is
troublingly scant. The 2022 Draft EIR fails to
properly focus on the indirect and secondary effects
that can be expected to follow from the adoption of
the General Plan amendment. (CEQA Guideline
15146, subd. (b).) Given the specific land uses
proposed in the General Plan Update (see 2022
General Plan Figure 4-3), CEQA requires that the
2022 Draft EIR provide correspondingly detailed
analysis of reasonably foreseeable potential
impacts. “The degree of specificity required in an
EIR will correspond to the degree of specificity
involved in the underlying activity which is
described in the EIR.” (CEQA Guideline 15146.)
Under Impact 3.7-4 (implementation of the
proposed General Plan would not interfere
substantially with the movement of species or
See Master Response 6: ESHA and Master
Response 4: Undeveloped San Pedro Ave Sites
for more information. On DEIR p. 3.7-50,
presence of special status species near San
Pedro Creek is noted: "This analysis addresses
species that are either known to occur or are
highly likely to occur within the key sites and
Planning Area"; occurrence of California redlegged frog is also shown on Figure 3.7-4.

Regarding potential impacts, the following
clarification is made: "Development at the
undeveloped San Pedro site could potentially
result in indirect adverse impacts to the
wildlife utilizing nearby creek habitat."
Proposed Project policies are not intended to
act as mitigation measures; rather, they are
policy statements indicating actions the City
will take on an ongoing basis as the Proposed
Project is implemented and the DEIR has
correctly considered the effects of
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Individuals (C)
wildlife corridors), the 2022 Draft EIR states only
that development at the undeveloped San Pedro
Avenue site could potentially result in indirect
impacts to the wildlife utilizing nearby creek
habitat, including from fuel spills and/or leaks which
could make their way into the riparian corridor of
San Pedro Creek. DEIR, p. 3.7-62. This is insufficient
for three independent reasons:
(A) there is no discussion of the interference with
California red-legged frog movement from
reasonably foreseeable Project development;
(B) there is no disclosure of whether the noted
indirect impacts to wildlife utilizing nearby creek
habitat is adverse or significant; and
(C) there is no discussion of how this impact will be
mitigated.
implementing these policies, including any
beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project.

The General Plan and associated DEIR identifies
areas of city-wide sensitive and Critical Habitat
and general locations of Special Status Species.

The General Plan proposes numerous policies
to reduce habitat loss, as summarized noted in
responses to comments A2-4 and C46-24. The
General Plan establishes policies to protect or
mitigate sensitive species habitat, such as the
California red-legged frog, and impacts to
creek habitats. Therefore, potential impacts to
Sensitive Species or Critical Habitat will be less
than significant with implementation of the
General Plan.

C123-20 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 6) The analysis of land use impacts at Section 3 of the 2022 Draft EIR is fatally flawed as it “compared
the Land Use Diagram to existing land use
conditions to determine whether implementation of
the Proposed Project would trigger any impacts.”
2022 Draft EIR, p. 3.1-18. “Figure 2.3-1 shows the
General Plan Land Use Diagram.” 2022 Draft EIR at
p. 2-14. However, the 2022 Draft EIR does not have
a Figure 2.3-1. Thus, there is no way the public
could know what the 2022 Draft EIR compared the
existing land uses to in order to determine potential
impacts.

The comment is noted. It is reasonable to infer
the General Plan Land Use Diagram by its title.

The following clarification is thereby made on
p. 2.3-1: “Figure 2.32-1 shows the General
Plan Land Use Diagram.”
C123-21 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 7) The 2022 Draft EIR’s analysis of Project impacts is flawed as it relates to “buildout” resulting from the
2022 GP Update. The Executive Summary (at p. E5)
states the Project will result in a population of
41,280 at buildout, referencing Table ES-1. Yet, that
Table ES-1, as well as Table 2.4-1 and Section 5.1 of
the 2022 Draft EIR state a population of 41,050. The
2022 Draft EIR fails to acknowledge or evaluate this
discrepancy in its analysis of land use, traffic, air
quality, or GHG impacts.

The comment is noted. The following
clarification is thereby made on DEIR p.E-5:
"the Planning Area would result in a population
of approximately 41,280 41,050 people at
buildout..." The clarification does not change
any findings of significance in the DEIR.

C123-22 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 8) The 2022 GP Update provides that only a few
months from now, by January 31, 2023, the City will
update the General Plan Housing Element to
accommodate 1,892 housing units in compliance
with the 6th Cycle Regional Housing Needs
Allocation (RHNA 6). 2022 GP Update, p. 1-6.

Further, ADUs, ministerial development llowed by
SB 9, and lot splits are reasonably foreseeable.The
2022 Draft EIR fails to acknowledge or evaluate
these factors in its analysis of land use, traffic, air quality, or GHG impacts.

The comment is noted. Project buildout under
the Proposed Plan represents an reasonable
projection and adequate yardstick for
determining the significance of CEQA impacts.

At the time of Housing Element preparation,
the City would be required to conduct
additional CEQA analysis. SB9 projects and
ADUs are speculative at this time and are
exempted under CEQA. Please see Master
Response 3: Buildout and RHNA for more
information.

C123-23 Brian Gaffney
(representing
Pedro Point
3/8/22 9) The 2022 Draft EIR references that population growth is necessary in order to meet Pacifica’s
Regional Housing Needs Assessment (RHNA)
The comment is noted. Mitigation measures in
the DEIR already reduce the impact of GHGs
within the City to a less than significant level.
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Community
Association)
(pursuant to California Government Code Section
65584(a)), as well as in accordance with the regional
policies of Plan Bay Area 2040. Yet, the 2022 Draft
EIR fails to consider the Plan Bay Area 2040’s
regional policies in evaluating Project impacts.

Incorporation of the additional measures
would reduce an already less than significant
impact and would, thus, not change any
findings of significance.

C123-24 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 10) This uncertainty as to buildout – instability of the Project Description – thwarts the 2022 Draft
EIR’s analysis of impacts. For example, “for
purposes of the cumulative impacts analysis, the
City utilized the ‘summary of projections’ method
by considering the buildout scenario of the
Proposed Project within the relevant cumulative
impacts context for each potential impact.” DEIR, p.
5-6. Thus, the 2022 Draft EIR did not evaluate
cumulative impacts in the context of the RNHA,
ADUs, ministerial development allowed by SB 9, or
lot splits.

Please see more information about the
adequacy of buildout, planning for RHNA, and
CEQA analysis in Master Response: Buildout
and RHNA
C123-25 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 11) The 2022 Draft EIR “groups” land use
designations before analyzing impacts,
without explaining why this approach was utilized.

DEIR, p. 3.1-18 & Table 3.1-4.

Please see response to comment C123-22.

C123-26 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 12) The 2022 Draft EIR fails to adequately analyze impacts to sensitive species. The DEIR concludes
that “there are several specific areas where
proposed buildout could adversely affect
[steelhead] and its habitat.” DEIR p. 3.7-50. Having
acknowledged the adverse effect of the Project
buildout to steelhead, the 2022 Draft EIR fails to
disclose where this potential impact may occur,
whether it will be significant and why, and how the
adverse impact to steelhead could be mitigated.

As noted on DEIR p. 3.1-18, "The impact
analysis considered the full buildout of the
Proposed Project, although it is uncertain
when or if this full development would occur.

For the purposes of comparing the different
land use designations between the existing
conditions and the Proposed Project,
generalized land use categories were used."
Put simply, the tables help show where existing
land use categories might be the same (in the
same grouped category, such as 'commercial'
to 'retail commercial') or change into
something different (in a different grouped
category, such as 'commercial' to 'mixed use').

C123-27 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 13) While the 2022 Draft EIR states the proposed General Plan includes numerous trail improvements
which could adversely affect wildlife movement
corridors, it does not disclose whether this impact
will be adverse or significant, and does not discuss
how this impact will be mitigated. DEIR, p. 3.7-61.

The section mentioned in this comment was
taken out of context and falsely asserts the
DEIR does not identify steelhead habitat. As
noted on DEIR p. 3.7-50, "is known to spawn
along the main stretch of San Pedro Creek in
the area parallel to Linda Mar Boulevard." On
DEIR p. 3.7-49, it state "future land use
changes proposed under the Proposed Project
could impact biological sources if sensitive
natural communities, critical ahbitat, and
special-status or sensitive species are disturbed
or altered." The General Plan has multiple
policies to protect Species Status species,
which are included in Impact 3.7-1, and the
following policies specifically address the
steelhead trout habitat:

CO-G-9 Creeks and Riparian Areas. Protect
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year-round creeks and their riparian habitats.

San Pedro Creek has been designated an
“impaired waterway” by the Regional Water
Quality Control Board and provides critical
habitat to a federally-listed threatened species,
the California coast population of steelhead.
(CO-I-1) Creek Protection and Restoration.

Maintain, protect, and restore Pacifica’s
creeks, including San Pedro, Calera, Sanchez,
and Milagra creeks, as environmental and
aesthetic resources. Actions will include, but
are not limited to:
• Continuing restoration efforts along San
Pedro Creek to improve conditions for
steelhead by removing obstacles to fish
passage, placing rock weirs to facilitate fish
passage, and by monitoring the effectiveness
of these projects;
• Partnering with local organizations, such as
the San Pedro Creek Watershed Coalition, Go
Native, the Pacifica Land Trust, and others, on
restoration efforts;
• Exploring opportunities to collaborate with
other agencies and organizations on stream
restoration and riparian habitat restoration
along Sanchez and Calera creeks;
• Enforcing restrictions on the planting of
invasive species near creek areas;
• Identifying and working with property
owners to take advantage of unique
opportunities where human active use (e.g.,
through trail development) would enhance
creek appreciation without disrupting
ecological function;
• Requiring a minimum of 100-foot setbacks
from the top of creek banks, or from the outer
edge of riparian vegetation, where it exists, for
development proposed adjacent to creeks, in
keeping with City regulations and Best
Management Practices. Exceptions to such
buffer requirements should be supported by a
biological report demonstrating that the
adjusted buffer, in combination with
incorporated siting, design or other mitigation
measures, shall prevent impacts that
significantly degrade the creek. Buffer
adjustments should also be limited to where
the entire subject legal lot is within the buffer
or where it is demonstrated that development
outside the buffer would have a greater impact
on the creek.

Additional policies to protect Sensitive Species
and Habitat are included in Master Response 3.

The General Plan DEIR provides analysis which
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is sufficient for a programmatic EIR. Therefore,
potential impacts to Sensitive Species or
Critical Habitat will be fully mitigated with
implementation of the General Plan.

C123-28 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 14) The 2022 Draft EIR fails to first analyze impact significance and then analyze mitigation measures.

The first step in an EIR’s analysis of a proposed
project’s environmental effects is to evaluate
significant project impacts, followed then by
analysis of mitigations. (1 Kostka & Zischke, Practice
Under the Cal. Environmental Quality Act
(Cont.Ed.Bar 2014, §13.2).) This DEIR skips that first
step. The 2022 Draft EIR lists proposed General
Project policies as if the Project will mitigate itself, and then little or no mitigation measures are
included in the 2022 Draft EIR for each impact. The
2022 Draft EIR is flawed as it only discusses the
significance of impacts after applying mitigation
measures. An EIR “must determine whether any of
the possible significant environmental impacts of
the project will, in fact, be significant.” (Protect
Historic Amador, supra, 116 Cal.App.4th at 1109;
CEQA Guideline 15126.)
In Lotus v. Department of Transportation (2014) 223
Cal.App.4th 645, the court considered an EIR which
likewise incorporated proposed mitigation
measures into its description of the project and
then concluded that any potential impacts from the
project will be less than significant. The court held
that “avoidance, minimization and/or mitigation
measures” characterized in the EIR, are not “part of
the project.” “By compressing the analysis of
impacts and mitigation measures into a single issue,
the EIR disregards the requirements of CEQA.” (Id.
at 655-56.)
Review of Table ES-3 shows that the 2022 Draft EIR
repeats this error - determining significance of
impacts only after applying mitigation - for almost
every impact it analyzes. Table ES-3 lists each
impact with no discussion of its significance.

Likewise, the impact discussions in the body of the
2022 Draft EIR largely fail tonalyze impact
“significance” separate from and before applying
mitigation measures. For example, for Impact 3.7-1
(substantial adverse effect on sensitive species), the
2022 Draft EIR never describes if impacts will be
potentially significant or why, and instead jumps to
the conclusion that “implementation of the
following Proposed Project policies would reduce
potential impacts to special-status species to a less
than significant level.” DEIR, p. 3.7-51. Given that
San Francisco garter snake, California red-legged
The commenter's assertion of inadequate
analysis is incorrect. The DEIR analyzes impacts
of the Proposed Project, and the DEIR
evaluates the potential of beneficial policies in
the Proposed Project to reduce impacts that
could be significant. As noted on DEIR p. 3.7-
49, ''future land use changes proposed under
the Proposed Project could impact biological
resources if sensitive natural communities,
critical habitat, and special-status or sensitive
species are disturbed or altered. Potential
impacts to species are described, followed by
descriptions how land uses change in those
areas: "Red-legged frog and garter snake both
occur in Sharp Park, which would remain a
public open space managed for both public
access and natural conservation under the
Proposed Project. Both of these special status
species also occur at Mori Point, which is a
known breeding location for red-legged frog,
and which is managed for conservation with
limited public access....there are several
specific areas where proposed buildout could
adversely affect this species and its habitat.

While the great majority of Planning Area land
where special status species occur is
designated as park land or for conservation,
the Proposed Project calls for the development
of new trails. The Sharp Park Trail and an
unnamed trail that would run parallel to the
west side of Highway 1 in the southern
Planning Area near Devil’s Slide Trail, would
both occur within critical red-legged frog
habitat." The DEIR then describes how
compliance with federal, state, and local
regulations, as well as Proposed Plan policies,
reduce these potential adverse impacts to less
than significant.
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frog and steelhead are threatened/endangered
species, and that CEQA requires a finding of
significance if a project is likely to substantially
impact threatened or endangered species, the 2022
Draft EIR was required to properly analyze Project
impacts for their potential significance and then
discuss potential mitigations.

C123-29 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 This same approach of impermissibly avoiding
explanation of potential impacts, based on the
unexplained conclusion that “implementation of the
following Proposed Project policies would reduce
potential impacts to special-status species to a less
than significant level,” is used by the 2022 Draft EIR
also in regards to biological impacts:
• Impact 3.7-2 (substantial adverse effect on
riparian habitat or other sensitive natural
communities) (DEIR, p. 3.7-57);
• Impact 3.7-3 (substantial adverse effect on
protected wetlands) (DEIR, p. 3.7-60);
• Impact 3.7-4 (substantially interfere with fish or
wildlife movement or with wildlife corridors, or
impede use of wildlife nursery sites) ((DEIR, p. 3.7-
62);
The level of detail of analysis and
programmatic nature of the DEIR is outlined in
Master Response 2. The General Plan
proposes numerous policies to reduce
potential impacts to habitat and biological
resources; at the time of a development
application, the environmental conditions will
be analyzed in coordination with applicable
habitat conservation policies as outlined in
response to comment C123-30. Thus, potential
impacts to biological will be reduced to less
than significant with implementation of the
General Plan.

The following clarifying language will be added
under Impact 3.7-2 on page 3.7-56. This does
not change the findings of significance of the
DEIR.
"Proposed Project policies ensure that
implementation would preserve and restore
steep and sensitve terrain (LU-I-14), coastal
environments and special status communities
(CO-G-8), creeks and riparian areas as habitat
(CO-G-9), wetlands (CO-I-4), and water quality
through best management practices (CO-I-11).

Therefore, compliance with the provisions of
the California Coastal Act in combination with
implementation of the Proposed Project set
forth below would help reduce potential
impacts to riparian habitat or other sensitive
natural communities to a less than significant
level."
Please see also response to comment C123-7
regarding Impact 3.7-4.
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C123-30 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 Perhaps the most glaring flaw regarding biological impacts in this regard comes under the heading
“Cumulative Impacts to Biological Resources.” DEIR,
p. 5-5-7. There it states
Pacifica’s population is expected to increase in
coming years, which could result in a decrease in
habitat for native flora and fauna, increased indirect
effects such as oise disturbance, increased night
lighting, harassment from pets, increased mortality
from automobiles, and increased fragmentation of
habitat. Pacifica contains habitat or several specialstatus plants, insects, CRLF, and SFGS.

Implementation of the Proposed Project may result
in a considerable incremental contribution to
cumulative impacts, because the majority of
undeveloped areas in Pacifica (about 50 percent of
the Planning Area) have habitat types known to
support special-status species.

The DEIR concludes that the Project may result in a
considerable contribution to cumulative impacts.

Yet, the 2022 Draft EIR reverses itself by following
up with “due to the policies proposed in the
Proposed Project and Local Coastal Land Use Plan,
the Proposed Project’s contribution to this
potentially significant cumulative impact is not
cumulatively considerable.” DEIR, p. 5-5-7. Thus,
there is no analysis of whether this impact is
significant without mitigation measures, and
instead only a conclusion of insignificance by
reference to completely undefined Project policies.

The public is left wondering what policies could
possibly decrease this impact and the analytic route
the 2022 Draft EIR travelled in getting from facts to
a conclusion of insignificant cumulative biological
resource impacts.3 By circulating the 2022 Draft EIR
for public review that did not disclose if impacts
before mitigation measures are significant or not,
the 2022 Draft EIR thwarts informed public
participation and does not serve CEQA’s
information disclosure purpose.

As noted on DEIR p. 5-5, "the analysis of
cumulative impacts need not provide the level
of detail required of the analysis of impacts
from the project itself, but shall 'reflect the
severity of the impacts in their likelihood of
occurence." To rise to a level of level of
significance, the Proposed Project must result
in both a cumulatively significant impact AND
have a considerable incremental contribution.

The cumulative impacts to biological resources
analysis on page 5-7 in the DEIR takes into
consideration the land use conservation
strategies, in addition to the multiple goals and
policies to protect sensitive species and
habitats as summarized in all impacts in
Biological Resources Ch 3.7, to determine that
implementation of the Proposed Project would
reduce impacts to less than significant level.

Therefore, the Proposed Project's contribution
to this potentially significant cumulative impact
is not cumulatively considerable. The following
clarification is thereby made: "Implementation
of the Proposed Project may result in a
considerable incremental contribution to
cumulative impacts, because the majority of
undeveloped areas in Pacifica (about 50
percent of the Planning Area) have habitat
types known to support special-status species.

However, due to the policies proposed in the
Proposed Project and Local Coastal Land Use
Plan, any development in these areas would be
required to comply with existing federal, state,
and local regulations as applicable (including
FESA, CESA, the Clean Water Act, and the
Coastal Act). Compliance with policies in the
Proposed Plan related to sensitive species,
preservation of habitat, and coordination with
the CDFW as described in Ch 3.7 reduce
impacts to less than significant; and the
Proposed Project’s contribution to this
potentially significant cumulative impact is not
cumulatively considerable.

C123-31 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 15) Under Impact 3.5-1 (New Development Would
Not Degrade Surface Water Quality) the 2022 Draft
EIR acknowledges that new construction,
redevelopment, and infrastructure upgrades that
would require earthwork. Earthwork activities such
as excavation, soil stockpiling, boring, pile driving,
and grading could generate loose, erodible soils
that, if not properly managed, could be washed into
surface water by rain or by water used during
grading operations. Soil erosion could cause excess
sediment loads in storm drains and affect the water
quality of receiving waters. Construction could also
As stated on page 3.5-20, adherence to the
Construction General Permit under the NPDES
program would require that a SWPPP with best
management practices (BMPs) be prepared for
construction sites; it would include measures
to protect water quality of stormwater that is
discharged offsite and practices to limit erosion
or unintentional releases of hazardous
materials used during construction.

Additionally, any development that would
occur under the Proposed Project would be
subject to the erosion and runoff control
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involve use of fuel and other chemicals that, if not
managed properly, could be washed off into the
stormwater. Although construction of specific
projects would be relatively short-term, the impact
on water quality could be significant if not managed
appropriately.”
DEIR, p. 3.5-20. Yet, the 2022 Draft EIR title heading
for Impact 3.5-1 states “Less than Significant.” Ibid.

The 2022 Draft EIR asserts that compliance with the
Project general policies would ensure the impact to
water quality is less than significant. DEIR, p. 3.5-22.

No mitigations are discussed. DEIR, p. 3.5-27.

The 2022 Draft EIR’s analysis of water quality
impacts is flawed (1) by not explaining the analytic
route to reach its conclusion, (2) by not explaining
how general policies would “ensure” the impacts is
insignificant, (3) by combining the analysis of
impacts with mitigations, and (4) by not discussing
mitigations at all.
provisions described in the regional Basin Plan.

The Construction General Permit authorizes
the discharge of storm water to surface waters
from construction activities. It prohibits the
discharge of materials other than storm water
and authorized non-storm water discharges
and all discharges that contain a hazardous
substance in excess of reportable quantities
established at 40 Code of Federal Regulations
117.3 or 40 Code of Federal Regulations 302.4,
unless a separate NPDES Permit has been
issued to regulate those discharges. Please see
pages 3.5-15 and 3.5-16 for more information
regarding the requirements of the
Construction General Permit. Please see also
response to comment C123-18 regarding
NPDES regulatory requirements.

C123-32 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 16) Coastal development is not discussed at all in the EIR except in regards to Alternative 2, where the
2022 Draft EIR vaguely states that “coastal
development, depending on site specifics, could
result in coastal flooding and coastal erosion” and
that “Depending on location, coastal development
locations could be susceptible to coastal erosion
hazards.” DEIR, pp. 4-18 & 4-19. These statements
do not constitute adequate disclosure of potential
Project impacts as Project to avoid or minimize such
impacts.
(A) the site specifics of coastal development
reasonably foreseeable from the proposed Project
are known and thus must be analyzed in this
document,
(B) the 2022 Draft EIR does not state if coastal
flooding and coastal erosion impacts will be adverse
or significant,4 and
(C) there is no discussion of mitigation measures
including changes in the proposed
Contrary to the commentor's assertion, the
DEIR discusses coastal development and
impacts.

Please see comment C69-8 for more
information on where the DEIR addresses
coastal erosion, and how compliance with
federal, state, and local regulations and
Proposed Plan policies reduce impacts to less
than significant. Please see response to
comment 13-3 for more information on sea
level rise analysis and regulations and policies
that reduce the impact, as well as policies in
the LCLUP regarding sea level rise monitoring.

C123-33 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 17) The 2022 Draft EIR does not properly analyze growth inducing impacts of the Project. An “EIR
must discuss growth-inducing impacts even though
those impacts are not themselves a part of the
project under consideration, and even though the
extent of the growth is difficult to calculate.” (Napa
Citizens for Honest Government v. Napa County Bd.
of Supervisors (2001) 91 Cal.App.4th 342, 368.) This
includes consideration of a project’s potential to
foster economic or population growth, future
The commenter's assertion that the DEIR does
not properly analyze growth inducing impacts
is incorrect. As noted on DEIR p. 5-2, rather
than inducing growth, the Proposed Project
intensifies development in target areas in
order to provide its fair share of future housing
to support the Bay Area as a whole. The
environmental impacts associated with a
growth-inducing action are secondary, or
indirect, physical effects of growth. An
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development, or construction of additional housing.
(Pub. Res. Code § 21100, subd. (b)(5); CEQA
Guidelines 15126, subd. (d), 15126.2, subd. (d).)
The 2022 Draft EIR is confusing and contradictory as
to whether the Project will foster or induce
population growth or construction of additional
housing. It states in the same paragraph that “the
Proposed Project allows for increased housing
development and resulting population growth,” but
reverses itself by continuing that “[r]ather than
inducing growth, the Proposed Project intensifies
development in target areas… .” DEIR, p. 5-2. The
DEIR also states that “[t]he Planning Area will
accommodate a population of approximately
41,050 people at buildout in 2040,” and that this is
an increase (p. 5-2), but does not analyze whether
the proposed Project will “foster” or facilitate this
growth. Instead, the 2022 Draft EIR pretends that
this growth is something that the planning area will
accommodate, and the General Plan update and the
City of Pacifica are hapless bystanders to this
growth and have no role in inducing or fostering
such growth.
example of inducing unplanned growth would
be providing a large number of new jobs. As
stated on DEIR p. 5-4, "The Proposed Project
seeks to create a balanced community, with
retail uses, parks, and other features to
accommodate population growth, though since
the jobs/employment ratio is still projected to
be weighted towards jobs, any increase in jobs
in the Planning Area has the potential to
induce growth, lead to growth pressure, or
lead to pressure on services in surrounding
communities. Moreover, as discussed in
Chapter 3.1, Land Use, the Proposed Project
includes land use plans that specify allowable
residential development density in specific
locations within the city, such that unplanned
population growth would be unable to occur."
C123-34 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 The 2022 Draft EIR Fails to Adequately Analyze
Mitigation Measures.

In addition to assessing a project’s significant and
cumulative impacts, an EIR is also required to set
forth and analyze feasible mitigation measures to
eliminate or substantially minimize each significant
impact. (Pub. Res. Code §§ 21002, 21002.1(a) & (b);
CEQA Guidelines 15126(e), 15126.4.) Mitigations
must be designed to minimize, reduce, rectify or
compensate for the project’s impacts. (CEQA
Guideline 15370.)
Analyzing “the manner in which [the] significant
effects can be mitigated or avoided" is one of the
main functions of an EIR. (Pub. Res. Code §
21002.1(a).) As with all aspects of an EIR, the
discussion of mitigation measures must be
"prepared with a sufficient degree of analysis to
provide decisionmakers with information which
enables them to intelligently take account of
environmental consequences. . . . The courts have
looked. . . for adequacy, completeness and a good
faith effort at full disclosure." (CEQA Guideline
15151.)
An EIR is inadequate where mitigation efforts
largely depend upon management plans that have
not yet been formulated, and have not been subject
to analysis and review within the EIR. (Communities
for a Better Environment v. City of Richmond (2010)
184 Cal.App.4th 70, 92, citing San Joaquin Raptor II,
Please see also responses to Comment C34-17
and C46-46. Proposed Project policies are not
intended to act as mitigation measures; rather,
they are policy statements indicating actions
the City will take on an ongoing basis as the
Proposed Project is implemented and the DEIR
has correctly considered the effects of
implementing these policies, including any
beneficial effects they would have in reducing
potentially significant impacts of the Proposed
Project. True, adequate mitigation measures
are described in DEIR p. 3.2-42, 3.2-43, 3.4-37,
and 3.4-38. Please also see response to
comment C46-30.

Policies LU-G-7 and LU-G-10 represent guiding
policies. As noted on DEIR p. E-4, "Guiding
policies define an ideal future related to the
public health, safety,
or general welfare of the community; they set
directions for policies. Implementing policies
are specified ends or conditions that are an
intermediate step towards attaining a goal;
they are specific statements to guide decisionmaking." Discretionary projects are required to make findings of general plan consistency, and
ministerial projects are also checked for
consistency.

The following clarifications are made to p. 3.7-
51; they merely serve to amplify and clarify
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Letter Commenter Date Comment Combined Response
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supra, 149 Cal.App.4th at 670.) “[A]n agency
violates CEQA by deferring the formulation of
mitigation measures without committing to specific
performance criteria for judging the efficacy of the
future mitigation measures.” (POET, LLC v.

California Air Resources Board (2013) 218
Cal.App.4th 681, 698-99; see also CEQA Guideline
15126.4(a)(1)(B.) Simply stating a generalized goal
for mitigating an impact is not adoption of a specific
performance criteria. (POET at p. 740.)
In Communities for a Better Environment (2010)
184 Cal.App.4th 70, the Court struck down an EIR
which merely proposed a generalized goal of “no
net increase” in greenhouse gas emissions and then
set out a handful of cursorily described mitigation
measures for future consideration. Similarly, an
agency goes too far when it simply requires a
project applicant to obtain a biological report and
then comply with any recommendations that may
be made in the report. (Save Panoche Valley v. San
Benito Cty. (2013) 217 Cal. App. 4th 503 citing
Defend the Bay v. City of Irvine (2004) 119
Cal.App.4th 1261, 1275.)
The 2022 Draft EIR’s Mitigation Measures are
flawed in the following ways:
1) The 2022 Draft EIR repeatedly lists General Plan
policies (by number and often cryptic explanation),
without explaining the manner in which the impacts
can be mitigated or avoided by each of the listed
policies." The 2022 Draft EIR only provides the
glaringly conclusory statement that
“Implementation of the following Proposed Project
policies would reduce potential impacts to…to a less
than significant level.” Such policies include, but are not limited to, General Plan policies LU-G-7, LU-I-12,
CO-G-10, CO-I-27, CO-I-33, and CO-I-42.
findings of significance. 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.

Implementation of the following Proposed
Project policies would reduce potential impacts
to special-status species to a less than
significant level. Policy LU-G-7, CO-G-8, and
CO-G-9 sets forth the City’s vision and
commitment to preserving areas that support
critical wildlife habitat and special status
species and communities, including creeks and
hillsides; discretionary projects would be
required to make findings of General Plan
consistency. Policies CO-I-1, CO-I-2, and CO-I40 describe how creeks, waterways, and wetlands will be protected and impaired
waterways to reduce adverse effects, including
through required minimum setbacks,
controlled runoff and wastewater reclamation.

Policies CO-I-43 and CO-I-44 describe how the
City will seek public acquisition of land of
conservation easements to optimize habitat
protection, particularly for the CRLF and SFGS.

Other specific activities to reduce adverse
effects either directly or through habitat
modifications include policies that relate to
construction or new development, including
CO-I-27, CO-I-37, CO-I-28, CO-I-29, CO-I-35, COI-36, and CO-I-37. These policies prohibit development in critical habitat and require
biological resource assessments and surveys.

Together with federal, state, and local
regulations, policies in the Proposed Project
reduce the impacts to special status species to
a less than significant level." This addition only
clarifies how the policies reduce impacts and
does not change findings of significance in the
DEIR.

CO-I-27 (Protection of Biological Resources
with New Development) and CO-I-33 (Habitat
Preservation) require consultation with a
biologist, as well as ongoing monitoring. This is
described in DEIR p. 3.7-51: "Prior to project
construction under the Proposed Project, the
applicant would be required to conduct
biological resource assessments and pre-
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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." These requirements are conditions of
project development.

Land use classifications guiding development
under the Proposed Plan are described on DEIR
p. 2-14 to 2-20; each land use classification
describes the maximum density, intensity, and
allowed uses for each category. Zoning is a tool
to implement land use, and as a general law
city, Pacifica must update its zoning code to be
consistent with an adopted General Plan. Thus,
hillside preservation update (LU-I-12), does not
represent a deferred mitigation, as the zoning
code must be updated.

Policy CO-I-42 (Regulations and Incentives to
Preserve Habitat) represent a combination of
required survey and zoning update, both of
which do not constitute deferred mitigation.

Please see responses to comments C123-35,
C123-36, and C123-37.

C123-35 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 This failure to explain the manner in which policies will reduce impacts to a level of insignificance is
particularly troublesome regarding traffic Impact

3.2-2 where the 2022 Draft EIR concludes that the
Vehicles Miles Traveled impact is both significant
and unavoidable. The 2022 Draft EIR concludes that
certain Circulation Element policies will “Reduce the
Impact,” but doesn’t explain how these reductions
will occur or how much the impact will be reduced.

This comment contains an error; the DEIR does
not claim that policies reduce impacts to a
level of insignificance. as noted on P. 3-41,
"proposed policies listed below would reduce
potential impacts by supporting TDM measures
and requiring that new developments prepare
transportation impact assessments to
determine project specific impacts of new
development under the proposed General Plan
such that impacts can be appropriately
mitigated. Additionally, City goals and policies
strive to develop a multi-modal transportation
network that would provide transportation
alternatives to the single-occupant vehicle and
encourage complete street design.

The City shall implement all policies identified
in the proposed General Plan Circulation
Element to reduce the demand for vehicle
travel within and through the Planning Area, as
well as work with local, regional, and state
agencies to implement regional transportation
improvements. Additionally, new
developments would be required to evaluate
their project-specific impacts on the
transportation system and fund improvements
to maintain acceptable levels of service, except
where exemptions are identified in the
Circulation Element of the proposed General
Plan. However, even with implementation of
these policies, the impact would remain
significant and unavoidable."
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On 3-42,the DEIR explains: "It is difficult to
quantify the exact reduction potential of these
mitigation measures as MM-TRA-1 applies only
to new non-residential development of a
certain size and MM-TRA-2 is a voluntary
measure. MM-TRA-2 responds to the recent
surge of remote and hybrid work schedules
following the COVID-19 pandemic. While both
measures could reduce VMT metrics, it is
unlikely that either would be sufficient in
reducing these metrics to the proposed
thresholds and the impact would remain
significant and unavoidable. Please see also
response to comment C46-30 for more
information.

C123-36 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 Even where the City has the highest level of duty to protect endangered and sensitive species, the 2022
Draft EIR fails to offer any discussion of how the City believes each policy will reduce impacts. It provides
only a list of policies with no explanation of the
manner in which the measure will reduce impacts.

See e.g. DEIR, p. 3.7-51: “Implementation of the
following Proposed Project policies would reduce
potential impacts to special-status species to a less
than significant level.” This is the sum total of any
discussion offered by this fatally flawed draft EIR.

See responses to C123-29 and C123-30.

The following clarifying language will be added
under Impact 3.7-1 on page 3.7-51. This does
not change the findings of significance of the
DEIR.
"Proposed Project policies ensure that
implementation would protect critical wildlife
habitat and special status species and
communities (CO-G-7), creeks and riparian
areas as habitat (CO-G-9), wildlife corridors
(CO-I-31), and other environmentally sensitive
habitat areas (CO-G-11), as well as restore
creeks (CO-I-1), improve impaired waterways
(CO-I-2), and properly manage public land (COI-42). Therefore, compliance with the provisions of the Federal Endangered Species
Act, California Endangered Species Act,
Migratory Bird Treaty Act, and California State
Fish and Game Code in combination with
implementation of the following Proposed
Project would reduce potential impacts to
special-status species to a less than significant
level."
C123-37 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 After listing these policies, without explanation of the manner in which each will reduce impacts, the
2022 Draft EIR frequently fails to propose any
further mitigation measure. It simply states:
“Mitigation Measures. None required.”
As discussed above, this DEIR’s approach of
compressing the analysis of impacts and mitigation
measures into a single issue, disregards the
requirements of CEQA.” (Lotus v. Department of
Transportation (2014) 223 Cal.App.4th 645, 655-56.)
The court held that “avoidance, minimization
and/or mitigation measures” characterized in the
EIR are not “part of the project.” This flaw affects
the EIR’s other procedural requirements, including
This comment makes a vague assertion
without referring to specific mitigation
measures or passages in the DEIR. Please see
also responses to Comments C34-17, C46-46,
and C123-34. The DEIR identifies the potential
environmental impacts that could result from
implementation of the Proposed Project and
discusses the effects that existing regulations
and Proposed Project policies would have in
reducing or avoiding those impacts. In cases
where compliance with existing regulations
and implementation of Proposed Project
policies would not reduce a potentially
significant impact to a less than significant
level, the DEIR recommends feasible mitigation
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(1) consideration of a range of specifically targeted
mitigation measures, including analysis of whether
the project itself could be modified to lessen the
impact, (2) the discussion of potentially feasible
alternatives to avoid or substantially lessen
otherwise significant project effects, and (3) what
should be included in a mitigation and monitoring
plan. (Id. at 656.)
measures and makes a finding of significance
after implementation of mitigation. Proposed
Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take
on an ongoing basis as the Proposed Project is
implemented and the DEIR has correctly
considered the effects of implementing these
policies, including any beneficial impacts
Proposed Projects may have for reducing or
avoiding potential impacts.

C123-38 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 2) The 2022 Draft EIR improperly defers mitigation measure formulation in many of the General Plan
policies the City claims will reduce Project impacts.

Many of the plan policies listed in the 2022 Draft EIR
are conditioned by terms such as “to the extent
feasible”, “strive to”, “study”, “consult with”,
‘coordinate with” and similarly vague, noncommittal language that fail to assure that the proposed mitigation measures will be implemented
or, if implemented, will be successful in reducing
project impacts to a lessthan-significant level. There
are no performance standards. There is no
discussion of feasibility of each such policy.

In utilizing this approach the City of Pacifica has not committed itself to specific performance standards.

The measures in the 2022 Draft EIR are similar to
those the Court critiqued in Communities for a
Better Env't v. City of Richmond (2010) 184 Cal.

App. 4th 70, as “nonexclusive, undefined, untested
and of unknown efficacy. The only criteria for
‘success’ of the ultimate mitigation plan adopted is
the subjective judgment of the City Council, which
presumably will make its decision outside of any
public process a year after the Project has been
approved.” (Id. at 93.)
CEQA prohibits loose or open-ended performance
criteria. Where as here, the measures are loose or
open-ended, such that they afford a means of
avoiding mitigation during project implementation,
it is unreasonable to conclude that implementing
the measures will reduce impacts to less than
significant levels. (Rialto Citizens for Responsible
Growth v. City of Rialto (2012) 208 Cal.App.4th 899,
945.)
Even where the 2022 Draft EIR proposes specific
mitigation measures, these measures fail to meet
CEQA standards as they lack performance
standards. Mitigation Measures MM-TRA-1 and
MM-TRA-2 are proposed to reduce traffic impacts,
air quality impacts, and energy and GHG impacts.

See 2022 Draft EIR pp. 3-42, 3-43, 3.3-25, 3.3- 28,
The DEIR identifies the potential
environmental impacts that could result from
implementation of the Proposed Project and
discusses the effects that existing regulations
and Proposed Project policies would have in
reducing or avoiding those impacts. In cases
where compliance with existing regulations
and implementation of Proposed Project
policies would not reduce a potentially
significant impact to a less than significant
level, the DEIR recommends feasible mitigation
measures and makes a finding of significance
after implementation of mitigation. Proposed
Project policies are not intended to act as
mitigation measures; rather, they are policy
statements indicating actions the City will take
on an ongoing basis as the Proposed Project is
implemented and the DEIR has correctly
considered the effects of implementing these
policies.
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3.4-33. Mitigation Measure MM-TRA-1 proposes to
implement an employee commute trip reduction
(CTR) program, but there is no performance
standard. “The project applicant or designee shall
implement at least one of the following incentives
for commuters as part of the CTR program, or
another equally effective incentive. DEIR, p. 3-42.

There is no performance standard, the applicant
gets to choose the measures or an undefined
“equally effective” incentive. Likewise, MM-TRA-2, a
voluntary measure that would simply “encourage,”
has no performance standard. The 2022 Draft EIR
admits that it has not even attempted to quantify
the reduction potential of these mitigation
measures. DEIR, p. 3-43.

So too, the mitigation measures to reduce
significant GHG emission impacts are flawed. MMGHG-1 proposes to “expand” vehicle recharging network with no performance standard, and uses
the loose goal that it will “promote” zero-emission
VMT. Likewise, MM-GHG-2 and MM-GHG-3 only
consist of loose goals of promoting and
encouraging, without performance standards.

C123-39 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 3) The 2022 Draft EIR has not proposed or
adequately analyzed mitigations that would reduce
significant unavoidable impacts. Where the 2022
Draft EIR concludes that impacts are significant and
unavoidable (Impact 3.2-2 [General Plan Update
Increases the Vehicle Miles Traveled (VMT) Per
Person]), it has not adequately analyzed mitigations
that would reduce impacts to less than significant,
including changes in the proposed Project. Only two
mitigations for this significant “unavoidable” impact
are proposed: MM-TRA-1 and MM-TRA-2. “MMTRA-1 applies only to new non-residential development of a certain size and MM-TRA-2 is a
voluntary measure.” DEIR, p. 3-43. The 2022 Draft
EIR is flawed as CEQA requires a more robust
proposals to reduce and avoid significant project
impacts.

Please see response to comment C46-30 for
more information about VMT mitigations.

C123-40 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 4) The 2022 Draft EIR impermissibly relies on
mitigations it assumes that California and federal
agencies will impose. This approach contravenes
CEQA which requires “each” public agency to
comply with CEQA and “meet its responsibilities,
including evaluating mitigation measures and
project alternatives. (CEQA Guideline 15020;
Citizens for Quality Growth v. City of Mt. Shasta
(1988) 198 Cal.App.3d 433, 442, fn. 8.)
The commenter's allegation that reliance on
California and federal agencies represents
deferred mitigation is untrue. California and
federal agencies that impose regulations by
law do not represent deferred mitigation.

C123-41 Brian Gaffney
(representing
Pedro Point
3/8/22 The 2022 Draft EIR Fails To Integrate Other
Required Environmental Analysis With This CEQA
Process.

To the fullest extent possible, the City of Pacifica
This comment is untrue. Although the LCLUP is
a separate planning document, the LCLUP
policies and relevant narratives are included in
the General Plan Update to ensure
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Community
Association)
must integrate its CEQA review of the proposed
Project with related environmental review and
consultation requirements. (CEQA Guidelines
15124, subd. (d)(1)(C), 15006, subd. (i).) Toward
that end, agencies are encouraged to “[c]onsult[]
with state and local responsible agencies before and
during preparation of an environmental impact
report so that the document will meet the needs of
all the agencies which will use it.” (CEQA Guideline
15006, subd. (g).) Lead agencies must take a
comprehensive view in an EIR. CEQA requires that
the City integrate the requirements of CEQA with
planning and environmental review procedures
required by other law “so that all those procedures,
to the maximum feasible extent, run concurrently,
rather than consecutively.” (Pub. Res. Code §
21003, subd. (a).)
1) The City of Pacifica has ignored its obligation to
integrate CEQA review with the requirements of the
Coastal Act. The City is impermissibly segmenting
the Project and its environmental analysis of the
whole of the Project. The 2022 Draft EIR
acknowledges that the proposed Project “includes
an update to the Local Coastal Land Use Plan, but
expressly excludes this part of the Project from any
analysis in this EIR. DEIR, p. 1.1.
coordination between the two documents. The
beneficial impacts of these shared policies as
they relate to reduction of potential impacts
required under CEQA, such as impacts related
to geology or hydrology, are analyzed in the
DEIR. The City has prepared a draft of the LCP
Update in 2019, approved by the City in 2020,
and which is currently under review for
certification by the California Coastal
Commission. To the extent the General Plan
Update proposes any policies beyond those
which were sent to the California Coastal
Commission for review and certification, a
subsequent LCP amendment would be
necessary to make the LCP consistent with the
General Plan. The DEIR does include discussion
of the Coastal Commission requirements;
please refer to response to comment C123-42
for more information.

Discussion of Coastal Act policies and
requirements occur in Chapter 3.1, Land Use
and Housing (DEIR p. 3-12), Chapter 3.5,
Hydrology and Flooding, (DEIR p. 3.5-14),
Chapter 3.6, Geology and Seismic Hazards
(DEIR p. 3.6-31), Chapter 3.7, Biological
Resources (DEIR p. 3.7-44 and 45), and Chapter

3.9-10, Visual Resources (DEIR p. 3.9-10). The
beneficial impacts of these shared policies as
they relate to reduction of potential impacts
required under CEQA, such as impacts related
to geology or hydrology, are analyzed in the
DEIR. All policies in the General Plan and the
LCLUP are indicated with a wave symbol in the
General Plan.

C123-42 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 2) LCP amendments, including the City’s LCLUP
Update, are not exempt from CEQA, as the 2022
Draft EIR erroneously claims. The Coastal Act does
not exempt the City of Pacifica from evaluating the
environmental impacts of the whole of its Project,
including its proposed LCP amendment. The City is
required to conduct its own environmental review
of the discretionary approval of an LCLUP, and is not
exempt from CEQA review based on a subsequent
Coastal Commission staff report.5
The 2022 Draft EIR must include discussion of the
Local Coastal Land Use Plan or LCLUP, the first and
primary element of the City’s LCP. The Local Coastal
Program consists of a coastal land use plan, zoning
ordinances, zoning district maps, and other actions
which taken together implement the Coastal Act
provisions. The Local Coastal Land Use Plan “serves
as the basis for the City to update its zoning code
and any other implementing tools needed in the
This comment is untrue. As noted on DEIR p. 2-
7, "The City of Pacifica started an LCLUP update
in 2009 and continued its work through 2014.

Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan
Update to ensure coordination between the
two documents. The beneficial impacts of
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Coastal Zone, and apply to the Coastal Commission
for recertification of the LCP.” DEIR, p. 2.7. The City is the lead agency for this Project under CEQA, while
the Coastal Commission is a responsible agency.
(CEQA Guideline 15050, subds. (b)(1), (c).) “CEQA
mandates a lead agency to conduct a thorough
review of the project in question even though
additional review might later be undertaken by
other agencies with jurisdiction over specific
resources.” (Save San Francisco Bay Assn. v. San
Francisco Bay Conservation etc. Com. (1992) 10
Cal.App.4th 908, 921.)
these shared policies as they relate to
reduction of potential impacts required under
CEQA, such as impacts related to geology or
hydrology, are analyzed in the DEIR. The City
has prepared a draft of the LCP Update in
2019, approved by the City in 2020, and which
is currently under review for certification by
the California Coastal Commission.

To the extent the General Plan Update
proposes any policies beyond those which
were sent to the California Coastal Commission
for review and certification, a subsequent LCP
amendment would be necessary to make the
LCP consistent with the General Plan. The DEIR
does include discussion of the Coastal
Commission requirements; please refer to
response to comment C123-42 for more
information.

C123-43 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 3) The 2022 Draft EIR fails to include any analysis of the impacts of reasonable foreseeable development
resulting from the 2022 GP Update on ESHAs under
the Coastal Act. Instead, ESHAs are mentioned only
as part of policies that will reduce impacts. Nor are
ESHAs identified on the Figures in the 2022 Draft
EIR. The DEIR’s approach is similar to that rejected
by the California Supreme Court in Banning Ranch
Conservancy v. City of Newport Beach (2017) 2 Cal.
5th 918. There the court found that the city “did not
use its best efforts to investigate and disclose what
it discovered about ESHA” and held that the City’s
approach of delaying consideration of ESHA until
the project permitting phase was “inconsistent with
CEQA's policy of integrated review. (Id. at 939 citing
Pub. Res. Code § 21003, subd. (a).)
The DEIR does identify areas of potential ESHA
in Figure 3.7-3. More information about ESHA
at the site in question can be found in Master
Response 6: ESHA.

The Banning Ranch case represented a project
EIR. This EIR is a program EIR, which conducts 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. Please see Master
Response: Programmatic EIR for more
information.
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C123-44 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 4) The 2022 Draft EIR does not identify or discuss which LCLUP policies and relevant narratives are
included in the General Plan Update.

The LCLUP Update is not a part of the
Proposed Project and, therefore, need not be
analyzed in the DEIR. However, the General
Plan Update includes all policies that are also
contained in the LCLUP Update. Page 1-15 of
the General Plan Update states that "Policies
that are included in both the General Plan and
the LCLUP are marked with a [wave symbol] in
the General Plan. All policies in the LCLUP are
also in the General Plan." Therefore, because
all LCLUP Update policies are also included in
the General Plan Update, the DEIR analyzed
these policies for potentially significant
environmental impacts.

C123-45 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 5) The City has ignored or refused to comply with the Coastal Commission’s demands for more
information regarding the City’s proposed LCLUP
Update. The September 9, 2020 comment of the
CCC stated any General Plan policies will need to be
consistent with the LCP. Despite this, the 2022 Draft
EIR does not analyze the Project for consistency
with the LCP. Instead, the DEIR impermissibly defers
this consistency analysis to a subsequent LCP
Amendment. (DEIR, p. 2-7.)
Please see response to comment C33-1.

C123-46 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 Further, CCC correspondence to the City demanded that the City provide (1) a map highlighting all
properties that will result in a land use designation
change as a result of the LCLUP amendment, (2)
discussion of the City’s reasoning behind the
proposed land use designation changes, and (3) a
description of how the proposed land use
designation changes are consistent with the Coastal
Act. The City refused to provide the CCC with this
information.

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

C123-47 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 In addition, the City’s October 11, 2021 response to the Coastal Commission indicates that the City
intends not to comply with the CCC’s demand for
additional explanation and evaluation in regards to
its proposed LCLUP. Further, the figure at Appendix
A to the City’s October 11, 2021 response appears
to designate by color code the San Pedro Avenue
field as “Commercial,” further obfuscating the land
use designation for this parcel.

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

C123-48 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 VI. The Draft EIR Will Need to Be Recirculated for Additional Responsible Agency and Public
Comment.

Because significant new information will need to be
is added to the DEIR before certification to address
each of the issues identified above and in other
public comments. the City of Pacifica will be
required to recirculate the 2022 Draft EIR. (CEQA
Guideline 15088.5.) Recirculation is also required
because this draft EIR is so fundamentally and
basically inadequate that meaningful public review
The comment alleges that the DEIR will need to
be recirculated, which is false. All additional
information provided in the FEIR merely
clarifies and amplifies existing findings of
significance.
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and comment is precluded. (Mountain Lion
Coalition v. Fish & Game Com. (1989) 214
Cal.App.3d 1043).

C123-49 Brian Gaffney
(representing
Pedro Point
Community
Association)
The 2022 GP Update Fails to Comply With California
General Plan Law
Every city must adopt a ‘comprehensive, long-term
general plan for the physical development of the
city, and of any land outside its boundaries which in
the planning agency’s judgment bears relation to its
planning. (Citizens of Goleta Valley v. Bd. of Sups.
(1990) 52 Cal.3d 553, 570.) The Supreme Court has
described the general plan as “the constitution for
all future developments within the city or county.”
Id.

A city’s general plan is “atop the hierarchy of local
government law regulating land use.”
(Neighborhood Action Group v. Cty. of Calaveras
(1984) 156 Cal. App. 3d 1176, 1183.) “Zoning
ordinances are regulations governed by the superior
enactments in the hierarchy of planning laws.” (Id.
at 1184.) The “propriety of virtually any local
decision affecting land use and development
depends upon consistency with the applicable
general plan and its elements.” (DeVita v. Napa
(1995) 9 Cal.4th 763, 803.)
To be legally adequate, the general plan must show
“substantial compliance with the statutory
requirements” for general plans. (Camp v. Bd. of
Sups. (1981) 123 Cal.App.3d 334, 348.) A general
plan must be internally consistent, both among the
elements and within each element. (Govt. Code §
65300.5; Concerned Citizens of Calaveras Co (1985)
166 Cal.App.3d 90, 97-98.) This requirement applies
to maps and drawings as well as text. (Citizens
Assoc. v. Inyo, 172 Cal.App.3d 151 (1985); Environ.

Council v. Bd. of Sups. (1982) 135 Cal.App.3d 428.)
Each of the general plan elements must be carefully
correlated with one another to “comprise an
integrated, internally consistent and compatible
statement of policies for the adopting agency.”
(DeVita , 9 Cal. 4th at 803.)
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.

C123-50 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 The 2022 GP Update is flawed in the following ways:
1) It is impossible to assess the General Plan’s claim
that the Housing Element is consistent with the
General Plan (GP, p. 1-6) without access to this
Element.

Please see Master Response: Buildout and
RHNA for more information about the
adequacy of buildout.

C123-51 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 2) The 2022 GP Update is inconsistent regarding the amount of new housing which will be allowed. The
General Plan states that “only a small amount of
new housing—about 990 units—is expected to be
developed during the planning period.” (2022 GP
Update, pp. 1-13 & 4-29.) Yet, the 2022 GP Update
Please see Master Response: Buildout and
RHNA for more information about the
adequacy of buildout.
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also provides that by January 31, 2023, the City will
update the GP Housing Element to accommodate
1,892 housing units in compliance with the 6th
Cycle Regional Housing Needs Allocation (RHNA 6).
(2022 GP Update, p. 1-6.) Further, while the 2022
GP Update acknowledges that “Accessory dwelling
units may be built in areas zoned to allow
residential uses pursuant to State law” (at p. 4-16),
and includes Policy CD-I-6 to “Facilitate the creation
of second units” (at p. 3-9), the 2022 GP Update
does not consider these ADUs in its calculation of
housing units or density. Nor does the 2022 GP
Update consider ministerial development allowed
by SB 9 or lot splits.

C123-52 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 3) The 2022 GP Update improperly defers standards development to future zoning ordinances,
standards and regulation updates.

Zoning does not represent a deferral. As a
general law city, Pacifica is required by law to
update its zoning code after adoption of a
General Plan; thus, this does not represent
deferred mitigation. This comment is not
related to the adequacy of the FEIR, thus no
further response is required. Please see Master
Response 1 for more information.

C123-53 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 4) The circulation element of the 2022 GP Update is not correlated with the land use element or the
other elements of the General Plan.

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

C123-54 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 5) Land use designations in the 2022 GP Update
conflict with policies, particularly
at the San Pedro Avenue site.

The commenter provides no evidence to
support this statement. This comment is not
related to the adequacy of DEIR analysis, thus
no further response is required
C123-55 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 6) There are vertical and horizontal internal
inconsistences in and between the
General Plan and the LCP updates.

The commenter provides no evidence to
support this claim.

As noted on DEIR p. 2-7, in February 24, 2020,
the City Council considered the PostConsultation Draft LCLUP and approved transmittal of the LCLUP to the California
Coastal Commission for review and
certification. The LCLUP was transmitted to the
Coastal Commission on June 12, 2020.

Although the LCLUP is a separate planning
document, the LCLUP policies and relevant
narratives are included in the General Plan
Update to ensure coordination between the
two documents. The City has prepared a draft
of the LCP Update in 2019, approved by the
City in 2020, and which is currently under
review for certification by the California
Coastal Commission. To the extent the General
Plan Update proposes any policies beyond
those which were sent to the California Coastal
Commission for review and certification, a
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subsequent LCP amendment would be
necessary to make the LCP consistent with the
General Plan.

C123-56 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 7) The 2022 GP Update, in its current form, is
inconsistent and does not provide guidance as to
what uses, intensities or densities are allowable for
specific parcels where policies regarding wetlands,
ESHAs, steep slopes, and flood-prone areas conflict
with land use designations. This is true, for example,
with the proposed CRMU designation at the San
Pedro Avenue (Calson) site. Thank you for your
careful attention to these issues
Allowable densities and intensities for every
type of land use designation in the Planning
Area are described in Table 2.3-1. As described
in Master Response: Buildout and RHNA, no
parcel develops at maximum capacity, due to
zoning regulations, setbacks, and potential
environmental constraints. Given
environmental factors such as slope and
sensitive species, there are some constraints
on the development potential of these sites.

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.

C123-57 Brian Gaffney
(representing
Pedro Point
Community
Association)
3/8/22 7) The 2022 GP Update, in its current form, is
inconsistent and does not provide guidance as to
what uses, intensities or densities are allowable for
specific parcels where policies regarding wetlands,
ESHAs, steep slopes, and flood-prone areas conflict
with land use designations. This is true, for example,
with the proposed CRMU designation at the San
Pedro Avenue (Calson) site. Thank you for your
careful attention to these issues
Allowable densities and intensities for every
type of land use designation in the Planning
Area are described in Table 2.3-1. As described
in Master Response: Buildout and RHNA, no
parcel develops at maximum capacity, due to
zoning regulations, setbacks, and potential
environmental constraints. Given
environmental factors such as slope and
sensitive species, there are some constraints
on the development potential of these sites.
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Letter Commenter Date Comment Combined Response
Individuals (C)
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.
613
C124: Christine Boles, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C124-1 Christine
Boles
2/11/22 As I read the DEIR, I am very puzzled as to how some of the CEQA required conclusions in Chapter
5 were reached.

This is why I have asked you, Planning Director
Wehrmeister and City Manager Woodhouse a
number of questions via email over the past few
weeks about dates of source documents, the lack
of a current bibliography beyond 2014, and
whether these draft documents were reviewed
recently by agencies such as North County Fire
before they were released. The lack of
transparency and answers to these basic
questions is directly affecting my ability to review
the DEIR and I want to again raise my objections
to both the short review time and the poor quality
of the documents which makes a thorough review
impossible.

I have filed several official Public Document
Requests to try to obtain some of this
information, and the city has responded by
declaring the need for time extensions. Isn’t that
ironic given that the city won’t answer our
requests for an extension until next Monday, only
a week before the self-imposed deadline, which is
the minimum period allowed by state law?
The following is a list of my outstanding PRA
requests related to the General Plan.
• 22-24 Filed 1/24/22 Dyett & Bhatia
communications
• 22-26 Filed 1/25/22 North County Fire
Communications
• 22-30 Filed 1/27/22 Fish and Wildlife
Communication. This PRA request was
inappropriately closed, indicating that the city is
not complying FOIA regulations. I was only given
the voicemail message from Will Kanz at Fish and
Wildlife to Christian Murdock. I know for a fact
that Will spoke to someone at the city and that he
asked for an extension to the DEIR review period
deadline, and that the request was denied. Where
are the records of that conversation? And was the
denial of an extension approved by the Council or
was it simply a staff decision? It is my
understanding that only the Council can make the
determination to extend the deadline. Please
reopen the PRA request and provide the required
records.
• 22-48 Filed 2/9/22 Communications with the
city’s other technical consultants DKS Associates,
Environmental Science Associates, and Charles
Salter and Associates.

EIR comments for more information about GP- or SPSPrelated responses.

C124-2 Christine
Boles
2/11/22 As an example, of the impossibility of making
CEQA required findings, let’s talk about traffic. We
Congestion is not a required topic of CEQA analysis.

The commenter asserts that traffic counts are from
614
Letter Commenter Date Comment Combined Response
Individuals (C)
all know that traffic is bad in Pacifica, especially on the southern end of town. The fact that traffic has
gotten worse since the tunnel was opened in 2013
is clear (please see supporting social media
answers from many residents, attached at the end
of this letter) and yet apparently the traffic data
used in the DEIR analysis dates from 2010, pretunnel. Much more recent traffic data is available free online from Cal Trans and other sources, see
correspondence sent to you directly from Vicki
Sundstrom, who is licensed Civil Engineer and who
works professionally as a traffic engineer. To imply
that the city cannot afford a new traffic study and
is therefore relying on “best available data” from
2010 is ludicrous and a fatal flaw in this DEIR and
draft General Plan.

Chapter 5.1 on Growth Inducing Impacts says that
per CEQA Guidelines Section 15126.2(d) that “this
analysis must also include the removal of
obstacles to population growth, such as
improvements in the regional transportation
system.” Please clarify what obstacles were
studied and removed and how projected
cumulative traffic impacts was calculated and
mitigated under full buildout.
2010; this is incorrect. Traffic counts from pages 3-12 to 3-21 were conducted in 2018 and 2019, and analysis
from Table 3.2-7 on page 3-41 was conducted in 2020
and 2021, in accordance with the table references in
the DEIR.

C124-3 Christine
Boles
2/11/22 Please also clarify how projected hazards, like flooding and sea level rise are addressed and
mitigated in relation to major transportation
corridors and emergency evacuation routes, like
Highway One, and how this information has
informed project buildout and specific zoning
changes that increase density.

Policies within the LCLUP related to effects of climate change and sea level rise are addressed in the LCLUP.

See response to comment C13-3 for more information
about coastal flooding and sea level rise. See also
Master Response 9: Emergency Access.

Analysis pertaining to whether the implementation of
the Proposed Project will require or result in the
relocation or construction of new or expanded storm
water drainage facilities as discussed under criterion

3.13-1, specifically on pages 3.13-16 to 3.13-20. In
regard to stormwater, development under the
Proposed Project will incorporate best management
practices from construction and development, meeting
the requirements of the City’s stormwater permit,
regional and state regulations, and Proposed Project
policies. The increasing incorporation of stormwater
management in site planning will further reduce the
need for development of new storm drainage
infrastructure. Such Proposed Project policies to
reduce impact on stormwater facilities include CO-I-9,
CO-I-10, CO-I-11, CO-I-12, CO-I-13, CO-I-14, CO-I-15,
CO-I-16, and CO-I-17. Thus, the stormwater
infrastructure in Pacifica is adequate to provide for the Proposed Project buildout population.

C124-4 Christine
Boles
2/11/22 The fire risk with the highly flammable eucalyptus forest at the approach to the tunnel is also a
major issue that I have not seen addressed
anywhere. The fire map in the DEIR, figure 3.14-1
Please see Master Response 5: Wildfire for more
information on data used for mapping. Maps from
2014 do not use the 2008 CAL FIRE Recommended LRA
maps and thus do not represent the latest and best
615
Letter Commenter Date Comment Combined Response
Individuals (C)
does not include mapping of Very High Fire Hazard
Severity Zones, but the one in the old 2014 draft
GP does, see below. Please confirm why this
critical information is missing in the DEIR, and
where it can be obtained so I can start a proper
review of the Fire Hazards chapter. Note that this
map shows several areas of Very High Fire Hazard
Severity Zones are within City Limits, despite the
DEIR saying multiple times that these areas are
only outside city limits.
available data. Flammability of eucalyptus forest as
vegetation is included as a factor in Fire Hazard
Severity Zones designated by CALFIRE; mapping is
based on factors such as fuel, slope, and weather.

Figure 3.14-1, which shows Fire Threat, a measure of
fuel conditions and fire potential in the ecosystem.

C124-5 Christine
Boles
2/11/22 And please clarify why the DEIR is quoting the
Multi-Jurisdictional Local Hazard Mitigation Plan
for fire risk analysis when staff and council
members clearly stated in the 11/21/21 Council
hearing that it was not important for this
document to be accurately updated despite the
obvious errors I and others pointed out; that we
only needed to file it in time to be eligible for
FEMA disaster funding.

The MJ-LHMP was adopted and certified by the state
government, and actions related to wildfire and
emergency planning remain applicable. The DEIR does
not solely rely on the MJ-LHMP for its analysis. Please see Master Response: Wildfire for more information on
the adequacy of analysis.

C124-6 Christine
Boles
2/11/22 Chapter 5.1 continues under Growth Management
that “Rather than inducing growth, the Proposed
Project identifies developments in target areas.”
But the basis of the “Project” is an additional 990
units, most in Sharp Park, but also in other parts
of town such as the Pedro Point Avenue
site/wetlands where housing density is proposed
to be increased, as well as in shopping centers
scattered throughout town, including at the far
back of Linda Mar/Park Pacifica at the Park Mall
and at Manor Plaza. All of these projects would
increase traffic in already highly congested areas
with minimal evacuation options based on exiting
roadway infrastructure and in areas identified
with very low grades (E and F) of traffic levels of
service.

As the commenter describes, planned development
does not represent induced growth; the DEIR analyzes
potential impacts of lands use changes (planned
growth) in areas where development could reasonably
occur. Congestion is not a required topic for CEQA
analysis. As discussed in Impact 3.2-4, project level
review required by the City includes site access review for emergency vehicles and traffic control plans as
needed that account for emergency vehicles. Thus,
new development would be required to comply with
Municipal Code requirements for emergency access to
the site and LHMP and Emergency Plan
implementation will reduce impacts to the maximum
extent practicable. In addition, new development
would be subjected to policies listed under Impact 3.2- 4 as well as the existing programmatic framework to
reduce impacts of evacuation to less than significant
level. Please see Master Response 7: Evacuation
Routes for more information regarding emergency access. C124-7 Christine Boles
2/11/22 The DEIR also speaks in favor of annexing land on San Pedro Mountain and in Shamrock Ranch to
build housing. Please clarify in detail how the
consultants and/or planning staff determined that
all of these proposed project and zoning changes
are determined to not be “growth inducing” under
the full buildout per this plan, and under the much
greater buildout that will need to be identified
with the upcoming update to the Housing Element
later this year for a total of almost 1900 new units.

This comment contains an inaccuracy. The DEIR does
not contain an opinion about annexing land. Shamrock
Ranch is outside of the City limit, under the jurisdiction of San Mateo LAFCo. Policy LU-I-45 would have the City
coordinate with San Mateo County to ensure that any
new development at Shamrock Ranch is clustered to
preserve open space. Any subdivision of greater than
ten lots or development of more than ten housing
units or 40,000 square feet of non-residential space
should occur through a master planning process and
may involve annexation into the city. These controls
show that growth would not be unplanned; instead, it
would account for growth that could require additional
services.
616
Letter Commenter Date Comment Combined Response
Individuals (C)
C124-8 Christine
Boles
2/11/22 And please clarify how the DEIR will still be
applicable in January of 2023 when we are forced
to plan for our full RHNA allocation, with almost
double the environmental impacts analyzed in the
current DEIR.

As noted in Master Response: Buildout and RHNA, the
City is updating its 6th cycle Housing Element update,
which will likely include land use changes to
accommodate the RHNA. The Housing Element update
and development of the required housing sites
inventory will involve an extensive period of
community input and additional CEQA review. This
approach does not constitute “piecemealing”, dividing
a large project into separate parts, each of which might have individually minimal environmental
consequences, because the CEQA document would
analyze the proposed General Plan in addition to any
future changes to the land use diagram.

C124-9 Christine
Boles
2/11/22 One sentence in this section on page 5-2 seems to be missing words:
“The Planning Area is located in an area that is
partially and urban and lacks opportunities for
greenfield development.” Please clarify the
missing word(s) and also please define “greenfield
development” as it is missing from the glossary.

This comment is noted. The following edit has been
made for clarity:

DEIR p. 5-2: "The Planning Area is located in an area
that is partially and urban and lacks opportunities for greenfield development, as nearly all of the open,
undeveloped areas are designated for open space."
This is a minor correction made to clarify and does not affect the findings of the DEIR.

C124-10 Christine
Boles
2/11/22 Further down, section 5.3 Significant and
Unavoidable Impacts identifies
transportation/traffic as a major issue that cannot
be itigated. It says, “Impacts to transportation
would be cumulatively considerable”. Further
down on page 5-7 under Cumulative Impacts of
Transportation So somehow with these vague
undefined policies that are deferred for future
analysis the “Project” has been determined to
have less than significant cumulative impacts on
traffic?
Please see also response to comment C123-26. This
comment incorrectly asserts that the DEIR identified
policies that would reduce VMT related impacts of the
Proposed Plan to a less than significant level. In fact, as noted on page 3-41of the DEIR found a significant and
unavoidable VMT impact related to increases the
Vehicle Miles Traveled (VMT) per person above the
baseline conditions even after implementation of all
feasible mitigation measures.

C124-11 Christine
Boles
2/11/22 It is my understanding that this poor work and
analysis will not hold up very well to a CEQA
challenge especially if the lack of analysis has the
potential to cause harm. For example, traffic
issues need to be understood as part of
Greenhouse gas emissions in Chapter 3.4. What
source of traffic data did Dyett & Bhatia use for
this new analysis required by BAAQMD in their
response to the NOP?
Traffic counts from pages 3-12 to 3-21 were conducted
in 2018 and 2019, and analysis from Table 3.2-7 on
page 3-41 was conducted in 2020 and 2021, in
accordance with the table references in the DEIR.

For this analysis, impacts of the proposed Project on
GHG emissions and energy resources from
construction were assessed qualitatively, while impacts from operations were assessed quantitatively using
standard and accepted software tools, techniques, and
emission factors. The primary assumptions and key
methods used to quantify emissions and estimate
potential impacts are described below. Model inputs
and calculation files are provided in Appendix C: Air
Quality and Greenhouse Gas Data. Thus, GHG analysis
of This reference edit does not change any findings of
significance.

C124-12 Christine
Boles
2/11/22 Current traffic demand also needs to be
understood so that North County Fire can verify
that they can provide the right level of service.

See response to comment C82-21.
617
Letter Commenter Date Comment Combined Response
Individuals (C)
Today I was given access to the 2010 Existing
Conditions Report that informed the 2014 draft
General Plan. The screenshot below shows that
even with 2010 traffic and road conditions, they
were having difficulty meeting the level of service
standards that they were comfortable with.

And North County Fire was already in discussions
with the city in 2009 about the potential need to
build a third fire station. I have not seen any
planning for this future fire station in the Land Use
Element. Please confirm. Will a new station be
needed for 990 new units? For 1892? For the
buildings over three stories that are proposed for
Sharp Park that are too tall for our traditional fire
trucks? Has land been designated for a new
station? Are these needs included in the capital
improvements program for North County Fire in
the near future?
618
C125: Nancy Tierney, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C125-
1 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 Regarding the Proposed
Project, it’s not clear what
this is, or for that matter
how the alternatives
compare (including No
Project).

As noted on p. 4-2 and 4-3, the Proposed Project represents the project analyzed in chapters 3.1-3.15 in the DEIR. Comparative analysis of the Alternatives is presented in section 4.3.

C125-
2 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 Section 1.2 Planning
Process, covering the
period of 2009 – 2019.

Why the 10-year period
and why wasn’t the 2014
update adopted?
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.

C125-
3 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 I note two different project
population figures: 41,280
(established buildout on
page 6) and 41,050 in table

2.4-1 (page 181). While not
materially different,
accuracy and consistency
are important.

This comment is noted. The following edit has been made for clarity:

DEIR p. E-5: "As shown in Table ES-1, the Planning Area would result in a population of approximately 41,280 41,050 people at buildout, an increase of about 7.1 percent over the current estimated population, or 2,720 new residents."
This is a minor correction made to clarify and does not affect the findings of the DEIR.

C125-
4 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 The Land Use Framework
identifies the objectives of
concentrated
development, higher
density housing, compact
mixed used development,
along with conserving open
space and protecting
habitat—all worthwhile.

Further the Conservation
section addresses the
importance of insuring
good water and air quality
and protecting biological
resources. Yet it’s not clear
how these objectives are
met with the Proposed
Project and in light of the
apparent focus on
expanded development in
the City of Pacifica through
approved projects and the
SPSP.

Projects undergoing approval now are not yet subject to policies in this Proposed Plan, which have not yet been adopted. 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.

C125-
5 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 Plan Bay Area 2040 is
referenced (page 298).

Note that the current
document that Pacifica
should adhere to, adopted
in October 2021, is Plan
Bay Area 2050.

The comment is noted. The text changes are incorporated in the General Plan errata. They do not relate to adequacy of DEIR analysis. 619
C125-
6 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 In section 3.3-5 addressing
BAAQMD 2017 Clean Air
Plan, where are the
recommended actions?
Further, there are
statements (CO-I-60) about
monitoring the
effectiveness of the CA
Green Building Code and
(CO-1-62) to promote use
of solar. I think the current
climate crisis calls for more
aggressive steps. [This also
warrants updating the
City’s Climate Action Plan.]
The comment is noted. The applicable recommendations are mentioned in Table 3.3-5.

The comment also mentions taking more aggressive steps in relation to the climate crisis. As the recommendations mentioned in Table 3.3-5 would reduce the impact to a less than significant level, no additional policies are required and no further response is required.

C125-
7 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 CO-1-54 on Climate Action
Plan and GHG emissions
reduction. What is the
status of a baseline GHG
inventory? That will inform
how we can reduce
emissions.

The CAP has not been updated yet. The latest information about the update can be found in the City's website:
https://www.cityofpacifica.org/depts/planning/climate_action_plan.asp As noted on DEIR p. 3.4-27, it is acknowledged that "implementation of [the existing] CAP does not necessarily guarantee that an updated CAP will be prepared or that all GHG reduction measures included will be capable of meeting an updated, and potentially lower, GHG emissions reduction target." Because impacts and potential reductions could not be quantified, the DEIR concludes that "therefore, on a local scale, implementation of the Proposed Project would generate GHG emissions that could have a significant impact on the environment and this impact would be potentially significant and mitigation measures would be required." These mitigation measures are described on p. 3.4-47, and

3.4-48.

C125-
8 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 In the Land Use Element
(LU-1-16) regarding density
bonuses “up to 50% over
maximum allowed by
zoning,” it makes sense to
identify specific sites that
meet the criteria, e.g.,
accounting for a city center
or neighborhood.

C125-
9 Nancy
Tierney,
Campus and
Facility
Planner
3/7/2
2 In Section 3.4 on Energy
and GHG, a reference to
2011 data is made. A
source for current data, is
the IPCC Sixth Assessment
Report.

References will be updated to reflect the latest data used in analysis.

This does not change any findings of significance in the DEIR. 620
C126: Lawrence Bothen, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C126-1 Lawrence
Bothen
3/7/22 Due to the sprawling mass of the General Plan, I will confine my remarks to the areas that directly
affect me as a resident of Pacifica and the
Rockaway Beach neighborhood, and that I had
time to read. That said, I also support and concur
with the remarks submitted by Richard Harris of
the San Francisco Public Golf Alliance, which notes
that the Sharp Park Golf Course is not included
with its clubhouse as a Pacifica Historical Site,
despite its inclusion as such in the 1980 general
plan. Obviously, the golf course must be included
with its clubhouse as a significant historical site in
Pacifica.

There aren’t many golf courses that can trace
their origin to the legendary golf course architect,
Alister MacKenzie. Augusta National, home of the
Masters Tournament, Pasatiempo in Santa Cruz,
and St. Andrews in Scotland are towering
examples of how he integrated man’s plan into
the natural environment and enhanced both. His
collaboration in the late 1920’s with John McLaren
on Sharp Park Golf Course, and its clubhouse, is a
testament to that ethos. The fact that we are
blessed with this resource within our city limits is
something that should be identified with signage
directing visitors to it. There should be a
concomitant upgrade to restore the Sharp Park
Restaurant to a status worthy of a visitor’s time,
or a local’s for that matter.

The comment is noted. Please refer to response to
comment C3-1
C126-2 Lawrence
Bothen
3/7/22 Fig. 3-3, Visual Resources, are Pacifica’s greatest asset. Coastal View Corridors, refers to the views
of Sharp Park Golf Course from Rt. 1 and from
Sharp Park Rd. and how they establish the visual
character of Pacifica. You cannot exclude the golf
course from its proper designation as a Pacifica
Historical Site when it is so representative of that
visual character, and you have referred to it in this
document.

What kind of visual experience are you offering to
visitors when you have already enabled lining
these corridors with derelict RV’s that park along
Esplanade, with its spectacular view of the pier
and Pedro Pt., Francisco Blvd. from the offramp to
the golf course, Fairway and Ridgeview drives next
to the golf course, Rockaway Beach parking area,
and Roberts Rd? Not to mention the other
significant view corridor of San Pedro Mountain
from eastbound Linda Mar Blvd. That is also slated
to be a parking area for homeless RV’s from
Adobe Drive to Oddstad Blvd., in front of existing
single family homes.

RV parking is controlled by City Ordinance,
enforcement of this ordinance is beyond the scope of
the DEIR, thus, no further response is required.
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Letter Commenter Date Comment Combined Response
Individuals (C)
C126-3 Lawrence
Bothen
3/7/22 CD-G-5 and CD-I-II, hillsides & ridgelines, states development should “minimize grading and
conform with natural landforms.” Well, that ship
has sailed. The new condo project on Fassler
doesn’t even attempt to conform to that
standard, or this one; “design structures so that
they follow contours and limit their downslope
exposure.” The new proposed developments off
Coast Highway between the Lutheran Church and
Reina del Mar completely ignore it. The proposed
8 story apartment tower next to the church might
be OK on El Camino from SSF to Millbrae, but it’s a
boiler plate flatland project with no attempt to
integrate into the steep hillside it’s sited on. The
adjacent single family home project, built on
steep, hazardous hillsides pretends that’s a
flatland project too. Neither one says how they’d
dump all that traffic on Coast Highway at peak
crush hours, but that’s our problem, not theirs,
right?
The comment is noted. This DEIR provides a
programmatic analysis of potential environmental
impacts. 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 intended to
be developed over a 22-year 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 projectspecific 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.

C126-4 Lawrence
Bothen
3/7/22 CD-I-17, Headlands Special Area for Rockaway
Headlands. This section calls for hikers huts and
kiosks, and maybe a “view restaurant” if it can be
made accessible to hikers. Have you ever visited
this area? It’s a 10 minute walk from Rockaway to
Linda Mar. There’s 4 restaurants in Rockaway you
can drive to and park, plus Taco Bell and several
more restaurants at Pedro Pt. shopping center on
the other side. This is pure detritus from an earlier
draft of this plan.

C126-5 Lawrence
Bothen
3/7/22 CD-I-18, Rockaway Quarry Site, proposes to
rename Mori Pt. special area for visitor serving
development on portion of quarry site, two
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
622
Letter Commenter Date Comment Combined Response
Individuals (C)
distinctly separate areas. Have you been here?
What is the intent? The entry to Mori Pt. for
GGNRA is near the Moose Lodge.
“Development on the Quarry flats should be
connected to adjacent Rockaway Beach business
district. If a hotel is built there it must be designed to blend with landscape and convey a high quality
image.” No problem there. I’m thinking of
something climbing inside the bowl of the
excavated hillside with south facing ocean views.

Prepare for pushback from dog owners who think
the entire quarry is a free range kennel.
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.

C126-6 Lawrence
Bothen
3/7/22 3.4 Scenic Routes, states Coast Highway and Sharp Park Rd. should be scenic highways. Well, if that
isn’t self evident put up a couple signs saying that.

I don’t think we need to waste taxpayer dollars on
a study by a consultant to tell us what we already
know. Spend half of that money for Public Works
to pick up trash and cut down weeds on Sharp
Park Rd and make CalTrans spend our tax dollars
to do the same on Rt. 1 That would make both
roads a lot more scenic.

C126-7 Lawrence
Bothen
3/7/22 Roadway “Enhancements.” This states “on Sharp
Park Road completion of bicycle improvements
will improve the character of this roadway and
make its scenic quality available to cyclists,” while
needlessly ruining the commute over the hill we
all make so that maybe dozens of cyclists can
include this in their weekend ride. This is the same
stupid idea put forth by our Council in 2021 and
roundly condemned by any regular or occasional
commuter in and out of Pacifica because it would
cut the roadway to one lane for vehicular traffic in
either direction. Fig. 5-4 highlights Sharp Park Rd
as a Class IV road, by definition a road with a
separated bike lane. This may be practical when
we are crashing into each other in the airspace
above with our flying electric cars. But it won’t be
before 2040.

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.
623
C127: Richard Harris, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C127-1 Richard
Harris, San
Francisco
Public Golf
Alliance
3/9/22 The Environmental Impact Report text should identify Sharp Park Golf Course as a Pacifica Visual Resource, and the Coastal View Corridors on the Visual Resources maps in both the General Plan and the Environmental Impact Report should identify as “Coastal View Corridor” the unique open Coastal view to the east from the California Coastal Trail across the golf course into the surrounding hills.

1. The identical “Visual Resources” map in the Public Comment Draft ‘General Plan (January 2022) 1 and its Supporting Environmental Impact Report2 designates as Pacifica “visual resources” Sharp Park Road (identified as both a scenic “gateway” to Pacifica and as a “Scenic Route”), and the view from Sharp Park Road to the west across Sharp Park Golf Course as a “Coastal View Corridor”.

2. Scenic views of the ocean and along the beach are not the only “Coastal” views protected by the Coastal Act, but also views from the shore inland across Coastal Zone lands and waters. The unique open scenic view to the east from the California Coastal Trail, across Sharp Park Golf Course into the surrounding hills is such a view and should also be designated a “Coastal View Corridor” on the Visual Resources maps in the General Plan and EIR.

The Draft EIR notes, at page 3.9-10, that “Section 30251 of the California Coastal Act requires that scenic and visual qualities of coastal areas be considered and protected as a resource of public importance.” The Coastal Act defines, at Section 30103(a) the term “Coastal zone” to include not just the shore, but also “. . that land and water . . . extending inland generally 1000 yards from the mean high tide land. . . ”3 And at Section 30116, the Coastal Act provides that “highly scenic areas” constitute “sensitive coastal resource areas”.

So views inland from the shore across Coastal Zone lands and waters are to be protected under the Coastal Act. The only “Coastal View Corridors” identified on the Visual Resources maps (Draft General Plan Figure 3.3, at page 56/299, and Draft EIR Figure 3.9-1, at page 588/1001 – see footnotes 1 and 2 at page 2, above) are views from roads. As if views from a vehicle were the only protectable Coastal views. This is not so. The California Coastal Trail in the section that runs atop the Sharp Park berm between the Pacifica Pier and Mori Point (which section of trail atop the berm was recently improved by the City of San Francisco with viewing platforms, beach access stairways, and interpretive signage, under an order from the Coastal Commission) has a magnificent view inland from the shore across the golf course into the hills (pictured on page 1 of this letter), which merits the “Coastal View Corridor” designation.

This open view of the hills from the shore – without streets, houses, or buildings of any kind (other than the historic Sharp Park Clubhouse sometimes glimpsed across the fairways and through the Cypress) – is unique in Pacifica and should be No development is proposed
that would block scenic views to
the hills to the east of the Golf
Course from the Coastal Trail;
the impact is less than
significant. Please see Master
Response 1 for more
information on General Planrelated response to comments. 624
Letter Commenter Date Comment Combined Response
Individuals (C)
identified as “Coastal View Corridor” on the Visual Resources maps of both the General Plan (Figure 3-3, at 56/299) and the EIR (Figures 3.9-1). See Footnotes 1 and 2 at page 1, above.

3. Notwithstanding that the Draft EIR’s “Visual Resources” map identifies Sharp Park Golf Course as a Pacifica Visual Resource, the Draft EIR omits mention of the golf course in a key section of text and in Figure 3.9-2, “Pacifica Visual Resources”.

These omissions should be cured.
(i) The textual omission occurs in a sentence listing “dramatic coastal features” under the heading “Regional Scenic Features,” at EIR Page 3.9-2 (587/1001). The omission should be cured by adding “Sharp Park Golf Course” to the final sentence of text as follows:
“Mori Point, Rockaway Headlands, and Pedro Point Headlands, as well as Pacifica State Beach, Rockaway Beach, Sharp Park Beach, [ADD: Sharp Park Golf Course,] and the Northern Coastal Bluffs, are dramatic coastal features.”
(i) Figure 3.9-2, “Pacifica Visual Resources” (which appears at page 3.9.8 (593/1001) of the Draft EIR (See Footnote 2, at page 2, above) should be augmented with a photo of the view to the east from the Coastal Trail across the golf course into the hills. (This letter contains such a photo at page 1, above, and the San Francisco Public Golf Alliance will be pleased to make that photo available to the Planning Department for this purpose.)

CONCLUSION
The dramatic coastal scenery of the Sharp Park Golf Course should be expressly recognized and designated by both the General Plan and the EIR as a significant Pacifica coastal scenic resource, as requested above.
625
C128: Richard Harris, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C128-1 Richard
Harris, San
Francisco
Public Golf
Alliance
3/7/22 I. The Public Comment Draft Pacifica General Plan (January 2022) and its Supporting Environmental Impact Report both fail to identify Sharp Park Golf Course as a Pacifica Historical Site. This is error. It is inconsistent with the existing 1980 General Plan, and inconsistent with unanimous resolutions of the Pacifica Historical Society, Pacifica City Council, San Mateo County Board of Supervisors, an historic resource property determination under CEQA by the San Francisco Planning Department, and inconsistent with the April 2015 Response to Comments on the Draft General Plan Prepared by Pacifica Planning Department and Dyett & Bhatia.

A. The existing (1980) Pacifica General Plan at page 95a identifies both the Sharp Park Golf Course and Clubhouse on the list and map of “Pacifica Historic Sites”.

B. Sharp Park Golf Course and Clubhouse are both designated “historically significant facilities” by unanimous resolutions of the Pacifica City Council4 and the San Mateo County Board of Supervisors.

C. The Pacifica Historical Society by unanimous resolution of its Board of Directors, has determined and declared Sharp Park Golf Course to be a “significant historic and cultural resource.

D. The Planning Department of the City and County of San Francisco – the owner of the property – has determined Sharp Park Golf Course to be “historic resource property” pursuant to provisions of the California Environmental Quality Act (CEQA).

E. San Francisco Public Golf Alliance, by letter dated July 9, 2014, submitted to Pacifica Planning Department in the course of public comment on the Draft Revised General Plan, commented with extensive documentation, on the architectural history of Sharp
Park Golf Course and the fame and preeminence of its architect, Alister MacKenzie. This July 9, 2014 San Francisco Public Golf Alliance letter was resubmitted to the Planning Department when Pacifica reopened in 2020 reopened public comment on the Draft General Plan.

F. The April 15, 2015 Response to Comments on the Draft Pacifica General Plan, prepared by City [of Pacifica Planning] Staff and Dyett and Bhatia, recommend that Sharp Park Golf Course be identified as a historic resource, and that the text, table, and map in the Historic Resources sections of the EIR and Revised General Plan be corrected to show both Sharp Park Golf Course and Clubhouse as historic resources.
• Chapter 2, Responses to Plan-Related Comments Page 2-50 [“Master Response”]
”SHARP PARK GOLF COURSE AS A HISTORIC RESOURCE
Multiple commenters stated that Sharp Park Golf Course itself – and not only the Clubhouse—should be identified in the General Plan and EIR as a historic resource. The Golf Course and Clubhouse are identified as a historic site in the 1980 General Plan, and were identified by Resolution No. 63-2007 as
“historically significant facilities” by the Pacifica City Council. The fact that the golf course is not identified in the Proposed General Plan or Draft EIR as an historic resource reflects the language in the zoning code, which only recognizes the Sharp Park Golf The comment accurately describes
the accidental omission of the entire
Sharp Park Golf Course as a historic
resource, and is noted and
appreciated.

The comment stated that that Sharp
Park Golf Course itself—and not only
the Clubhouse—should be identified
in the General Plan and EIR as an
historic resource. The Golf Course and
Clubhouse are identified as an historic
site in the 1980 General Plan, and
were identified by Resolution No. 63-
2007 as “historically significant
facilities” by the Pacifica City Council.

The fact that the golf course is not
identified in the Draft EIR as an
historic resource reflects the language
in the zoning code, which only
recognizes the Sharp Park Golf Course
Clubhouse. However, given other
formal recognition of the Golf Course
by the City, the Draft EIR has been
updated to reflect this change.
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Letter Commenter Date Comment Combined Response
Individuals (C)
Course Clubhouse. However, given other formal recognition of the Golf Course by the City, and the Draft EIR and is corrected here. . . .

Recommendation: Identify Sharp Park Golf Course as a historic resource. Sharp Park Golf Course is identified as a historic resource in the text, table and map on pages 7-44 and 7-45 of the Draft General Plan. Please see Chapter 3: Recommended Plan Modifications.”
• Chapter 3: Recommended Plan Modifications
“Page 7-44
The City has nine local historical landmarks: Sanchez Adobe; the Little Brown church; the former San Pedro Schoolhouse (now City Hall); the 1907 Anderson’s Store building on Paloma Avenue; the Sharp Park Golf Course and Club-house, from 1932; Vallemar Station; the former Dollaradio Station; and two private residences (see Table 7-5).

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

Page 7 ends

Figure 7-6: Historic and Cultural Resources
Map will be revised to show Sharp Park Golf Course and
Clubhouse as a historic resource.”
The failure of the 2022 Draft Revised General Plan/EIR to incorporate the Planning Department’s April 2015 Responses to Comments regarding the historical status of Sharp Park Golf Course is inconsistent with the Department’s assurance of its “intent to rely on any environmental analysis which was completed in the earlier EIR process.”
II. CONCLUSION: Sharp Park Golf Course is the eponym of Pacifica’s Sharp Park District. The golf course is the work of world-renowned master architect Alister MacKenzie, and is recognized as architecturally and historically significant by unanimous resolutions of the Pacifica City Council, Pacifica Historical Society, San Mateo County Board of Supervisors, and an Historic Resource Property
determination under CEQA by the San Francisco Planning
Department. The General Plan and EIR should be revised – as provided in the April 2015 Responses to Comments on the Draft General Plan – to show and determine Sharp Park Golf Course to be a Pacifica Historic Site and Resource.
627
C129: Jake Scussel, 2/30/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C129-1 Jake Scussel 2/30/2022 We should strive to limit or halt urban expansion and avoid exceeding development
on 50% of Pacifica's land mass.

The comment is noted. The Proposed Plan envisions
“concentrated and compact development primarily in
already developed areas” (DEIR p.3.1-19).

C129-2 Jake Scussel 2/30/2022 Particularly concerning is the proposed Higgins Way development located in the "Urban
Reserve" that is currently in planning stages.

It's on an HPD, the land is critical habitat for
endangered species and is labeled Very High
fire risk...

Development should be limited to only areas
adjacent to existing roadways throughout
Pacifica. The wooded hillsides between San
Pedro Valley Park and Pedro Point Headlands
should be protected land, and efforts should
be made to ensure that if/when Shamrock
Ranch is sold, development is limited strictly to
alongside Peralta and Shamrock Ranch Rd.

The comment is noted. While it is possible that
development 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. 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 MJLHMP Annex for Pacifica also includes actions that would reduce the risk of loss or damage dure to
wildfire in and adjacent to fire-prone 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 (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.

C129-3 Jake Scussel 2/30/2022 We need to focus on utilizing under-developed and under-utilized existing spaces first and
foremost, then building up - not out - once
those options have been exhausted. I would
be more than willing to map out potential
locations for renovation/development if it
would be helpful
The comment is noted. The Proposed Plan envisions
“concentrated and compact development primarily in
already developed areas” (DEIR p.3.1-19).

C129-4 Jake Scussel 2/30/2022 Population growth is slowing, and may very well be declining in 40 years:
https://www.ppic.org/publication/californiaspopulation/ The comment is noted. The DEIR uses an adequate
baseline; please see Master Response: Buildout and
RHNA for more information.

C129-5 Jake Scussel 2/30/2022 Small-scale wind farms should be strongly considered in/near the old quarry and Nike
missile site. Fog collection systems should also
be considered. Fresh water could be harvested
directly from the air during summer months
The comment is not related to the adequacy of the
DEIR, therefore no further response is required in the
FEIR. However, the comment addresses the content of
the Proposed Plan and will be shared with decisionmakers in that context. Please see Master Response:

EIR comments for more information about GP- or SPSPrelated responses.

C129-6 Jake Scussel 2/30/2022 Strong incentives should be implemented to move residents away from heating their
homes with wood-burning fireplaces to reduce
air pollution.

C129-7 Jake Scussel 2/30/2022 Does the city have a plan if something like a tsunami/earthquake were to make HWY 1
impassable for days/weeks on end leaving
many residents in Linda Mar and Rockaway
stranded with no way for people/goods to
easily move in/out or out of the city?
Please see Master Response 9: Emergency Access.
629
C130: Laura Sloan, 1/14/2022
Letter Commente
r Date Comment Combined Response
Individuals (C)
C130-1 Laura
Sloan
1/14/2
2 Thank you for the opportunity to provide feedback on Pacifica's general plan draft.

I'm writing to comment that I am in support of the land around Old San Pedro Mtn road at the end of Higgins to become Transitional Open Space/Residential with up to 0.1 units/acre). My home today is on Perez Dr. and I use this area regularly for hiking and occasional bicycling. I think the more this hillside land is preserved for future outdoor enjoyment and use by everyone, the better. I am not in favor of the development property proposed there. I think making Old San Pedro Road Higgins entrance an official trailhead to connect to McNee Ranch state park trails would be a welcome addition as well.

Please see Master Response:

EIR comments for more
information about GP- or SPSPrelated responses.
630
C131: Danny Estrella, 2/26/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C131-1 Danny
Estrella
2/26/22 As a resident of the Pedro Point Community, I’m writing to express my concern for the sections of the Pacifica General Plan Update (GPU) pertaining to the area referred to as the Undeveloped San Pedro Avenue Site. I will emphasize the history of this property as stated in the summary below.

Imagine a five-acre, outdoor, visitor-serving destination nestled between the Bay Area's most accessible surf break, a commercial kitchen, four restaurants, and a historic community center with a community-built playground. This is the Pedro Point Basin, the heart of our Community.

The Pedro Point Community Association (PPCA) welcomes commercial recreational opportunities such as kayak and bike rentals, for-profit community spaces and outdoor events consistent with the current land use designation and conditions on the ground.

The Proposed General Plan Update would change the land-use designation from very low density visitor-serving commercially-viable recreational uses to the development of high-density (at least 70 homes, pre-ADUs) housing on this property, despite strong opposition from the Pedro Point Community and state regulatory agencies.

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

C131-2 Danny
Estrella
2/26/22 Existing Allowed Uses:

The City of Pacifica's current Local Coastal Land Use Plan, Certified by the California Coastal Commission on March 24, 1980, describes the appropriate uses of this property, which is designed Commercial Recreation. The Basin has since been designated a likely Environmentally-Sensitive Habitat by the California Coastal Commission.
“The designated land use for this area is Commercial with emphasis on coastal related and/or visitor-serving uses... this small, oceanside commercial center could be rejuvenated and expanded to become an attractive visitor destination, as well as provide for neighborhood retail needs ""Small scale, rustic design and ample landscaping throughout the commercial development would complement the existing attractive design elements in the Pedro Point area. Adequate public access through the development to the shoreline and a general orientation to coastal related/visitor-serving uses within the project would be appropriate in ·this location. Given these criteria, commercial use of this portion of the neighborhood is consistent with the following policies of the Coastal Act: 30212 (Provision of Public Access in New Developments), 30222 (Priority of Recreational/VisitorServing Uses), 30250 (Concentration of Development)." The current field has a floor area ratio (FAR) of 0.2, to promote non-intensive recreational use of the site, retaining most of the site in open space.

The PPCA has been, and remains committed to ensuring that any new developments, and in particular, large-scale land-use changes are sustainable and consistent with State Law. The following table summarizes some of the likely Coastal Act violations inherent to the City's proposed Land Use Designation change.

The LCLUP is being updated
concurrently with this General
Plan; thus, the land uses are
consistent. Please see more
information in Master
Response 6: ESHA for more
information about how
compliance with federal, state,
and local regulations as well as
Proposed Plan policies would
reduce impacts to ESHA to less
than significant.
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C131-3 Danny
Estrella
2/26/22 Coastal Act Policy
Section 30212 New development projects – (a) Public access from the nearest public roadway to the shorelineand along the coast shall be provided in new development projects except where:
(1) [conflict] public safety, military security..protection of fragile coastal resources,
(2) [redundant shore access]
(3) [conflict] agriculture
Commercial – Recreation [CR] (current) or Low-Intensity Visitorserving Commercial (LIVC); PPCA alternative) Fully consistent; Recreational land use: physically compatible with public access from public road to shore.

Coastal Residential Mixed Use [CRMU] proposed LU Update CONSTRAINT OR CONFLICT: Mixed residential land use at 10-15 units/acre: constraint on access from public road to shore The Proposed Plan is
programmatic; a land use
designation does not represent
a project. Coastal Development
Permits are the regulatory
mechanism by which proposed
developments in the coastal
zone are brought into
compliance with the policies of
Chapter 3 of the Coastal Act.

Any project brought forth
would be required to
demonstrate compatibility
with Coastal Act policies.

C131-4 Danny
Estrella
2/26/22 Coastal Act Policy
Section 30221 Oceanfront land; protection for recreational use and Development
Oceanfront land suitable for recreational use shall be protected for recreational use and development unless present and foreseeable future demand for public or commercial recreational activities that could be accommodated on the property is already adequately provided for in the area.

Commercial – Recreation [CR] (current) or Low-Intensity Visitorserving Commercial (LIVC); PPCA alternative) Fully consistent; directly furthers purpose of section 30221.

Pedro Point Field is adjacent to Pacific Ocean, separated by historic railroad berm segment; thus “oceanfront”; fully suitable for recreational use (Outdoor beer garden or socially-distant eating opportunities, food trucks, mini-golf, Easter egg hunts, Firehouse children’s park spillover, dog walking; ball games)
Coastal Residential Mixed Use [CRMU] proposed LU Update CONFLICT: Residential development precludes recreational use and development.

Recreational opportunities in the neighborhood on alternate sites are precluded: steep hillslopes, saturated residential development.

Please see response to
comment C131-3 for more
information on project
permitting in the Coastal Zone.

As noted in DEIR p. 3.12-40,
public spaces that are
accessible to the community
are required as part of policy
OC-I-9. As noted in Proposed
Plan policy LU-I-29, the CRMU
zoning district would allow
small-scale visitor oriented
commercial uses as a standalone 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.

C131-5 Danny
Estrella
2/26/22 Coastal Act Policy
Section 30222 Private lands; priority of development purposes The use of private lands suitable for visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation shall have priority over private residential, general industrial, or general commercial development, but not over Please see response to
comment C131-3 for more
information on project
permitting in the Coastal Zone.

The land use designation
allows visitor-serving
632
Letter Commenter Date Comment Combined Response
Individuals (C)
agriculture or coastaldependent industry.

Commercial – Recreation [CR] (current) or Low-Intensity Visitorserving Commercial (LIVC); PPCA alternative) Fully consistent: visitor-serving commercial recreational facilities designed to enhance public opportunities for coastal recreation Coastal Residential Mixed Use [CRMU] proposed LU Update CONFLICT: Private residential development and general commercial development allowed to have priority over and exclude visitor-serving commercial recreational development.
commercial uses. As noted in
Proposed Plan policy LU-I-29,
the CRMU zoning district
would 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.

C131-6 Danny
Estrella
2/26/22 Coastal Act Policy
Section 30240 Environmentally sensitive habitat areas (ESHA); adjacent developments
(a) Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on those resources shall be allowed within those areas. (b) Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade those areas, and shall be compatible with the continuance of those habitat As noted in response to
comment C131-5, a wetland
survey is required to delineate
potential wetlands on the site
as part of the development
application and environmental
review process. Please also see
Master Response 6: ESHA for
more information on how
compliance with federal, state,
633
Letter Commenter Date Comment Combined Response
Individuals (C)
and
recreation areas.

Commercial – Recreation [CR] (current) or Low-Intensity Visitorserving Commercial (LIVC); PPCA alternative) Compatible: Low-intensity recreational uses may be compatible with seasonal wetlands (no fill or drainage required for dry season use) and adjacent perennial wetland swale tributary to San Pedro Creek (documented California redlegged frog habitat)
Coastal Residential Mixed Use [CRMU] proposed LU Update CONFLICT: Residential development at proposed density range would require fill and drainage of seasonal wetlands and degrade ESHA wetlands.
and local regulations and
Proposed Plan policies would
reduce potential impacts to
ESHA.

C131-7 Danny
Estrella
2/26/22 Coastal Act Policy
Section 30242. Lands suitable for agricultural use; conversion All other lands suitable for agricultural use shall not be converted to nonagricultural uses.

Commercial – Recreation [CR] (current) or Low-Intensity Visitorserving Commercial (LIVC); PPCA alternative) Compatible: historical artichoke field soils may be kept intact or converted back to coastal agriculture (U-pick berry farm model) Coastal Residential Mixed Use [CRMU] proposed LU Update CONFLICT: Residential development would require placement of pad fill (flood protection; 100-year floodplain) and drainage) precluding agriculture physically and by land use conflict
This use is not used at present
for farmland, nor is it
designated Farmland under the
Farmland Mapping and
Monitoring Program.

Conversion would not occur.

C131-8 Danny
Estrella
2/26/22 Coastal Act Policy
Section 30251 Scenic and visual qualities
The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance.

Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding areas…
Commercial – Recreation [CR] (current) or Low-Intensity Visitorserving Commercial (LIVC); PPCA alternative) Compatible: Low-intensity or open space recreational development protects scenic ocean views.

Coastal Residential Mixed Use [CRMU] proposed LU Update CONFLICT: Residential development would infill the last open space in coastal lowlands from Linda Mar to Pedro Point.

Please see response to
comment C131-3 for more
information on project
permitting in the Coastal Zone;
projects would be required to
demonstrate compliance with
Coastal Act policies.

C131-9 Danny
Estrella
2/26/22 Coastal Act Policy
Section 30253 Minimization of adverse impacts
New development shall do all of the following:
(a) Minimize risks to life and property in areas of high geologic, flood, and fire hazard.
(b) Assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area or in any way require the construction of protective devices that would substantially alter natural landforms Please see response to
comment C131-3 for more
information on project
permitting in the Coastal Zone;
comments about armoring are
inaccurate and speculative.

Projects would be required to
demonstrate compliance with
Coastal Act policies. Policy LU-
634
Letter Commenter Date Comment Combined Response
Individuals (C)
along bluffs and cliffs. […]
Commercial – Recreation [CR] (current) or Low-Intensity Visitorserving Commercial (LIVC); PPCA alternative) Compatible: Coastal Residential Mixed Use [CRMU] proposed LU Update
CONFLICT. Most of field lies approximately 15-17 feet in elevation above Mean Sea Level (MSL), only about 3-5 feet above the marsh and high tide beach at the mouth of San Pedro Creek. Residential development requires flood protection and drainage.

Wave runup to the field depends on the non-engineered privately owned berm which is not maintained by Pacifica. Residential development would require armored flood protection structures as sea level rises.

Alluvial soils (historical wetland) of the field have the same relative liquefaction (earthquake shaking) potential as diked bay muds and marshes in San Francisco Bay
I-29 requires an assessment of
geotechnical hazards as part of
the development application
and environmental review
process.

C131-10 Danny
Estrella
2/26/22 Coastal Act Policy
Section 30255 Priority of coastal dependent developments Coastal-dependent developments shall have priority over other developmentson or near the shoreline.

Except as provided elsewhere in this division, coastal-dependent developments shall not be sited in a wetland. When appropriate, coastalrelated developments should be accommodated within reasonable proximity to the coastal-dependent uses they support.

Commercial – Recreation [CR] (current) or Low-Intensity Visitorserving Commercial (LIVC); PPCA alternative) Fully consistent. Coastal visitor-serving recreational uses do not require fill or drainage of wetlands in field directly landward of the ocean shoreline.

Coastal Residential Mixed Use [CRMU] proposed LU Update FULL CONFLICT. Residential development is not coastal-dependent, and would infill the seasonal wetlands in the lowland floodplain of the field.

Please see response to
comment C131-4.

C131-11 Danny
Estrella
2/26/22 The Pedro Point Community has a vision, compatible with existing land uses, for this critical parcel as a bridge between Pacifica State Beach, the Bay Area's only accessible beginner's surf break, the Pedro Point Headlands, and the Coastal Trail. The Pedro Point basin can be a vibrant community corridor connecting emerging recreational commercial tourism and job opportunities that make use of existing environmental assets, and do not require extensive non-permeable paved areas and roofed buildings. Examples of existing opportunities which align with Pacifica's economic and the region's commercial and recreational commercial needs and the environment include SparkSocialSF, Half Moon Bay Kayak Company, an outdoor familyfriendly party destination, a bicycle rental and repair shop, and Beach Break Entertainment. Any changes to land-use designations must take into account the present geologic and biological realities of this parcel.

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

C131-12 Danny
Estrella
2/26/22 A History of Neighborhood Comments Pertaining to Zoning Changes and Development in the Pedro Point Field
The background information is
noted. The comment is not
635
Letter Commenter Date Comment Combined Response
Individuals (C)
Historically, the Pedro Point Field has been a wetlands owned by the Archdiocese of San Francisco, which was leased out for recreational uses such as a golf driving range. These uses are compatible with the seasonal flooding inherent in a coastal wetlands.

In 1996 and 1997 this property was acquired in three private transactions by "Calson Ronald W", "Calson Ronald W & Sheryl W", and "Calson Ronald W & Sheryl W Trs." for $550,000, total. (Ron Calson of RC & Associates in Millbrae has represented the Archdiocese of San Francisco in past real estate transactions.) The designated land use at the time of the acquisition was--and remains--Commercial Recreation.

Subsequent, persistent unauthorized diking, dumping, and infill events have eroded the native plant species and habitat in this designated Environmentally Sensitive Habitat Area, but opportunities for restoration abound, consistent with State law, which requires cities to identify natural infrastructure that may be used for adaptation projects including the restoration of wetlands and coastal floodplains "Upzoning" this key parcel without adequate environmental review will severely impact the quality of life and coastal access rights of Pacifica's citizens and visitors to the Coast, while endangering future homeowners who are unwittingly purchasing new homes built on a FEMA-Designated flood plain and historical wetlands temporary protected by coastal armament built for the short-lived Ocean Shore Railroad.

Excerpt of U.S. Coast Survey map of San Francisco Peninsula, 1869, based on 1850s topography: San Pedro Creek Valley and beach, now Linda Mar. Approximate location of Field in red.

Parallel horizontal hatched lines indicate freshwater marsh. Stippled shoreline area indicates sandy beach, dune, washover. Fine horizontal hatching is open freshwater (Lake Mathilda; historical Pedro Creek Lagoon, drained for agriculture 19th century). Irregular circles/dots within marsh = wooded freshwater swamp (alder, willow). 1995 Community Plan "…Pedro Point residents have registered strong support for preserving a major portion of the Archdiocese property in some form of open space. It would be a major setback to the entire Pedro Point community if any development calling for intensive coverage of the land with buildings and pavement were to take place without a generous reservation of land for open space use. The community would look with favor on an adequate provision for open space and a compatible mix of visitor-serving uses appropriate to the Point’s oceanside setting."
2011 Letter in Opposition to the Proposed Land Use Designation Change The Pedro Point Community Association rejected the Draft GPU's proposed Land Use Designation change, and recommended that it adopt "Commercial-Recreational," the designation most similar to the existing land use. The PPCA also supported a change in the land use designation to Open Space.
2012 Letter in Support of Commercial-Recreational Uses: In 2012, the PPCA again, after extensive discussions which included inviting the current-land owners to the PPCA board, voted for the field remain in its current zoning of Commercial- Recreational. The proposed 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 SPSPrelated responses.
636
Letter Commenter Date Comment Combined Response
Individuals (C)
Commercial Recreation designation in the current Draft General Plan is intended for land use that would remain in a primarily undeveloped state but would allow for limited commercial establishments supporting recreational uses in keeping with the enjoyment of the beach and community character.

C131-13 Danny
Estrella
2/26/22 2014 DOCUMENTS: In 2014, the PPCA unanimously voted to pool their resources to hire experts and an attorney citing deficiencies in City's General Plan Update and draft Environmental Impact Report (DEIR).

The Proposed Land Use change did not pass, and the approved Land Use Designation remained Commercial Recreation. The following documents have been submitted to the City and are part of the comments on the GPU.
• PPCA Comment Letter Summarizes the PPCA's official position • Brian Gaffney The DEIR fails to comply with the California Environmental Quality Act. Errors found by the PPCA's witnesses are materially tied to the legal adequacy of the plan.
• Grassetti Environmental Consulting (GECO) The general plan land use designations are the heart of the plan; once a site is designated, applicants have certain development rights. Therefore, it is essential that the City fully consider site values and constraints prior to redesignating sites, not after the site is re-designated. This GPU fails to do that, and the EIR fails to adequately or accurately assess impacts of the proposed redesignation of the Pedro Point Field site. • Peter R. Baye, Ph.D., Coastal Ecologist, Botanist: The Draft Environmental Impact Report fails to recognize the parcels as an Environmentally Sensitive habitat for Endangered Species.

Comments do not apply to the
most recent EIR submittal and
pertain to the 2014 DEIR. As
such, these are not addressed.

C131-14 Danny
Estrella
2/26/22 In 2019, the PPCA formally requested a Neighborhood-Specific Study to consider the robust community input and evidence presented thusfar. This request was denied.

The proposed GPU disregards the facts of the history and community concern for this land. For the sake of completing the GPU so the City of Pacifica can move forward with intelligent development the GPU should be revised to reflect the comments presented here.

This comment is noted. The
comment does not relate to
the adequacy of the DEIR, thus
no further response is
required.
637
C132: Kathy Castor, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C132-1 Kathy Castor 3/9/2
2 I am writing to you to express my distress, dismay, disgust and whole-heart objection to the general plan update that would change the Pedro Point field from commercial recreation to COASTAL RESIDENTIAL MIXED USE???!!! What in the world? Must we completely destroy Pedro Point?
As I mentioned earlier, I have lived on Pedro Point for 27 years.

Not once in these 27 years, has the building of homes ceased on Pedro Point. The single family residences just march up the hill.

And recently, numerous multi-family and mixed-use projects have been approved and are being built. Every tiny piece of land - even designated PAPER STREETS are being approved for construction.

Pedro Point used to be a nice SINGLE FAMILY RESIDENTIAL NEIGHBORHOOD.

I understand the City needs to generate income, but for crying out loud...must it all come from never ending building permits? You state that the proposed land use change would "not create significant visual impact"....REALLY? I live far enough up the hill to have full view of this parcel of land and enjoy that sight. The thought of another black, 2-story mixed use building box with limited parking (which is another HUGE issue on PP) makes me physically ill. Not to mention the amount of traffic this will generate. Have you visited Pedro Point on the weekends? If not, come have a look at the weekend parking issues.

The kids have an Easter egg hunt every year in the field.

Numerous dogs love to frolic in the field. Gobs of us residents walk the field. Most of the residents I walk this field with moved to Pacifica, like me, for the "small town" feel. There are a number of birds and wildlife that occupy the field that will be greatly impacted.

What about the strain on San Pedro Avenue? What about the strain on sewer and water issues? What about all their lights, glare, etc. affecting the evening darkness we all now enjoy? I firmly believe this project (changing the land use designation) is going to negatively affect the entire Point.

For all of these reasons and a million more that I will not get into right now, changing the land use to residential mixed use for this parcel, is the worst decision the city could make. It needs to stay low intensity commercial - high density residential.

Please see Master Response 1:

EIR Comments for more
information about GP- or SPSPrelated responses.

This DEIR is a programmatic
document and analyzes
potential impacts citywide, not
for individual projects; please
see Master Response 2:

Programmatic EIR for more
information. Please see Master
Response 6: ESHA for more
information on sensitive
species; response to comment
C9-2 for sewer and water
impacts; and response to
comment C27-3 for glare.

Please see also Master
Response 4: Undeveloped San
Pedro Ave Sites for more
information on how the land
use designation and zoning will
influence development on the
site.
638
C133: John Keener, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C133-1 John Keener 3/7/22 Page 6-33 Insert Pacifica Gardens paragraph below Pacifica Resource
Center Proposed addition: Pacifica
Gardens, located behind the Linda Mar
School, donates over 3,000 pounds of
the produce it raises to the Pacifica
Resource Center for distribution to
needy families.

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

C133-2 John Keener 3/7/22 Page 7-3 Figure 7-1: Hydrology Proposed change:

A tributary to San Pedro Creek is
incorrectly labeled as Brooks Creek. This
tributary is Sanchez Fork. Brooks Creek
is the small tributary to the South Fork
San Pedro Creek, and the location of
Brooks Creek Falls in San Pedro Valley
Park. This error originated with Google
maps and they have so far been
unwilling to fix it. Please don't
compound their error!
This comment is noted. The following edit has been made for clarity:

DEIR p. 3.5-4: "San Pedro Creek watershed is the largest of the surface water channels within the City of Pacifica, draining approximately 5,300 acres west to the Pacific Ocean in the area to the north of Devil’s Point. The watershed extends north to Sweeney Ridge, east to Spring Valley Ridge, and south into the slopes of Montara Mountain. San Pedro Creek has four main tributaries extending well past the City’s eastern and southern boundaries. The tributaries are: South Fork, Middle Fork, North Fork, and Brooks Creek Sanchez Fork."
DEIR p. 3.7-56: "Other creeks within the Planning Area are Rockaway Creek, San Pedro Creek, Brooks Creek Sanchez
Fork , and Middle Fork San Pedro Creek. Rockaway Creek and San Pedro Creek are both nearby two of the key sites;
Rockaway Creek is just south of the Rockaway Quarry Site and San Pedro Creek is very close to the San Pedro Site.

Brooks Creek Sanchez Fork and Middle Fork San Pedro Creek are both located in the southern end of the Planning Area, and are fairly removed from the key sites."
DEIR p. 3.7-61: "Several wildlife movement corridors exist within the Planning Area, which include creeks, specifically designated corridors, ridgelines, and valleys. Sanchez Creek exists within the Sharp Park Golf Course and Calera Creek exists within the Rockaway Quarry Site. Rockaway Creek is located south of the Quarry site and San Pedro Creek is located very close to, but just north of the undeveloped San Pedro site. Other creeks within the larger Planning Area are Brooks Creek Sanchez Fork and Middle Fork San Pedro Creek.

Riparian corridors are used in particular by steelhead, California red-legged frog, and San Francisco garter snake.

Steelhead is known to occur along San Pedro Creek, and the entire portion of this creek within the Planning Area is designated as critical steelhead habitat. California red-legged frog and San Francisco garter snake are known to occur in and along lower Calera Creek which runs through the Quarry site. Both Milagra and Sweeney Ridges are considered
corridors for wildlife as they are large areas of open space that animals can use for movement. In the middle of these two ridgelines exists another important wildlife corridor which has been identified as a migration corridor for the 639
Mission blue butterfly."
These are minor corrections made to clarify and do not affect the findings of the DEIR.

C133-3 John Keener 3/7/22 Page 7-4 San Pedro Creek San Pedro Creek has several tributaries extending
past the City boundaries. These
tributaries include the South Fork,
Middle Fork, North Fork, and
Brooks/Sanchez Creek. Proposed
change: San Pedro Creek has several
tributaries, some of which extend past
the City boundaries. The tributaries
include the South Fork, Middle Fork,
North Fork, Sanchez Fork, and Brooks
Creek. Proposed inserted sentence after
"Wetlands along San Pedro Creek
provide habitat for the threatened
California red-legged frog.": Recently,
the northern tidewater goby, a small
federally-listed endangered fish, was
detected near the mouth of of San
Pedro Creek. [[Reference: Michael
Sutter & Andrew P. Kinziger, Rangewide
tidewater goby occupancy survey using
environmental DNA. Conservation
Genetics (2019) 20:597-613. see page
608]]
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C133-4 John Keener 3/7/22 Alterations from urban development have resulted in a deep channel with
steep banks.

Proposed change: Alterations from
historical agriculture and more recent
urban development have resulted in a
deep channel with steep banks.

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

C133-5 John Keener 3/7/22 7-6 Stormwater This drainage system acts to convey drainage to area creeks
or the ocean. Two areas in the City,
Linda Mar and lower Sharp Park, are too
low to allow drainage to a creek or the
ocean, and are served by pump stations
to prevent street flooding. Proposed
changes: This drainage system acts to
convey stormwater and other drainage
via storm drain pipes to area creeks or
the ocean. San Pedro Creek acts as a
conduit for stormwater from storm
drains to the ocean. Two areas in the
City, lower Linda Mar and lower Sharp
Park, are too low to allow drainage to a
creek or the ocean, and are served by
pump stations to prevent street
flooding.

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

C133-6 John Keener 3/7/22 7-11 CO-I-3 Funding for Creek Maintenance.

Establish funding mechanism to require
property owners with land adjacent to
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

However, the comment addresses the content of the
Proposed Plan and will be shared with decision-makers in 640
creeks to pay proportionate share of
creek improvement maintenance.

Comment: Given that stormwater from
all of the San Pedro Creek watershed
washes through the creek, it seems
inappropriate to require creekside
residents to pay for the creek's
maintenance. At present, maintenance
of the creek by the city primarily
consists of a yearly trek up the creek for
removal of trunks and large branches.
that context. Please see Master Response: EIR comments for more information about GP- or SPSP-related responses.
641
C134: Breck Hitz, 3/6/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C134-1 Breck Hitz 3/6/22 My wife and I have lived on Pedro Point for more than 30 years.

We’ve raised two kids here, and made many good and lasting friendships with our neighbors. I am writing you today to state my objection to the General Plan Update (GPU) and Draft Environmental Impact Report (DEIR)’s proposed land use
designation change of the undeveloped San Pedro Avenue site in Pedro Point (i.e., the Pedro Point field) from “Commercial Recreation” (CR) to a new “Coastal Residential Mixed Use” (CRMU) designation.

Such a designation change would have a detrimental effect on the congestion and safety on the Point, especially on lower San Pedro Avenue. I’m sure you’re aware of the congestion that occurs now on a sunny weekend day: there are surfers, kids, dogs, skateboards, baby carriages, and cars wandering around looking for a parking place. Everybody is intent on whatever he’s doing, and it’s not at all unusual for surfers, kids, dogs, baby carriages, etc, to suddenly wander into the street despite approaching traffic.

The addition of dozens and dozens of housing units in the Pedro Point field would elevate this problem a sunny-weekend-day issue to an everyday problem, and exacerbate the sunnyweekend issue even further. I emphasize that this is an issue of public safety – perhaps life-or-death safety – and I hope it will be taken into account in any decision regarding the future of the Pedro Point field.

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.
642
C135: Christine Boles, 2/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C135-1 Christine
Boles
2/11/22 I have spent a LOT of time over the past year researching the subject of safety in Pacifica, both in the hills with landslides and fires, and on the coast with coastal
erosion and sea level rise. I spent days reviewing and
commenting on Pacifica’s Local Hazard Mitigation Plan
this year, only to be told after the fact that that this work was not needed, and that Pacifica’s hazards will be
properly addressed very soon with the release of the
updated General Plan Safety Element.

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

C135-2 Christine
Boles
2/11/22 I spent the majority of this weekend reviewing the Safety Element, and honestly, I am appalled. Besides the
landslide and coastal erosion errors I have already
brought to your attention, the fire map only considers
risks to property in the county (State Responsibility
Area); there is no data at all for the entire area in City of Pacifica in the city limits.

The commenter's assertion that there is no
data for the City of Pacifica is incorrect and
mischaracterizes available CALFIRE maps for
Very High Fire Hazard Severity Zones.

The DEIR characterizes wildfire hazards
within the Planning Area on pages 3.11-4
through 3.11-6 and 3.14-1 through 3.14-4,
making use of data and information from
CALFIRE and from the Multi-Jurisdictional
Local Hazard Mitigation Plan (MJ-LHMP) for
San Mateo County. The characterization in
the DEIR includes a description of vegetation
in the Planning Area, a history of wildfire
occurrence in the Planning Area, the
probability of a fire occurring in the future,
and identification of Fire Hazard Severity
Zones designated by CALFIRE based on
factors such as fuel, slope, and weather. Two
maps are included:

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

Fire Threat is not a risk assessment by itself,
643
but can be used to assess the potential for
impacts on various assets and values
susceptible to fire. Impacts are more likely
to occur and/or be of increased severity for
the higher threat classes. Please see Master
Response 5: Wildfire for more information.

Analysis in the 2021 MJ-LHMP and the safety
element of the Proposed Project identifies
areas of the city that have constrained
emergency access. Reliance on Highway 1 as
a north-south connection causes challenges
for timely fire response, and the Vallemar,
West and East Fairway Park, Rockaway
Beach, and Rockaway neighborhoods in
central Pacifica are beyond four-minute
travel distance from northern San Mateo
County fire stations, meaning that a new
station would be needed if the central part
of Pacifica were to experience substantial
new development.

Potential improvements to the roadway
network could contribute to mitigating the
impacts of additional traffic on emergency
response times. Furthermore, traffic signal
preemption devices on emergency vehicles,
as well as emergency sirens, will improve
emergency response times ven in instances
of intersection congestion during peak
commute periods. The Proposed Project
provides for improved emergency access
through policies that promote mobility
connections between communities; provide
additional access routes; require new streets
and developments meet adopted
emergency access standards; and ensure
adequate fire, police, and emergency service
in line with any new development, including
in Central Pacifica where service times do
not currently meet NCFA’s standards, and in
areas that have less than two evacuation
routes north of the VHFHSZ (Proposed
General Plan Implementing Policy SA-I-104)
Future development would be required to
adhere to all policies, goals, and standards in
the MJ-LHMP, Pacifica Municipal Code, and
CBC, including vehicular access and
emergency access. Implementation of the
following Proposed Project policies will
ensure that inadequate emergency access
does not occur, and will result in a less than
significant impact
C135-3 Christine
Boles
2/11/22 The Introduction section of the General Plan talks about the importance of Horizontal Consistency within General Plan documents on page 1-5. I’ve copied the text below. (screenshot in letter) Horizontal Consistency between
General Plan documents is a legal term and a basic
requirement, along Vertical Consistency with other city This comment is related to the General Plan.

In the DEIR, the map shows areas of where
critical coastal erosion may occur. The
comment is not related to the adequacy of
the DEIR, therefore no further response is
required in the FEIR. However, the comment
644
documents like our zoning ordinances. I’m copying the
City Attorney here because I am afraid that this poorly written document could actually put the City in legal
jeopardy if adopted as written.

To be specific, here is one glaring example of horizontal inconsistency. Page 8-9 of the Safety Element talks about coastal bluff erosion and discusses the apartment
buildings on the 300 block of Palmetto that were lost
and had to be demolished in 2016. The Map of Slope
Failure and Coastal in Figure 8-3, which was definitely updated since the 2014 version as it now includes riprap locations, still shows these bluffs as “Not Landslide
Prone”.

There are no other maps in the Safety Element for
coastal erosion or sea level rise, which obviously are an immediate and long-term issue of our city.
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.

C135-4 Christine
Boles
2/11/22 SB 379 also requires cities to update their Safety Elements by January 2022 for climate change adaptation. “This bill would, upon the next revision of a local hazard mitigation plan on or after January 1, 2017, or, if the local jurisdiction has not adopted a local hazard
mitigation plan, beginning on or before January 1, 2022, require the safety element to be reviewed and updated
as necessary to address climate adaptation and resiliency strategies applicable to that city or county. The bill would require the update to include a set of goals, policies, and objectives based on a vulnerability assessment,
identifying the risks that climate change poses to the
local jurisdiction and the geographic areas at risk from climate change impacts, and specified information from
federal, state, regional, and local agencies.”
There is very vague information about coastal
vulnerabilities in section 8-3 which I will comment on in detail later, but I want to point out that the
requirements of SB379 are for the entire city, not just the coastal zone. So much is missing from this draft
document.

The comment is noted. Climate change and
requirements for SB379 are included in the
MJ-LHMP, incorporated by reference into
the Pacifica GP. Please see response to
comment C13-30 for more information on
the vulnerability assessment and adaptation
plan conducted as part of the LCLUP process.

As the comment does not address the
adequacy of the environmental analysis
contained in the DEIR, no further response is
required.

C135-5 Christine
Boles
2/15/22 I am disappointed, because I have reached out to planning staff and the City Manager on numerous
occasions over the past 16 months offering my
assistance with the General Plan update and other
planning issues. Were any public meetings ever held
related to the Safety Element? Even if they were held in 2009, with climate change, these factors are now
completely different. We have the resources here with
coastal and geotechnical engineers, scientists and other professionals like me who would gladly donate time to
improve this document. There is a wealth of knowledge
and experience on the Planning Commission. Were they
asked to review this document before its release?
By the City Manager choosing to save staff time and not involve the public in this update, I fear we are now on a much more expensive, confrontational, and lengthy
Please see DEIR p. 1-2 for more information
about the General Plan public engagement
process.
645
path. I hope that is not the case and that you will be
willing to reconsider the process to allow real dialogue. I and many others are ready and willing to volunteer our
time to work with you all for a proper General Plan
update that will be able to safely guide Pacifica through the next 20 years.
646
C136: Nick Lusson, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C136-1 Nick Lusson
Protect San
Pedro
Mountain
Operations
Team
3/8/22 As you well know, our organization's primary efforts center on the protection of our environmental health and community safety as we work towards the preservation of the cherished undeveloped lands along our southern border of San Pedro Mountain. The outcome of this General Plan will clearly play a significant role in those efforts, but we also understand that our work extends beyond it. We're a small operations team of passionate Pacifican residents, but with a very large following both here and from neighboring communities and regions. Our ability to properly and professionally review the Draft General Plan and the Draft Environmental Impact Report are limited. We acknowledge our limitations and are still in the process of engaging with all resources at our disposal to best ascertain our position on the plan and respond accordingly.

C136-2 Nick Lusson
Protect San
Pedro
Mountain
Operations
Team
3/8/22 One area that does stand out to us for concern is the inclusion of sufficient hazard information for areas that are deemed in the highest tiers of fire risk by state agencies. This leaves ambiguities as to what and how much development is allowed. In this era of severe climate change, California has had to learn some tragic lessons about the risks of building & development into these areas. From what we've seen so far, this plan could use more work and detail to fill in the gaps of areas on the map that are known to be severe fire risk zones. We would hope that this type of additional hazard overlay would also further prohibit development of these vulnerable areas.

Impacts related to wildfires are
adequately addressed in
chapters 3.11 and 3.14. Please
see Master Response: Wildfire
for more information on the
adequacy of mapping and
policies the reduce impacts to
the maximum extent
practicable.

C136-3 Nick Lusson
Protect San
Pedro
Mountain
Operations
Team
3/8/22 To summarize, we're writing to inform you that we will be turning in more detailed comments on the Draft General Plan and EIR in a timely manner, but they will be late from the deadline of March 8 as we work towards ensuring that this feedback is constructive and effective. We also would like to review the feedback provided by other regional and state agencies that we believe may be providing official comment on the drafts, as our preference is to be wellresearched via objective sources before offering further feedback or opinion.

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.
647
C137: Clifford Lawrence, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C137-1 Clifford
Lawrence
3/8/22 a. What happens when Sea Level
Rise accelerates?
i. Where is the analysis of what
happens when the seawall
infrastructure fails before it is
relocated?
ii. Where is the analysis of the
flood potential on Sharp Park
area and Linda Mar?
As noted in the DEIR p. 3.5-11, "The Vulnerability Assessment mapped seven coastal sub-areas at increased risk of coastal inundation using the OCOF and Pacific Institute Study maps. The subareas were used to facilitate
more focused development of adaptation strategies and policies. The subareas identified as vulnerable to increased coastal flooding are:

Fairmont West, West Edgemar, Pacific Manor, Northwest Sharp Park, Sharp Park/West Fairway Park/Mori Point (these areas were combined because the entire stretch of shoreline is publicly owned and fully government owned shoreline may have different policy or funding considerations), Rockaway Beach/Quarry/Headlands, Pacifica State Beach, West Linda Mar, and Pedro Point/Shelter Cove." Linda Mar and the coastline of Sharp Park are also identified as areas that experience flooding, as shown in Figure 3.7-1. Please see response to comment 13-3 for more information on sea level rise analysis and regulations and policies that reduce the impact, as well as policies in the LCLUP regarding sea level rise monitoring.

C137-2 Clifford
Lawrence
3/8/22 b. What happens when cliff
erosion accelerates?
i. How will it be “managed”?
ii. What will happen at 400
Esplanade?
iii. What will happen at 200-240
Palmetto Ave?
iv. What happens when erosion
at the Palmetto South Canyon
severs Palmetto Ave?

1. Where is the analysis for the
impact on West Fairmont
residents if there is no Palmetto
access to Manor District?

2. What will be the impact on
emergency services to that area?
Please see response to comment C69-8 for more information on erosion hazards and policies that reduce impacts that could occur as result of implementing the Proposed Plan to less than significant.

As noted on DEIR p. 3.6-21, the MJ-LHMP concludes that
landslide/mass movements, which includes traditional landslides as well as coastal erosion, and earthquakes, with the potential to cause ground shaking, liquefaction, and landslides, are Pacifica’s two highest priorities for the mitigation of geologic and seismic hazards.

All goals and policies in the adopted MJ-LHMP are applicable to the Proposed Project, including those that concern geologic hazards. The MJ-LHMP include several actions that address erosion and landslide concerns, including update of the Emergency Operations Plan, pursue opportunities to preserve and protect critical transportation infrastructure (including Beach Blvd.), and seek to replace/upgrade its seismically-vulnerable facilities to ensure provision of vital services following a hazard. Policies related to emergency services in instances of erosion hazards include SA-I-114, Critical Facilities Location, which avoids locating structures necessary for protection of the public’s health and safety, public assembly, or emergency services in hazardous areas unless no reasonable alternative exists.

C137-3 Clifford
Lawrence
3/8/22 c. What happens if it is
discovered the Mussel Rock
Landfill has leached into West
Fairmont?
The Mussel Rock Transfer Station is located outside of the City's jurisdiction. As described on DEIR p. 3.11-17, the use of these hazardous materials is controlled and permitted by San Mateo County’s Toxic Programs and regulations, and otherwise ensures that risks associated with the use of hazardous materials in the community are minimized.

C137-4 Clifford
Lawrence
3/8/22 d. What happens if retreat is
unmanaged?
Policies within the LCLUP related to effects of climate change and sea level rise are addressed in the LCLUP. See response to comment C13- 3 for more information about coastal flooding and sea level rise.

C137-5 Clifford
Lawrence
3/8/22 e. Where is the analysis for a full
buildout in Pacifica?
Please see Master Response: Buildout and RHNA for more
information on the adequacy of buildout.

C137-6 Clifford
Lawrence
3/8/22 f. Where is the analysis of what
is actually “affordable” in
Pacifica?
Affordability is not a required topic of analysis under CEQA. As this comment doesn't relate to the adequacy of analysis, no further response is required. However, the comment addresses the content 648
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.

C137-7 Clifford
Lawrence
3/8/22 g. Where is the analysis of
economic sustainability in
Pacifica?
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.

C137-8 Clifford
Lawrence
3/8/22 a. What is the plan i. If the water
treatment plant is
compromised?
See response to comment C9-26.

C137-9 Clifford
Lawrence
3/8/22 a. What is the plan ii. If public
utilities are hijacked by internet
hackers?
This comment is not related to a required topic of analysis under CEQA. Thus, no further response is required.

C137-10 Clifford
Lawrence
3/8/22 a. What is the plan iii. What is
the plan for the inevitable quake
on Pacifica’s San Andreas Fault?
The comment is noted. Please see Impact 3.6-1, which describes how any potential seismic hazards as a result of a San Andreas Fault earthquake would be reduced to less than significant.

C137-11 Clifford
Lawrence
3/8/22 a. What is the plan iv. If Pacifica
cannot meet its RHNA quotas?
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.

C137-12 Clifford
Lawrence
3/8/22 b. What are the options …
i. To evacuate residents of
Vallemar area if needed?
An overarching programmatic framework addresses emergency access through local and regional regulations and proposed General Plan policies, in addition to policies related to evacuation planning at the project level. Given the existing framework 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.

Please see Master Response: Evacuation for more information.

Evacuation routes are addressed in Impacts 3.2-4 and 3.11-1. As noted in Impact 3.2-4, project-level review by the City includes site access review for emergency vehicle sand traffic control plans as needed that account for emergency vehicles. Potential
improvements to the roadway network (policies described on DEIR p.

3.2-46), traffic signal preemption devices, additional access routes (CI-I-26, SA-I-94, SA-I-103, SA-I-104), community evacuation education (SA-I-35), and agency coordination (SA-I-102) and ensure inadequate emergency access does not occur. The impact remains less than significant.

C137-13 Clifford
Lawrence
3/8/22 c. What is the plan if developers
continue to bring high-end
residential proposals?
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.

C137-14 Clifford
Lawrence
3/8/22 a. To Open Space?
i. Where is the commitment of
1980 Pacifica to promote
alliances with non-profit
conservancies such as Peninsula
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.
649
Open Space Trust, Golden Gate
National Recreation Area?
C137-15 Clifford
Lawrence
3/8/22 b. To Pacifica’s iconic Hillsides
and Ridgelines?
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.

C137-16 Clifford
Lawrence
3/8/22 c. To housing that Pacificans can
afford?
i. Pacifica teachers, police, fire,
store clerks, restaurant workers?
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.

C137-17 Clifford
Lawrence
3/8/22 d. Where is the commitment to
the homeless?
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.

C137-18 Clifford
Lawrence
3/8/22 e. Where is the commitment to
preparing for elevated fire risk in
Climate Change?
Impacts related to wildfires are adequately addressed in chapters

3.11 and 3.14. Please see Master Response: Wildfire for more information on the adequacy of mapping and policies the reduce impacts to the maximum extent practicable. Elevated wildfire risk due to climate change is addressed in the MJ-LHMP, incorporated by reference in the General Plan. DEIR p. 3.4-7 also describes increased fire risk due to climate change.

C137-19 Clifford
Lawrence
3/8/22 f. Where is the commitment to
emergency preparedness?
Evacuation routes are addressed in Impacts 3.2-4 and 3.11-1. As noted in Impact 3.2-4, project-level review by the City includes site access review for emergency vehicle sand traffic control plans as needed that account for emergency vehicles. Potential
improvements to the roadway network (policies described on DEIR p.

3.2-46), traffic signal preemption devices, additional access routes (Ci-I-26, SA-I-94, SA-I-103, SA-I-104), community evacuation education (SA-I-35), and agency coordination (SA-I-102) and ensure inadequate emergency access does not occur. The impact remains less than significant.

An overarching programmatic framework addresses emergency access through local and regional regulations and proposed General Plan policies, in addition to policies related to evacuation planning at the project level. Given the existing framework 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.

Please see Master Response: Evacuation for more information.

C137-20 Clifford
Lawrence
3/8/22 g. Where is the commitment to
full cooperation with the
California Coastal Commission?
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.

C137-21 Clifford
Lawrence
3/8/22 h. Where is the commitment to
historical preservation?
i. Native communities
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 650
comments for more information about GP- or SPSP-related responses.

C137-22 Clifford
Lawrence
3/8/22 h. Where is the commitment to
historical preservation?
ii. Ocean Shore Railroad
iii. Early highways into and
through today’s Pacifica
The comment is noted. The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

C137-23 Clifford
Lawrence
3/8/22 i. Where is the commitment to
preservation of wetlands?
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.

C137-24 Clifford
Lawrence
3/8/22 j. Where is the commitment to
wildlife preservation?
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.

C137-25 Clifford
Lawrence
3/8/22 k. Where is the commitment to
public engagement?
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 Proposed Plan engagement process 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.

C137-26 Clifford
Lawrence
3/8/22 l. Where is the commitment to
cleaning up our beaches and
water?
The comment is noted. The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

However, the comment addresses the content of the Proposed Project and will be shared with decision-makers in that context.

Please see Master Response: EIR comments for more information about GP- or SPSP-related responses.
651
C138: Andrew, 2/21/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C138-1 Andrew 2/21/22 I am writing you as a homeowner in the Ebken Street Neighborhood of Rockaway Beach. I request an adjustment to the Pacifica General Plan to better serve its stated Guiding Policy.

Request: Update the Plan to show Cattle Hill classified as “Prominent Ridgeline” fully to the HPD boundary. This area is currently shown as Hillside Preservation District with a partial prominent ridgeline. Small revision to Figure 4-4, Figure 3-3, and see excerpts below.

Designating prominent ridgeline to the HPD boundary better aligns with the General Plan:

1. “The General Plan envisions the Rockaway Beach district growing into a more distinct and highprofile visitor destination, with strong links to the natural setting of beaches, headlands, and ridges.” [page 4- 22, emphasis added] 2. “Coastal views from Highway 1 toward Mori Point, Cattle Hill, and the Rockaway Headlands are important in establishing the identity of this area and Pacifica as a whole.” [page 4- 22, emphasis added]

3. Guiding Policy
a. “CD-G-3 Neighborhood Conservation. Preserve the unique qualities of each of Pacifica’s residential neighborhoods.”
b. “CD-G-5 Hillsides and Prominent Ridge-lines. Maintain development standards that ensure that new development does not detract from the visual qualities of Pacifica’s hillsides and visually prominent ridgelines.”
c. “CD-G-6 Scenic and Visual Amenities of the Coastal Zone. Protect the City’s irreplaceable scenic and visual amenities in the Coastal Zone by protecting landforms, vegetation, special communities, and important viewsheds.”
d. “CD-I-12 Protection of Ridgelines. Protect visually prominent ridgelines from residential land commercial development.” e. “CD-I-15 Minimize Impacts of Coastal Development on Landforms.

Ensure that negative visual impacts resulting from new development in the Coastal Zone are minimized. In areas characterized by bluffs and landforms. Strategies to implement this policy include:

Prohibiting development on slopes in excess of 35 percent and highly visible tops of prominent landforms;” [emphasis added]

4. “This dramatic terrain [Hillsides and Ridges] is a defining feature of the city” [page 3-2]

5. “The General Plan supports continued investment in existing neighborhoods and development of a greater variety of housing types, while ensuring that new development is compatible in scale and density and respectful of neighbors.” [page 3-6]

6. “The key issues for hillside development are slope stability, grading, and visual impact.

Prominent ridgelines are identified based on their visual importance or scenic quality.” [page 3-10]

7. “Ensure that development of highly sensitive slopes does not endanger the public” [page 4-13] ;

8. “Ensure that development of highly sensitive slopes does not … harm the environmental or scenic values of the site” [page 4-13]; This steep sloped area encompasses defining ridgelines for the signature topography of this coastal area. This hill is a gateway to recreation for both visitors and residents, including daily regular trail 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 GPor SPSP-related
responses.
652
Letter Commenter Date Comment Combined Response
Individuals (C)
use by bicycles and pedestrians. From personal observation, this ridgeline is home to wild bobcat, hawks (and other birds of prey) riding coastal thermals to “hover” and hunt, and other wildlife. This small adjustment to the plan will positively impact the development of land use and will protect our community’s character and natural coastal appeal for years to come. Thank you for your support and leadership, Andrew, Ebken Street, Rockaway Beach, Pacifica, [email protected] 653
C139: Christine Boles, 12/17/21
Letter Commenter Date Comment Combined Response
Individuals (C)
C139-1 Christine
Boles
12/17/
21 While I appreciate that the General Plan document release has been delayed until January, I was hoping for some more clarification from staff about the process that the city will undertake to allow for the most input from the public. I have the following questions:
• How will the general public be notified? Will mailers also be sent to people not on social media/signed up for city updates? • Will there be a launch meeting to explain the purpose, the documents, the process and how the public can best give input where we can ask questions?
• For people without computer access will there be copies provided at a library or at the community center?
• Will there be any community meetings where we can discuss certain elements of the GP?
• Will someone on staff be available to answer questions during the 45 day period? Can we expect timely responses given the short time frame? Who do we complain to if we’re not getting responses? • To understand the timing and what is expected of the community, can you tell us approximately how many pages are in the EIR? And the General Plan ?
• Which General Plan elements are being updated now versus later - ie. we know the Housing Element will follow after the main GP update. What about the Sharp Park Specific Plan and Local Coastal Plan since the LCLUP is still nowhere near being approved by the Coastal Commission?
• It was my understanding that public meetings were to have been scheduled to review and discuss the Sharp Park Specific Plan. The last meeting I recall was with the council where they gave direction to allow 5 story development, but there were a lot of questions left unanswered, and as Mayor Bier pointed out, the consultant's renderings didn't even show the context of the existing neighborhood homes.
• Should we not review and approve the EIR first in case changes to the EIR need to be incorporated into the various GP elements? • Does the public get to see the comments from the state agencies such as Fish and Wildlife and USGS after their 45 day review while the city is preparing responses?
• Will we have enough time to review the changes made to the GP and EIR before the public hearings? A staff report issued a few before the hearing is not enough for these enormous documents. • Will changes be tracked to enable easy scanning of updated documents without having to reread the whole of the documents? • Processes such as Hazard Mitigation Plan where the public commented and staff responded to questions globally is not enough. Many comments were ignored or mis-interpreted. How will this process be different?
• How will the Planning Commission and City Council hearings be divided up? Do we only get 3 minutes to comment on the entire EIR and GP, or will there be separate hearings for each element? I could talk for 1/
The general public was notified of release
of the General Plan and DEIR through
newspaper announcement and email list.

An FAQ document was prepared to
explain more about the process.

Copies were provided at the Pacifica
Library and Community Center.

Please see DEIR p. 1-2 for more
information about the public engagement
process that informed the plan.

All DEIR-related comments will receive a
response; please see Master Response:

EIR topics vs. GP topics for more
information.

The DEIR is approximately 1000 pages
long, including appendices.

The Sharp Park Specific Plan is part of the
Proposed Project analyzed under the
DEIR. The LCLUP draft is with the Coastal
Commission for certification, it is not
included as part of the DEIR.

Please see the planpacifica.org website
for information on history of past
meetings. SP-related issues will be
presented to decisionmakers.

Comments from public agencies will
become part of the public record.

Tracked changes will be made.

Each CEQA-related comment will receive a
response; however, some comments may
refer to responses in others, or to a
master response, which addresses some
CEQA-related comments more holistically.

The Planning Commission will be
responsible for certification and
recommendation of adoption; the City
Council will be responsible for adoption.
654
C140: Virgilio Jr. L Yap, 1/19/21
Letter Commenter Date Comment Combined Response
Individuals (C)
C140-1 Virgilio Jr L
Yap
1/19/21 Question, regarding the plans can be directed to you. The comment is noted. As the comment does not address the
adequacy of the environmental
analysis contained in the DEIR,
no further response is
required. Response to
comment is included in
comment letter C-148.
655
C141: Remi Tan, 2/26/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C141-1 Remi Tan,
Architect
2/26/2
2 Pacifica's proposed General Plan update has zoned the Rockaway Headlands for development for visitor serving
commercial use. That is a prominent scenic headland ridge and should not be built on. Because the headland's edges are all steep - any access would require significant grading. Visitor serving should be on the parking lot next to the left and right of the Linda Mar BeachTaco Bell on the first row of parking, so there are more waterfront eating places by the beach like in HMB. Also at Rockaway, they should add more restaurants on the parking lots fronting the beach on the right side of the hotel and to the left of Nicks...

This headlands should be zoned park or open space in the General Plan. To avoid legal taking issues since this is private land, the city should allow TDR's where the headlands parcel owners can sell TDRs to other landowners who have parcels near transit and not on hillsides to develop denser housing or commercial projects that will help meet Pacifica's RHNA requirements and economic development needs.

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.
656
C142: Chuck Gust, 1/21/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C142-1 Chuck Gust,
Nick's
Seashore
Restaurant
1/21/2
2 I am sure you have lots to deal with these days as we all do. I have tried to follow progress of the EDC and the general plan. I have read a number of suggestions. I do not believe I have read anything that deals with parking. You can attract all the people you want but if there is no plan to park you just create a mess for businesses. My example is Rockaway Beach. It is a mess on nice summer days when surfers, beach goers and anyone
visiting the coast stops by. There was a long term plan many years ago for parking in Rockaway, but it never materialized.

Much of the problem was the city selling parking for in lieu of fees, putting more stress on parking that was existing. Anyway, it’s a long story so my suggestion is that you consider putting parking on the top of the list. It’s not just Rockaway, its Pedro Point, Highway 1 Beach Parking and actually most areas on the coast side have fallen way behind concerning parking. I thought the coastal commission was formed to assist with coastal recreation; Hmmm, that is another story for another day.

The comment is noted. Parking
is not a required topic of
analysis under CEQA. Thus, no
further response is required.

The comment is noted. As
the comment does not
address the adequacy of
the environmental analysis
contained in the DEIR, no
further response is
required. Response to
comment is included in
comment letter C-148.

C143-2 Sue Digre 3/7/22 Understood but the web does not indicate that info clearly. Info on the DEIR says it is "due".

The info on the GP & SharpPk Specific Plan say they are " requested by 3 08" with no clarification. If you don't look carefully at the fine print for each at the same time and on all related pages a reader may not assume that "requested" does give them some lee way. Th General Plan is the focus, but wait in statements about " plan pacifica" , (which include Sharp Park Specific plan, etc ,etc ), then confusion rises. The relationships to each other are not clear. It seems reasonable a GP draft & DEIR would be essential before any of the others because the others must conform to a GP. To add to the confusion: the operative GP is 1980.

Soooo what are the other specific plans conforming to? It can't be legal to be conforming to a Draft GP. Hopefully not!
For those of us who are not techy, all these confusions are a nightmare.

For those of us who work full time and our work and life circumstances are severely impacted by COVID impacts keeping up is nearly impossible.

I started months ago! We are in a pandemic. Then there are other PACIFICANS who can not know that any of this is even going on . I am very concerned and frustrated for them and all of us. Please state who are the Stakeholders? My assumption is that Pacifica constituents, (residents, voters )are the most important persons to get ample responses from. Are we??
Or are "special interest" groups of higher importance? Esp are there " for profit agencies or lobbyists" that are considered "stakeholders". What are the %ages of outreach towards all & the %age of input to the Drafts.

Sorry. I have tried to keep pace. But ,I am failing and getting exasperated.

I tried to avoid having to state these things but, a Gen Plan is the vision of Pacificans about who they are and want to be. As stated on the web , a Gen Plan is a constitution, Of, by for the people . Are we mistaken in our understanding?
These questions should be addressed in the process including in the DEIR & in the draft of the Gen Plan.

The General Plan includes
the Specific Plan; these
constitute the Proposed
Project analyzed in the
DEIR.
658
C144: James Kremer, 1/17/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C144-1 James Kremer 1/17/2
2 Here is a strange issue with the PDF file provided for the DEIR. I think it is serious, and I wonder if you are aware of it? I downloaded files for all the dropped docs from the Project Docs page on PlanPacifica.org. (I like to be able to save notes.).

The problem seems to be also present online, though I’ve spent more time tracking it down with my downloaded files.
• There is a problem with SEARCH, online and with downloaded PDF files in 2 PDF reader laptop apps: Apple’s Preview, but also with Adobe Acrobat Pro XI.
• The problem is ONLY with the DEIR. The GP works fine. (Perhaps it happened in the compression step?)
• Text words are NOT recognized as words everywhere; most places text seems to only be as block phrases, not searchable. • I am painfully aware this may not be a problem for everyone, but I am sure you want to check if others have it.

A. Please try this:

1. Open the DEIR file online (Public Review Draft EIR (January 2022 Version) | Public Comments Due by 2/21/2022)

2. Use the FIND feature to search for “CEQA” &/or “(CEQA)”.

3. It MISSES the word in the first ¶.

4. Now Search for “Executive" or “Summary”. It finds them fine, in the first header.

If this happens for you, it is not just me!
B. Please view my short clip that shows the problem –
C. One last example from the start of chapter INTRODUCTION shows what might be going on –
Again, search for “CEQA” which is right there in the 3rd line. It does NOT see the first hit (does not highlight the word) but it does find it in the heading. When I click-and-drag to select text (shown in green) it behaves inconsistently, sometimes missing the headings, and most importantly, selecting the text IN BLOCKS. You can see the small heavier green bands where the selected blocks overlap. The search DOES NOT SEE text in these blocks. (It really seems to be bad OCR coding for the main text ¶s, but it works for headings, and maybe some places in tables.) All this seems especially unfortunate since the City has said you are most interested in comments on the EIR which is over 1000 pg and does not have an interactive Table of Contents. If the public (anyone using files from the website) can’t search for key words, it makes it even more intractable. If you cannot repeat this behavior, it still might be worth checking with some others. I hope it is not just me! Again, i’ve seen it on 2 different Macs with 2 browsers online, and with downloaded files using two PDF readers.

Please let me know if you confirm or deny this. It has me dead in the water, essentially unable to work with the EIR, with only manual navigation.

Please see response to
comment C62-8.
659
C145: Christine Boles, 2/8/2022
Letter Commente
r Date Comment Combined Response
Individuals (C)
C145-
1 Christine
Boles
2/9/2
2 1) I do see in Chapter 3.3 Air Quality that Dyett and Bhatia provided new emissions data in several tables.

Can you confirm where they got their data for travel/trip information - was it from the 2010 traffic study or
something more recent?
This comment is noted. For this DEIR and GP
update, traffic counts from pages 3-12 to 3-21
were conducted in 2018 and 2019, and
analysis from Table 3.2-7 on page 3-41 was
conducted in 2020 and 2021, in accordance
with the table references in the DEIR. The raw
results of this analysis can be found at
https://cityofpacifica.egnyte.com/dl/QvA0lqyN
5J.

C145-
2 Christine
Boles
2/9/2
2 2) Dyett and Bhatia (D&B) also references Pacifica's
Climate Action Plan on page 3.3-40 but doesn't list the source.The Bibliography refers to Pacifica's 2012 draft Climate Action Plan and I know there is one later that
was adopted by council. What did they use?
References will be updated to reflect the latest
data used in analysis. This does not change any
findings of significance in the DEIR. Pacifica's
2014 CAP was used in analysis.

C145-
3 Christine
Boles
2/9/2
2 3) I keep trying to look at the bibliography to find
sources, but I don't think it was updated at all since
2014. It does not include BAAQMD's newer data sources
referenced by D&B in Chapter 3.3. Can you confirm? Do
you have access to a more current bibliography that just did not make it into this published draft? That would be very helpful if you could share it.

References will be updated to reflect the latest
data used in analysis. This does not change any
findings of significance in the DEIR.

C145-
4 Christine
Boles
2/9/2
2 I understand from Vicki Sundstrom that no new
technical studies were found in the public records to
assess our traffic conditions as part of this DEIR update, but I wanted to confirm that with you. It seems odd
because DKS Associates is noted as a source in 2020 in
the DEIR - see screenshot below. Please clarify.

Were any other technical studies required or prepared
as part of the CEQA process to inform the DEIR? The
NOP on page 14 says "The environmental assessment
will utilize the most current CEQA Guidelines and for
each issue area, including global warming and
greenhouse gases/climate change."
A city planner friend tells me that you would normally
find these technical studies in an appendix, but there is no appendix. I was pointed to Los Angeles County that
had recently updated their general plan as a good
example as they have a lot of the same issues we do
with sensitive biology, steep hillsides, coastal erosion and sea level rise. Their website shows all these
appendices and detailed technical documents. Am I
missing something?
See response to comment C55-2 and C55-3.
660
C146: Christine Boles, 1/31/2022
Letter Commente
r Date Comment Combined Response
Individuals (C)
C146-1 Christine
Boles
1/31/2
2 The DEIR references two Existing Conditions Reports, one done in 2010 and one done in 2019 for Sharp Park.

I think I found the one for Sharp Park here, please confirm this is current. https://www.planpacifica.org/spsp-ecr
I cannot find the one for the whole city that was discussed at a public hearing in September 2010. Can you forward that to me or should I file a PRA request?
And can you confirm if any updates were done for the city wide studies? I'm currently specifically looking for more recent traffic studies as 2010 was before the tunnel opened.

Thank you and I appreciate a quick response as our review time is so limited.

This comment is not related to
the adequacy of the DEIR.

Traffic counts were conducted
in 2018 and 2019, and analysis
was conducted in 2020 and
2021. Thus, findings of
significance and analysis that
relies on transportation counts,
such as VMT analysis and air
quality, remain valid.
661
C147: Christine Boles, 2/10/2022
Letter Commente
r Date Comment Combined Response
Individuals (C)
C147-1 Christine
Boles
2/10/2
2 I am trying to understand the calculation of Buildout per the draft General Plan. See screenshot below from Page 4-29. The whole DEIR is based on this maximum buildout number to assess environmental impacts for a project of 990 new units, so I wanted to clarify how these numbers were obtained. I am assuming that you have in your files or in Dyett & Bhatia's the detailed calculations that informed these numbers that would list specific properties and their acreage that were included in each of these land use categories.

Please see Master Response:

Buildout and RHNA
662
C148: Christine Boles, 1/15/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C148-1 Christine
Boles
1/15/22 Thank you Mr. Woodhouse. Is it possible to also get an answer to my question of whether North County Fire and other stakeholder agencies were given the opportunity to review the drafts for factual accuracy before they were released?
And thank you also for copying Chief Myers of North County Fire.

State and regional Cal Fire staff I contacted were not completely clear about who the responsible fire authority was for reviewing our General Plan and Safety Element.

It does concern me greatly that the Safety Element does not seem to have any information about fire risk in LRA (Local Responsibility Areas) and one of my goals in reaching out is to ascertain where I can find the current maps. This is my first time participating in a General Plan update and I am very confused as to the detailed process and how to be most helpful. How can I look at proposed land use changes for example without a thorough understanding of our hazards as a starting point? If I am confused as a professional, then I am sure I am not alone among the public. And I know for a fact that fire risk is one of the top concerns of the residents on the south end of town near the proposed Linda Mar Woods project.

Please see more information about
the adequacy of fire mapping in
Master Response: Wildfire.

C148-2 Christine
Boles
1/16/22 I just noticed that the North County Fire District is not on this distribution list. Is that perhaps an oversight?
And section 7-8 of the DEIR, attached, notes them as a stakeholder agency, but says they were last contacted in 2009. Surely that must be a typo? Were the stakeholder agencies not all recontacted and interviewed in 2019? According to a city planner friend, 2009 is too long ago, the legal term is "stale". This document mentions Michael Crabtree and Van Campo as well who have obviously been gone from Pacifica for some time.

Are there copies of information collected from interviews with these agencies that I can request to view? I'm happy to file a document request, but Sarah is asking me to be as specific as possible to help her with her job.

NCFA reviewed portions of the
DEIR in 2019; the bibliography will
be updated accordingly.

C148-3 Christine
Boles
1/17/22 I'm just looking for the Distribution list for the DEIR - the list of agencies who are required to, or invited to provide comments.

The comment is noted. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR, no
further response is required.

Response to comment is included
in comment letter C-148.

C148-4 Christine
Boles
1/18/22 Could you please forward a copy of the instructions to the State Clearinghouse, OPR along with the distribution list to responsible and optional agencies that will be reviewing the City's DEIR? The comment is noted. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR, no
further response is required.

Response to comment is included
in comment letter C-148.
663
C149: Christine Boels, 1/13/2022
Letter Commente
r Date Comment Combined Response
Individuals (C)
C149-1 Christine
Boles
1/13/2
2 Comments already included in C148 Please see comment responses to letter C-148.
664
C150: Christine Boles, 1/13/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C150-1 Christine
Boles
1/13/2
2 Good morning Christian and Tina,
I just noticed that the North County Fire District is not on this istribution list. Is that perhaps an oversight?
And section 7-8 of the DEIR, tached, notes them as a
stakeholder agency, but says they were last contacted in 2009.

Surely that must be a typo? Were the stakeholder encies not all recontacted and interviewed in 2019? According to a city planner friend, 2009 is too long ago, the legal term is "stale".

This document mentions Michael rabtree and Van Campo as well who have obviously been gone from Pacifica for some time.

The comment is noted. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR,
no further response is
required. Response to
comment is included in
comment letter C-148.

C150-1 Christine
Boles
1/13/2
2 Comments already included in C148 Please see comment responses to letter C-148.
665
C151: Ellen Natesan, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C151-1 Ellen Natesan 3/7/2
2 Hi again Christian, I realized I forgot to put a date, so I added it.

Please use this version with a date in it as my comment letter.

Thank you. Ellen On Mar 6, 2022, at 6:30 PM, ellen.natesan <[email protected]> wrote: Hello Christian, Here is my comment letter on the Pacifica General Plan and associated Draft Environmental Impact Report. Please let me know if you have any trouble with the attached file. I would be happy to talk to you or your consultants to answer questions or provide more
information if that would be helpful.
<Natesan_PGP_Comments_March_2022.pdf> CAUTION: This
email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

The comment is noted. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR,
no further response is required.

Response to comment is
included in comment letter C107
666
C152: Christine Boles, 1/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C152-1 Christine
Boles
1/9/22 Correction, I meant the upcoming January 18th Planning Commission hearing for the Talbot project, sorry about that. And for the Planning Commissioners, here is a link to my Google folder with the documents I received from the city in regards to the HPD variance discussions for the adjacent property at 722 Talbot Avenue. I think these will be useful to you in looking at precedence. These are from the City Council hearing; I have still not been able to obtain any documentation from the Planning Commission hearing on 11/4/2004 or the previous Planning Commission Study Session despite my 8/16/21 PRA request. The city prematurely closed my request, but I am following up to try to obtain these documents and I will forward it to you if/when I get them. https://drive.google.com/drive/folders/1efu90KFgl8ozcZr81k-uFPMrazgJVEt?usp=sharing The comment is noted. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR,
no further response is
required.

C152-2 Christine
Boles
1/10/2
2 I was finally able to download the general plan documents after receiving several error messages about the city's lack of bandwidth. The first thing I wanted to do was look at the landslide/coastal erosion map.

I am copying the Council and Planning Commission as this relates to an article I wrote in the Tribune this week as well as private discussions I have had recently with two council members. It also relates to a project on the Planning Commission agenda for Monday the 10th on Talbot Avenue.

I have apparently been screaming into the void for over a year now...my letters, public comments, expert reports from
scientists I sent you, mostly ignored. The Esplanade bluffs and Oddstad Boulevard where the kids died are still shown in white as not landslide/coastal erosion prone. I appreciate the new map of debris flow slides, but it does not reference the HDAI report that the city commissioned after the 475 landslides that winter of 1982 or consider all of these historic landslides. Even some of the 9 major slides studied, like the one between Moana and Talbot are not included on either map. The recent landslide on Highway One is missing, which is a blockage of a major
evacuation route. You have these records in your files; I just saw them recently as part of a document request. And the new 2021 USGS maps, which I also shared with planning staff recently, shows most of Pacifica in landslide prone zones. Your document page 8-5 references USGS maps from 19888 (yes 3, 8s) by the way.

There is some discussion of bluff erosion in the written text, but again the map does not match. And there have been many more properties that were forced to be removed in proximity to the shoreline than are mentioned, including at Linda Mar Beach, Rockaway and Manor that I know of.

I am so disappointed, and frankly, angry that the city after 40 years is apparently still not seriously considering our greatest environmental hazards. We must do better.

The comment is noted. Historic
mapping and the landslide
inventory was used to develop
the Seismic Hazard Zones map.

Please see response to
comment C119-16 and C110-2
for more information about the
adequacy of mapping.
667
C153: Mike O’Connell, 1/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C153-1 Mike
O'Connell
1/8/2
2 See attached comments on the GP. It doesn't look
like the consultant picked up the changes on Rosita.

The comment is noted. As the comment does
not address the adequacy of the
environmental analysis contained in the
DEIR, no further response is required.

C153-2 Mike
O'Connell
1/9/2
2 Thanks for incorporating the updates for 535 and
195.

The other one I had noted was 900 Rosita Road,
which I had changed the GP plan to low density
residential in 2012 (Reso 870). It is noted as
undeveloped on figure 4-1. Figure 4-8 shows it as
public facilities. I think it has been mistakenly
shown as part of Linda Mar School which is how it
got the PF designation. There are 2 small lots
behind 900 Rosita which are also shown as public
facilities but have never been owned by the school
district and so I believe those should also have a
LDR designation (I do not own those lots).

The comment is noted. As the comment does
not address the adequacy of the
environmental analysis contained in the
DEIR, no further response is required.
668
C154: Mike O’Connell, 1/10/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C154-1 Mike
O'Connell
1/10/22 Comments already included in C153 The comment is noted. As the comment does not address the adequacy of the environmental analysis
contained in the DEIR, no further response is required.

Response to comment letter included in C-153
669
C155: Mike O’Connell, 1/11/2022
Letter Commente
r Date Comment Combined Response
Individuals (C)
C155-1 Mike
O'Connell
1/11/2
2 Comments already included in C153 The comment is noted. As the comment does not address the
adequacy of the environmental
analysis contained in the DEIR,
no further response is required.

Response to comment letter
included in C-153
670
C156: Brian Gaffney, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C156-1 Brian
Gaffney
3/8/22 Please add the attached 4 documents to the City's administrative record for the 2022 GP Update and the 2022 Draft EIR.

This office represents the Pedro Point Community Association in regards to the 2022 GP Update and the 2022 Draft EIR. Please see the attached comments.

The comment is noted. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR,
no further response is required.

These attachments will be
included as part of the DEIR
record.
671
C157: Terry Watt, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C157-1 Terry Watt 3/8/22 Please see the attached for our public comment. Thank you! There are no comments in this letter. No further response is
required.
672
C158: Vicki Sundstrom, 2/1/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C158-1 Vicki
Sundstrom
2/1/22 I noticed references in Pacifica's general plan about traffic analysis from 2010...

In trying to understand traffic issues in Pacifica,
particularly the congestion on Hwy 1, I went looking for traffic counts. Traffic data for other cities is available online and so are traffic counts from Caltrans. I don't think Pacifica does regular traffic counts like other cities do - I do believe this is a requirement or at least a best practice in city administration. I took the time to
download what Caltrans had available and came up with
the table below (an hour and a half tops)
A couple of key points from the data & analysis:

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

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

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

4. The data - numbers - speak to the growth in vehicles.

Actual traffic conditions are based on lane geometry,
speed, road conditions etc. In other words, a 10%
increase on a four lane road isn't really a problem but it may be if it's a one lane road with poor traffic control.

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

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

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

8. Overall, Pacifica is generating a fair amount of it's own traffic and we have a lot of analysis to do to understand & solve the problems. The fact that the general plan is using stale data and analysis, from as far back as 2010, is a grave error and a huge disservice to our city. This is something that impacts the residents as well as any
future economic development. I am shocked at the fact
that any professional - a consultant or staff member -
would even suggest using 12 year old data in a region
that has seen so much growth. If this bad analysis isn't proof that you're rushing the general plan through, I
don't know what is. Please, let's get honest about the
traffic and actually pay someone to do some proper
analysis and fix it.

Traffic counts from pages 3-12 to 3-21 were
conducted in 2018 and 2019, and analysis from
Table 3.2-7 on page 3-41 was conducted in 2020
and 2021, in accordance with the table references
in the DEIR. The raw results of this analysis can be
found at
https://cityofpacifica.egnyte.com/dl/QvA0lqyN5J.
673
C159: Gwendolyn Holden, 2/26/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C159-1 Gwendolyn
Holden
2/26/22 I would like to comment on the Pacifica General Plan Draft. On page 189 Figure 7-3 Sensitive Critical Habitat, the riparian habitat on San Pedro Ave. is not listed as critical habitat for the reg legged frog. Attached are
images from May of 2020 and April of 2021 of frogs in
the riparian habitat at the base of Grand Ave, along
San Pedro Ave.

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

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

Therefore this "drainage ditch" should be reclassified
as a riparian habitat with documented cases of the red
legged frog in the habitat.

Thank you for your attention in this matter.

Thank you for your comment. The DEIR uses
the best available evidence from credible
government sources, such as the National
Wetlands Inventory and the U.S. Fish &
Wildlife Services, at the appropriate scale of a
Programmatic EIR for a General Plan. Figure

3.7-3 shows Critical Habitat which is a specific
designation applied by the CFWD. Figure 3.7-4,
Special Status Species, does show that the
CRLF could appear in the San Pedro Avenue
area. The DEIR and General Plan include
multiple policies to protect these species,
including CO-I-35 which states:
(CO-I-35) Protection of the Californian RedLegged Frog and San Francisco Garter Snake during Construction. To minimize disturbance,
require all grading activity within 100 feet of
aquatic habitat shall be conducted during the
dry season (May 1 and October 15) to protect
California red-legged frog and San Francisco
garter snake. A qualified biologist shall
conduct presence/absence surveys for
California red-legged frog and San Francisco
garter snake prior to construction in or
adjacent to riparian areas, grasslands near
ponds/wetlands, or
other sensitive habitat. Any individuals
identified shall be treated in consultation with
USFWS. Construction shall follow accepted
procedures for exclusion and avoidance of
California red-legged frog and San Francisco
garter snake and their habitat. Additionally,
the biologist shall supervise the installation of
exclusion fencing along the boundaries of the
work area, shall conduct environmental
awareness training for construction workers,
and shall be present during initial vegetation
clearing and ground-disturbing activities.

Please see Master Response 6: ESHA and
Master Response: Undeveloped San Pedro Ave
Sites for more information.
674
C160: Ellen Natesan, 1/19/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C160-1 Ellen Natesan 1/19/2
2 Hello Christian, Please add me to the list of people asking Pacifica to please consider extending the public comment period for the Draft EIR for the General Plan.

Thank you for your comment.

CEQA establishes a minimum
DEIR comment period of 45
days if the DEIR is submitted to
the State Clearinghouse for
review (Public Resources Code
Section 21091). The CEQA
Guidelines further address the
review period length, stating
that the comment period
should not be less than 30 days
nor more than 60 days except
in unusual circumstances
(California Code of Regulations,
Title 14, Chapter 3, (CEQA
Guidelines) Section 15105(a)).
“Unusual circumstances” are
not defined in CEQA. On
January 14, 2022, the City
Council extended the draft
period of time on the draft
Environmental Impact Report
(EIR) evaluating the General
Plan Update and Sharp Park
Specific Plan to 5 PM on March
8, 2022. This 15-day extension
provides the public additional
time to evaluate the draft EIR
and offer substantive
comments for the City’s
consideration.
675
C161: Arlene Patton, 1/22/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C161-1 Arlene Patton 1/22/2
2 Thank you for the opportunity to review the Draft General Plan, Draft EIR for the General Plan and the Draft Sharp Park Specific Plan. Pursuant to my comment at the OSPAC meeting, I'm
formally requesting a 30-day extension to the 45-day comment period. As you know this is an enormous amount of material to review and even as a retired person, I don't think I'll meet the current 45-day deadline! From what I've read so far, the General Plan is very good and an enormous improvement from the 1980 version. Thank you and the rest of the planning staff for the good work you do.

Thank you for your comment.

CEQA establishes a minimum
DEIR comment period of 45
days if the DEIR is submitted to
the State Clearinghouse for
review (Public Resources Code
Section 21091). The CEQA
Guidelines further address the
review period length, stating
that the comment period
should not be less than 30 days
nor more than 60 days except
in unusual circumstances
(California Code of Regulations,
Title 14, Chapter 3, (CEQA
Guidelines) Section 15105(a)).
“Unusual circumstances” are
not defined in CEQA. On
January 14, 2022, the City
Council extended the draft
period of time on the draft
Environmental Impact Report
(EIR) evaluating the General
Plan Update and Sharp Park
Specific Plan to 5 PM on March
8, 2022. This 15-day extension
provides the public additional
time to evaluate the draft EIR
and offer substantive
comments for the City’s
consideration.
676
C162: Mark Hubbell, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C162-1 Mark
Hubbell
3/9/22 Good day again! Realizing that I had forgotten to put my contact information on the document I sent before the deadline
yesterday, I've added it here, just in case you wanted to talk to me. Good day. Attached is my comments on the General Plan DEIR Please confirm receipt of this email.

The comment is noted. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR,
no further response is required.

Response to comment is
included in comment letter C-95
677
C163: Paul Totah, 2/27/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C163-1 Paul Totah 2/27/22 Please see below for some changes I made to the comments sent to you a few days ago. -- Paul
As a member of Tree City USA, I have worked to
protect and grow our urban forest. Pacifica's urban
forest includes all trees, both public and private,
within the city limits. The DEIR (and General Plan)
have some aspects that reflect this commitment and
others that need adjusting. Below you will find some
comments, questions and requests. 1. The Guiding
Principle CO-G-10 in the DEIR (and General Plan)
instructs the City to “Conserve trees and encourage
native forestation and planting of appropriate trees
and vegetation”. This is an excellent guiding principle and reflects the intent of a Tree City USA. There are a couple of cases on pages 85 and 560 where other
guiding principles are mislabeled CO-G-10. Can these
be relabeled?
The comment is noted. Guiding Principles
are renumbered to correspond with the
correct GP Principle in the redlined DEIR.

C163-2 Paul Totah 2/27/22 2. Although the Clean Air and Energy and Greenhouse Gases chapters of DEIR acknowledge the value of
trees, the Natural Resources Chapter is less than
thorough. It doesn’t acknowledge the concept of the
urban forest as a whole, and mentions only a few
species of trees. In the section titled
Urban/Developed it doesn’t recognize that trees in
neighborhoods are at risk due to the lack of
enforcement of the Heritage Tree Ordinance, or
acknowledge the environmental contributions of
these trees other than habitat for wildlife. As climate change warms California, growing the urban forest
with diversified species will become even more
important to keep cities livable. Please add these
points to the Natural Resources Chapter.
“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.”
C163-3 Paul Totah 2/27/22 3. In Figure 3.7-1 Vegetation in the DEIR (Figure 7-2 in the General Plan) part of the information comes from
the Department of Forestry in 2005. Some of this
information is either outdated or in error. For
example, the North side of Vallemar is labeled as
Eucalyptus, but it is primarily Monterey Cypress and
Pine, with only a few Eucalyptus trees. Current online
resources such as i-Tree can more accurately assess
tree canopy. Please update this map with more
accurate information.

The General Plan and DEIR make use of
best available evidence from reputable
federal and State governmental sources. As
described on DEIR p. 3.7-1 and 3.7-2, "The
basis for the vegetation classification
system utilized in this analysis relies on the
currently accepted California Department
of Fish and Wildlife List of Vegetation
Alliances and Associations (also known as
the Natural Communities List). Plant
communities generally correlate with
wildlife habitat types, and these typically
are classified and evaluated using CDFW’s
California Wildlife Habitat Relationship
classification system." Thus, this represents
the most accurate source of mapping for
analysis.

C163-4 Paul Totah 2/27/22 4. As stated above Pacifica’s urban forest includes all trees within the city limits.

Unfortunately Figure 3.7-1 labels
"Urban" refers to areas that have human habitation. Figure

3.7-1 is intended to show general vegetation and not tree canopy. The comment is not related to the adequacy of
678
Letter Commenter Date Comment Combined Response
Individuals (C)
neighborhoods as “urban” with no indication
of trees and other vegetation. Can the
“urban" areas be relabeled as “neighborhood"
with the presence of trees identified? Most
cities with Tree City USA status regard trees as
infrastructure, providing services such as
controlling storm water and reducing air
pollution. In addition, research shows that
neighborhoods with trees have higher
property values and greater health benefits.

Having an accurate representation of all trees
in Figure 3.7-1 will help Pacifica manage this
important resource. Please change Figure 3.7-
1 to reflect the entire urban forest.
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.

C163-5 Paul
Totah
2/27/22 5. There is no Implementing Principle to
correspond with the Guiding Principle CO-G10. Most Tree City USA cities have Canopy Goals for the urban forest that guide the
actions of staff and citizens. Tree City Pacifica
is requesting that Pacifica establish a Canopy
Goal. Please add an Implementing Principle
that states “Adopt an aspirational Canopy
Goal to promote the protection and growth of
the urban forest”.

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

C163-6 Paul
Totah
2/27/22 6. In the DEIR the Heritage Tree Implementing
Principle CO-1-41 states “Protect trees
designated by the City Council as having
special value, according to the terms on the
Heritage Tree Ordinance”. In the General
Plan, Heritage Trees are under Principle CO-I39 which has different wording. Please reword both of these Implementing Principles
to better reflect the purpose of the Heritage
Tree Ordinance, such as “Protect essential
trees in Pacifica’s Urban Forest by enforcing
the Heritage Tree Ordinance".

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

C163-7 Paul
Totah
3/5/22 7. The Sharp Park Specific Plan 5-1-4
promotes the addition of curb bulb outs to
plant street trees along Palmetto as well as
east west connections. Research shows that
trees promote commerce, so this would be a
notable addition to this plan. Is this reflected
in the DEIR? Thank you for all your hard work
on the DEIR and General and Sharp Park
Plans. We appreciate you addressing these
concerns regarding our urban forest. Yours,
Paul Totah (124 Nataqua Avenue)
The comment is not related to the adequacy of the DEIR, therefore no further response is required in the FEIR.

Separate maps would serve Pacificans better. “Coastal
Erosion” can be anticipated as continuing and
accelerating with more frequent extreme events caused
by climate change and sea level rise. Slope failure inland from the coast usually depends on severe precipitation
and is aggravated by poor engineering choices or
nadequate site investigation.

The comment is noted. Specific descriptions of
coastal erosion are described on DEIR p. 3.6-14
and 3.6-17. Description on 3.6-17 references
erosion projections from the Pacific Institute,
California Climate Change Center, The Impacts
of Sea-Level Rise on the California Coast, May
2009, which represents the latest and best
available science in the 2018 Sea Level Rise
Vulnerability Assessment.

C164-2 Stan Zeavin 3/5/22 1. Safety Element
Document page 7
• Figure 8-3 MAP titled Slope Failure and Coastal Erosion (page 7)
>> Legend identifies the “Coastal Zone” by a dotted pale blue line which is obscured by “seawall” and “riprap,
other revetments”
>> To identify the “Coastal Zone” as only the immediate meeting of sea and land ignores the “Coastal Zone”
definition used elsewhere to indicate that portion of land to which the 1976 Coastal Act applies. To avoid
confusion the term “Coastal Zone” must be defined
specifically and used uniformly.
>> The Figure 8-3 “Note” ( •Figure 8-3 “Note: Beach and cliff erosion are typical of much of Pacifica coastline.”) requires more detailed consideration.
>> “Slope Failure Threat” must recognize and include the threat of bluff failure along nearly all our coast
The Coastal Zone is shown in Figure 2.1-2 and
defined on DEIR p. 2-6. Coastal erosion threat
and policies that reduce the impacts are
described in response to comment C47-3.

C164-3 Stan Zeavin 3/5/22 Document page 10 (8-10)
• “Increased Coastal Erosion from Potential Sea Level
Rise”
>> Use current information from USGS COSMOS and
Pacifica’s 2018 ESA vulnerability study to explain
projected increase.

Please see response to comment C164-1 for
more information on coastal erosion data sources. C164-4 Stan Zeavin 3/5/22 • Photo caption: “New development in the Coastal Zone must not require the construction of riprap or other
protective devices that would substantially alter natural landforms (left)
New development is required to be set back from coastal bluffs enough to accommodate a 100-year event,
whether caused by seismic, geotechnical, or storm
conditions (right).”
>> Photo caption is consistent with State policy and
should be emphasized. Information elsewhere
contradicts this caption.

C164-5 Stan Zeavin 3/5/22 >> Identify policies specific to coastal bluffs/cliffs more clearly.
cf. SA-I-3 Real Estate Disclosure specifies “suspected
seismic or geologic hazards…and…risk of liquefaction,
subsidence or landslide.”
cf. SA-I-7 Erosion Prevention … “of hillside areas by
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
680
Letter Commenter Date Comment Combined Response
Individuals (C)
revegetation…”
>> Sea Level Rise and cliff/bluff risk of retreat MUST also be specified and disclosed in Real Estate transactions. >> Revegetation is inappropriate for cliff/bluff erosion. comments for more information about GP- or
SPSP-related responses.

C164-6 Stan Zeavin 3/5/22 Cf. SA-I-8 Geotechnical Studies. ,,,, Within 50 feet of a coastal bluff
>> Add and Emphasize: “The City's Seismic Safety and
Safety Element requires the bluff setback to be adequate to accommodate a minimum 100- year event, whether
caused by seismic,
geotechnical, or storm conditions. The setback should be adequate to protect the structure for its design life.” 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.

C164-7 Stan Zeavin 3/5/22 Document page 12 (8-12)
SA-I-9 Maintain Restrictions on Hazardous Areas.
>> Clearly identify “Hazardous Areas”
These areas are clearly shown on maps. Please
see comment C22-10 regarding adequacy of
hazards mapping.

C164-8 Stan Zeavin 3/5/22 Document page 13 (8-13)
SA-I-15 New Development in Coastal Zone.
>> Define new development in accord with the Coastal
Act.
>> Clarify sentence intent: strike beyond the existing
development’s life
>> Provisions must align with current State certified
LCLUP
The comment refers to a LCLUP policy; this
comment is not related to the adequacy of the
DEIR. Thus, no further response is required.

C164-9 Stan Zeavin 3/5/22 Document p 18 (8-18)
SA-I-27 Critical Facilities Location. Site criti- cal public facilities including hospital and healthcare facilities, emergency shelters, police and fire stations, and
emergency communications facilities outside of the
tsunami evacuation zone and 100-year flood plains.
>> Add sewer pump stations as a Critical Facility
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.

C164-10 Stan Zeavin 3/5/22 Document page 21 (8-21)
SA-I-28 Vulnerability Identification and Map- ping. The City’s Coastal Vulnerability zones shall be mapped …
>> Mapped in 2018 LCP draft
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.

C164-11 Stan Zeavin 3/5/22 page E-46
Table ES-3 Summary of Impacts and…
S A-I-15 New Development in Coastal Zone.
• Assure stability and structural integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding area or in any way require the construction of protective
devices that would substantially alter natural landforms along bluffs and cliffs; • Not accelerate the need for a shoreline structure or increase the likelihood of a future seawall beyond
the existing development’s expected life; and
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.
681
Letter Commenter Date Comment Combined Response
Individuals (C) • Not violate required setback provisions. >> Add BEACHES after bluffs and cliffs.
>> Define “substantially.”
>> Follow State of California Coastal Act guidance and
clarify the date for “existing development ” to be
consistent with the 1976 date for California voters’
approval of the Coastal Act.
>> Define “expected life.”
>> Add “New development is required to be set back
from coastal bluffs enough to accommodate a 100-year
event, whether caused by seismic, geotechnical, or
storm conditions” according to certified LCP.

C164-12 Stan Zeavin 3/5/22 >> Placing coastal erosion in SMCMJLHMP under “Landslide/Mass Movements” does not adequately
emphasize on-going and increasing erosion with SLR.

Document page 470
The comment is noted. Coastal erosion due to
sea level rise is discussed on p. 3.6-14 and
adequately describes ongoing and future risk
of coastal erosion.

C164-13 Stan Zeavin 3/5/22 Beaches and Coastal Erosion
>> Update erosion history and bluff retreat.

Current data is based on 1998 report.

The comment is noted. Coastal erosion due to
sea level rise is discussed on p. 3.6-14 and
adequately describes ongoing and future risk
of coastal erosion, as well as historical events
of erosion in Pacifica. The MJ-LHMP also
catalogs historical erosion events. Please see
response to comment C164-12 for more
information on where the latest maps of
coastal erosion can be found.

C164-14 Stan Zeavin 3/5/22 Figure 3.6-3 Slope Failure and Coastal Erosion Map figure 8-3 is repurposed with legend including red
line to indicate general “critical coastal erosion”
>> Map requires better accuracy and precision to be
meaningful.
> Arrow indicating “Severe Beach and Cliff Erosion”
should bracket from north of the pier to the city limit and include “gullies” area.
> Beach erosion extends south from the pier to Mori
Point.
> Arrow indicating “Severe Beach & Cliff Erosion“ on
northwest Mori Point should include all area south from SF revetment.
> Beach and Cliff erosion occur on the hidden beach
(AKA Smuggler’s Cove
> Serious cliff erosion resumes with marked effect on the porous limestones north of the Rockaway revetment.
> Cliff erosion wraps around all of Aramai Point
(Rockaway Headland).
> Remove “Wave Surge” at Pacifica State Beach north
end.

The comment is noted. Coastal erosion due to
sea level rise is discussed on p. 3.6-14 and
adequately describes ongoing and future risk
of coastal erosion, as well as historical events
of erosion in Pacifica. Please see response to
comment C164-12 for more information on
where the latest maps of coastal erosion can
be found.

C164-15 Stan Zeavin 3/5/22 3.6-17 Effects of Sea Level Rise Paragraph 1: These general projections for the northern California Coast of dune and bluff erosion by 2025, 2050 and 2100 are inappropriate for Pacifica’s exposed coast north of Mori Point where bluff erosion has already
exceeded the 2025 prediction in several places.
>> 2018 LCP vulnerability mapping would give Pacifica
This information is the same source as that
used in the 2018 Sea Level Rise Vulnerability
Assessment, p. 27.
https://www.cityofpacifica.org/civicax/filebank
/blobdload.aspx?BlobID=13746
682
Letter Commenter Date Comment Combined Response
Individuals (C)
citizens a much better idea of the area of potential
erosion.
683
C165: Christine Boles, 1/10/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C165-1 Christine
Boles
1/10/22 Could one of you confirm if there were even any public meetings about the Safety Element portion of the General Plan?
The comment is noted.

Meetings for the General Plan
and LCLUP were held in
summer 2019. As the
comment does not address the
adequacy of the environmental
analysis contained in the DEIR,
no further response is
required.
684
C166: Pez Godsoe, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C166-1 Pez Godsoe 3/7/2
2 This is a letter to object to residential development of the field at San Pedro and Grand Avenues.

Since 2016 we have been subjected to construction up against our house and property lines at 1335 Grand Ave. We now live with an « unmanaged motel The Anchor Inn » directly behind us.

We also have behind us a very large house still under construction since 2018. Those windows look directly into our bedrooms from high above. Most construction starts at 7:01am. It has been constant noise since 2016. Now the construction on Olympian Way involves very large loud trunks and cranes going up/down Grand Ave at all hours.

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

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

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

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

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

Please see Master Response;
Undeveloped San Pedro Ave
Sites. Please also see Master
Response 1.
685
C167: Peter K, 1/16/2022
Letter Comment er Date Comment Combined Response
Individuals (C)
C167-1 Peter K 1/16/22 I notice that Sharp Park plan doesn't actually address sea level rise. It does not that sea level rise is an issue, but has not one plan address issues.

Issues like:
- Spending tons of money to beautify Sharp Park, and do nothing to protect that investment.
- The pier has been damaged at least twice in the last decade. This is only going to get worse with sea level rise. How does the plan protect the pier, which the plan notes is a precious resource?
- The properties near the end of the sea wall are getting damaged by the water forces being directed there by sea wall. Those residents might have a claim against the city. Sea walls are known for causing damage in adjacent areas:
https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fbeachapedia.org %2fShoreline_Structures&c=E,1,ScSmH7L
HE7I3dhdumWCaaCrK99GhGTpEHzPPLV9tRFA_lUclyBLTgZ7zwvjqnPjFIvO UfF84L2WACWvQqIh6DzgyMVLSnmkjhMCg3RRNKj7qTCM5DSgM2zfQY
M,& typo=1
What is Pacifica doing to protect these homes in the Sharp Park plan? How is Pacifica protecting itself from the legal liabilities around building a seawall next to private property?
- Also, what is Pacifica going to do about the buildings that are literally falling into the ocean, and at risk of doing of falling into the ocean? Not just the Esplanade fiasco, but also the residences just north of the sea wall.
- And when there are high sea waves, building facing the ocean get damaged, one place has had it garage door blown in at least twice in my memory. How much taller does the wall need to be, versus how tall the plan is? Which is to ask, why doesn't the Sharp Park Plan include data about how tall the sea wall needs to be? Deciding how tall to making the sea wall without knowing how tall it needs to be seems stupid. - During major storms, the Sharp Park golf course floods, and two things happen that are environmental issues:
-- They pile sand up next to the "illegal" berm protecting the golf course.

Is that permitted from an environmental standpoint?
-- The golf course pumps out flood water into the ocean. The water from the golf course is polluted with herbicides and pesticides. Does the Sharp Park have a permit to pollute Pacifica's coast waters like that? This snapshot of the Sharp Park plan shows that they don't even know the scope of the problem of sea level rise.

The comment is noted.

As the comment does
not address the
adequacy of the
environmental analysis
contained in the DEIR, no
further response is
required. Sea level rise in
the Sharp Park area is
addressed in the Local
Coastal Land Use
Program.
686
C168: Bill, 1/11/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C168-1 Bill 1/11/2
2 This comment is to a portion of the proposed Sharp
Park Plan.

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

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

2. How will the thousands of Pacificans who don't
drive get to a central library? Pacifica is still cardependent. The bus system is deficient. Pacifica's decision-makers all drive and only hear from fellow
motorists. Kids, seniors, disabled and poor people
who don't drive are overlooked in Car-Town, USA,
yet they'd be taxed for the library. Will there be a
library shuttle? An overbuilt library is nice for library staff (who have asked for private potties, among
other perks to be paid by Pacificans) but
inconvenient to residents miles away in Forgotten
Fairmont or Linda Mar. City Hall won't tell you this,
(the interior design is not disclosed) but the "library" bond we'd be taxed for includes a new City Council
chamber (called a "community room") when our
existing community center would do just fine. It's
overbuilt. Two libraries are better than one. Many
Pacificans use the libraries in nearby cities without
cost. For years, City Hall has failed to fund library
maintenance, cynically betting that voters can be
compelled to vote for a new one. City Hall promises
the central library will be open daily. I don't believe it. Would a building on the coast withstand the harsh
weather?

3. Pacifica has the lowest per capita tax revenue in
the county, with no corporations or big malls to
share the tax burden. A costly library bond, in
addition to the many bonds, parcel taxes, and usual
property and sales taxes we already pay, would fall
mostly on residents, making living here even less
affordable. There's no low-income or senior
exemptions. Including interest payments, the actual
cost of the bond is double the stated cost. City Hall
won't tell you that, either. City Hall is always poormouthing, but property taxes and city revenues are UP. Why doesn't our City chip in?

4. How much has Pacifica raised for this project from
private donors? There's vast wealth nearby, but City
Hall can only envision a hefty property tax hike.

Another city in San Mateo County is building a new
library, privately funded. Has Pacifica even tried? If a donor is willing to donate for naming rights, why not
reduce the cost to Pacificans?
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.
687
C169: Jackie Rosenheim, 2/21/2022
Letter Commente
r Date Comment Combined Response
Individuals (C)
C169-1 Jackie
Rosenheim
2/21/2
2 I have reviewed the plans and would like to share my
concerns and feedback. While I do think that general
development of the area to create a downtown
atmosphere would be a good thing for Pacifica, I have
concerns over the design as described in Chapter 5 of
the plan. First of all, Chapter 1 states the vision for the downtown becoming" charming and vibrant with
a seaside atmosphere" and that the plans are to
"enhance Sharp Park as a creative and historic
enclave." I really appreciate the motive to honor the
area's character, history and coastal locale as worded
on 1.6 I would like to state that I am opposed to High
Density Residencies (3.10) as it detracts from history
and charm. The area will become boxy and lose all of
its charm. I believe that Medium Density Residency
buildings can become Mixed Use Centers and this will
help to sustain our city's charm.

I like all the guiding policies described on 4.18 such as complete streets and improved public realm (in fact,
this should be a goal for the entirety of Pacifica). We need safer pedestrian crossings that offer coastal
access all over this town. Now, Chapter 5 promotes
an "Attractive Urban Design". The documents don't
describe what is envisioned by 'urban design,' yet the
photos show boxy and bland buildings that are not
consistent with (5.1.19) "employing designs, features,
materials, color that are consistent with character of
Sharp Park." The buildings in the 3-D renderings
shown are similar to the newly renovated Eureka
Square, which is a poorly designed hodge podge of
materials and will take away all of our local seaside
charm. I would like to propose that the vision for
"urban design" design is removed and instead we
look towards other beautiful coastal California towns
that are thriving in vibrancy and tourism. The designs
should be more along the lines of Carmel, Santa
Barbara. We can look for inspiration towards our own
Rockaway Beach with the light colored shingled
buildings. Please do not use mixed materials such as
stucco, wood and tiles as in the design of Eureka
Square. Pacifica will end up looking just like Daly City and that does not exemplify a "charming and vibrant
seaside atmosphere".

EIR comments for more information about
GP- or SPSP-related responses.
688
C170: Bryan O’Flynn, 3/9/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C170-1 Bryan
O'Flynn
3/9/22 What makes the Sharp Park neighborhood in Pacifica uniquely wonderful is due in great part to its
location fronting on the Pacific ocean and the people
who are drawn to it . Its embrace of the sea first
created and then subsequently has shaped Sharp
Park.

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

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

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

Building a new replacement sea wall north of the
Pier in the same location as the existing
seawall/revetment is a straightforward and efficient
proposition. Years of study by the city with
community involvement has resulted in a great plan
for doing so . The study recognized the importance
of protecting the community, housing , property,
structures and infrastructures - both public and
private via a new sea wall. The construction of a new
sea wall should be made a key part of the Sharp Park
Specific Plan and written into the plan as specific
public policy and top priority.

EIR comments for more information about
GP- or SPSP-related responses.
689
C171: Tom Thompson, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C171-1 Tom
Thompson

3.7.202
2 I just emailed in my Sharp Park Specific Plan Public
Comments to the email address
[email protected] with a PDF of signed
comments as well. Please, kindly confirm they were
received within the deadline.

There are no comments in this letter. No
further response is required.
690
C172: Tom Thompson, 3/7/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C172-1 Tom
Thompson
3/7/22 As a Sharp Park property owner and taxpayer for
35+ years, I am submitting the following public
comments regarding the Draft Sharp Park Specific
Plan. I have attached a signed PDF copy as well.

The Sharp Park Specific Plan (SPSP) has a major
flaw. Environmental justice and economic justice
issuesare at risk. Let’s fix the SPSP. Now, while we
can. Essentially, the Sharp Park Specific Plan
(SPSP) is spot-on. Visionary. Essential. Brilliant.

The vision for Palmetto Ave as a vibrant and
walkable small “Downtown Pacifica” is just what
we need. A new hotel at 2212 Beach Blvd. is key
to making this happen. Adding shops, eateries
and other businesses will make Pacifica thrive.

And the increased tax revenue to our city
treasuries is essential to our economic viability as
a city.

The SPSP goes into detail about the potential for
Sea Level Rise. Yet, the SPSP is virtually silent
about a commitment to seek a simple sea level
rise solution for Pacifica and Sharp Park… A
RUBUST SEAWALL. Is this just a major oversight,
or a plan for failure? Unless the SPSP includes a
commitment to pursue a robust seawall… within
the Sharp Park Specific Plan itself, the SPSP
becomes a plan for failure. Furthermore, without
a commitment to pursue a robust seawall….
investment in Sharp Park to make it a robust
“Downtown Pacifica”… will never happen.

This single flaw in the SPSP is easy to fix though.

The SPSP needs a strong policy commitment
statement that Pacifica will pursue the design and
funding to build a robust seawall. A plan to guard
against the potential for sea level rise. Public
infrastructure, family homes, retirement nest
eggs, businesses, and affordable recreation are at
stake. Hundreds of millions of dollars of public
infrastructure are potentially at risk, without a
robust seawall. This critical essential public
Infrastructure must be protected from potential
sea level rise. Without the existing standing sewer
pump station alone, 40% of Pacificans will lose
their sewer service. Not just lost in Sharp Park,
but 40% of all Pacifica! The golf course, pier and
access to coastal trails provide affordable
recreation that need the protection of a robust
seawall. A robust seawall is both an
environmental justice issue, and an economic
justice issue. Pacifica family investments in homes
& businesses must be protected. Homeowners
who invested their life savings never thought they
should fear their government might abandon
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.
691
Letter Commenter Date Comment Combined Response
Individuals (C)
them and effectively condemn their homes by not
protecting public infrastructure and places to
live… with a robust seawall.

Again, environmental and economic justice issues.

A robust seawall north of the pier is a no brainer.

The Sharp Park Specific Plan needs to be clear
that we are working to make a robust seawall
north of the pier happen. The simple solution is a
robust seawall north of the pier. Let’s fix the
Sharp Park Specific Plan, with a clear policy
statement within the SPSP itself that we will work
to make a seawall happen. Here is more detailed
list of what is at stake, unless we make a
commitment to pursue a robust seawall… within
the Sharp Park Specific Plan itself. PRIORITY
SOLUTION: WE NEED TO COMMIT, WITHIN THE

SPSP ITSELF, TO BUILDING A SEAWALL NORTH OF
THE PIER, so we can:

A) Protect Public Infrastructure Investment.

Economic & Social Justices
Issues Involving:
1) Streets & Roads
2) Sidewalks
3) Beach Promenade
4) Storm Drains
5) Access to Coastal Trails
6) Sewer Lines
7) Natural Gas Lines
8) Electrical Service
9) Internet
10) Cable lines
11) Water Service Lines
12) Golf Course
13) Fishing Pier
14) Existing major sewer pumping station at 2212
Beach Blvd. Sewer service for 16,000 people.

That’s 40% of all Pacificans. Not just Sharp Park.

B) Protect Private Investment. Economic & Social
Justices Issues Involving:
1) 1,000 + of our most affordable existing homes.
2) 100+ existing small businesses.
3) Future Investment to make Palmetto a thriving
walkable downtown district.
4) 2212 Beach Blvd Hotel won’t happen without a
commitment to a seawall. Pacifica’s financial
future depends upon a new hotel on that site.
5) No commitment to pursuit of a robust seawall.

Means no commitment to a hotel. How and why
would investors move forward without this
assurance?
6) The same holds true for other investors in
Sharp Park. Why would any investors come to
Sharp Park, if the city is not committed to
protecting Sharp Park?
C) Again, Protect Environmental and Economic
692
Letter Commenter Date Comment Combined Response
Individuals (C)
and Social Equity Justice
Issues including:
1) Think of the environmental & economic mess if
40% of Pacifica loses their sewer service because
we didn’t protect the sewer pumping station with
a robust seawall.
2) Preserving Pacifica’s 1,000+ most affordable
homes in Sharp Park.
3) Preserving 100+ small businesses in Sharp Park.
4) Homeowners and small businesses have their
nest eggs and retirement invested in Sharp Park.
5) These homeowners and businesses never
dreamed their city might abandon them by not
making it a policy to protect their homes &
investments with a robust seawall.
6) Affordable access to our fishing pier provides
affordable food to many families.
7) Access to affordable recreation like fishing,
picnicking, golf & hiking trails are at risk.
8) Protecting Sharp Park with a simple robust
seawall, north of the pier, is essential to getting
the investment we need to make Sharp Park
thrive.
9) And the increased tax revenue to our city
treasuries from these investments is essential to
our economic viability as a city. Economic justice
for the city itself.
693
C173: Bob Haxo, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C173-1 Bob Haxo 3/8/22 It was very recently brought to my attention that included in the Plan Pacifica Project is a new Sharp
Park Specific Plan that includes improvements to
San Jose Ave., specifically changes/improvements to
the sidewalks along the eastern portion of San Jose
Ave.

Our house is at 180 San Jose Ave., which is toward
the Francisco Blvd. end of San Jose Ave. On “Figure
4-6b: San Jose Ave Improvements” of the SPSP, our
house is on the S side of San Jose Ave, where there
is the “Potential side-walk expansion” label with the
narrow green stripe indication the strip of unwatered but maintained strip of grass between the curb and the 4’ wide sidewalk. This same green
stripe indication in front of the house to the east of us. Our small strip of grass serves an unexpectedly important neighborhood function: the dogs walked
by neighbors in the area use this area to, uh, relieve
themselves. The owners are good at cleaning up
after their dogs. Would be a shame for
neighborhood dogs to lose this grass and other such
stretches of grass along the block.

There are more concerning issues with the sidewalk
improvements along the street than keeping the
street dog friendly:
1) An 8’ (or 6’) wide sidewalk is out of keeping with
the neighborhood. The existing sidewalks are 4’
wide and that seems to be an adequate width.
2) There are stretches of the street where there is
currently no sidewalk. Most of these stretches could
have curbs and 4’ wide sidewalks added without
affecting the neighbors and the “charm” of the
neighborhood.
3) However, there are stretches without sidewalks
along which even a 4’ wide sidewalk would
significantly impact neighbors. My guess is that the
city has in the past been very lax with enforcing the
city street R.O.W. I hope that much consideration
and consultation of these situations will occur
before any construction plans are created.
4) We have an expensive-to-maintain heritage
cypress in front of our house. I would be very, very,
very, very (!) concerned if improvements along San
Jose Ave. were in any way to impact the root-system
of this heritage cypress.
5) Across the street from us (as indicated in Figure 4- 6b) there is a tree located where a sidewalk would
be added. Is the plan to whack trees that are in the
way or is there a plan for dealing with trees along
the street that would be in the way of adding
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.
694
Letter Commenter Date Comment Combined Response
Individuals (C)
sidewalks/
MY suggestions for immediate improvements:
1) Figure a way to prevent cars from going at speed
the WRONG WAY up the street. Happens daily along
San Jose Ave, and I assume along the other Sharp
Park one-way streets. We really shouldn’t need to
wait for this improvement until there is an accident,
right? Start by adding ARROWS ON THE STREETS
indicating traffic flow direction. Then add a barrier
blocking the south half of San Jose Ave. at Palmetto.

Top that barrier with, uh, how about a big “DO NOT
ENTER” sign? Same for other one-way streets in the
neighborhood,
2) There is a stretch of seriously damaged and
unsafe sidewalk immediately to the east of the
Ballet School parking. This damaged sidewalk is
where a city heritage tree was removed several
years ago. This piece of sidewalk should be fixed now. 3) Before planning for improvements along the street, have a REAL meeting with the
residents/owners. This will require communication
so that all are aware of what is being planned. I
receive USPS mail regarding owners planning to
improve their houses blocks away from our house,
but only learned about the SPSP from a friend
follows city planning.
4) With discussion with property owners, add 4’
wide infill sidewalks where this can be done without
too much bother of property owners.
5) Sections of San Jose Ave. need to be re-paved by
a professional contractor. Re-paving is being done
along Oceana Blvd. by the high school. That type of
repair could be done to sections of San Jose Ave.

C173-2 Bob Haxo 3/8/22 I seen no direct reference to the development proposed (or dreamed of) on San Pedro Mountain,
to the south of Higgins Way. Nonetheless I have
some thoughts about this. I bicycle up and over the
Old San Pedro Mountain Road to Montara. Lovely
exercise. I’m quite familiar with the area. The
proposed development atop the hill is very
inappropriate.

A development atop the hill would be a scary fire
hazardous place to live. Fire, as I’m sure you
understand, goes uphill quite readily. This
development would be at the top of a hill covered
by a eucalyptus forest. Escape would require driving
down the hill, along the narrow Higgins Way,
perhaps the source of the fire. And fire fighting
trucks would be needing to go UP the road. I find a
couple references to San Pedro Mount in the
Pacifica General Plan Draft indicating this area as
both fire and slide danger zones.

The comment is noted. Please see Master
Response: Wildfire. The Sphere of Influence is
within a SRA VHFHSZ. The City of Pacifica does not
have permitting jurisdiction in the Sphere of
Influence. Should any land be annexed into the
City of Pacifica, development would be subject to
all state regulations regarding development in
VHFHSZ, as well as Pacifica General Plan policies.
695
Letter Commenter Date Comment Combined Response
Individuals (C)
I had occasion to have a long chat with someone
associated with the project. He was pushing the
project as much need infill housing. I find that to be
a very strange argument given it would constitute a
completely new housing development.

There should be no development atop San Pedro
Mountain.
696
C174: James Kremer, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C174-1 James
Kremer
3/8/22 I submitted personal comments on the SPSP DEIR
two weeks ago. At that time, I tried to emphasize
things I had personally identified in my review of the
initial DEIR file, mostly done before the City release a revised version, which had some corrections and was
more userfriendly.

Since then I have become aware of additional issues
that have been noted by others, in talking with
friends, reading online, and following discussions in
the Tribune. Here I annotate a more complete list of
items that I feel are of special importance. They are
itemized without lengthy explanations. My intent is
to offer a vote of support for their importance,
whether new or mentioned earlier. Many of my
bullets (denoted •) involve the Coastal zone as well
as the city at large.
• If material factual changes are deemed necessary, I
understand that California guidelines require a
changed version to be re-circulated for agency and
public review, especially if CEQA compliance is
affected. It seems to me that numerous substantive
changes meeting this criterion have been found. I
urge the City to do this, and add that it can be done
in a way
now that encourages greater inclusion of Pacifica
citizens.

The comment is noted. A lead agency is required
to recirculate an EIR when significant new
information is added to the EIR after public notice
is given of the availability of the draft EIR for
public review under Section 15087 but before
certification. As used in this section, the term
"information" can include changes in the project
or environmental setting as well as additional
data or other information. New information
added to an EIR is not "significant" unless the EIR
is changed in a way that deprives the public of a
meaningful opportunity to comment upon a
substantial adverse environmental effect of the
project or a feasible way to mitigate or avoid such
an effect (including a feasible project alternative)
that the project's proponents have declined to
implement. "Significant new information"
requiring recirculation include, for example, a
disclosure showing that:
(1) A new significant environmental impact would
result from the project or from a new mitigation
measure proposed to be implemented.
(2) 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.
(3) 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.
(4) The draft EIR was so fundamentally and
basically inadequate and conclusory in nature
that meaningful public review and comment were
precluded. (Mountain Lion Coalition v. Fish &
Game Com.(1989) 214 Cal.App.3d 1043).
(b) Recirculation is not required where the new
information added to the EIR merely clarifies or
amplifies or makes insignificant modifications in
an adequate EIR.

C174-2 James
Kremer
3/8/22 The LCP (LCLUP) is correctly identified as directly implicated in many Policies. The decision to push
ahead with the DEIR, the GP, and especially the SPSP
before having a viable LCP is confusing, is inefficient and counter productive. Having a viable LCP is
essential, and it is NOT on the horizon.

The City of Pacifica started an LCLUP update in
2009 and continued its work through 2014.

Between 2014 and 2018, the update work
paused. Work on the LCLUP update resumed in
2019 with a series of five community meetings
and study sessions with the Planning Commission
and City Council. On February 24, 2020, the City
Council considered the Post-Consultation Draft
LCLUP and approved transmittal of the LCLUP to
the California Coastal Commission for review and
certification. The LCLUP was transmitted to the
Coastal Commission on June 12, 2020. Although
the LCLUP is a separate planning document, the
697
LCLUP policies and relevant narratives are
included in the General Plan Update to ensure
coordination between the two documents. The
City has prepared a draft of the LCP Update in
2019, approved by the City in 2020, and which is
currently under review for certification by the
California Coastal Commission. To the extent the
General Plan Update proposes any policies
beyond those which were sent to the California
Coastal Commission for review and certification, a
subsequent LCP amendment would be necessary
to make the LCP consistent with the General Plan.

C174-3 James
Kremer
3/8/22 Hazard maps and discussion do not use timely,
current Best Available Data, as they must. Indeed,
many maps are incomplete & inconsistent not only
with respect to content germane to policies, but also
even basic geography (sand beaches missing; RLF
habitats disagree).

This is untrue. Please see response to comment
C22-10 for more information on the adequacy of
hazards mapping. CLF occurrences are shown in
DEIR Figure 3.7-4; CLF critical habitat is shown on
DEIR Figure 3.7-3; this is not an inconsistency.

C174-4 James
Kremer
3/8/22 Many of the plans for Housing development have
been justified by City officials by reference to dire
needs of the State, some of which are mandated.

These justifications ring untrue for various
developments now and recently under consideration
for high-end luxury homes. Do Plan Policies have this
emphasis? Are the areas being promoted for
development consistent with the goals for affordable
housing?
The comment is not related to the adequacy of
the DEIR, therefore no further response is
required in the FEIR. However, the comment
addresses the content of the Proposed Plan and
will be shared with decision-makers in that
context. Please see Master Response: EIR
comments for more information about GP- or
SPSP-related responses.

C174-5 James
Kremer
3/8/22 The HPD ordinance regulates allowable development based on a single criterion, hillside slope. While I
strongly support the HPD and worry that frequent
recent variances are dangerously weakening it, it
certainly needs careful revision for corrections,
ambiguities, and inconsistencies. These should be
included in the Plan, not deferred.

C174-6 James
Kremer
3/8/22 More importantly, the city needs to add one or more protective overlays based on hazards (fire, landslide,
flooding, SLR) and protection (wildlife corridors,
stronger protective Implementation Policies for
protected species and habitats). Other cities do this
for hazards, and it is an appropriate planning
mechanism that should be in this EIR and G.P.

The commenters' preference is noted.

Compliance with federal, state, and local
regulations, in addition to Proposed Plan policies,
already reduce impacts to hazards and biological
resources to less than significant. Please
C174-7 James
Kremer
3/8/22 The Plan’s build-out scenarios consider a projection for growth, but do not consider the full allowable
build-out projections. Isn’t this important and
perhaps required?
Please see response to comment C4-1 and Master
Response: Buildout and RHNA for more
information on adequacy of buildout projections.

C174-8 James
Kremer
3/8/22 Residential development is well known to cost more in services than will be repaid in taxes. Lax
development actions, especially of high-end units
favoring real estate interests, will worsen the
financial condition of Pacifica in the mid- to longterm. Implementation policies should encourage tighter compliance with Growth Controls while
emphasizing housing that helps the city meet state
mandates.

C174-10 James
Kremer
3/8/22 Decarbonization, Electrification and Reach Codes should receive substantial explicit attention in plans
for the future of a city. Now they are essentially
missing.

The comment is noted. As the comment does not
address the adequacy of the environmental
analysis contained in the DEIR, no further
response is required.

C174-11 James
Kremer
3/8/22 Another DEIR for the Quarry has been released. Is it not a direct conflict to bring this forward? The
premise and the conclusion of the SPSP DEIR is that
the Proposed Alternative is for Palmetto, while the
Quarry as Alternative 1 is definitely not chosen. The
logical structure of the SPSP DEIR obviates substantial Quarry development. DEIR p. E-6 does try to suggest
the alternatives are a shift in balance, but that is not clear in stating the Proposed Project. In fact the new
Quarry DEIR weakens the main premise for the whole
DEIR. Do we really believe that the Quarry plan in its
EIR has been reduced in scope to conform to this
SPSP alternative?
The Quarry Reclamation Plan does not include
the development of any buildings or change in
use of the Quarry site. Any future development
on the Quarry site will require an application to
the City of Pacifica and a public review process.

The end result of the Quarry Reclamation Plan is
a safe site that is suitable for reuse in accordance
with City of Pacifica land use regulations. The
General Plan is the guiding document, and
proposes a Visitor-Serving Commercial
designation on the Quarry site. A land use
designation is implemented through more
specific zoning. While the Visitor Serving land
uses applies broadly to the area, zoning
implementation could provide different standards
to the subsection of this area. Thus, analysis of
the Draft DEIR is valid and adequate.

C174-12 James
Kremer
3/8/22 Public involvement of Pacifica citizens was far below what it should have been. Strong evidence is in the
frequent observation that few people are even aware
that the process is underway. The supposed logical
sequence of public meetings actually took place out
of order! The release of a DEIR file that was nearly
unusable (no search for text, no interactive TOC, etc.) further belies the contention that the City
encouraged active engagement by all citizens. This
can be improved as required revisions are now
undertaken.

A usable DEIR with an interactive TOC was
provided on Feb 14, 2022. The comment does not
relate to the adequacy of analysis in the DEIR,
thus no further response is required.

C174-13 James
Kremer
3/8/22 Growth Management” is only mentioned on p. 5-2
(thank you, searchable PDF file), and the Growth
Management Ordinance is unmentioned. That
ordinance makes it clear that it must be revised and
brought into compliance with a new G.P.: “On or
after June 30, 2020, this chapter shall be reviewed
and revised… to insure consistency with the City's
General Plan”. This ordinance has strong public
support. It MUST NOT be just allowed to expire just
because the Plan update is so slow. The new Planning
documents should address this mandatory update.

Additionally, Council should vote a temporary
extension until it an be considered in light of an
eventual approved G.P.

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.
699
C175: Dan Stegink, 3/8/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C175-1 Dan Stegink 3/8/22 LOWER LINDA MAR FLOODING
There are two sewer systems Sanitary Sewer
Overflow (toilets and most sinks), and Storm Sewer
(house gutters, street drains and beach drains) and
lower Linda Mar neighborhood has flooded with
sewage and storm water in December for almost
sixty years like clockwork, and is even deliniated as
a problem in the 1980 General Plan. As of 2015 City
of Pacifica had the highest volume of Sanitary
Sewer Overflows (SSOs) in the State of California
and even after completion of the $30M Sanitary
Sewer Equalization Basin, lower Linda Mar still
suffered single day SSOs of over three million
gallons, a regional record.

On Monday, March 16, 2020 the Department of
Public Works received a call regarding a fire at the
Anza Pump Station at the Pacifica State Beach that
had burned in a fire later determined to be
suspicious. Anza was one of two pump stations on
Pacifica State Beach (aka Linda Mar Beach).

Pacific City Council resolution 19-2020 (passed April
13 2020) concluded that the storm drain pumping
system was damaged during the fire and that the
engine and the motors would need to be replaced.

On Sunday October 24 2021(one year and seven
months later), under Mayor Sue Beckmeyer, Linda
Mar residents suffered a record breaking three
million gallon sanitary sewer overflow spill
#2SSO10100 of which only 1600 gallons was
recovered.

The head of Wastewater immediately resigned for a
job in a nearby city. The recently completed
Sanitary Sewer Equalization Basin had failed to
protect lower Linda Mar for even a single year.

On December 23, 2021 Lower Linda Mar flooded for
the third time in ninety days but this time the City
denied knowledge of any flooding based on a photo
they had seen on Nextdoor. City of Pacifica claimed
that pumps had been manned and automatically
turned on but walked the statement back a week
later stating that the Anza Pump station equipment
had mistakenly never been installed but the money
had been spent. The City of Pacifica is almost
bankrupt with a $2M annual structural deficit
projected in the next 24 months. Many current and
prior Wastewater employees believe that funds
allocated for sewer equipment including pumps has
been diverted into other departments to prevent
insolvency. An immediate audit of the Anza and
See response to comment C90-3.
700
Letter Commenter Date Comment Combined Response
Individuals (C)
Linda Mar Blvd Pump stations are necessary to
determine what equipment has actually been
installed and what funds remain of the previously
fully allocated money.

C175-2 Dan Stegink 3/8/22 SHELTER COVE
Residents have complained about additional
unreported oceanfront SSOs at APN 023-720-230
Shelter Cove Beach, Pacifica CA
Shelter Cove is a public beach accessed by a cliffside
set of stairs with 22 rental units (on APN 023-720-
230 ) with approximately 40 residents that does not
appear to be connected to the municipal sewer
system, and several times per month the strong
smell of sewage is discernible at the top of the cliff
above Shetlter Cove.

In 1982 the access road washed away and nearby
residents state they have not seen septic tank
trucks or boats in the area in a long time.

As of September 2019 there was no available record
of any inspection or service to any sewer system,
septic tank or leach field that exists on Shelter Cove
and concern was raised that units may be dumping
sewage directly into the ocean. City of Pacifica
planning inspectors had been unable to access the
site due to steep stairs. It is inappropriate for
Pacifica to encourage further development before
curing this horrible recurring sewage flooding
problem and the sewage problem should have
prevented Pacifica from ever appearing on the
State of California's HCD Pro Housing Designation
Highest Priority Development area map adopted in
Dec 2021.

The comment is noted. See response to
comment C175-1.
701
C176: Clif Lawrence, 1/29/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C176-1 Clif
Lawrence
1/29/22 "...we have a problem"
No one person is responsible. We all are.

WE need to fix this. It's going to take some
time...But that is what must be done.

General Plans must be "consistent". That's a
problem here. Some of it technical. Most of it is in
format. But it's also substance.

How does one review two documents for
consistency...when they do not share format.

How does one establish "correlations?" between
this DGP and DEIR?
Why is the average source age ten+ years old?
Why haven't we seen the use of other city's models
as facilitated by OPR in their program established in
2017?
What do we want to be our legacy?
What is the RUSH?
The DEIR analyzes how implementation of
the Proposed Project would affect the
environment, specifically, required topics of
CEQA analysis. The DEIR analyzes what
impacts might be significant, and how
compliance with regulations and policies
could potentially reduce any of these
impacts. Up-to-date sources referenced in
the DEIR chapters represent the best
publicly available science from reputable
public agencies; the bibliography changes
will be made to reflect these sources.
702
C177: Rick Nahass, 3/4/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C177-1 Rick Nahass 3/4/22
In light of the recent Proposed Sewer and Service
Charges letter - please also consider including fees
and funding even outside of transit to mitigate the
impact of municipal development. See links below
which mention that if included in the General Plan
then "Impact fees do not require voter approval."
https://lao.ca.gov/handouts/localgov/2020/Local_Go
vernment_Revenues_and_Impact_Fee-022420.pdf
https://www.hcd.ca.gov/policy-research/plansreports/docs/impact-fee-study.pdf Personally I will remain neutral on the Proposed
Sewer Service Charges.

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

C177-2 Rick Nahass 3/4/22 (1) For Public Transit and Transportation Demand Management: Replace the text 'SamTrans' with 'San
Mateo County Transit Authority (SMCTA) and the
Metropolitan Transit Commision (MTC).' The SMCTA
encompasses both SamTrans and Commute.org bus
operators as well as various Bicycle, Pedestrian
programs. The MTC originally established for regional
transit coordination has recently been given regional
authority to mandate fare integration (AB-629) and
authority through SB-917, Seamless Transit
Transformation Act, to
develop standards and processes to manage a single
Bay Area transit network and requires the 27 Bay
Area Operators to comply. State route 1 on the
Coastside is already congested beyond population
and visitor capacity.

Thank you for your comment. This
correction is noted and incorporated in
the DEIR.

As amended in December 2018, State
CEQA Guidelines Section 15064.3
(Determining the Significance of
Transportation Impacts) now specifies
that “vehicle miles traveled” (VMT) shall
be the most appropriate measure of
transportation impacts. VMT refers to the
amount and distance of automobile travel
attributable to a project. A project’s effect
on automobile delay and roadway
congestion, previously measured by “level
of service” (LOS), will no longer constitute
an environmental impact.

C177-3 Rick Nahass 3/4/22 (2) Establish a Vehicle Miles Travelled (VMT) Mitigation Bank - see
https://www.fehrandpeers.com/wpcontent/uploads/2020/04/VMTFees_Exchanges_BanksWhite-Paper_Apr2020.pdf - to manage future growth per vehicle miles travelled (VMT) SB- 743
environmental impact mandate.
• For each new housing unit require a 1 time
developer fee based on miles to the nearest high
quality transit stop (e.g., $2100 x 6 miles to Colma
BART = $12,600 per unit)
• For each new housing unit require a yearly owner
fee (tariff) based on miles to the nearest high quality transit stop (e.g. $160 x 6 miles to Colma BART =
$960 per year)
• SB-743 definition says "a high-quality transit
corridor means a corridor with fixed route bus
service with service intervals no longer than 15
minutes during peak commute hours." Add
specifications 'specific' to the coastside, for example:

Limited stops (3 from HMB to Montara, 2 in Pacifica
to BART, possibly continuing to GG Bridge), Coastside
Thank you for your comment. 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 SPSPrelated responses.
703
Letter Commenter Date Comment Combined Response
Individuals (C)
Commute Hours (M-F morning and evening, Sat-Sun
10AM-3PM) - don't want a bus operator to add
another bus to an existing route that takes 45
minutes to and hour to get to BART or Caltrain and
call it satisfying the SB-743 requirement.
• Possible exemptions or fee relief for low-income
housing development
• Councils sit on the commute.org Board. As housing
development is approved and potential fees
identified, a budget can be forecast for establishing
and growing a shuttle program based on capital
income (one time developer fee) and yearly
operating income (yearly owner fee)
• If a coastside transit corridor is established per the General Plan definition, then the fees are reduced.

See attached illustrative orksheet for Pacifica stops.
• This makes housing growth mandates (RHNA
ABAG) dependent on both developers' willingness to
pay to reduce VMT and Regional ransportation
Operators and Caltrans ability to deliver a high
quality transit corridor to the coastside. Also serves
to mitigate GHG, Climate and Circulation elements of
the GP.
704
C178: Christine Boles, 1/11/2022
Lette
r Commenter Date Comment Combined Response
Individuals (C)
C178
-1
Christine
Boles
1/11/22 Good evening you two. It’s been quite a day. A few things to share here, other things I’d rather talk about in person.

And Remi, I’ve been trying to meet with the City Manger and planning staff for over a year. They refuse. I encourage to try!
I spent most of my day talking to state agencies and a retired Planning Director who is giving me a lot of advice. What we’re after is making sure this update is the best possible document and it’s obviously going to require a lot of revisions, just based on the huge errors already found. The question is whether they’ll make the revisions or not, and that’s when we’ll need to carefully think about next steps, but that won’t be for a few months.

The most important things to do are to find the inconsistencies and errors in the EIR. That document they have to modify by law and they have to provide written responses to comments. Frame any comments so they have to answer a question, not be able to respond « noted ».

A friend divided up the document into its chapters so the files are smaller. https://drive.google.com/drive/folders/1RWZYA_LEfd6euiezXuQqBqZ1RXJH R3iY
Right now, the EIR is unruly, which makes it even harder for the public to access and review. Some people have trouble downloading and opening the files because they’re so large. Actually that’s something you can write to Christian and complain about. I would copy the council members on this too, but not your technical comments because they don’t understand them and then they just tune you out. I would also copy this official city email address. <[email protected]>
Dawn if you’re willing, I have a big task you could take on, or perhaps you two could split it.

Section 7-8 lists the stakeholder organizations that the city had to consult and interview as part of the drafting of the General Plan. Several of these have dates of 2009, and most have no dates at all as to when these interviews were conducted. 2009 is way too long ago, and even the fire department says 2009. The city says they conducted new meetings in 2019, but were these stakeholders actually consulted then? It would be great to call each one and find out. Best case for the city, they did their jobs and just need to update this form, worst case, they have to conduct new interviews, and other parts of the GP need to be updated.

I’m sure we’ll identify other ways to help after Friday if this is something you’d rather not do, no worries. And please start reading the EIR.

Woodhouse said yesterday that comments on the GP would be accepted later, all the way up to the Planning Commission hearing. But we’ve only got til 2/22 to comment on the EIR.

There are no
comments in this
letter. No further
response is required.
705
C179: Dawn Zidonis, 1/12/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C179-1 Dawn
Zidonis
1/12/22 I’d be haply to take on what you
described below. This might be farfetched but do we need to find a way to better inform residents of whats
happening? So few people are on
nextdoor, and I’m consistently finding
out about things happening in pacifica
after the fact. Wondering if we need to
send out letters, copies of the draft or
just go door to door and ask for
volunteers or help getting more
residents to pay attention to this?
My guess is most neighbors wont want
to be bothered with the stress of daily
life, but we might find a few more to
support. We have 3 new residents on
our street as well. This could be
something I could also help organize: a
packet for neighbors to share with
neighbors. Plus, we’ll have more allies
for anything that arises in the future.

There are no comments in this letter. No further
response is required.
706
C180: Irene Davies, 2/14/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C180-1 Irene Davies 2/14/2
2 Yes, please remove any physical
personal information so I don't have
strangers visiting or calling me.

There are no comments in this letter. No further response is required.
707
C181: Irene Davies, 1/21/2022
Letter Commenter Date Comment Combined Response
Individuals (C)
C181-1 Irene Davies 1/21/22 We need real affordable housing, not some developers' high price condos, or just adding ADUs to existing houses.

1. Develop affordable housing with joint partnerships of Fed/State/local governments/nonprofits, and get feedback from folks who are in need of continuous housing, not just the homeless. Don't leave folks out who are in between earning incomes.

2. Put high density (high rise) housing near transit hubs (bus stops or BART stations) for ease of transportation.

3. Each unit with partial rent toward ownership, more like a Co-op, rent to own.

4. Each unit occupants would participate in upkeep of common areas by rotation.

5. Each apartment/co-op would have an in-building rotating committee to oversee the whole complex common rules. Each unit would have a vote on everything.

6. Most or all units would be subsidized by the government.

7. Portion of the rent would be toward the upkeep of the buildings' such as elevators, structural inspections and repairs, exterior paintings, and other maintenance. An escrow account to be set up for the building maintenance fund that will be overseen by the building committee who are responsible and reporting to all the units.

8. No subletting of units within the building, each unit must be occupied by the people who live there.

9. Each high-density building could have basement parking; first floor retails/grocery/health clinics/cafes; second floor offices; and third to top floors residents (up to 20 levels), utility and people elevators, individual balcony per unit for green space, individual tankless water heater, washer/dryer, electric stoves, common garbage/recycle/compost at first level for ease of pickup. Each unit could have 1 or more bedroom(s), kitchen, bathroom, utility, living/dining areas, and outdoor balcony.

10. Roof tops serve as green roofs with walkable and play areas, separate smoking areas, garden space for residents with compost areas for gardens, and community gathering places with kitchens.

11. Build on non-erodible stable soil, away from flood zones or protect from floods, and earthquake proof buildings.

12. Obtain most of the energy from solar and wind farms, and/or add vertical solar panels to the side of buildings.

13. Architectural and landscaping layout of one or more high density buildings to provide maximum light exposure to each unit (step back), pleasing landscaping on the ground level, ease of reaching the first level retail shops, and transit pickups.

14. Group these high-density buildings with mixed use
purposes. Maybe one building can be a school, another be partial offices/clinics.

15. Have green spaces both at roof tops and also ground level.

16. Have design contests to generate good designs and get inputs from people who are interested in renting/ownership.

17. Have public groups which include various agencies, nonprofits, and potential low-income folks to develop the affordable housing plans.

C181-2 Irene Davies 1/21/22 Below are comments to both the City of Pacifica General Plan and to the Draft Environmental Impact Report.

Comments on the City of Pacifica General Plan
Need to provide an executive summary in the City of Pacifica General Plan to summarize the overall general plan. Do not just copy selected sections into the executive summary.

Both the General Plan and DEIR should be parallel to each other with the same alternatives mention in each document. I did not see any clear alternatives mentioned in the General Plan and the Draft EIR switched from Alternatives numbering to alphabets.

The general plan need to provide a recommendation and
conclusion sections and summarize these into the executive summary.

P18, Complete streets
Need to have alternative or secondary bypass routes in case Hwy 1 is obstructed and people will have another mean of egress in case of fire or other emergencies. See attached map of suggested short sub routes to bypass Hwy 1 during
emergency.

P21, Section 1.4 Plan themes and key initiatives
Open space preservation and trail system expansion
What about wildlife corridor crossings at various road
obstructions so wildlife can move from one open space to another without injuries. See attached map of sub routes (alternate routes) and wildlife corridors locations.

Sustainable development and practices
What about high-density development away from coastal area such as east of Hwy 1?
Creating a destination for tourism
Congestion is not a significant
impact under CEQA.

Furthermore, please see Master
Response 8 regarding emergency access.
709
Letter Commenter Date Comment Combined Response
Individuals (C)
What about revitalize some or all of the existing commercial areas for better functional tourism, local residents, and away from vulnerable coastal area due to climate change and sea level rise?
Have one or more places where we can have weekly food
trucks for tourists and local. What about at the Sea Bowl area by Sea Bowl Lane. This place could be developed into a highdensity tourist area.

P1-13 Sharp Park specific plan for new stores and restaurants What about the coastal commission concerns on management retreat, vulnerable coastal erosion, climate change, sea level rise, and tsunami? Consider including some of the graphic layouts that are within the DEIR into this report for visual understanding: See identified Figures below.

P591, Fig 3.9.4 Impacts on views looking south, 35 feet (current height maximum)
P591, Fig 3.9-5 Impacts on views looking south, 45 ft
P591, Fig 3.9-6, Impacts on views looking south, 55 ft
P592, Fig 3.9-7, Impacts of views looking west, 2212 Beach Boulevard Site
P593, Fig 3.9-8, Impacts of views looking west, 2212 Beach Boulevard site, with pedestrian pathway
P593, Fig 3.9-9 Impact of views looking west, 2212 Beach Boulevard site, with pedestrian pathway and upper stepback P22-P23 Diversity of Housing n population
Will need more high-density housing away from coastal area and sea level rise. Where are the affordable housing for low income, homeless, and van living folks? We need a place for the van living and homeless so they don’t pollute our beach and wetland environment any further.

P23, Infrastructure improvements
Need a bypass around Hwy 1 in case of emergency. Need to plan for electric car charging stations. See attached map of sub routes (alternate routes) and wildlife corridors locations.

P23, Protection from natural hazards
Develop building codes that prohibit developers and
homeowners from developing on unstable land slope, and also need to take account impact to downslope drainage, sea level rise, climate change, earthquake, soil liquefaction.

P25, Sharp Park Specific Plan
Bad idea to do long term development of Sharp Park west of Hwy 1 due to coastal management retreat, climate change, sea level rise, tsunami, beach erosion, and other hazards. If the City can mitigate all of these issues, maybe we can move forward and let everyone know that the various hazards are still in place to avoid future lawsuits.

Once all the known hazards mentioned in the above paragraph are mitigated, to draw in more tourism, maybe create a
boardwalk like Santa Cruz with smaller rides, food court, or 710
Letter Commenter Date Comment Combined Response
Individuals (C)
food trucks area, and a visible Visitor Center with maps of local attractions. Develop local tourist buses that only go to all the local areas. People would pay a nominal daily or monthly fee to use this local buses.

P26, Rockaway Beach specific plan
Same bad idea as for Sharp Park specific plan unless can mitigate all the known hazards. See above comment.

P30, 2.1 Vision and Priorities
Revitalize all the existing commercial areas, but keep in mind of climate change and sea level rise.

Better to revitalize on the east side of Hwy 1 due to coastal management retreat, sea level rise, climate change, tsunami, earthquake, beach erosion, and other hazards.

P41, 2-13, Rockaway Beach Quarry site photo
This is a high potential for development as long as we are smart about coastal management retreat, sea level rise, climate change. Would need to be able to mitigate for all of these hazards before we can develop this area and also set aside green space for wildlife.

P46, 3 Community Design
P48, Fig 3-1 Urban Structure
Need a short sub-route between Rockaway and Vallemar, short sub-route between Vallemar to the Sharp Park Road entrance, from there people can escape by way of Sharp Park Road or go thru Palmetto Ave to either Manor Drive or Hickey Blvd during emergency evacuations and when Hwy 1 is blocked. See
attached map of sub routes (alternate routes) and wildlife corridors locations.

See suggested high-density developments.

P49, Balance of Activity Centers
Provide local buses for locals and tourist and charge a daily or monthly nominal fee to use the service.

P50, 3.2 Neighborhoods and District
Need a place for the homeless and van living folks away from the beaches due to daily environmental wastes generated and polluting our beaches, roads, and wetland areas.

P51, Commercial and mixed-use districts
Need high density housing and mixed use at these areas as long as the City is taking into account Coastal management retreat, climate change, sea level rise, earthquake,
liquefaction, down slope drainage, and other hazards.

P52, Fig 3-2 Illustrative urban form: Eureka Square
Good plan for high-density housing and mixed use at this location. Maybe even higher height density. Could even have parking at the ground level and green space on top of the parking area, input solar panels also.
711
Letter Commenter Date Comment Combined Response
Individuals (C)
P55, 3.3 Hillside and coastal development
P56, Fig 3-3 Visual Resources
Need to pay attention to slope stability, erosion, watershed drainage, impact to downhill drainage, impact on views, liquefaction, earthquake, and include wildlife corridors.

P62, 4 Land use
P67, fig 4-3 Land use diagram
P68, High density residential
Maybe allow higher density height more inland and flat area, and lower density height along coastal area. step back slope height is a good idea per the DEIR figures:

Increase density in already existing high-density area. Need to preserve open space, especially on slope areas. Need
affordable housing and not just let the developers pay off affordable housing with nominal fee. See attached suggestion on high-density development.

Nice the idea of step back high-density buildings to reduce sun shadowing.

P72, Coastal Development
What is being done to balance development west of Hwy 1 with climate change and sea level rise?
P73, Fig 4-4 Hillside preservation
It is definitely in our best interest to preserve the existing hillside due to potential of erosion, liquefaction, earthquake, and unstable soil if we try to build on top of steep slope. We also need to preserve these hillsides for the wildlife.

P74, Transfer of Residential Development Rights.

It is not ok to force long time residents to move from their homes just so the City can transfer the land to developers.

There must be above market payout to the residents or if the residents choose not to move so they are not being forced out by eminent domain.

P76, fig 4-6 Pacifica North
The city needs to find a place with bathroom facilities and garbage bins for the van folks who are currently parking behind Manor Plaza and other locations since they are generating garbage and human wastes that are polluting our roads and beaches. Also need to find a place for the homeless folks who are impacting our wetland areas.
712
Letter Commenter Date Comment Combined Response
Individuals (C)
P77, Below market rate program
Developers must provide below market rate housing at their developments, not by paying off a nominal fee or set aside somewhere else.

P77, Accessory residential units
ADUs are fine, but they don’t solve the housing problem.

Better to have higher density housing at current high-density areas, or areas away from coastal zone. See attached
suggestions for high-density developments.

See attached suggestion for high-density developments.

P80, East Sharp Park, Milagra Ridge, Gypsy Hill
Need a wildlife tunnel underneath Sharp Park Road so wildlife can access the Milagra Ridge without being hit by vehicles. See attached map of propose wildlife corridor tunnels/crossings.

P81, fig 4-7 Pacifica Central
P84, fig 4-8, Pacifica Southwest
P87, fig 4-9 Pacifica southeast
The city needs to find a place with bathroom facilities and garbage bins for the van folks who are currently parking behind Manor Plaza and other locations since they are generating garbage and human wastes that are polluting our roads and beaches. Also need to find a place for the homeless folks who are impacting our wetland areas.

Page 101 ends

Pacifica City CouncilJuly 11, 2022

Pacifica City Council
July 11, 2022