Pacifica City Council
July 11, 2022

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 12 the field. The extensive seasonal pond likely represents flooding patterns prior to partial filling of the wetlands.

Flooding patterns delineate undrained depressions of shallow open water in a matrix of saturated soils in San Pedro Field following heavy rainfall. December 26, 2005. View to N.

Shorebirds (likely sanderlings) forage in the seasonally saturated and flooded field during high tide and storm wave conditions that restrict foraging habitat availability on the adjacent San Pedro (Pacifica State) Beach. December 27, 2005, prior to unauthorized ditching of the field. Red-necked phalaropes also forage in the saturated to flooded field during winter storms.
2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 13 January 19, 2006. Manual excavation of drainage ditches in flooded field at the east end of the field. Grass grows above water surface. Water in bare spots can be seen as reflected sunlight on the field; emergent unvegetated mud is dark brown.

2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 14 During discing of the field in summer, the berm along the east end of the field was mechanically breached at multiple locations to connect new drainage ditches (excavated in seasonal wetlands of the field) to the large drainage swale occupied by California red-legged frogs, draining to San Pedro Creek through culverts at the northwest end.

August 20, 2006.

Despite new unauthorized ditching and drainage connections of the field, ditches merely reduce the extent and duration of soil saturation and flooding; they do not eliminate wetland conditions in the winter following ditching.

December 27, 2006
Today, wildlife in the seasonal wetlands of the Pedro Point field includes shorebirds, meadowlarks, black-tail deer, tree frogs, small mammals, and raptors, all of which move between the field wetlands, the adjacent drainage swale wetlands, uplands, and the mouth of San Pedro Creek. Sanderlings and red-necked phalaropes occur intermittently in the flooded to saturated fields, particularly during high tides and storm wave conditions that flood the beach.. In summer, meadowlarks inhabit the field some years, particularly when grass and forb vegetation cover is thick. Small mammals, including mice, pocket gophers, and voles, occur frequently in the field (indicated by burrows, runs) and provide a prey base for raptors, including great horned owls (roosting in eucalyptus trees near the field), and red-tail hawks. Deer browse in the field at night, and at times in the morning as well. The marsh swale bordering the east end 2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 15 of the field has supported a breeding population of tree frogs (Pseudacris sierra) and a population of federally listed threatened California red-legged frogs (Rana draytonii) most years at least since 2000 (see special-status species, below). The DEIR fails to disclose intermittent red-legged frog populations in the vicinity (and sometimes directly bordering) the field, and the existence of probably nocturnal foraging habitat (for this species spring-fall non-breeding adults) within in the field itself. The DEIR failed to identify these significant wildlife movement and habitat connections between the field and habitats in its wetland setting. The DEIR fails to analyze potentially significant impacts to red-legged frogs using the field that would be affected by proposed conversion to coastal residential mixed use development.

The DEIR’s failure to correctly characterize the wetland environmental setting (the wetland complex comprising the San Pedro Creek mouth wetlands, the drainage swale wetlands, and the historical and existing condition of the Pedro Point field wetlands) prevents the DEIR from accurately analyzing potentially significant cumulative impacts caused by wetland habitat loss, degradation or fragmentation in the lower San Pedro Creek corridor, and the Pedro Point neighborhood.

Given the outstanding biological significance of the field as the only open, level (flatland) space left in the Pedro Point neighborhood, and despite years of being the focus of substantial public concern and comment in scoping and other public meetings, the DEIR’s failure to provide even minimally accurate, consistent baseline environmental description of the field is a very serious defect in the DEIR.

It precludes accurate assessment of potentially significant impacts that are not mitigated at the policy or site-specific level.

1.6. Biological Resource Impact Assessment and Mitigation in the DEIR Despite identifying wetlands occurring potentially throughout the field, the DEIR fails to assess potential adverse, significant impacts to Coastal Act wetlands from the proposed land use designation changes at the Pedro Point Field. The DEIR provides no explanation why converting existing wetlands of the Pedro Point field to residential mixed use development would have no significant biological or land use policy impacts. The DEIR omits any specific reference at all to the Pedro Point field wetlands in discussion of biological impacts.

Further, the DEIR’s cumulative impact analysis must consider that the extent of Coastal Act wetlands in the field was modified by ditching and drainage activities conducted by the landowner and assistants on January 19, 2006, during conditions of saturation and widespread flooding of the field. As far as I am aware, ditching and draining activities of these wetlands occurred without issuance of a Coastal Development Permit or analysis of environmental impacts. The apparently unauthorized drainage of the field probably results in underestimation of the actual extent of proper Coastal Commission jurisdictional wetlands in the field. See wetland history, below. The errors in the DEIR’s environmental baseline, described above, contribute to basic errors in assessment of significant biological impacts and mitigation to wetlands and special-status species.
2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 16 The DEIR identifies only two potential general city-wide biological impacts, without areaspecific reference to Pedro Point neighborhood and the specific land use changes proposed in the revised General Plan. Both of these impacts are incorrectly assessed with respect to Pedro Point biological resources, and their proposed programmatic (policy-level) mitigation is infeasible applied to Pedro Point field.

Figure 3.1-2 of the DEIR (p. 3.1-9; “Existing General Plan Land Use”) shows the majority of the Pedro Point field mapped in red (“Commercial”), and apparently one small lot in the northwest corner of the field mapped in light yellow-orange (“low density residential”). The biological impacts of this proposed land use change must be assessed at a programmatic level, commensurate with the level of detail of land use designation change in the programmatic EIR at neighborhood-scale. The DEIR, however, fails to assess biological impacts at this geographic scale even at a programmatic level. It merely assesses biological impacts at a sweeping, vague, city-wide, policy level, omitting neighborhoodlevel biological impacts of specific land use changes proposed (DEIR p. 3.7-48 Impact 3.7-1; p. 3.7-57, Impact 3.7-3). The DEIR also provides only vague, policy-level “mitigation” (pseudo-mitigation; purely speculative policy without reference to physical or biological conditions) for land use change impacts in the aggregate, city-wide:

Impact 3.7-1 Implementation of the proposed General Plan would not have a substantial adverse effect, either directly or through habitat modifications, on candidate, sensitive, or special status species identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service. (Less than Significant)
Impact 3.7-3 Implementation of the proposed General Plan would not have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. (Less than Significant)
The DEIR provides no substantial evidence and no arguments for either impact findings or their level of significance. It is inconsistent with proposed land use changes (coastal residiential mixed-use development) for the field, and the presence of extensive seasonal wetlands and adjacent special-status species populations.

Although the DEIR does not need to assess impacts of land use change at a project-specific level (i.e., it cannot speculate about the design of specific project proposals or their impacts in site-specific detail), it must address biological impacts that are reasonably foreseeable for the type of land uses proposed in the environmental setting under existing conditions. There is only one major land use change proposed in Pedro Point, and the DEIR provides no biological impact or mitigation discussion about it at 2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 17 all – not even the cursory programmatic wetland discussion presented in the Draft Land Use plan itself (LUI-30, p. 4-36, Pacifica Draft Land Use Plan, March 2014). The boilerplate, standard wetland permit discussion in the DEIR at p. 3.7-42 has no substantial bearing on impact or mitigation analysis for wetlands at Pedro Point.

Potentially significant biological impacts of proposed residential land use (development) at the Pedro Point Field and adjacent habitats are enumerated below. These are based on a more adequate characterization of the Pedro Point field wetlands, their relationship to San Pedro Creek wetlands, and their wildlife and hydrological attributes described above. None of these potentially significant biological impacts were analyzed in the DEIR.

Coastal Zone Wetland impacts
o Direct filling (loss) of the last coastal zone seasonal wetlands in Pedro Point watershed due to residential development. Lack of available off-site compensatory mitigation area within the coastal zone of the San Pedro Creek watershed (no feasible compensatory mitigation).
o Degradation of remaining coastal zone wetlands (wetland swale east of field) the San Pedro Creek watershed due to hydrological changes; increased impermeable surfaced area, decreased groundwater infiltration, increased storm runoff from drained residential lots within basin (historic floodplain).
o Degradation of remaining wetlands (wetland swale east of field) due to increased contaminant loading from adjacent residential development: pesticides (residential pesticide use and pesticide loading from runoff and drainage), increased petroleum hydrocarbon contaminant loads from street and driveway runoff; increased surfactant runoff to the drainage swale from residential car washing.

Wildlife and Special-status species impacts
o Loss of storm high tide refuge habitat for shorebirds o Loss of meadowlark foraging habitat
o Loss of nocturnal deer browsing habitat
o Loss of raptor foraging habitat (Great Horned Owl, red-tail hawk, kestrel) o Loss of terrestrial foraging habitat for California red-legged frogs o Loss of flood refuge habitat for California red-legged frogs during peak flood events of San Pedro Creek.
2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 18 2.0 Land Use Impacts – Coastal Zone
The DEIR proposes to change the land use designation of the Pedro Point field from “Commercial” (Pacifica General Plan, pp. 86 and 90; DEIR Figure 3.1-2) to “Coastal Residential Mixed Use“ (CRMU; DEIR Figure 2.2-1). The DEIR inaccurately states that the new proposed CRMU designation corresponds with an existing “Mixed Use” land use category (Table 3.1-3), but no such independent or category or subcategory of “mixed use” exists in the 1980 General Plan; “mixed use” is simply described as a contingent allowable use of “commercial” land use in the original General Plan (1980 General Plan p. 32-33). The project description is inconsistent, incorrect, and confusing in terms of existing and proposed land uses.

The 2014 Draft General Plan Land Use element states the following with regard to the CRMU designation on p. 4-24: “The Plan retains flexibility for any future development on the vacant site west of the shopping center, which could have residential and small-scale commercial and visitor-oriented uses.

Future development should include a small park and access to the berm and the beach beyond”. Table 4.1 of the Draft General Plan states that residential density with CRMU designation may range between 10- 15 gross units per acre.

The DEIR, in contrast with the original 1980 General Plan, fails to assess even at a programmatic level the area-specific effects of proposed land use designations for the Pedro Point neighborhood, and specifically for the vacant Pedro Point field, in terms of land use impacts (cf. 1980 General Plan, pp. 84- 89). The DEIR gives no reason why the level of specificity for impact assessment should be broader and more programmatic than the level of specificity for individual parcel land use designations like the Pedro Point field, or why the level of neighborhood-specific assessment should be significantly less than that of the 1980 General Plan’s treatment of Pedro Point, especially in the Coastal Zone.

The existing land use designation of the field, “commercial” is compatible with low-intensity, visitorserving commercial recreational land uses that support coastal-dependent (beach and coastal scenic) recreation and associated economic uses, which matches the existing zoning (commercial-recreation) of the field. Low-intensity commercial land uses that do not involve ditching, draining, filling, paving, or construction in the field (open-space and recreational uses, special events, coastal agriculture) are potentially compatible with conservation of wetlands, environmentally sensitive habitat areas, and special-status species, and relevant Coastal Act policies. Proposed Coastal Residential Mixed Use land uses, however, are likely to have significant impacts on Coastal Act land use policies (cited in Draft Pacifica Local Coastal Land Use Plan, March 2014, Appendix A) and Pacifica General Plan policies involving these elements, as discussed below.

The extensive distribution of Coastal Act jurisdictional wetlands in the Pedro Point field, and the presence of California red-legged frog habitat and population in the adjacent freshwater marsh swale, 2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 19 both indicate that land use designations for the field must be compatible with ESHA policies of the Coastal Commission. According to the Coastal Commission’s LCP Update Guide: Sensitive Habitats and Natural Resources (April 3, 2007 update), the DEIR and LCP should clearly state that only “resource dependent” development, such as restoration or nature study, is allowed in ESHA, consistent with Coastal Act §30240. No ESHA assessment for the proposed changes in land use designation of the Pedro Point field has been provided in the DEIR, which is likely related to the DEIR’s failure to accurately identify wetlands and special-status species at the site. The DEIR must be revised to include this analysis of potentially significant environmental impacts even at a programmatic level.

The 1980 Pacifica General Plan provided a programmatic analysis of consistency between proposed (commercial) land use designation of the Pedro Point Field and specific Coastal Act policies (1980 General Plan p. 86), including assessment of unimproved coastal access through foot trails (p. 88).

The DEIR for the General Plan update has provided no such analysis for proposed changed land use designation of the field or coastal access impacts. It merely included the Coastal Act policies as an appendix, without analysis of proposed land use designation change impacts. The changed land use designation has potential significant land use policy conflicts (impacts) with Coastal Act land use policies, each of which affects ESHA (wetlands and special-status wetland-dependent wildlife). Some examples are provided below. The DEIR should fully assess at a programmatic level all such potential significant land use impacts, and compare the compatibility (conflict) of existing, proposed and alternative land use designations for the field in terms of Coastal Act policies.

Section 30212 New development projects
(a) Public access from the nearest public roadway to the shoreline and along the coast shall be provided in new development projects except where:
(1) it is inconsistent with public safety, military security needs, or the protection of fragile coastal resources,
(2) adequate access exists nearby, or,
(3) agriculture would be adversely affected.

Pedro Point field has three well-established and persistent foot trails that lead from San Pedro Avenue (the nearest public roadway to the shoreline) to a private beach with long-established open public access.

The foot trails are visible in aerial photographs dating back to at least 1993 (Google Earth images) and reemerge after being temporarily erased by discing, ditching, or mowing. The foot trails are formed by trampling patterns established between physical points of access from the roadway to a stairway from the beach to the historic railroad berm, and to a public path to the beach at the mouth of San Pedro Creek.

Foot trails are frequently used by beach visitors and surfers seeking minimal travel distances to the beach.

The foot trails evidently established long before the current ownership of the property. The foot trails are the most efficient short cuts from San Pedro Avenue to the public shore; alternative routes along public 2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 20 roads would nearly double foot trail distance from the public roads to the shore from established access points.

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

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

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

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

Pedro Pt
Field
2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 22 Detail of Pedro Point field foot trail connection to the public access walkway to privately owned beach (with public access) across the historic railroad berm. 2013 Google Earth image.

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

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

PEDRO POINT FIELD
stairs
2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

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

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

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

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

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

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

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

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

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

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

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

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

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

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

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

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

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

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

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

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

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

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

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

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

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 27 (whether or not they meet federal wetland criteria for fill authorization under the Clean Water Act) would conflict with this policy.

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

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

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

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 28 mitigation is identified. Furthermore, the DEIR alleges that no mitigation is even required because it wrongly asserts that there is no impact.

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

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

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

2-19-0026
Exhibit 8

Peter R. Baye, Ph.D.

Coastal Ecologist, Botanist
33660 Annapolis Road
Annapolis, California 95412

Peter R. Baye Ph.D.

Coastal Ecologist, Botanist, Pacifica General Plan Update DEIR comments 29 ATTACHMENT A – STATEMENT OF QUALIFICATIONS - Peter R. Baye, Ph.D.

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

 

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2-19-0026
Exhibit 9
Pa
ge 8 of 8
California Natural Diversity Database
Department of Fish and Wildlife
1416 9th Street, Suite 1266
Sacramento, CA 95814
Fax:

CNDDB Online Field Survey Form Report
www.dfg.ca.gov/biogeodata/cnddb/
Source code_____________________
Quad code______________________
Occ. no. ________________________
EO index no._____________________
Map index no.____________________
This data has been reported to the CNDDB, but may not have been evaluated by the CNDDB staff VAS20F0001
3712254
Scientific name: Rana draytonii
Common name: California red-legged frog
Date of field work (mm-dd-yyyy): 04-12-2020
Comment about field work date(s): Field observation in a drainage channel along road near my home on San Pedro Road
Observer: Michael C. Vasey
Affiliation: San Francisco State University
Address: 368 San Pedro Avenue , Pacifica, CA 94044
Email:

Phone: (650)
Other observers: Sheila Harman and Jon Harman

DETERMINATION
Keyed in: Visually and from close up photograph
Compared w/ specimen at:

Compared w/ image in: https://www.nps.gov/rlc/pacificcoast/california-red-legged-frogs.htm By another person:

Other:

Identification explanation: The individual frog was in drainage channel along road. Observation was about 3' away.

Close-up photo taken by Jon Harman (my neighbor) is attached Identification confidence: Confident
Species found: Yes If not found, why not?
Total number of individuals: 1
Collection? No Collection number:

Museum/Herbarium:

ANIMAL INFORMATION
How was the detection made? Seen
Number detected in each age class:

Age class comment: Appears to be juvenile (relatively small) but I'm not an expert adults juveniles larvae egg mass unknown
1 Level of survey effort: Low. Drainage channel along road. Drainage known to harbor CRLF in the past (a few years ago) but they have not been present recently.

OBSERVER INFORMATION
Submitted: 04/20/2020 VAS20F0001 Page 1 of 3
2-19-0026
Exhibit 10

Site use description: Drainage channel that drains water from Pedro Point down, across San Pedro Road, and then along east side of Calson field into a willow swale and then into San Pedro Creek near its entry into the ocean.

What was the observed behavior? Resting on floating vegetation half submerged.

Describe any evidence of reproduction: None observed.

SITE INFORMATION
Habitat description: Drainage channel along roadway
Slope: 0 Land owner/manager: City of Pacifica
Site condition + population viability: Fair
Aspect: standing water
Immediate & surrounding land use: 5 acre vacant field known to have been filled during mid 1900's, drainage channel flows east down to 'dogleg' bend and then along eastern boundary of the field until going under some culverts and a swale before entering San Pedro Creek near ocean
Visible disturbances: Recent tree trimming near site but frog observed to persist after this activity. Human and dog traffic into the field but frog about 2-3 feet below banks of channel so reasonably well protected.

Threats: Water could dry up but persisting due to run-off from neighborhood. Non-point source run-off could be polluted. Possible disturbance by people and dogs passing by.

General comments: First sighting of CRLF in around five years. Used to be a larger population, apparently breeding, in the dogleg portion of the channel near the road. So far, only one individual observed.

The mapped feature is accurate within: 5 m
Source of mapped feature: CNDDB Field survey form
ID
County
San Mateo
1 24K Quadrangle Elev. (ft) Latitude
NAD83
Longitude
NAD83
UTM E
NAD83
UTM
Zone
Montara Mountain 18 37.59432 -122.50808 543426 4160920 10 Public Land Survey
M T04S R06W 10
Feature Comment
Drainage channel in 2 feet of standing water
UTM N
NAD83

MAP INFORMATION
Submitted: 04/20/2020 VAS20F0001 Page 2 of 3
2-19-0026
Exhibit 10

Attachment(s): CRLF in drainage channel Pedro Point, Pacifica.pdf Mapping notes: Drainage channel along north side of San Pedro Road near junction with Grand Ave in floating algae but clearly visible. Frog has been there persistently since first observed.

Location/directions comments: Take turn off from Hwy 1 and San Pedro Road, cross creek by shopping center, take big curve by Ace Hardware, just past Grand Ave is the drainage channel on north side of road.

Submitted: 04/20/2020 VAS20F0001 Page 3 of 3
2-19-0026
Exhibit 10

Presumed California red-legged frog in drainage channel along San Pedro Road – Observed by Sheila Harman, Jon Harman, and Michael Vasey on April 12, 2020. Photo by Jon Harman. 2-19-0026 Exhibit 10

STATE OF CALIFORNIA – CALIFORNIA NATURAL RESOURCES AGENCY GAVIN NEWSOM,

GOVERNOR

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

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

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 2 • Wood Biological Consulting. One-Parameter Wetland Delineation for the Proposed NorCal Surf Shop Mixed-Use Development, San Mateo County, California (CDP Application 2-19-0026). Prepared for Shawn Rhodes, 5460 Pacific Coast Highway, Pacifica, CA 94044; May 14, 2019.

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

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

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

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

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

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

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

Biological productivity; water quality
The biological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes 3 Baye, P. 2014. Letter to City of Pacifica RE: Draft Environmental Impact Report for the Pacifica General Plan Update Project – SCH #2012022046. 29pp
4 Baye, P. 2014. Ibid.
5 City of Pacifica. 2018. 505 San Pedro Avenue Project Initial Study/Mitigated Negative Declaration, Public Review Draft. April 2018. 2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 4 appropriate to maintain optimum populations of marine organisms and for the protection of human health shall be maintained and, where feasible, restored through, among other means, minimizing adverse effects of waste water discharges and entrainment, controlling runoff, preventing depletion of ground water supplies and substantial interference with surface waterflow, encouraging waste water reclamation, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing alteration of natural streams.

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

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

6 United States Army Corp of Engineers jurisdictional wetlands, based upon the presence of all three parameters (hydrology, vegetation and soils), totaled 0.088 ac; Coastal Commission wetlands, based upon the presence of at least a single parameter, totaled 0.248 ac. 2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 5 northern end, in the Commission’s jurisdiction). Of note is that the increase in area delineated in 2019 relative to what was reported from 2005 (Thomas Reid Associates 2005a) supports observations also made by Dr. Baye that wetland areas have expanded at this location.7
According to estimates provided in the analysis of the November 2019 wetland delineation, the proposed development would occur inside the wetland boundary at the arroyo willow thickets where a retaining wall to support an existing earthen berm and proposed pedestrian pathway along the full length of the subject parcel would be constructed. Figure 5 illustrates that the retaining wall would in fact encroach roughly 20 ft into the willows and directly remove wetland habitat; however, the project fails to qualify as an allowable use under Coastal Act §30233 and moreover, the willow stand also qualifies as ESHA (see next section). Elsewhere along the length of the drainage, the retaining wall would be sited no more than 11 ft from the delineated Commission wetlands while the buildings and other development features would sit between 9 and 30 ft of the wetland boundaries at their nearest points.

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

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

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

7 Baye, P. 2014. Ibid.
8 For example, see: Blackman and O’Connell (A-2-PAC-15-0046) where wetland buffers surrounding a willow stand were reduced to 50 ft, or Trask (A-1-DNC-07-036) where wetland buffers surrounding emergent vegetation were reduced to a minimum 68 ft. 2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 6 determinations.9 An ESHA determination may also be made on the basis of an area constituting ‘especially valuable habitat’ where it is of a special nature and/or serves a special role in the ecosystem, such as providing a pristine example of a habitat type or supporting important ecological linkages.

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

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

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

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

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

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

61.201.01) in California Sensitive Natural Communities list (version: September 9, 2020) – accessible online at https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153609&inline. 11 Bolsa Chica Land Trust v. Superior Court (1999) 71 Cal.App.4th 493 2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 7 (Scirpus microcarpus), is represented at this site and though unranked, is considered sensitive.12 The species is an obligate wetland indicator and like the arroyo willow, is necessarily treated under wetland policies but warrants the protection of a 50-ft buffer due to its ecological significance. Species such as the California red-legged frog (see below) frequently use bulrush habitat for breeding.

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

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

12 See Small-fruited Bulrush Marsh alliance (CaCode: 52.113.00) and Scirpus microcarpus association (CaCode: 52.113.01) 13 California Assembly Bill 2364, approved June 28, 2014 - http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201320140AB2364 14 USFWS. 2004. Federal Register: Endangered and Threatened Wildlife and Plants; Proposed Designation of Critical Habitat for the California Red-legged Frog (Rana aurora draytonii); Proposed Rule. 50 CFR. Part 17. Vol 69. No. 71: 19620-19642. 15 Fellers, G. 2005. Rana draytonii Baird and Girard, 1852b California red-legged frog. Pages 552-554 in M. Lannoo (editor). Amphibian declines: the conservation status of United States species. University of California Press. Berkeley, California; CWHA database 16 Bulger, JB, NJ Scott Jr. & RB Seymour. 2003. Terrestrial activity and conservation of adult California red-legged frogs Rana aurora draytonii in coastal forests and grasslands. Biological Conservation 110(1): 85-95. 17 Fellers, G. 2005. Ibid. 18 Hayes, MP & MR Tennant. 1985. Diet and feeding behavior of the California red-legged frog, Rana aurora draytonii (Ranidae). The Southwestern Naturalist 30(4): 601-605; Fellers, G. 2005. Ibid. 2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 8 Key threats to CRLF are recognized as habitat loss, urban encroachment, and the introduction of non-native species such American bullfrogs that can compete with CRLF for habitat as well as prey upon them. Several introduced freshwater fish species are also known prey on CRLF. Herbicide and pesticide use as well as disease may be other significant threats to CRLF, as has been documented for many amphibians around the globe.19 Prior to April 2020, we were unaware of any records affirming the presence of California red-legged frogs (Rana draytonii) at the subject parcel or its immediate surroundings although it has been well-documented at nearby San Pedro Creek.20 While I and the consulting reports I had initially reviewed for this project considered the species to have at least a moderate potential to occur given records from the nearby creek, there has also been recognition of the degraded state of the subject parcel and adjacent drainage as relatively unfavorable when compared to nearby habitat opportunities. No published record had appeared in the California Natural Diversity Database (CNDDB) beyond the creek’s main channel, the project’s IS/MND, or the other known reports for the location that staff generally relies upon. In addition, recent neighboring developments within the City’s jurisdiction along San Pedro Avenue had truncated the drainage’s corridor extension to more forested areas in the south and potential foraging, aestivation, and dispersal areas to the east (Figure 2). As such, my recommendations had focused on the wetlands and ensuring that appropriate measures would be taken during construction, in the off chance a frog was encountered.

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

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

19 Davidson, EW, M Parris, JP Collins, JE Longcore, AP Pessier, & J Brunner. 2003. Pathogenicity and transmission of chytridiomycosis in tiger salamanders (Ambystoma tigrinum). Copeia 2003(3): 601-607. 20 CNDDB records for Occurrence Number 652 cover the lower half-mile of San Pedro Creek since 2002, when a total of 5 frogs were recorded from approximately 0.2 mi north of the subject parcel; reports since 2014 have more frequently detailed occurrences, including as many as 129 frogs caught in June-October in 2014 and notes that that adults were observed year-round in 2015. Egg masses were documented in 2014 and 2015.
21 Vasey, M. (personal communication, April 18, 2020)
22 Harman, S. (personal communication, April 24-29, 2020) 23 Vasey, M. (personal communication, April 29, 2020)
24 Baye, P. 2014. Ibid.
2-19-0026
Exhibit 11

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

25 Baye, P. 2005. Letter to United States Fish and Wildlife Service RE: Documentation of California red-legged frog occurrence at Pedro Point, Pacifica, San Mateo County. May 4, 2005.
26 https://www.drought.gov/historical-information for January 2017 27 For example: United States Fish and Wildlife Service. Consultation Letter to United States Army Corps of Engineers RE: Formal Consultation on the San Pedro Terrace Project in San Mateo County, California. Reference #08ESMF00-2017-F-1370. April 5, 2018. 28 UC Santa Cruz Marine Science Campus - Coastal Long Range Development Plan. January 2017. 344pp. 29 https://www.drought.gov/historical-information for March 2015 and April 2020 2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 10 the subject parcel. Though these avenues of dispersal are perhaps not the most idyllic, the species is capable of having used any variety of these. Finally, the consultant argues that the location is unlikely to provide “consistent, stable long-term habitat for [CRLF] over time” and that it would likely be considered a population sink. However, CRLF is known to use (and require) a mosaic of habitat types across the landscape and we cannot ignore that the species has been documented using this location intermittently for decades, even in the absence of focused study.

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

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

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

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

The recent repeated daytime observations of multiple CRLF at the roadside end of the drainage indicates that even in the absence of formal surveys, the area has been functioning as habitat for more than an individual transient CRLF. Consideration of this, the multiple reported occurrences of CRLF at the drainage since at least 2005, and the concurrence of information from colleagues at partner resource agencies informs my revised opinion that CRLF occurrence here is not a moderately hypothetical possibility but in fact, a demonstrated pattern of use. Given the connection to San Pedro Creek, including by way of the underground culvert, the observations of CRLF near San Pedro Avenue, wetlands, and evidence of the drainage’s role as a green corridor year-round, the full length of the drainage adjacent to the subject parcel should be considered habitat. In addition, because CRLF requires not only wetted areas but also makes use of upland habitats for foraging, dispersal, and estivation, this habitat is very likely extends to adjacent upland areas on either side of the drainage. Though we cannot presently delineate the full extent of CRLF use in these areas without protocol-level surveys, we can interpret that at a 2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 11 minimum, the drainage itself constitutes ESHA and is likely functioning as a habitat corridor for this species between San Pedro Creek and upland areas.

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

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

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

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

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

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

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

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

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

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

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 13 Figure 1a: 505 San Pedro Avenue parcel (approximated in yellow) as situated in the broader surrounding landscape, and b: relative to specific features including the adjacent drainage (approximated by dashed white arrow), scour pool (red asterisk), and willow thickets. restored wetlands
forested area,
minor drainages
open field
(grassland, likely
wetlands)
willow
thickets
*
restored wetlands
open field
(grassland, likely
wetlands)
2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 14 Figure 2: CDFW Biogeographic Information and Observation System (BIOS) Viewer display of the California Aquatic Resources Inventory (CARI) stream layer and California Natural Diversity Database (CNDDB) records surrounding the subject parcel (yellow box). CARI data shown as blue lines, including the drainage immediately west (left) of the parcel and San Pedro Creek (far right). Red thatching represents areas with known occurrences of California Red-Legged Frog.
2-19-0026
Exhibit 11

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

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 16 z
f
e
g
subject parcel
field
subject parcel
field
subject parcel
field
(forest)
2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 17 Figure 4: Subset of larger aerial time series (2002-2020) of the subject parcel (yellow box) and the surrounding landscape, showing wet versus dry season patterns of vegetation. Note how the drainage immediately adjacent to the subject parcel consistently provides a green corridor and effectively links San Pedro Creek with the open field to the west while providing a valuable secondary connection to the forested habitat south of the site.

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

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 18 May 2010
September 2003
2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 19 April 2020
July 2020
recently developed parcels
& interrupted tree canopy
recently developed parcels
& interrupted tree canopy
2-19-0026
Exhibit 11

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

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 21 Figure 6a: CRLF as observed at San Pedro Avenue on April 12, 2020 by Michael Vasey, Sheila Harman and Jon Harman (photo credit: Jon Harman); b-d: CRLF as observed at San Pedro Avenue on April 23, 2020 by Sheila Harman. Individual CRLF circled in white for visibility.

a b
c d
2-19-0026
Exhibit 11

20210125 MEMORANDUM: 505 San Pedro Avenue – L. Garske-Garcia | 22 Figure 7a: From San Pedro Avenue, looking northeast, view of scour pool in drainage with subject parcel as grassy area immediately behind the fence, and b: CRLF observed in scour pool by Peter Baye. Photos by Peter Baye, as submitted to USFWS in May 4, 2005 letter.
a
b
2-19-0026
Exhibit 11

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

Approximate
site location
2-19-0026
Exhibit 11

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

GRASSLAND &

WETLANDS

RIPARIAN
FOREST

CEHC FEATURE

CEHC FEATURE
2-19-0026
Exhibit 11

From: Terry Watt [
Sent: Tuesday, March 8, 2022 5:16 PM
To: 'Nick Lusson' [ Public Comment [[email protected]] CC: 'Sydney Sulak' [ 'Cassie Leonardi'
[ 'Xavier Macy' [
Subject: RE: public comment on DEIR
[CAUTION: External Email]
Excellent and nice letterhead!
From: Nick Lusson <
Sent: Tuesday, March 8, 2022 5:07 PM
To: [email protected]
Cc: Sydney Sulak < Cassie Leonardi < Xavier
Macy <
Subject: public comment on DEIR
Please see the attached for our public comment. Thank you! Nick Lusson
Sydney Sulak
Cassie Leonardi
Xavier Macy
(Protect San Pedro Mountain Operations Team & all Pacifica residents) 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.

From: Woodhouse, Kevin [[email protected]]
Sent: Tuesday, February 1, 2022 10:10 AM
To:

CC: _City Council Group [[email protected]]; Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]] Subject: RE: Traffic Growth in Pacifica
Dear Ms. Sundstrom,
I have forwarded your General Plan comment to Deputy Planning Director Christian Murdock so it can be properly included in the public comments on the General Plan.

Sincerely,
Kevin Woodhouse
City Manager
City of Pacifica
www.cityofpacifica.org
650.738.7409
From:

Sent: Tuesday, February 1, 2022 9:45 AM
To: _City Council Group <[email protected]>; Woodhouse, Kevin <[email protected]> Subject: Traffic Growth in Pacifica
[CAUTION: External Email]
Good morning Pacifica City Council Members & Kevin,
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.

Regards,
Vicki Sundstrom
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.

From:

Sent: Saturday, February 26, 2022 9:18 PM
To: Public Comment [[email protected]]
CC:

Subject: Red Legged Frog Pedro Point
Attachments: IMG_3307.jpeg; IMG_1657.jpeg; IMG_0459.jpeg [CAUTION: External Email]
Hello,
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.

Gwendolyn Holden
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.

From:

January 19, 2022 7:52 PM
To: Murdock, Christian [[email protected]]
Subject: Request of time extension to review General Plan DEIR [CAUTION: External Email]
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 very much! Ellen Natesan 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.

From: Patton, Arlene [
Sent: Saturday, January 22, 2022 11:32 AM
To: Murdock, Christian [[email protected]]
CC: _Open Space & Parkland Advisory Committee Group
[OpenSpace&[email protected]] Subject: Request to Extend Comment Period another 30 Days for Draft General Plan, Draft EIR and Draft Sharp Park Specific Plan
Dear Mr. Murdock,
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.

Sincerely,
Arlene Patton
From:

Sent: Wednesday, March 9, 2022 9:58 AM
To: Public Comment [[email protected]]
Subject: Resending General Plan DEIR Comments
Attachments: GENERAL PLAN DEIR COMMENTS_2.pdf
[CAUTION: External Email]
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
Thank you,
Mark
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PACIFICA GENERAL PLAN AND DEIR COMMENTS – JANUARY 2022
Good day, City Staff and Councilmembers.

First, please accept my sincere appreciation for the monumental amount of effort you’ve obviously dedicated to creating these documents – thank you! After such a long wait, every member of our community should be grateful in having an upto-date General Plan.

Having said that, the absence of opportunities for current citizen participation in the process is clearly evident and rather disappointing. Particularly disturbing is the safety element failure in addressing the likelihood of devastating wildfires throughout the Park Pacifica and eastern Linda Mar neighborhoods with a presentation of specific, comprehensible, and effective plans for the prevention of and protection from these deadly hazards.

HISTORY:

Thirty years ago, the Oakland Hills firestorm – Tunnel Fire -- of 1991, swept through a nearby residential neighborhood with surprisingly similar terrain and autumn weather conditions as the Back Of The Valley neighborhoods in Pacifica, burning through 1520 acres; killing 25 people and injuring 150 others; destroying 2,843 single-family homes and 437 apartment and condominium units. The economic loss from the fire was estimated at $2.59 billion in 2020 dollars.

Division Chief Riley and Oakland Police Officer John Grubensky were killed while trying to help citizens escape the fire. Both Chief Riley and Officer Grubensky were found with the remains of those people they were trying to help. (Source:

Wikipedia)
Let’s also dispel the notion that eucalyptus trees aren’t flammable: “The leaves produce a volatile highly combustible oil, and the ground beneath the trees is covered with large amounts of litter which is high in phenolics, preventing its breakdown by fungi. Wildfires burn rapidly under them and through the tree crowns. It has been estimated that other than the 3,000+ homes that burned in California’s 1991 Oakland Hills Fire, about 70 percent of the energy released was through the combustion of eucalyptus” — Bill Gabbert (Author of Wildfire Today) Why is there is no mention of city support and assistance for fire mitigation through tree removal and replacement with less flammable native foliage in this General Plan? Most likely, the opportunity for community participation would have brought this to The City’s attention.

In 2021, a record number of wildfires burned across the western states. As of December 16, 2021, a total of 8,619 fires had been recorded, burning 2,569,009 acres across California. So far in just the first couple months of 2022, there have already been two significant fires, the Alpine Fire on the Sonoma Coast and The Colorado Fire near Camel By The Sea, burning a combined 700 acres of nearby coastal area, in the middle of winter, in what is normally the rainy season.

The first two months of 2022 are shaping up to be the driest January and February in California history, prompting state officials to warn of dire water conditions ahead. “There’s no precipitation forecast through the remainder of February. And there’s very little precipitation in the long-range forecast for March,” Erik Ekdahl, a deputy director with the State Water Resources Control Board, said at a board meeting Tuesday. “All this is pointing to, again, some pretty dire conditions statewide for drought.”
In the 1970s, Pacifica, as did many other California cities, started Trees-For-ADollar campaigns with Planting Parties. Many trees were planted in the indefinable spaces between fence lines weaving through hillside neighborhoods.

Today, most of those trees are dead or dying tinder-towers, and they are fire and falling hazards costing from $5,000 to $9,000 apiece for the individual homeowner to remove. If only it had been a more enlightened program providing fire-resistant native species, like coastal live oaks or redwood trees, we wouldn’t be having this problem. Many years later, it is hard to get neighbors to agree on responsibility; so the trees become an increased danger for everybody.

Somehow and soon, those trees will have to be equitably removed for the safety of residents in these neighborhoods.

Understandably, it is challenging to extrapolate current conditions with data trends decades into the future. But isn’t that the point of creating The 2040 General Plan? So the question for validating this Environmental Impact Report is:

What will The City do over the next few years to potentially ensure the safety of thousands of citizens, as well as firefighters and police for decades to come, by eradicating these life-threatening conditions? CURRET HAZARD ASSESSMENTS:

The City has very recently been distributing inconsistent versions of its wildfire hazard maps. Map ‘A’ below is the map included in this DEIR. This map does seem to represent the actual concerning levels of wildfire severity in the Park Pacifica / East Linda Mar neighborhoods. Map ‘B’ is incorporated into the General Plan tethered to this same DEIR project is substantially different by eliminating the actual severity of most wildfire threats within the Pacifica City limits – an obvious inconsistency. Map ‘C’ was provided By The City last summer to the San Mateo County Hazard Risk Ranking program, possibly by accident, yet assuring them that Pacifica is indeed fireproof. Image ‘D’ is the response from The County acknowledging that the risk of wildfire in Pacifica is less than “dams breaking,” even though there are no dams in Pacifica.*

Map ‘A’ Map ‘B’
Image ‘D’ Map ‘C’
For the sake of accuracy, here are the actual Cal Fire percentages.

*Note: Dam Failure -- There are no dams within or above Pacifica, and therefore the city is not at risk from a seismically induced dam failure. However, water tanks located in the hills above populated areas could burst and inundate areas below due to a seismic event. (Pacifica Planning Dept.) Earthquake damage facts show fires caused by earthquakes are the second most common hazard. Earthquake fires start when electrical and gas lines are dislodged due to the earth’s shaking. Gas is set free as gas lines are broken and a spark will start a firestorm (Source: Cal Fire). The main natural gas pipeline (blue line) running into Park Pacifica is an extension of the one that exploded in San Bruno, 2010. As you can see, the pipeline crosses the San Andreas Fault, which moves northward at the rate of 4 to 6 cm (1.6 to 2.4 inches) per year since the early 20th century. Parts of the fault line moved as much as 6.4 meters (21 feet) during the 1906 earthquake. (Source: Enc. Britannica, Feb 7, 2022)

The good news is that many grant funding programs are available for areas in high wildfire threat areas:

Cal Fire: Urban and Community Forestry Grant Programs – Reforesting With More Fire Resilient Foliage
PG&E: The10,000-mile Undergrounding Program – Undergrounding Utility Lines In High Threat Wildfire Areas
FEMA: Fire Service Grants and Funding -- Assist fire prevention programs and support firefighter health and safety research and development.

So the question for validating this Environmental Impact Report is: Why not come clean about our situations to qualify for available resources, instead of hiding or confusing the hazards that threaten us?
FIREWORKS:

Senator Dianne Feinstein’s office can speak to that:
“The drought in California has created dangerous conditions for wildfires this summer. And the risk will spike this weekend as millions celebrate the July 4 holiday. I urge all Californians to leave fireworks to the professionals this year. “Last year we saw how much damage irresponsible use of fireworks can cause.

The San Francisco Fire Department reported at least 100 grass fires, Fresno saw at least 135 fires and the Los Angeles Fire Department responded to nearly 400 fires, many started by fireworks.
“Fireworks at one party in Yucaipa last September sparked a wildfire that burned more than 20,000 acres. Just last week, firefighters in Fresno County responded to a brush fire caused by illegal fireworks.
“The bottom line is that with the hot, dry conditions California is currently experiencing, using fireworks risks sparking destructive and deadly wildfires. And using illegal fireworks can lead to fines of up to $50,000 and a year in jail.

Parents are also liable for any damage or injuries caused by their children using fireworks.
“Do your part to prevent wildfires and celebrate the holiday safely by skipping fireworks at home and instead watch a public show in your community.”
Pacifica may not be able to qualify for wildfire prevention grants. So the question for validating this Environmental Impact Report is: Would any safe and sane professional person approve grant funding for wildfire safety to a city offering legal fireworks?
EVACUATION:

In the event of a wildfire emergency, it would be a very bad idea for hundreds or potentially thousands of families in cars to try evacuating to the beaches via only two available routes for sanctuary. The Zonehaven Evacuation program seems to be a brilliant solution to avert a horrible disaster. So the question for validating this Environmental Impact Report is: Why won’t The City concentrate on promoting this program more effectively? “Every acre in California can and will burn someday,” he announced, as the massive Dixie Fire continued to spread. “Just make sure that you're ready when it does.” According to Cal Fire Chief Them Porter, who retired last December after leading the agency through record wildfire seasons.” Thanks to all of you on The City Staff for your service.

Best,
From: Mr. Paul Totah [
Sent: Sunday, February 27, 2022 11:55 AM
To: Public Comment [[email protected]]
Subject: Revised comments
[CAUTION: External Email]
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?

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.

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 iTree can more accurately assess tree canopy. Please update this map with more accurate information.

4. As stated above Pacifica’s urban forest includes all trees within the city limits. Unfortunately Figure 3.7-1 labels 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.

5. There is no Implementing Principle to correspond with the Guiding Principle CO-G-10. 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”.

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-I-39 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".

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)
--
Paul Totah
Freelance Writer
c: 650-303-1841
e:
w: www.siprep.org/genesis
t: @ptotah
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From: Stan Zeavin [
Sent: Saturday, March 5, 2022 5:49 PM
To: Public Comment [[email protected]]
CC: Nibbelin, John [[email protected]]; Berman, Lauren [[email protected]]; Domurat, George [[email protected]]; Ferguson, Alex [[email protected]]; Godwin, James [[email protected]]; Hauser, Samantha [[email protected]]; Leal, David [[email protected]]; _City Council Group [[email protected]]; Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]
Subject: Safety element figure 8-3 & DEIR 3.6-3
Attachments: Coastal Zone maps comment .docx .docx
[CAUTION: External Email]
Please consider the following:
“Coastal Zone” Maps and following – Safety element figure 8-3 & DEIR 3.6-3 >> Combining upland and coastal information on one map minimizes the impact of each. 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 inadequate site investigation.

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
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.
• 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.

Document page 11 (8-11) Implementing Policies
>> 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 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.

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.”
Document page 12 (8-12)
SA-I-9 Maintain Restrictions on Hazardous Areas.
>> Clearly identify “Hazardous Areas”
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 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
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

2. DEIR
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 􏱈 􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈
• 􏱈 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.

3.6-14
>> Placing coastal erosion in SMCMJLHMP under “Landslide/Mass Movements” does not adequately emphasize on-going and increasing erosion with SLR.

Document page 470
Beaches and Coastal Erosion
>> Update erosion history and bluff retreat.

Current data is based on 1998 report.

3.6-15
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.

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 citizens a much better idea of the area of potential erosion.

Thank you for your consideration,
Margaret Goodale
Naturalist
Educator
Environmental advocate
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“Coastal Zone” Maps and following – Safety element figure 8-3 & DEIR 3.6-3 >> Combining upland and coastal information on one map minimizes the impact of each. 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 inadequate site investigation.

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
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.
• 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.

Document page 11 (8-11) Implementing Policies
>> 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 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.

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.” Document page 12 (8-12)
SA-I-9 Maintain Restrictions on Hazardous Areas.
>> Clearly identify “Hazardous Areas”
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 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
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

2. DEIR
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 􏱈 􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈 􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈􏱈 • 􏱈 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.

3.6-14
>> Placing coastal erosion in SMCMJLHMP under “Landslide/Mass Movements” does not adequately emphasize on-going and increasing erosion with SLR.

Document page 470
Beaches and Coastal Erosion
>> Update erosion history and bluff retreat.

Current data is based on 1998 report.

3.6-15
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.

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 citizens a much better idea of the area of potential erosion.

From: Christine Boles [
Sent: Monday, January 10, 2022 10:16 AM
To: Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Bier, Mary [[email protected]]; Woodhouse, Kevin [[email protected]]; Coffey, Sarah [[email protected]] Subject: Safety Element public meetings?
[CAUTION: External Email]
Could one of you confirm if there were even any public meetings about the Safety Element portion of the General Plan?
Christine Boles, Architect
Beausoleil Architects
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
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From:

Sent: Monday, March 7, 2022 5:15 PM
To: Murdock, Christian [[email protected]]
CC: Public Comment [[email protected]]
Subject: San Pedro field
[CAUTION: External Email]
Dear Christian
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.

Sincerely,
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From:

Sent: Sunday, January 16, 2022 2:14 PM
To: Public Comment [[email protected]]
CC: _City Council Group [[email protected]]; City Manager [[email protected]] Subject: Sharp Park plan comments
Attachments: problem no solution.jpg
[CAUTION: External Email]
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_lUclyBLTgZ7zwvjqnPjFIvOUfF84L2WACWvQqIh6DzgyMVLSnmkjhMCg3RRNKj7qTCM5DSgM2zfQYM,&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.

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From: Bill [
Sent: Tuesday, January 11, 2022 11:20 AM
To: Public Comment [[email protected]]
Subject: Sharp Park Plan proposal
[CAUTION: External Email]
January 11, 2022
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 car-dependent. 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 poor-mouthing, 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?
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From:

Sent: Monday, February 21, 2022 2:34 PM
To: Murdock, Christian [[email protected]]
Subject: Sharp Park Specific Plan Comments
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Hi Christian,
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".

Thank you,
Jackie Rosenheim
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From: brian o'flynn [
Sent: Wednesday, March 9, 2022 12:17 PM
To: Public Comment [[email protected]]
CC: brian o'flynn [
Subject: Sharp Park Specific Plan public comment
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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. .Sincerely,
Brian O’Flynn
long time Sharp Park Property owner
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From: Tom Thompson [
Sent: Monday, March 7, 2022 5:44 PM
To: Murdock, Christian [[email protected]]
CC:

Subject: Sharp Park Specific Plan Public Comments
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Hi Christian:

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.

Best Regards
Tom Thompson, Sharp Park property owner and taxpayer for 35+ years CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

From: Tom Thompson [
Sent: Monday, March 7, 2022 5:35 PM
To: Public Comment [[email protected]]
CC:

Subject: Sharp Park Specific Plan Public Input
Attachments: Sharp Park Specific Plan Comments by Tom Thompson, Sharp Park property owner and taxpayer for 35+ years 3-7-2022.pdf
[CAUTION: External Email]
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.

Date: March 7, 2022
To: City of Pacifica
Subject: Public Comments on Sharp Park Specific Plan
The Sharp Park Specific Plan (SPSP) has a major flaw. Environmental justice and economic justice issues are at risk.

Let’s fix the SPSP. Now, while we 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 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 and Social Equity Justice Issues including:
1) Think of the environmental & economic mess if 40% of Pacifica loses their sewer service because we didn’t protect the sewer pumping station with a robust seawall.
2) Preserving Pacifica’s 1,000+ most affordable homes in Sharp Park. 3) Preserving 100+ small businesses in Sharp Park.
4) Homeowners and small businesses have their nest eggs and retirement invested in Sharp Park.
5) These homeowners and businesses never dreamed their city might abandon them by not making it a policy to protect their homes & investments with a robust seawall.
6) Affordable access to our fishing pier provides affordable food to many families.
7) Access to affordable recreation like fishing, picnicking, golf & hiking trails are at risk.
8) Protecting Sharp Park with a simple robust seawall, north of the pier, is essential to getting the investment we need to make Sharp Park thrive. 9) And the increased tax revenue to our city treasuries from these investments is essential to our economic viability as a city. Economic justice for the city itself.

Tom Thompson
Sharp Park Property Owner and Taxpayer for 35+ Years
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Date: March 7,2022
To: City of Pacifica
Subject: Public Comments on Sharp Park Specific Plan

The Sharp Park Specific Plan (SPSP) has a major flaw. Environmentaljustice and economic justice issues are 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 221,2 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 essentialto our economic viability as a city.

The SPSP goes into detail about the potentialfor Sea Level Rise. Yet, the SPSP is virtuallV silent about a commitment to seek a simple sea level rise solution for Pacifica and Sharp Park... A RUBUST SEAWALL. ls 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 "Downtown Pacifica"... will never happen.
investment in Sharp Park to make lt a robust
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 agalnst the potentialfor 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 lnfrastructure must be protected from potentialsea 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 Paciflca! 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 iustice issue, and an economic iustice issue.

Pacifica family investments in homes & businesses must be protected. Homeowners who invested their life savings never thought they should fear their government might abandon them and effectively condemn their homes by not protecting publlc 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 policv statement within the SpSp itself that we will work to make a seawall happen.

Page two includes a more detailed list of what is at stake, unless we make a commitment to pursue a robust seawall... within the Sharp Park Specific Plan itself.

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

March 1,2022 Page 2 of 2
Sharp Park Specific Plan Public Comments
PRIORITY SOLUTION: WE NEED TO COMMIT, WITHIN THE SPSP ITSELF, TO BUILDING A SEAWALL NORTH OF THE PIER, so we can:

A) Protect Public lnfrastructure lnvestment. Economic & SocialJustices lssues lnvolving:
1) Streets & Roads
2) Sidewalks
3) Beach Promenade
4) Storm Drains
5) Access to CoastalTrails
6) Sewer Lines
1) Natural Gas Lines
8) ElectricalService
9) lnternet
10) Cable lines
11) Water Service Lines
12) Golf Course
13) Fishing Pier
14) Existing major sewer pumping station a|221-2 Beach Blvd. Sewer service for l-6,000 people. That's 40% of all Pacificans. Not just Sharp Park.

B) Protect Private lnvestment. Economic & Socialiustices lssues lnvolving. 1) 1,000 + of our most affordable existing homes.
2) 100+ existing small businesses.
3) Future lnvestment to make Palmetto a thriving walkable downtown district. 4) 22L2 Beach Blvd Hotel won't happen without a commitment to a seawall.

Pacifica's financialfuture depends upon a new hotel on that site. 5) No commitment to pursuit of a robust seawall. Means no commitment to a hotel. How and why would investors move forward without this assurance? 6) The same holds true for other investors in Sharp Park. Why would any investors come to Sharp Park, if the city is not committed to protecting Sharp Park? C) Again, Protect Environmental and Economic and Social Equitv Justice lssues 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. 2l Preserving Pacifica's 1,000+ most affordable homes in Sharp Park. 3) Preserving 100+ small businesses in Sharp Park.
4) Homeowners and small businesses have their nest eggs and retirement invested in Sharp Park.
5) These homeowners and businesses never dreamed their city might abandon them by not making it a policy to protect their homes & investments with a robust seawall. 6) Affordable access to our fishing pier provides affordable food to many families. 7\ Access to affordable recreation like fishing, picnicking, golf & hiking trails are at risk. 8) Protecting Sharp Park with a simple robust seawall, north of the pier, is essential to getting the investment we need to make Sharp Park thrive. 9) And the increased tax revenue to our city treasuries from these investments is essential to our economic viability as a city. Economic justice for the city itself.

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

From: Bob Haxo [
Sent: Tuesday, March 8, 2022 4:03 PM
To: Public Comment [[email protected]]
CC:

Subject: Sharp Park Specific Plan: San Jose Ave. Improvements + Protect San Pedro Mtn. [CAUTION: External Email]
Dear Planners,
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 un-watered 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 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.

Protect San Pedro Mountain
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.

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
Thanks for reading.

Cheers,
Bob Haxo
180 San Jose Ave, Pacifica
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From: James Kremer [
Sent: Tuesday, March 8, 2022 12:55 PM
To: Public Comment [[email protected]]
CC: KoppmanNorton, [
Subject: Short listing of special comments on DEIR
Attachments: 22-03-08 JKremer special comments DEIR SPSP.pdf [CAUTION: External Email]
Attached please find a PDF of additional comments I am submitting for the DEIR. -- Jim
James Kremer
Pacifica, CA
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TO: [email protected]
COPY: CCC
FROM: James Kremer, Ph.D.

SUBJ: Additional special comments on DEIR
DATE: March 8, 2022
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 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.
• 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). • 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 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. • 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 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? • 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 long-term. Implementation policies should encourage tighter compliance with Growth Controls while emphasizing housing that helps the city meet state mandates.

J. Kremer – Planning Meeting 1/3/2022 p. 2
• Is the city planning to make use of sufficiently high Development Impact Fees? Many municipalities reportedly find it prudent to charge fees from perhaps $10K for ADUs to $50K for normal residences. This would seem to be an important aspect of future Planning planning and should be mentioned in the documents & policies. • Decarbonization, Electrification and Reach Codes should receive substantial explicit attention in plans for the future of a city. Now they are essentially missing. • 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?
• 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. • “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.

From: Clif Lawrence [
Sent: Saturday, January 29, 2022 7:28 PM
To: _City Council Group [[email protected]]; Ferguson, Alex [[email protected]]; Leal, David [[email protected]]; Domurat, George [[email protected]]; Godwin, James [[email protected]]; Nibbelin, John [[email protected]]; Berman, Lauren [[email protected]]; Hauser, Samantha [[email protected]]
CC: Clif Lawrence [ Woodhouse, Kevin [[email protected]]; [email protected]; Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]
Subject: There is a General Plan on life support... It is ours! [CAUTION: External Email]
"...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?
Clifford Lawrence
West Fairmont
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From: Rick Nahass [
Sent: Friday, March 4, 2022 11:01 AM
To: Public Comment [[email protected]]; Murdock, Christian [[email protected]]
CC: Bier, Mary [[email protected]]; Bigstyck,
Tygarjas [[email protected]]; Vaterlaus, Sue [[email protected]]; O'Neill, Mike [[email protected]]; Beckmeyer, Sue [[email protected]]; Debbie Ruddock [ Deborah Penrose [ Robert Brownstone
[
Subject: Update RE New Proposed Sewer Service Charges: General Plan DEIR and VMT Mitigation Bank
[CAUTION: External Email]
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_Government_Revenues_and_Impact_Fee022420.pdf https://www.hcd.ca.gov/policy-research/plans-reports/docs/impact-fee-study.pdf Personally I will remain neutral on the Proposed Sewer Service Charges.

Thanks again for considering public input.

Rick
On Sun, Feb 20, 2022 at 4:17 PM Rick Nahass < wrote:

To: Christian Murdock
Cc: Coastside Councils
Please consider the following changes to the city General Plan and DEIR:
(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. (2) Establish a Vehicle Miles Travelled (VMT) Mitigation Bank - see https://www.fehrandpeers.com/wp-content/uploads/2020/04/VMT-Fees_Exchanges_BanksWhite-Paper_Apr2020.pdf - to manage future growth per vehicle miles travelled (VMT) SB743 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 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 worksheet for Pacifica stops. • This makes housing growth mandates (RHNA ABAG) dependent on both developers' willingness to pay to reduce VMT and Regional Transportation 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.

Thank You,
Rick Nahass
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From: Christine Boles [
Sent: Tuesday, January 11, 2022 10:22 PM
To: Public Comment [[email protected]]; Remi Tan [ CC: dawn zidonis [
Subject: Re: Public Comment letter for tonight's council meeting regarding General Plan [CAUTION: External Email]
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_LEfd6euiezXuQqBqZ1RXJHR3iY 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.

Thank you both for your interest in working on this!
Christine
On Tue, Jan 11, 2022 at 8:25 AM Remi Tan < wrote:

Hi Christine, Yes I see your concerns - the Pacifica map does not even show any of the high fire danger of the state map. It seems like the consultant team hired to do the General Plan update should be getting these critical maps updated. As mentioned in my previous email, not only they need to look at other maps but this is a lot of grunt work to review reports of all submitted projects, approved and not approved, in the past 42 years since the last GP. Maybe our group needs to meet with City and consultants? Per the last paragraph on the letter to the city, is your group thinking over a lawsuit if the city and consultant ignores the safety issues?
Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Manager and Member
S.A.A. Equities, LLC
Architecture, Green/Sustainability Consulting, and Real Estate Investment On Tuesday, January 11, 2022, 06:22:03 AM PST, Christine Boles < wrote:

Hi Dawn and Remi,
You’re both design professionals in my neighborhood so I thought I’d connect you too.

My latest letter and the fire maps I referred to are attached. I am so concerned. We need help! I’m focusing on the Safety Element as that should be the first step in properly understanding our hazards.

It’s a hot mess!
Christine

---------- Forwarded message ---------
From: Christine Boles <
Date: Mon, Jan 10, 2022 at 3:29 PM
Subject: Public Comment letter for tonight's council meeting regarding General Plan To: <[email protected]>, Woodhouse, Kevin <[email protected]>, Wehrmeister, Tina <[email protected]>, Murdock, Christian <[email protected]>, Michelle Kenyon [BWS Law] <[email protected]>, _City Council Group <[email protected]>
Please see attached, thank you.

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

From: dawn zidonis [
Sent: Wednesday, January 12, 2022 7:45 AM
To: Christine Boles [
CC: Public Comment [[email protected]]; Remi Tan [ Subject: Re: Public Comment letter for tonight's council meeting regarding General Plan [CAUTION: External Email]
I’d be haply to take on what you described below.

This might be far-fetched 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.

Thoughts?
Dawn
On Tue, Jan 11, 2022 at 10:21 PM Christine Boles < wrote:

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_LEfd6euiezXuQqBqZ1RXJHR3iY 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.

Thank you both for your interest in working on this!
Christine
On Tue, Jan 11, 2022 at 8:25 AM Remi Tan < wrote:

Hi Christine, Yes I see your concerns - the Pacifica map does not even show any of the high fire danger of the state map. It seems like the consultant team hired to do the General Plan update should be getting these critical maps updated. As mentioned in my previous email, not only they need to look at other maps but this is a lot of grunt work to review reports of all submitted projects, approved and not approved, in the past 42 years since the last GP. Maybe our group needs to meet with City and consultants? Per the last paragraph on the letter to the city, is your group thinking over a lawsuit if the city and consultant ignores the safety issues?
Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Manager and Member
S.A.A. Equities, LLC
Architecture, Green/Sustainability Consulting, and Real Estate Investment 650-291-3097
On Tuesday, January 11, 2022, 06:22:03 AM PST, Christine Boles < wrote:

Hi Dawn and Remi,
You’re both design professionals in my neighborhood so I thought I’d connect you too.

My latest letter and the fire maps I referred to are attached. I am so concerned. We need help! I’m focusing on the Safety Element as that should be the first step in properly understanding our hazards.

It’s a hot mess!
Christine
---------- Forwarded message ---------
From: Christine Boles <
Date: Mon, Jan 10, 2022 at 3:29 PM
Subject: Public Comment letter for tonight's council meeting regarding General Plan To: <[email protected]>, Woodhouse, Kevin <[email protected]>, Wehrmeister, Tina <[email protected]>, Murdock, Christian <[email protected]>, Michelle Kenyon [BWS Law] <[email protected]>, _City Council Group <[email protected]>
Please see attached, thank you.

Christine Boles, Architect
Beausoleil Architects
478 Monterey Road
Pacifica, CA 94044
www.beausoleil-architects.com
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu --
Christine
--
Christine
--
Dawn Zidonis
Executive Director
AIGA San Francisco
aigasf.org
San Francisco Design Week
sfdesignweek.org
595 Pacific Ave, Floor4
San Francisco, CA
m
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.

From: Irene Davies [
Sent: Monday, February 14, 2022 11:40 PM
To: Murdock, Christian [[email protected]]
Subject: Re: Plan Pacifica - City of Pacifica Releases Draft General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report for Public Review Attachments: ~WRD0001.jpg
[CAUTION: External Email]
Christian,
Yes, please remove any physical personal information so I don't have strangers visiting or calling me.

Appreciate your help.

Irene
On Mon, Feb 14, 2022, 10:08 PM Murdock, Christian <[email protected]> wrote:

Hi Irene,
I’m confirming receipt of your comments and that I will use your second email that included a revised version devoid of personal contact information.

Regards,
Christian

CHRISTIAN MURDOCK, AICP

DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]
From: Irene Davies <
Sent: Friday, January 21, 2022 4:19 PM
To: Murdock, Christian <[email protected]>; Public Comment <[email protected]>
Subject: Re: Plan Pacifica - City of Pacifica Releases Draft General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report for Public Review [CAUTION: External Email]
Hi,
Please see my attached comments to both the City of Pacifica General Plan and DEIR. I also attached suggested bypass subroutes to Hwy 1 in case of emergency, wildlife corridor tunnels/crossings, and suggested affordable high-density housing.

Please let me know if you need the Word documents.

Thanks
Irene Lee
On Mon, Jan 10, 2022 at 3:08 PM Murdock, Christian <[email protected]> wrote:

Error! Filename not specified.

Error! Filename not specified.

City of Pacifica Releases Draft General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report for Public Review Error! Filename not specified.Error! Filename not specified.

Click Here to Review Documents
Error! Filename not specified.

Today, the City of Pacifica has released the General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report for public review. The Error! Filename not specified.Error! Filename not specified. General Plan and Error! Filename not specified.Error! Filename not specified. Sharp Park Specific Plan are comprehensive planning documents that will shape the future of development in Pacifica through policies that express and regulate transportation, utilities, land use, recreation, public safety, and more. The Error! Filename not specified.Error! Filename not specified.

Draft Environmental Impact Report provides an analysis of potential environmental impacts associated with the policies contained in the planning documents. These documents are being released concurrently to enable the public to consider these interrelated documents at the same time. An important and related document, the Error! Filename not specified.Error! Filename not specified. Local Coastal Land Use Plan, was previously approved by the City Council and is under review by the California Coastal Commission.

Why are the General Plan and Sharp Park Specific Plan important documents? The General Plan Update, once adopted, will replace the existing 1980 General Plan to reflect contemporary community goals; changes in State laws related to planning and development; and update policies related to public safety, such as fire hazards. The Sharp Park Specific Plan will establish a future vision for a more vibrant Sharp Park. During the preparation of these plans, the City conducted extensive community engagement over several years, including more than a dozen community, City Council, and commission/committee meetings, with over five hundred participants.

How can I participate in the adoption process of these documents? The public is encouraged to review the General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report and participate in the adoption process. The documents can be found by visiting the Error! Filename not specified.Project Documents page on the Plan Pacifica website. This page includes a Error! Filename not specified.Frequently Asked Questions document to help answer common questions about this process including how to submit comments and how to receive information about public hearings that will be held in the coming months.

Whom should I contact if I have any questions? Please reach out to Deputy Planning Director Christian Murdock, at (650) 738-7341 or [email protected] with questions.

Error! Filename not specified.

PLAN PACIFICA DOCUMENTS
Error! Filename not specified.Error!
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Draft General Plan
Error! Filename not specified.Error!
Filename not specified.

Draft Sharp Park Specific Plan
Error! Filename not specified.Error!
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Draft Environmental Impact Report
Error! Filename not specified.

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Local Coastal Land Use Plan

USEFUL LINKS
Error! Filename not specified.Error!
Filename not specified.

FAQs
Error! Filename not specified.Error!
Filename not specified.

Plan Pacifica Website
Error! Filename not specified.Error!
Filename not specified.

Plan Pacifica Press Release
Error! Filename not specified.Error!
Filename not specified. City
of Pacifica Planning Department
Error! Filename not specified.

Thank you for your interest in Plan Pacifica!
Error! Filename not specified.

STAY CONNECTED
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City of Pacifica | 540 Crespi Drive, Pacifica, CA 94044 Error! Filename not specified.Error! Filename not specified. Unsubscribe [email protected]
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Error! Filename not specified.Try email marketing for free today! CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

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

From: Irene Davies [
Sent: Friday, January 21, 2022 4:19 PM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]
Subject: Re: Plan Pacifica - City of Pacifica Releases Draft General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report for Public Review Attachments: We need real affordable housing.pdf; Comments for 2040 General Plan n DEIR.pdf; 20220119_alternative subroutes n wildlife corridor crossings.jpg [CAUTION: External Email]
Hi,
Please see my attached comments to both the City of Pacifica General Plan and DEIR. I also attached suggested bypass subroutes to Hwy 1 in case of emergency, wildlife corridor tunnels/crossings, and suggested affordable high-density housing.

Please let me know if you need the Word documents.

Thanks
Irene Lee
On Mon, Jan 10, 2022 at 3:08 PM Murdock, Christian <[email protected]> wrote:

City of Pacifica Releases Draft General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report for Public Review Click Here to Review Documents
Today, the City of Pacifica has released the General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report for public review. The General Plan and Sharp Park Specific Plan are comprehensive planning documents that will shape the future of development in Pacifica through policies that express and regulate transportation, utilities, land use, recreation, public safety, and more. The Draft Environmental Impact Report provides an analysis of potential environmental impacts associated with the policies contained in the planning documents. These documents are being released concurrently to enable the public to consider these interrelated documents at the same time. An important and related document, the Local Coastal Land Use Plan, was previously approved by the City Council and is under review by the California Coastal Commission.

Why are the General Plan and Sharp Park Specific Plan important documents? The General Plan Update, once adopted, will replace the existing 1980 General Plan to reflect contemporary community goals; changes in State laws related to planning and development; and update policies related to public safety, such as fire hazards. The Sharp Park Specific Plan will establish a future vision for a more vibrant Sharp Park. During the preparation of these plans, the City conducted extensive community engagement over several years, including more than a dozen community, City Council, and commission/committee meetings, with over five hundred participants.

How can I participate in the adoption process of these documents? The public is encouraged to review the General Plan Update, Sharp Park Specific Plan, and Environmental Impact Report and participate in the adoption process. The documents can be found by visiting the Project Documents page on the Plan Pacifica website. This page includes a Frequently Asked Questions document to help answer common questions about this process including how to submit comments and how to receive information about public hearings that will be held in the coming months.

Whom should I contact if I have any questions? Please reach out to Deputy Planning Director Christian Murdock, at (650) 738-7341 or [email protected] with questions.

PLAN PACIFICA DOCUMENTS
Draft General Plan
Draft Sharp Park Specific
Plan
Draft Environmental Impact
Report
Local Coastal Land Use Plan

USEFUL LINKS
FAQs
Plan Pacifica Website
Plan Pacifica Press Release
City of Pacifica Planning
Department
Thank you for your interest in Plan Pacifica!

STAY CONNECTED
City of Pacifica | 540 Crespi Drive, Pacifica, CA 94044 Unsubscribe [email protected]
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21 Jan 2022
Irene Lee
Pacifica, CA 94044
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 (stepback), 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, non-profits, and potential lowincome folks to develop the affordable housing plans. 21 Jan2022
Irene Lee
488 Manor Drive
Pacifica, CA 94044
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 subroutes 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
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 high-density 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 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.
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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.
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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.
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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.
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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. stepback slope height is a good idea per the DEIR figures:

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
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 stepback 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.
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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.
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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.
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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.
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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.
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Need to add into Fig 5-1 some alternate sub-routes to Hwy 1 in case of emergency. Sub-routes from Rockway beach ave to Reina del Mar Ave to Lundy Way that lead to Sharp Park Road.

Also need wildlife corridor tunnels underneath Sharp Park Road and Manor Drive. See attached map of propose sub-routes and wildlife corridor tunnels/crossings. **********************

The proposed illustrative roadway for Linda Mar Blvd and Crespi Drive do not seem to take into account the near future development of more housings on the Linda Mar hillside nor the mega church in the back of Linda Mar area which would increase traffic congestion on normal days. By reducing the traffic lanes, the city is essentially creating a fire trap for residents during emergencies. *************************
P129, 5.5 Public transportation and transportation demand management P131, fig 5-5 Existing transit routes
Need more high-density housing at transportation routes. Suggest having some areas set aside near transportation routes for homeless and van folks.
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P134, 5.7 Parking
Suggest installing parking meters at public street parking area. Allow local resident to show some type of QR bar code to the meter and be able to park free. All other visitors would have to pay some parking fees. This would generate revenue for the City of Pacifica. We have a lot of visitors to the Pacifica Beach and having them pay a small fee will help to offset some environmental costs. **********************
P137, 6 Open space and community facilities
P161, 6.3 Coastal Access
P164, fig 6-4 School and Community facilities
Converting closed public school into either high-density housing, a new civic center with local shops, cafes, homeless shelter and clinics.
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P170, OC-I-59 Beach Blvd property
Consider either use this site as the new Civic center, or high-density public housing, expand homeless shelter and clinics. Need to mitigate for Coastal management retreat, sea level rise, beach erosion, and future levee improvement that are acceptable to the Coastal Commission. **********************

P 180, Planned Improvements
Need to include wildlife corridors as part of the conservation. See attached map of suggested wildlife corridor tunnels/crossing.
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What is the city doing about future plan for use of desalination of sea water and coordinating with the North Coast County Water District? Maybe work with the North Coast County Water District to develop water conservation plan such as rebate for water harvesting with rain barrels. ********************
P186, Fig 7-2 Vegetation
P188, Eucalyptus, Monterey Cypress
We need to remove invasive plants in our parks area such as eucalyptus, Monterey Cypress, English ivy, and plant more native plants. The Eucalyptus is also a fire hazard due to it high oil content. Suggest working with the various other agencies who are management of various parks and local areas to combat these invasive plants.
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P190, Fig 7-3 Sensitive and Critical Habitat
P194, Wildlife Movement Corridors
Need wildlife corridors at obstructions such as Sharp Park Blvd, Manor Drive and other roads that blocked wildlife from traveling to various habitats. See attached map of suggested locations for wildlife corridor tunnels/crossings.

P191 Beach/Intertidal
What is the city future plans about coastal management retreat, climate change, and sea level rise? *************
P201 7.3 Land and soil resources
Need to pay attention to slope stability, earthquake, erosion, liquefaction, and downslope drainage for any future planned development for buildings. Don’t let developers put up a smokescreen on their future developments within Pacifica.
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P216, 7.7 Environmental Justice
Did not see any solution to environmental justice at all for homeless and van parking at designated places in this general plan and in the draft EIR. Need to provide plans for placing the homeless in some type of living and rehab areas with bathroom facilities along with place for vans to park without further increase of pollution by them around our beaches, roads, and wetland areas. ***************
P218, 8 Safety
P219, Seismic Hazards
P221, Fig 8-1 Seismic hazard zones
Need to pay more attention on earthquake problems on building at unstable slope, including erosion, landslide, and drainage issues. Also, the potential of liquefaction and landslide in fig 8-1. Don’t let developers build at unstable areas.
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P222, Tsunami and Seiche
Sharp Park, Rockaway, lower Linda Mar Blvd, Manor Plaza, and Fairmont are prone to tsunami. This plan needs to provide tsunami evacuation routes for all these areas. That is why it is very important to have alternative evacuation routes in case Hwy 1 is not usable either due to flooding and obstructions.

See attached map of suggested alternative sub-routes around Hwy 1. ***************
P222, Slope Failure and Erosion
Where are the tables showing history (when it happened) of slope failure, erosion, liquefaction, earthquake, landslides, earthquake damages?
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P233 Increased coastal flooding from potential sea level rise If the 2009 report from the Pacific Institute mentioned potential flooding, what are the solutions? *******************
P235, 8.3 Coastal Resilience
What are the solutions to the problem raised in this section of potential sea level rise, flooding, etc. **********************
P249, 8.4 Hazardous Materials and Operations
P253, fig 8-7 Fire hazards and public safety services
We need to remove invasive trees such as Eucalyptus to lessen fire hazard as shown on the map. *******************
P260, 9 Noise
Suggest planting of native trees (not invasive trees) to reduce noise level around the noise corridors. *****************
P272, 10 Implementation
This chapter mentioned implementation responsibility by various agencies, but there is no implementation solutions in the general plan. So, what are you implementing? I did not see a section on conclusions and recommendations. Also, the General plan did not spell out the alternatives as shown in the DEIR, why?
Comments on the Draft Environmental Impact Report
P2 Executive Summary
Glad to see there is an executive summary in the DEIR, but am dismayed that it was just another report and not very clear. Usually, executive summary is about 10 pages at most.

It seems the Executive Summary just copied and repeat word for word what were stated in the document. Someone need to clean up the Executive Summary so it is concise and to the point.

The executive summary should summarize the alternatives within the 10 pages at most and the alternatives should be mentioned in the General Plan in parallel. Also, the alternatives were switching from numbering to alphabets. Need to clean that up.
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P152, Draft and Final Documents
There is a disconnect between the Pacifica General Plan 2040 with the DEIR since the General plan did not spell out the alternatives as shown in the DEIR.
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P162, fig 2.1-1 Regional Setting
P163, figure 2.1-2 Planning Area an Coastal Zone
It seems foolish to plan future development of Sharp Park specific plan when it is mostly in the Coastal zone of management retreat. Better to plan on the east side of Hwy 1 of Sharp Park for long term stability and to account for climate change and sea level rise.

Did not see any concise solutions to offset coastal management retreat, beach erosion, liquefaction, climate change, and sea level rise for these proposed high-density developments. *********************
P164, fig 2.1-3 Sharp Park Specific Plan Planning Area
More high-density development of Eureka Square Shopping Center is warranted, but not the west side of Hwy 1 unless the city can get permission from the Coastal Commission to offset future climate change and sea level rise issues.

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.
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P165, Local Coastal Planning
P166, Fig 2.1-2 General Plan Land Use
P167, Fig 2.1-3 Sharp Park Specific Plan Land Use Diagram Need to address sea level rise and climate change in this Sharp Park Specific Plan on the west side of Hwy 1.
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P205, Sharp Park Specific Plan Area
More high-density development of Eureka Square Shopping Center is warranted, but not the west side of Hwy 1 unless the city can get permission from the Coastal Commission for future climate change and sea level rise protection.

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.
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P235, fig 3.2-1 Roadway Network and Planned Improvements P678, Fig 3.12-3 Trail System
Need wildlife corridors along Sharp Park road, Manor Drive, and other road obstructions to wildlife. See attached map showing potential wildlife corridor tunnels/crossings. ****************
P238, Fig 3.2-2 Existing Transit Routes and Facilities
P724, Infrastructure Modernization
More high density along transit corridors. Where are the designated parking for homeless and vans since there are environmental hazards produced by these folks who park along the beach area with their trash and other hazards. The homeless and travel vans need a designated place along with bathroom facility, and trash bins.

Need to have sub-routes from Rockaway beach Ave to Reina del Mar Ave to Ridgeway Dr to Sharp Park Road for emergency access in case Hwy 1 is not usable in either direction. These sub-routes are also critical during emergency evacuations. See attached map of suggested sub-routes to bypass Hwy 1 in case Hwy 1 is not useable.
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P241, Fig 3.2-3 Existing and Proposed Bicycle Network
The proposed bike lanes along Linda Mar Blvd and Crespi drive could be a people trap during fire and other emergencies, especially with the proposed high-density development on the hill of Linda Mar and at the back of Linda Mar. How is the city going to mitigate for this potential fire trap? *****************
P366, Reduced Parking
P372, LU-I-18 Parking Requirements
It is a bad idea of proposed General Plan policy LU-I-18 to allow developers to reduce parking spaces unless we have a robust and almost free public transportation for folks in Pacifica. What is the city going to do for the residents who need to be able to drive and find free parking? Suggest providing buses for local travel only to locals and tourists, and charge a daily or monthly nominal fee to use the buses. Allow the locals to use some type of Id or QR codes to ride the local buses for free. *****************
P366, Water Conservation
P723, Water Conservation
Is the city and the North Coast County Water District going to provide and help residents to install rain barrels to capture rain water and to provide recycled water containers and truck the recycled water to the residents to use to improve water conservation.

What are the future plans by the city and the North Coast County Water District to develop seawater desalination?
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P370, Trees and Native Vegetation
What is the city going to do to reduce invasive trees such as Eucalyptus, Monterey Pine, Monterey cypress, English ivy, and other invasive plants in our area? We need to educate folks to plant more native plants instead of invasive plants. Suggest the city work with other agencies who are managing various parks and places to work together to get rid of these invasive plants and plant native plants instead.
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P371, Impact of the Sharp Park Specific Plan
Did not see specific plan to offset future climate change and sea level rise for these future developments.

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.
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P372, Proposed General Plan Policies that Reduce the Impact LU-I-16, Density Bonus
Where in the General Plan are the proposed housing for low-income folks, homeless, and vans along our streets? The homeless and vans are producing human environmental waste along with other trash.

They need a place where they can live with bathroom facility, mental health services, and job training? See attached suggested high-density developments.

Do like the stepback for high-density buildings to reduce sun shadowing. *********************
P402, Fig 3.5-1 Hydrology and Flood Zones
What are the mitigations for areas under the Tsunami evacuation areas especially for Sharp Park area and Linda Mar Blvd close to Hwy 1 on the west side? How are the mitigations being in line with the Coastal Commission on management retreat?
Need to show Tsunami evacuation plan for folks to reach high ground. ******************
P407-408, Coastal flooding
How is the improvement of the seawall/revetment structure match up with the Coastal Commission on management retreat, future climate change, and sea level rise? ***********************
P454, Fig 3.6-1 Seismic Hazard Zones
P455, Fig 3.6-2 Liquefaction, Liquefaction Potential
P457, Landslides and slope failure
P459, Fig 3.6-3 Slope Failure and Coastal Erosion
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
Need to provide tables to show the historical seismic events, liquefaction, flooding, landslides, slope failure, and erosions at various locations in Pacifica and pinpoint within the fig for better understanding of these issues.

What protection measures are planned for the Sharp Park area future high-density development with the volubility of liquefaction, flooding, climate change, sea level rise, earthquake, and Tsunami? Nice the Stepback of high-density buildings to reduce sun shadowing. ********************
P458, Beaches and Coastal Erosion
Need a table and fig of historical beaches and coastal erosions for better understanding of these issues. ********************
P492, Vegetation
P506, Fig 3.7-3 Sensitive and Critical Habitat
P637, Fig 3.11-2 Fire Hazards and Public Safety Services P750, 3.14 Wildlife
Need to show in fig wildlife corridors for wildlife. See attached map for suggested wildlife corridor tunnels/crossings.

Need to provide a plan to eliminate Eucalyptus, Monterey Cypress, English Ivy, and other invasive plants/vegetations to reduce wildfire, increase plant diversity, and improve climate change.

We need to educate folks to plant more native plants instead of invasive plants. Suggest the city work with other agencies who are managing various parks and places to work together to get rid of these invasive plants and plant native plants instead.
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P662, Fig 3.12-1 Schools and Community Facilities
Need to show the closed school of Fairmont in the Fig to match the figure shown in the Pacifica General Plan 2040. See P164, fig 6-4 School and Community facilities, from the General Plan.

Suggest reuse the closed school for high-density public housing, mix up facilities, weekly food truck area, or use as a place for homeless and van parking so the homeless and van parking folks won’t pollute the roads, beaches, and wetland areas with human waste and trash.

Suggest high-density development at the Sea Bowl area, including having weekly food trucks gathering. ******************
P805 and P807 Analysis of Alternatives
P8, Executive Summary
Why are the alternatives listed as Alt 1, 2 and No Project Alt in page 8 of the Executive Summary and changed to Alt A, B, and C, and change again in page 807. Need to be consistence in naming the alternatives.
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P812, Fig 4.2-3 Alternative 2
How is this alternative stand up to climate change, sea level rise, coastal management retreat? Where is the plan for a parking place for the homeless vans and other vehicles so to reduce environmental hazards along the beach and wetland areas?