report as well. I find it shocking that this document and maps are not referenced. 1982 was indeed a 100 year El Nino series of events which cumulatively caused this damage. These events can and will happen again in Pacifica, especially given the increased severity of storms with climate change. Please see relevant sections of 1983 Safety Element below.
And continuing on page 135
12 And continuing on page 136
18. The HDAI report and 1983 Safety Element also include specific mitigation measures related to debris flow landslides which seem to be missing from the current draft DEIR and Safety Element. Please review these policies with a geotechnical and hydrological engineer to ensure appropriate policies are incorporated in the revised General Plan documents to minimize and mitigate debris flow landslides and protect public safety.
From the 1983 Safety Element, pages 101 and 102:
13 14
19. Policy 1 (again should these policies not have a specific identifying number to refence in the General Plan?) on page 3.6-22 states, “Prohibit development in hazardous areas unless detailed site investigations ensure that risks can be reduced to acceptable levels and the structure will be protected for its design life.
Development shall be designed to withstand a minimum of a 100-year hazard event, regardless of the specific nature of the hazard. This concept applies to both on-site and offsite hazards.” First of all, how you identify hazardous areas without properly updated maps using best available data in the DEIR and General Plan? Secondly these detailed site investigations, borings and geotechnical analysis should take place during the planning review (Entitlement) process so that hazards can be fully understood and properly mitigated as otherwise changes may be required to basic design, number of units, access, etc.
Vista Mar is a perfect example of a project in a high hazard landslide prone area where the city did not require a thorough geotechnical analysis. City policies and development procedures need to be revised to comply with this DEIR policy to ensure consistency in application. Please clarify how and when this will be accomplished to ensure vertical consistency between General Plan documents and the Pacifica Municipal Code.
20. Policy 4 on page 3.6-22 states, “Prohibit seawalls which are necessary as a mitigation measure for new development. Projects should not be approved which eventually will need seawalls for the safety of the structures and residents.” Ensure that this language is clear for all new development in the Coastal Zone, including Sharp Park. Even if existing sea walls are rebuilt to “protect infrastructure” their presence cannot be used as a mitigation measure for new development in the areas of projected sea level rise and coastal erosion. Any new buildings and their access points must be adapted to 100-year projections for sea level rise. This may involve major design issues such raising ground floor levels, providing long handicapped access ramps to commercial spaces, etc. Please clarify where such policies are found in the General Plan and Sharp Park Specific Plan to ensure horizontal consistency between documents.
21. Following Policy 4 on page 3.6-22 is Policy 7. What happened to policies 5 and 6. Please confirm if this is an omission or simply a misnumbering.
15 23. Methodology and Assumptions on page 3.6-23 neglects to include local hazard maps included in the DEIR and GP. Please revise this paragraph of the DEIR to name all sources required for evaluations of hazards as detailed in the DEIR.
24. Under Impacts of the General Plan, Liquefaction, on page 3.6-25 refers only to map 3.6-1, but it assesses areas of highest susceptibility to liquefaction, which are actually detailed on map 3.6-2. Please correct reference or combine maps as recommended above.
25. Under Impacts of the General Plan, Seismically Induced Landslides, on page 3.6-26, it states that proposed developments would adhere to existing regulations in the Hillside Preservation District (HPD). The Hillside Preservation District Requirements include limiting development/disturbance areas based on slope and size of parcel. The steeper the slope, the less development is allowed. That in itself is a mitigation measure in that it reduces the amount of development on sensitive and hazardous slopes.
By only referencing the need for geotechnical investigations in the HPD ordinance, the DEIR policies neglect to affirm this limitation as a valid mitigation measure. This language should be added, and clearly addressed. In my opinion density bonuses that allow for additional disturbance should not be considered on sites within HPD zoning that are subject to landslide hazards. Please confirm and add language as appropriate. This has the potential to become a source of litigation against the city of Pacifica as several projects such as Pacifica Highlands and Linda Mar Woods are currently proposing plans in hazardous areas with historic landslides that include HPD overlays. Clearly worded policies in the General Plan and Municipal Code can help the city avoid conflicting interpretations and unnecessary litigation. Clear policies also help us enforce our overarching General Plan goals of preservation of hillsides and open spaces. Please clarify the city’s intended approach to these policies in the DEIR.
26. The blanket statement on pace 3.6-26 that “the proposed project impacts from landslides is considered less than significant” without proper landslide maps in the General Plan or DEIR to understand the even basic locations of hazards, cannot be made. The maps must be redrawn with accurate information to fully understand the potential impacts of the Project, or the other variations of the Project that are being considered. Based solely on the ESA map of Sharp Park showing projected coastal erosion and sea level rise in my item #19, I could not in professional good conscience make the determination that the effects of large scale build out in Sharp Park can be mitigated. If you disagree please clarify in detail how the determination was made that impacts from landslides and coastal erosion are less than significant.
27. Proposed General Policies that Reduce the Impact LU 1-21, 2, 24, 29, and 34 require site specific geotechnical information. Please confirm how existing policies will be clarified such that site specific geotechnical investigations include sufficient borings on a site to understand the various conditions over the extent of the footprint of the proposed development. Two borings at the sidewalk for a project like Vista Mar on a 50+ percent slope are not sufficient to protect the public from hazards. Policies need to translate to procedures!
28. Policies LU I-15, 30, 31, 34, 35, 36, and 41 to reduce the impact by requiring sites with steep or sensitive terrain to be added to HPD are vague and of no enforceable use unless these sites are identified and mapped, or unless very specific criteria are established that would clearly determine if a property should be thus classified. Please clarify procedures, criteria, and a specific timeline for adding HPD designations. Otherwise, this vague language cannot be claimed as a policy that reduces the impact of the project.
16 29. SA I-2 “Development in Hazardous Areas. Prohibit development in areas of mostly landslides or high or very high liquefaction risk as shown in Figure 8-2, or on slopes steeper than 35 percent, unless detailed site investigations ensure that risks can be reduced to acceptable levels and the structure will be protected for its design life.”
Figure 8.2 is not accurate, as detailed above. Landslides have occurred on slopes less than 35% so the second criteria is not enough. Please fix the figures and updates the sources and policies appropriate.
Please confirm how this has been addressed.
30. SA I-3 Real Estate Disclosure includes disclosures for landslides. Please clarify if this includes debris flow landslides and clarify from what source this data would be obtained.
31. SA I-8 Geotechnical Studies. “Within the Coastal Zone and hillside areas, continue to require geotechnical site investigation for proposed development on sites located in any of the following areas, prior to allowing site development:
• On slopes greater than 15 percent.
• In areas showing evidence of landslides or landslide potential. • In areas showing evidence of ground shaking or earth movement • Within 50 feet of a coastal bluff
• Within sand dune areas.”
I object to the words continue to require based on Vista Mar. Also, again landslide maps need to be properly updated to understand evidence or potential of landslides, particularly debris flow landslides.
The maps need to be updated, the policies and General Plan updated accordingly, and then the documents recirculated to verify accuracy. Please clarify your intended procedures and timeline to properly assess and address these hazards. Please also clarify when off-site hazards (upslope and downslope) need to be addressed through geotechnical studies to comply with the recommendations in the 1983 Safety Element for debris flow landslides.
32. SAI-9 “Maintain Restrictions on Hazardous Areas. Continue enforcing the existing Coastal Zone Combining District and Hillside Preservation District regulations that restrict development in hazardous areas where access is impractical and areas prone to hillside and coastal erosion, landslides, seismic shaking, tsunami inundation, or flooding.”
Again I object to the terms “continue to enforce”. Since 2020, I have seen multiple projects approved by the Planning Commission and City Council in hazardous zones without proper geotechnical review, such as Vista Mar, 1567 Beach Boulevard and 1300 Danmann. The City has also approved multiple projects recently that did not comply with HPD including Harmony One Lot 3, Harmony One Lot D, 801 Fassler, and the home recently approved at the end of Talbot. Vista Mar was also proposed to be added to HPD. What are our policies, when are variances or takings arguments acceptable, how will density bonuses be considered? There are so many questions unanswered which are currently being viewed as loopholes for project approvals, so until we have clarification on the policy and exceptions, I strongly object to this being considered a mitigation measure. Please confirm when the city will undertake a proper and thorough review of our Hillside Preservation Ordinance so that it can START to be properly applied again as it was in the 70s, 80s and 90s. I have many examples of proper planning review from past project to share with staff and council so that we can start to review projects properly again for compliance with our HPD ordinance.
33. SA-I-114 Critical Facilities Locations – again proper maps are needed for a comprehensive understanding of hazardous sites so they can be avoided for critical facilities. Please map and provide a detailed list of any existing critical facilities currently located in hazardous zones, such as water storage tanks on hillsides, sewage pump stations near areas of projected coastal erosion and sea level rise, etc.
34. SA-I-7 Erosion prevention by revegetation. This is missing critical information from the 1983 Safety Element and the Howard Donley report about the dangers of planting trees and shrubs on slopes more than 50%. Please revise text of measure appropriately as was done for the recent Talbot project approval in 2022 and confirm new language.
35. SA-I-11 Grading and Drainage Plans – Grading and drainage plans should be required for all projects requiring a coastal development permit OR a grading permit, not AND a grading permit. I believe the word “and” is in error. In my professional opinion, all development on slopes over 15% should require 17 grading and drainage plans as part of the development review process before obtaining entitlements. I am happy to research similar policies in many other Bay Areas cities as examples.
This policy also prohibits development related grading and vegetation clearance on slopes steeper than 35%, but other policies herein permit this grading with geotechnical review. Which is it? These policies conflict and will subject the city to legal challenges. All General Plan documents must be horizontally consistent as is clearly stated in the introductory section of the GP and DEIR.
36. SA-I-70 Technical Reports please define “recent”.
37. CO I-46 Shoreline protection. Please clarify what “existing structures” are eligible for shoreline protection. My understanding is that it is only pre–Coastal Act (1972 I believe) and not that all existing structures are eligible. Please clarify and amend language.
38. Page 3.6-37 Impact of the Sharp Park Specific Plan says the area is at risk of few landslides, and yet the map Figure 3.6-3 indicates this area is subject to severe beach erosion and severe beach and cliff erosion on the northern section. I cannot evaluate the potential impacts of the Proposed Project and specifically the Sharp Park Specific Plan with the data and maps included in this DEIR. Please provide current updated information and accurate detailed maps and justify the city’s position that the impacts of the proposed project will be less than significant.
39. SA-I-18 Accessory structures in Coastal Zone on page 3.6-32 of the DEIR seems to be SA-I-16 in the GP Safety Element. Please confirm which number is accurate and what may be missing in the other document.
40. The Bibliography in the DEIR does not appear to have been updated since 2014. Please update accordingly including proper website links.
41. Please confirm that the Safety Element meets the requirements of Government Code Section 35602(g) (1) “A safety element for the protection of the community from any unreasonable risks associated with the effects of seismically induced surface rupture, ground shaking, ground failure, tsunami, seiche, and dam failure; slope instability leading to mudslides and landslides; subsidence; liquefaction; and other seismic hazards identified pursuant to Chapter 7.8 (commencing with Section 2690) of Division 2 of the Public Resources Code, and other geologic hazards known to the legislative body; flooding; and wildland and urban fires. The safety element shall include mapping of known seismic and other geologic hazards.
It shall also address evacuation routes, military installations, peakload water supply requirements, and minimum road widths and clearances around structures, as those items relate to identified fire and geologic hazards.” I have not come across evacuation routes and minimum road widths, nor peakload water supply requirements for example. Please clarify where this information is found in the General Plan or DEIR.
42. With Pacifica’s adoption of the Local Hazard Mitigation Plan by the City Council on November 21, 2021, Government Code Section 35602(g)(4) requires the Safety Element to be updated to “to address climate adaptation and resiliency strategies applicable to the city or county. This review shall consider advice provided in the Office of Planning and Research’s General Plan Guidelines and shall include all of the following:
(A) (i) A vulnerability assessment that identifies the risks that climate change poses to the local jurisdiction and the geographic areas at risk from climate change impacts, including, but not limited to, an assessment of how climate change may affect the risks addressed pursuant to paragraphs (2) and (3). (ii) Information that may be available from federal, state, regional, and local agencies that will assist in developing the vulnerability assessment and the adaptation policies and strategies required pursuant to subparagraph (B), including, but not limited to, all of the following:
(I) Information from the internet-based Cal-Adapt tool. (II) Information from the most recent version of the California Adaptation Planning Guide. (III) Information from local agencies on the types of assets, resources, and populations that will be sensitive to various climate change exposures.
(IV) Information from local agencies on their current ability to deal with the impacts of climate change. 18 (V) Historical data on natural events and hazards, including locally prepared maps of areas subject to previous risk, areas that are vulnerable, and sites that have been repeatedly damaged. (VI) Existing and planned development in identified at-risk areas, including structures, roads, utilities, and essential public facilities.
(VII) Federal, state, regional, and local agencies with responsibility for the protection of public health and safety and the environment, including special districts and local offices of emergency services. (B) A set of adaptation and resilience goals, policies, and objectives based on the information specified in subparagraph (A) for the protection of the community.
(C) A set of feasible implementation measures designed to carry out the goals, policies, and objectives identified pursuant to subparagraph (B), including, but not limited to, all of the following:
(i) Feasible methods to avoid or minimize climate change impacts associated with new uses of land. (ii) The location, when feasible, of new essential public facilities outside of at-risk areas, including, but not limited to, hospitals and health care facilities, emergency shelters, emergency command centers, and emergency communications facilities, or identifying construction methods or other methods to minimize damage if these facilities are located in at-risk areas.
(iii) The designation of adequate and feasible infrastructure located in an at-risk area. (iv) Guidelines for working cooperatively with relevant local, regional, state, and federal agencies. (v) The identification of natural infrastructure that may be used in adaptation projects, where feasible. Where feasible, the plan shall use existing natural features and ecosystem processes, or the restoration of natural features and ecosystem processes, when developing alternatives for consideration. For purposes of this clause, “natural infrastructure” means using natural ecological systems or processes to reduce vulnerability to climate change related hazards, or other related climate change effects, while increasing the long-term adaptive capacity of coastal and inland areas by perpetuating or restoring ecosystem services. This includes, but is not limited to, the conservation, preservation, or sustainable management of any form of aquatic or terrestrial vegetated open space, such as beaches, dunes, tidal marshes, reefs, seagrass, parks, rain gardens, and urban tree canopies. It also includes systems and practices that use or mimic natural processes, such as permeable pavements, bioswales, and other engineered systems, such as levees that are combined with restored natural systems, to provide clean water, conserve ecosystem values and functions, and provide a wide array of benefits to people and wildlife.” I do not see this analysis in the DEIR or General Plan. I believe these requirements coincide and perhaps overlap with state requirements under SB379. Please clarify what additional studies and sections of the DEIR and General Plan will be added to ensure compliance. 19 Thank you for your attention to these important matters of public safety. I look forward to reading the city’s responses to my comments and questions. Please feel free to reach out to me if I can provide any further clarification.
Sincerely,
Christine Boles, Architect
License #C024448
Principal
Cc: Honorable Mayor Mary Bier
Tina Wehrmeister, Planning Director
Kevin Woodhouse, City Manager
[email protected]
Attachments: 1 Christine Boles Resume 2 Elisabeth Boles letter 11.23.20 3 Christine Boles comment letter and links for LHMP 11.21.21 4 Christine Boles letter 11.22.20
CHRISTINE LEBEAU BOLES, ARCHITECT
Professional Registered California Architect, 1993, license number C 24448 Status: Certified Passive House Consultant, 2018
Green Point Rater, 2009
Certified Green Building Professional, 2008
University Massachusetts Institute of Technology
Education: Major in Architecture, 1982-1986. B.Sc.A.D., 1986 University of California, Berkeley
Masters in Architecture Program, 1988-1989
Continuing Passive House Institute Certified Passive House Designer/Consultant Training Education: Build It Green Green Building Professional and Rater Training PG&E Energy Center Multiple Courses in Environmental/Green Design Consulting Beausoleil Architects, 1992 - present
Experience: Project Architect/manager on a variety of projects including new custom residences, residential remodels, churches, community centers, hotels, restaurants, retail and corporate interiors.
Experience: Reel Grobman and Associates, San Jose, California, 1993 - 1997 Project Architect/Designer on corporate interiors projects, including high-tech clients such as Netscape, Applied Materials and Adaptec, and professional clients such as Ernst and Young and Comerica Bank.
Davenport Campbell Pty, Ltd., Sydney, Australia, 1989 - 1991 Project Architect on Bull HN highrise office building remodelling project, including creation of new retail and restaurant spaces,
Architect on Oceanic International Hotel, World Square Hotel, Horizon Country Club and Shoal Bay Country Club projects
John McLean, Architect, San Francisco, 1989
Job Captain, Designer/Drafter on live/work condominium project Stong and Associates, Architects, San Francisco, 1987-1989 Job Captain, Designer/Drafter on automobile dealership, new office building and senior citizen's center projects
Interests: French and Chinese Languages, Painting, Ceramics, Art Glass, Travel Founder and Lead Coach FIRST Robotics, Design Tech High School Cool Planet Committee Member at First Presbyterian Church Palo Alto Mission Bay Community Church Elder
Excelsior Community Food Pantry in San Francisco, previous Board Member 1 Elisabeth Lara Boles
Pacifica, CA 94044
November 23, 2020
Bonny O’Connor, Project Planner
Christian Murdock, Senior Planner
Tina Wehrmeister, Planning Director
Diedre Martin, Mayor
Sue Beckmeyer, Mayor Pro-Tem
Mary Bier, City Council Member
Michael O’Neill, City Councilmember
Sue Vaterlaus, City Council Member
Kevin Woodhouse, City Manager
Michelle Kenyon, City Attorney
cc: Pacifica Planning Commission Members
RE: Vista Mar Project, Monterey Road and the Pacifica General Plan and Safety Element Dear Planning Staff and City Council,
I am a Ph.D. student at Stanford University studying climate science and environmental engineering, and am frankly very worried about the disregard of the impacts of climate change in Pacifica’s General Plan and proposed General Plan Update. My family moved to Pacifica a year and a half ago, and in this short time we have learned of and personally experienced several examples of how the city infrastructure has been incapable of handling natural hazards that already occur. Delving into the history of the Vista Mar development has made this abundantly clear to me, and I hope that in reviewing this project tonight you will come to the same 2 conclusion. That said, testimonies from other residents around Pacifica are piling up as well. See the letters sent today (11.23.2020) about flooding from Toni Marie D’Amore and Lynn Adams and the letter (dated 11.18.2020) from Prof. Jerry Davis about landslides which references the slide in 1983 that killed three children on Oddstad Blvd. Remember too the apartment buildings on Esplanade that had to be torn down due to coastal erosion, displaced renters from 52 affordable housing units and costs to taxpayers of $330,000 because the developer went bankrupt.1,2
As I am sure you are aware, climate change will only exacerbate these hazards. Along the California coast, it will cause sea level rise, increased erosion and landslides, greater fire risk and more intense flooding. These worrying long-term trends are compounded on natural variability at shorter timescales, such as seasonal rainfall, king tides and El Niño events. El Niño events are particularly disastrous for Pacifica as they produce intense rainfall which can create flooding and destabilize hillslopes, as well as raise sea surface heights and lead to increased storm surge and coastal erosion. After the most recent El Niño in 2016, the city was granted $3.6 million in state and federal funds to repair damaged infrastructure, and it is expected that the replacement of five blocks of sea wall north of the pier will cost an additional $10 million.1I would hope that this money goes towards infrastructure improvements that will not only mend damages, but also protect the city from more extreme events in the future.
However, analysis of the General Plan Update does not instill confidence that this will be the case. Current and historic hazards are not even properly accounted for in the General Plan Update, much less future risks. For the remainder of this letter, I would like to focus your attention on the draft Safety Element of the 2014 General Plan Update. 1) Slope Failure and Erosion:
Figure 8-2 in the draft Safety Element of the General Plan Update is reproduced with additions below (Figure 1). The current maps are so devoid of real information that they are useless in assisting the city in determining hazard risks. This is corroborated by a November 18, 2020 email from Professor Jerry Davis of San Francisco State University who has extensively studied the historic slides in the San Pedro Creek watershed area.
In the July 29, 1982, Howard Donley Associates, Inc. report titled Geological Investigation Landslide Type and Distribution and Mechanic Details of Nine Representative Failures, commissioned by the city (referenced as HDAI report in the 1983 Seismic Safety and Safety Element), pages 18 and 19 (32 and 33 of the pdf), the author is very clear. He discusses the maps produced by the USGS and the San Mateo County Geotechnical Hazards Maps.
“Both of these map sets emphasize large, bedrock type of slides although slides with a maximum dimension of 500 feet are plotted. Discussion of various types of slides are provided with these maps but nowhere is there shown a high risk relationship to the City of Pacifica. The engineering geologic practice prior to January 1982, has been to consider the slopes highly sensitive to erosion and surficial sloughing only. Nowhere in the geologic literature of Pacifica is there shown or depicted the threat of mass wasting of overburden soils such as occurred in January, 1982. It is therefore our opinion that much of the published geologic hazard information affecting Pacifica is no longer valid for use in the City; a new set of landslide hazards maps should be produced for the area.”
In essence, the type of slide most common in Pacifica is not represented in the geologic maps the city uses for planning. The City has known that the geologic maps are inaccurate and not valid for use in reviewing proposed projects since 1982, and yet 32 years later, the 2014 Safety Element update still neglects to include this essential information! The HDAI report did detailed geotechnical analyses of 9 of the largest slope failures out of the 475 that occurred in Pacifica in 1982. I have mapped these 9 slides on the draft 2014 Slope Failure and Coastal Erosion Map. Except for the Highway 1 slide, all of these landslides occur in areas noted as Not Landslide Prone or Few Landslides. The 1983 Oddstad slide that killed three children is in a "Not Landslide Prone Area", as are the more recent major bluff erosion areas of Linda Mar Beach and Esplanade.
The City of Pacifica appears to have been negligent in its lack of follow through on the 1982 recommendations in this report, putting the lives and property of Pacificans in potential danger as the documented risks of building in hazardous areas have not been properly assessed.
Figure 1: Figure 8-2 of the draft Safety plan reproduced with additions of noted slides and erosion sites from the HDAI 1982 report
2) Flooding
Figure 8-3 in the draft Safety Element shows only very limited flooding along the coasts and some stream banks, with long return periods. Regions marked with a 1% annual chance of flooding are expected to experience flooding about once every 100 years. Similarly to the previous section, our experiences and anecdotal evidence dating back to the 1980s are inconsistent with the flooding map in the Safety Element. As other neighbors have discussed in their letters, the region around Monterey road experiences flooding on an annual basis, and during extreme El Niño events (which have recurred about every 15 years in recent history) the flooding has been catastrophic. This area is not even marked on the Safety Element map.
Quoting from Richard Drury’s letter dated 11.22.2020, “the current General Plan lacks accurate and up to date maps of flooding and flood related risks, and therefore lacks the information necessary to evaluate the safety implications of the proposed development.” Additionally, in reviewing the hydrology report for the Vista Mar development, it came to our attention that the city drainage system plans are nearly devoid of accurate data. 3) Sea Level Rise:
Although there is significant uncertainty in the amount of sea level rise we will see by the end of the century, the state of California has released clear guidance on planning for sea level rise.3 The 2018 Update to the State of California Sea Level Rise Guidance (link in footnotes) suggests that any projects with lifespans beyond 2050 should consider the more extreme H++ sea level rise scenario, and that this scenario is particularly “relevant to communities considering regional or general plans, climate action plans, local hazard mitigation plans, regional transportation plans, and other planning efforts, due to the interrelated nature of critical infrastructure, homes, businesses, etc.” This corresponds to an increase in sea level of 10.2 feet (3.1 m) by 2100. The medium to high risk aversion projection is 5.7 - 6.9 feet (1.7 - 2.1 m) by 2100.
While sea level rise is not as relevant for the Vista Mar development, it was noted at the City Council meeting last week that no geotechnical or hydrological analyses of the Sharp Park area have yet been done prior to consideration of the Sharp Park Plan. The USGS’s Our Coast Our Future project is a useful tool for visualizing the effects of different sea level rise and storm surge scenarios along the California coast. Figure 2 shows the results of 2 m of sea level rise and a 100 year storm surge event for the region of the Sharp Park. A significant portion of the proposed downtown development would be flooded in this medium-high risk scenario. Importantly, this does not take into consideration concurrent flooding from precipitation or local streams, which would also have to be factored in for El Niño events, for example. It seems the city is putting the cart before the horse in paying high priced consultant fees for development models that are not based on scientific facts.
Figure 2: Our Coast Our Future flooding map for Sharp Park for the scenario of 2 m Sea Level Rise and a 100 year flood.4
I would suggest the City concentrate its efforts on updating the Safety Element that is out of compliance with state regulations before other potential zoning changes can be considered.
Senate bill 379 that amended Section 65302 of the Government Code in 2015 requires the Safety Element to be reviewed and updated as necessary on or before January 1, 2022 to address climate adaptation and resiliency strategies. There is obviously a lot of work that needs to be done to meet this deadline, which is only 13 months away.
I recognize that there are major pressures on the city to provide more housing, but I urge the council to suspend new permits and construction until a full evaluation is completed of the hazards that the project could incur or create for surrounding properties. Performing this due diligence in advance of project approval will save time, money, and lives. I would be happy to use my expertise and connections to help the city develop more accurate maps and projections of climate change impacts.
Sincerely,
Elisa Boles
PhD Candidate | Environmental Fluid Mechanics Lab
Civil and Environmental Engineering | Stanford University Citations:
1. Kinney, Aaron. Pacifica to demolish another clifftop apartment building. Mercury News.
Published: December 14, 2016.
https://www.mercurynews.com/2016/12/14/pacifica-to-demolish-another-clifftop-buildin g/
2. Melendez, Lyanne. Crews demolish condemned Pacifica apartment complex. ABC7 News. Published: January 30, 2017.
3. https://abc7news.com/news/crews-demolish-condemned-pacifica-apartment-complex/172 8963/
4. California Natural Resources Agency and California Ocean Protection Council. State of California Sea Level Rise Guidance: 2018 Update.
http://www.opc.ca.gov/webmaster/ftp/pdf/agenda_items/20180314/Item3_Exhibit-A_OP C_SLR_Guidance-rd3.pdf
5. Our Coast Our Future. Interactive Flood Maps. Accessed November 23, 2020. https://data.pointblue.org/apps/ocof/cms/index.php?page=flood-map ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com DATE: November 22, 2021
TO: Pacifica City Council
City Manager Woodhouse
Assistant City Manager Wehrmeister
Deputy Planning Director Murdock
Chief of Police Steidle
RE: Multi-Hazard Risk Assessment, Consent Agenda item 5 Dear Council Members and staff,
As you can see from my letter on page 289 of your agenda packet, I have already spent a considerable amount of time analyzing the San Mateo County Multi-Hazard Risk assessment as it pertains to Pacifica. I reviewed the revisions this weekend and while I appreciate some of the changes that staff incorporated as a response to public comments, I still have concerns about the accuracy of some of the information in the revised report. I would ask you to pull the item from the consent agenda so that we the public can hear from staff and engage in some dialogue with you all about whether some other edits/clarifications might be needed. If your vote on accepting the document can be delayed, my preference would be to move this item to a future agenda allowing time for a more thorough review. As this report and process pertains to council priorities of ensuring public safety, building public engagement and rebuilding public trust, I would hope that you would see the value of an open discussion and partnership with the community on these important issues. The importance of having an accurate document that shows a deep understanding of the many natural hazards we face in Pacifica and the necessary mitigation steps to both prevent and respond to inevitable environmental catastrophes cannot be overstated.
I see that the draft response that you are reviewing as part of today’s agenda that has not yet been approved by Council has already been submitted to the County as it posted on their website. This seems very odd. I’d also like to point out that the Wildfire Hazard Severity Map is missing from both your agenda and the county website, so I question whether this incomplete draft can be adopted today.
I also wanted to ask if there was a draft of the General Plan Safety Element that I could see now? As according to the City Manager, you are going to release that draft next month, surely there is additional technical information in this new draft that relates to this hazard mitigation plan which would help better inform this document.
Attached are my red marks with suggestions and corrections to several pages current draft. Sorry, these are a bit sloppy, I am trying out a new document annotation method and am still getting used to the technology.
I would like to start by responding to staff responses to public comments, found starting on packet page 352.
Item 1 – Landslide Risks
Given our history, that in the winter of 1982/83 alone Pacifica was subject to 475 landslides, with multiple area evacuations for days due to the risk of saturated hillsides and flooding, which also led to the tragic deaths of three children, I am glad to see that the city recognizes this as the highest-ranked hazard in table 14-2.
While some commenters focused solely on Linda Mar Woods, which is in a high landslide susceptibility area, so the concern there is very real, I am not asking for property specific level assessment here as the staff response claims, but a robust assessment of landslide hazards that can be used as part of general planning for the entire city.
3 ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com I have pointed out to Council and Planning Staff multiple times in the last year, including exactly one year ago in public testimony as part of the Vista Mar City Council appeal hearing, that Pacifica’s General Plan and Safety Element do not address these hazards. The Howard Donnelly Report of 1983 which informed the Safety Element update, specifically said that Pacifica’s landslide maps were inaccurate for the type of shallow surficial debris flow landslides Pacifica is most subject to. The report called for new landslide maps to be created back in 1983, almost 40 years ago. The 2014 Draft General Plan Safety Element posted on the city website still does not address these landslides as I previously documented to you all in several letters and emails.
If the city is actually working on a proper update to the Safety Element now, which is supposedly soon to be released for public review with other General Plan documents, then surely there must be better information available that we can refer to analyze and mitigate our landslide risks. The state USGS has recently come out with new interactive landslide maps that appear to address debris flow landslides, so we have better tools available to us right now to address gross planning for these type of disasters. These maps should also start to be used immediately to inform our review of development applications as there are several pending currently being reviewed that are on hazardous sites, including
A) The home on Talbot on a site with mostly 100% slope that has already come before the Planning Commission once this fall 2021
B) Pacifica Highlands, which is on a fast-track SB 330 application due to be complete by February of 2022.
Project plans shows two areas with historic landslides, cutting right through proposed new roads and structures.
C) And of course, this Council majority approved the Vista Mar project in late 2020, on a site with a 52% average slope with a history of landslides, some noted as active, using a geotechnical report that had no recent borings in the area where the buildings were proposed. The test pits to analyze these landslides that were required in 1991 as part of the William Cotton geotechnical peer review for a very similar project by the same engineer, were never done.
D) Linda Mar Woods, which is also in an area with high landslide risk.
Notwithstanding our fatally out of date General Plan and Safety Element, our current planning processes do not sufficiently protect the public from landslide and flooding risks, and that is the core reason the city is currently being sued over this project’s approvals. We need a major overhaul of not only our General Plan and ordinances, but our planning policies and procedures to ensure the public is protected and that the city is protected from the financial losses in case of hazardous construction and bankrupt developers who leave us to pick up the pieces.
I am glad to see our Hillside Preservation Ordinance added to the hazard document, as item b under the very first paragraph about the intent of the ordinance in Article 22.5 of our Municipal Code specifically says to “Help protect people and property from all potentially hazardous conditions particular to hillsides;” As you are aware from public and Planning Commissioner requests, making sure our HPD ordinance is properly reviewed and enforced requires discussion. I have recently obtained historical project documents that show the ordinance was properly applied to projects in the past; we can easily learn together from these documents and improve our processes moving forwards if Council would allow the time for an open discussion in a study session. I have also offered several times to meet with the City Manager as well as planning staff on these issues and am still very willing to do so.
2. Wildfire Risk
As previously stated, the document you are scheduled to approve today appears to be missing the Fire Risk map.
As Pacifica residents Cindy Abbott and James Kremer so eloquently analyzed in their comments, wildfire risk does not magically change at a city border. As we saw in the recent CZU fires in the coastal zone with an identical climate to Pacifica, our risks have increased substantially with climate change in the past decade. Parts of Pacifica, especially our southern border is filled with very flammable eucalyptus, is indeed a high fire risk area.
Our own 2014 General Plan Safety Element notes this area and several other areas of Pacifica as Very High Fire Severity Zones. See image below. The fire risks in Pacifica are not uniformly “medium” as proposed in the current document revisions.
♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com And should we not consider planning for increasing fire danger due to climate change? Perhaps new developments adjacent to open spaces should be held to stricter state Wildland Urban Interface requirements to protect both people and firefighters? Many Bay Area cities already incorporate WUIZ fire codes. ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com And at what point is the Fire Department brought in to review projects in fire hazard zones? Recent examples:
A) The home on Talbot on a site bordering Milagra open space came before the Planning Commission this fall 2021. The drawings contained errors with relation to fire hose path lengths and the lengths exceeded state code maximum requirements of 150 feet. This non-compliance should have required special exceptions from the Fire Marshall, which were not addressed in the staff report.
B) Pacifica Highlands, which is on a fast-track SB 330 application due to be complete by February of 2022 I believe. The current notice of incomplete states, “A secondary egress route may be required. Additional consultation with North County Fire Authority is required prior to approval.” I am shocked that this basic issue of site access has not been resolved at this stage. On one of my current architectural projects, on a 69 acre site next to open space in Santa Clara County, the application is not deemed complete and yet the fire department has already given detailed feedback as to road design and water capacity. We have even had to add a new 60,000 water storage tank as a backup firefighting source as part of the initial planning review.
C) Linda Mar Woods - the long one-way road does not meet state fire or basic Pacifica city standards. Is the project even remotely viable?
Pacifica can and must do better in ensuring projects are safe from fire hazards with proper agency coordination and review early on.
3. Coastal Erosion and Building Condemnation
I have marked up packet page 402 with several other hazard events and building removals that are not included in the report. I have not done extensive research, so others are likely missing.
Staff response states that “The City has declared one additional building as unsafe for occupancy that is not included in Table 14-11 – the property at 1112 Palmetto Avenue. However, the building owner is continuing efforts to obtain approval from the California Coastal Commission to protect the property from further coastal erosion and the building has not been demolished.” Based on my research and recent correspondence on November 5, 2021, City staff and Council are aware that the owner of 1112 Palmetto has not worked with the Coastal Commission since 2016 when they received a temporary permit for armoring. This permit has expired and the armoring they did is now illegal. This documentation is all in the real estate listing disclosure papers that I attached in this email. The Coastal Commission had filed several violation notices on the property, including one as recently as last month. On Friday November 12th, I asked Coastal Commission staff in an email who takes authority to ensure a building is removed or moved before it becomes public danger and ocean environmental hazard? Here is the response I obtained from Jo Ginsburg, the Coastal Commission’s Enforcement Analyst. ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com So, what are our policies for coastal hazard removal? What are the triggers by which a structure is deemed uninhabitable and a public danger? And who pays for the removal? There are other buildings near the cliff edges too, such as 1044 Palmetto, where the building is now only about four feet from the edge. One major storm could send the foundations over the edge. The city’s responses in this document seem to be severely lacking in analysis and mitigation planning related to coastal erosion and sea level rise.
I have a client meeting now and do not have the time complete my response.
Again, I encourage the City Council to take public input tonight and to complete a proper update of this important document, which should also feed into the update to the General Plan Safety Element. Thank you.
Sincerely,
Christine Boles, Architect
Principal
♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com DATE: November 22, 2020
TO: Bonny O’Connor, Project Planner
Christian Murdock, Senior Planner
Tina Wehrmeister, Planning Director
Diedre Martin, Mayor
Sue Beckmeyer, Mayor Pro-Tem
Mary Bier, City Council Member
Michael O’Neill, City Councilmember
Sue Vaterlaus, City Council Member
Kevin Woodhouse, City Manager
RE: Vista Mar Project, Monterey Road and the 1980 General Plan and Safety Plan Dear Mayor Martin, Honorable City Council, City Manager Woodhouse, and Planning Staff, The 1980 General Plan contain several elements that should be applied when considering the approval of any development project. I want to draw your attention to the Seismic Safety and Safety Element, dated 1983, which is incorporated into the 1980 General Plan. Based on this element, it is clear that the Vista Mar project was not reviewed to these standards by either the Planning Department or the Planning Commission, and therefore the Planning Commission approvals are invalid and should be voided by upholding our appeal.
I have several documents I would like to share with you as part of this letter, and they located in this Google Folder. https://drive.google.com/drive/folders/1pePLw7vSsUPxoi_RrYL5Vap3wfEK8o9G?usp=sharing I have included the current 1980 General Plan and 1983 Safety Element document for reference, item 1) The safety element is on page 131 (document page 98).
The 1983 Safety Plan revision date stems from several landslides that occurred in the wet winters of 1982 and 1983. Prior to these events, shallow, debris flow type landslides, also known as “surficial landslides,” as noted on page 98, seem to have been poorly understood. It is unfortunate that it took the deaths of three children on Oddstad Road in Park Pacifica from a landslide that engulfed their home in mud in the middle of the night in early January 1983 to prompt this update to the General Plan.
I also want to take this opportunity to remind you that several other documented landslides have occurred on the Vista Mar hill since the General Plan was last updated in 1983. See image on next page. In my letter of 10.18.20, I shared several of these geotechnical reports with you as outlined below; The first three relate to landslides identified as 8, 9, 10 and 11 on the Vista Mar site itself.
C- 1988 Herzog Report for Vista Mar (I have included a more legible copy recently obtained from the public records search by Summer Lee and Kristin Cramer) D- 1991 Hom Report for Vista Mar
E- 1992 William Cotton Geotechnical Peer Review for Vista Mar In addition, I would like to add the following reports we have found in the city records to our documentation of other landslides on the hillside to the project record. 2) 1990 Baldwin Report for Pacifica Palisades Subdivision, identifying landslides 7 and 13. 3) 1998 PAC Geotechnical Report for Pacifica Palisades Subdivision, identifying landslides 6 and 12. 4) 2005/2006 Imperial Park Landslide, City Council meeting agenda to approve funds for repairs. 4 ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com
When I asked the city for records of previous landslides around the Vista Mar Site, I was only given information about two of these events.
1) The Imperial Park landslide off of Hickey in 2005/2006, which required $520,000 in repairs in 2008, that was reimbursed by FEMA. This is item 1 on the map above. 2) The landslide/major erosion on the two properties adjacent to mine at 460 and 462 Monterey Road in 2016 that lost half of their back yards to the open drainage channel behind our homes known as Big Inch Creek, item 4 on the above map. The only documentation provided to me by the City for that event were two photos. There was no documentation of the creek bank repair work and large tree removal that was done as their roots were undermined by the slide, and no associated costs were reported, even though the work took several days to complete and the city hired an outside tree removal company. At a minimum, the City should have a record of City approved engineering plans for this major landslide. Photos and videos, including additional items from neighbors, were shared previously and can be found here.
https://drive.google.com/drive/folders/19y_rIibT4t8Bsf_boc0WovfqF14nMBCg?usp=sharing The information in this 1983 Safety Element document is directly related to the Vista Mar landslides documented by Herzog and Hom, and by the William Cotton peer review as part of the previous 1991 submittal for this project. These four landslides, two of which are listed as active, are the same kind of surficial debris flow landslides that occurred in 1983 on Oddstad Road. Again, I remind you that the current project geotechnical report contains NONE of this information, and it is only because of neighbor demands of public records that we now have access to these more thorough geotechnical investigations, which the planning department was obligated to consider in the review of this project.
♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com Quoting from page 102 of the Safety Element, Item 1, “Policy – Prohibit developments in hazardous areas unless detailed site investigation ensures that risks can be reduced to acceptable levels.
Implementation- Environmental Review procedures mandate detailed studies for any discretionary review project which may constitute a risk or which is located in a hazardous area. Development is not permitted unless all risks are adequately mitigated. Building and planning permits are not issued unless the City is satisfied that the level of risk and mitigations are acceptable. The City recognizes both on- and off-site hazards and requires mitigation if necessary and appropriate.” [emphasis added]
Please note that planning permits are not allowed, and yet at the recommendation of the Planning Department, the Planning Commission erroneously approved this project. Does the Planning Department not consider the Safety Element in review of projects? Have other projects been mistakenly approved as well? I have not seen a risk assessment for this project or any study of potential off-site hazards. Is the City willing to accept responsibility for these unknown risks at this point without comprehensive updated geotechnical and hydrological investigations as is required by the Safety Element prior to the issuance of any planning permits? In terms of off-site hazards, besides the potential landslides, there are flooding issues that must be addressed.
While this project is not in an “identified” Flood Zone according to City hazard maps, I have previously shared with the Planning Department and Planning Commission evidence of regular flooding of the area downhill from the project, both on Monterey Road, and in Big Inch Creek. Here is a link to those photos and videos. https://drive.google.com/drive/folders/1iVYWM-Tv1aK-W9WwkpXqLAocH5JY0LTy?usp=sharingNote that the Monterey Road files are all recent, in dry winters.
As Monterey Road and Hickey join together just below Vista Mar, and just above my home, the city streets are regularly inundated in heavy rains. The existing stormwater infrastructure is woefully inadequate and cannot handle the amount of water coming down the hillside now, even without this development. In an email, my neighbor Lynn Adams, the President of the Pacific Beach Coalition, told me she has seen so much water coming down the hill that cars were moved. We only finished construction and moved into our home in 2019, but I have seen the streets flooded, with parked cars creating horsetails of water into our front yards from the street from curbed tires. Every house on our block which is located downhill from the street has barriers next to the sidewalk to try to contain some of this water, and additional sandbags stay in front yards and driveways all winter long. Neighbors have had to file insurance claims for flooding from the street. I have had to wade through 10” of water on the sidewalk to alert a neighbor to move their car in the middle of a hovering storm cell. When I asked the engineering department to consider adding additional drainage as part of the Monterey Road repaving that happened this year, I was told there was no money in the budget. (This begs the question of why the city is not requiring more infrastructure improvement funds from developers, including this one. $5,000 won’t even pay the permit fees.)
Because of these concerns about potential additional water flow from the Vista Mar Development, my husband, Bob Boles, met with Ray Donguines of the Engineering Department on September 14, 2020 to review existing stormwater systems and capacity in the area. The City block book records for this area are not up to date and contain major errors and omissions. The Block Book map in front of Vista Mar is actually blank. The correspondence from Bob is item 5) in the Drive folder.
The applicant, Javier Chavarria’s drainage calculations, even as they are without proper soils and groundwater analysis, show at least an 18” pipe is needed from the Vista Mar swale to connect to the 24” pipe in the street.
No one seems to know how much water is already coming into this pipe from further uphill. One of our neighbors, Garrick Meeker, who lives on Monterey just above the Vista Mar site has seen the stormwater manhole covers on the street pop off during heavy rains. We believe this to be a sign of an overloaded or blocked system. Again, this is uphill and before any additional water from Vista Mar is added.
We neighbors are very concerned for our safety because of these hazards, and that is why we have organized the Vista Mar Preservation Alliance and spent so much time and resources researching and questioning this project.
We are appalled that the planning department has abdicated their responsibility to fully evaluate the project risks ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com before advocating for project approval. We are here to ask you to carefully review the evidence we have provided and the questions we pose, and ask yourselves, can the City be satisfied with the level of risk this project poses without a full geotechnical and hydrological analysis as is required by the current General Plan and Safety Element?
Furthermore, there are specific items mentioned in the Safety Element that are not recommended for steep slopes, and yet the Vista Mar project proposes these very measures.
A. “It is recognized that intense rainfall is the triggering mechanism for the majority of slides and, therefore, drainage improvements are important mitigation measures. Surface swales and subsurface drainage can help avoid saturation of the soil.” P. 102
The Vista Mar Project proposes to pave over the existing natural surface drainage swale and probable wetland with a driveway and retaining walls, eliminating its ability to manage runoff on the only relatively flat area of the site.
B. “For steep slopes in excess of 50% (Vista Mar site has an existing 52% average slope), the slopes should contain a mature stand of grass or other type of groundcover. However, shrubbery, brush and trees appear to be more harmful to the overall stability of steep slopes and should be avoided.” P. 102 Because the Vista Mar project removes 57 trees, 6 of which are heritage, the project proposes to plant many new replacement trees on these steep slopes. Adding insult to injury, the Planning Commissioners actually added a substantial number of additional trees to be planted as a condition of approval. The planning staff made no mention of the incompatibility of this condition with the General Plan Safety Element in the staff report or during the public hearings. Senior Planner Christian Murdock even assisted in writing a new condition of approval to add more trees during the October 19th hearing where the project was approved.
C. Short term action item 1, on page 112 says, “Enforce and promote ordinances requiring geotechnical site investigation for any site with an average slope exceeding 15% prior to allowing site development. The impacts of increased water runoff from proposed development should be determined as part of the geotechnical study prior to site approval.”
The water runoff cannot be accurately calculated without full soils analysis that ascertains the underlaying soils, rock depth and water table. No borings were done in the area of proposed buildings as part of this application and so this information was not available to the civil engineer in the design of these systems. The 1991 soils report we found in the records shows water seepage in August, which could indicate the presence of a spring. We, our consulting engineer, Cliff Bechtel, and our consulting Geology/Hydrology expert, Steven Bond, have previously argued the deficiencies in Javier Chavarria’s drainage calculations.
In the 1991 geotechnical investigations we found, William Cotton and Associates wrote, “The stability of active and historic landslides at the site should be more fully evaluated. Geologic cross sections should be prepared illustrating the surface profiles and subsurface investigations of the landslide masses. Additional subsurface exploration should be completed as necessary to characterize the properties of landslide materials and the depth of failure. With consideration of the prepared cross sections, the project geotechnical consultant should recommend any supplemental mitigation measures which may necessarily prevent these features from adversely impacting proposed site improvements. The consultant should also address the landslide identified by Herzog Associates in the Vicinity of Herzog Test Pit #6.”
Why were these further thorough investigations required in 1991 under the very same General Plan and Safety Element, and yet, now in 2020, the Planning Department seems to have abdicated their responsibilities to the General Plan requirements by allowing this project to get this far and recommend approval to the Planning Commission without a single boring in the area of construction? ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com D. Short term action item 17, “Zoning and other City ordinances should be revised to restrict development in hazardous areas where access is impractical, or areas particularly prone to hillside and coastal erosion, landslides,” etc.
The City Planning Department has indeed updated its zoning ordinance for this site, twice actually, and yet the lack of any movement on the updates to the General Plan are directly hampering the ability to review the project to these more demanding standards that would account for the risks associated with development on hillsides.
1. The 2014 General Plan adds a Hillside Preservation District (HPD) overlay to the zoning, which specifically calls for special controls for any development on hillsides to:
a. Preserve and enhance their use as a prime resource;
b. Help protect people and property from all potentially hazardous conditions particular to hillsides; c. Assure that any development be economically sound; and d. Encourage innovative design solutions.
HPD zoning regulations contain a formula for allowing a certain amount of development area based on the project’s average slope. 40% is the maximum slope for which ANY development is allowed. The Vista Mar average slope is 52%.
2. The 2020 Draft General Plan changes the zoning of this site to ROSA – residential/open space/agriculture, limiting development to .2 units per acre. At 1.2 acres, this site would not even support one home.
As you can see, previous planning staff understood the risks of development on this hillside and recommended zoning changes that consistently prohibit all development on this site. And yet the current planning department staff report for the public hearing on August 3rd erroneously said there were no future proposed zoning changes to this site, thereby misleading the Planning Commissioners. So here we are, wasting everyone’s time and money in reviewing a project with 8 units on this steep site with identified hazards, a sea of retaining walls up to 25’ high, and over 6,000 cubic yards of grading (by comparison San Mateo County sees any grading over 250 cubic yards as excessive and requires a separate discretionary grading permit).
As I have argued in several previous letters, the project as currently designed does not comply with the 1980 General Plan standards for this site that on page 36 specifically describes this part of Pacifica, “A large steep area along Monterey Road and Norfolk Place, between Norfolk and the rear of the single-family lots on Heathcliff, has been planned and zoned for low density residential development. Each site proposed for development should have a thorough geotechnical investigation. In recognition of the high visibility of the area, innovative design solutions should be proposed which minimize height, building mass, and retaining walls to the extent feasible.” The Planning Department and Planning Commission that reviewed a very similar proposal for this site proposed by the same engineer, Javier Chavarria, in 1991 unanimously voted it down for many of these same reasons I have argued. (Exhibit F from my 10/18/20 letter, included in the current Drive folder). The current staff report for this meeting on the bottom of page 2 is misleading, as the 1991 City Council upheld the strict requirements that were imposed on this project by the Planning Commission, Planning Department, and the City Engineer. I encourage you to read this report as it shows the planning department’s clear review in relation to the 1980 General Plan. When Javier Chavarria pulled the application on March 31, 1992, he said it was because he could not comply with the strict requirements of the City’s Geotechnical Consultant in time.
The current Vista Mar project proposal should not have been approved at the October 19th Planning Commission Hearing as it does not comply with the 1980 General Plan or the 1983 Safety Element, and I urge the City Council to reconsider the ill-informed and non-compliant approval.
I also urge the City Council to pressure the Planning Department to finalize the General Plan updates as soon as possible as an outdated General Plan does not address the potential hazards and required mitigations. It is based on outdated analysis and facts regarding changing local conditions. Until this work has been done and adopted, ♦ Pacifica, CA 94044 ♦ Tel ♦ www.beausoleil-architects.com projects in hazard areas cannot be properly designed or reviewed. This can potentially put the Planning Commission and the City Council in jeopardy as you are required to make findings that the proposed projects risks are “manageable”.
In fact, I fear the City’s lack of an update to the Seismic Safety and Safety Element since 1983 is in conflict with California Government Code, Title 7, Planning and Land Use, Division 1, Chapter 3, Article 5 regarding Authority for and Scope of General Plans Here is a link to that section of the state code. https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=GOV&division=1.&title=7.&part= &chapter=3.&article=5.
Section 65302 (g)(2) says, “The safety element, upon the next revision of the housing element on or after January 1, 2009” shall be updated to include more information about flood hazards. As I understand it, Pacifica’s current Housing Element was approved in 2015, after the 2009 cutoff, and yet the current Safety Element still dates to 1983.
In addition, section 65302 (g)(3) says, “Upon the next revision of the housing element, on or after January 1, 2014, the safety element shall be reviewed and updated as necessary to address the risk of fire…” Section 65302 (g)(4) also requires any revisions to the local hazard mitigation plans after 2017 to review and update the safety element “as necessary to address climate adaptation and resiliency strategies applicable to the city or county.”
This seems to indicate that the Safety Element draft as part of the 2014 General Plan update may no longer be valid as its’ data was taken from studies done in 2009 and even the data from those studies is woefully inadequate concerning hazard zones. An updated EIR will take some time to prepare and circulate, and revisions to the 2014 General Plan and Safety Element will surely be needed to meet these state requirements. I would question how much longer we will need to wait for an update, and whether development projects can continue to be approved in the meantime.
Fortunately for residents of Pacifica, as of January 1, 2022, the state will now require all municipalities to update the safety element on a maximum 8-year timeline coinciding with required housing element updates. These updates will need to include climate adaptation and environmental justice elements, which are of particular importance to residents. These state requirements have both legal and financial implications for the City of Pacifica in the near term, and I just want to make sure that the City Council and Planning Department are working to address them now as the technical studies necessary to update these elements will take some time to prepare and process.
Please feel free to reach out to me if you have any questions. My husband, Bob and I, as well as many other neighbors who love this city, look forward to assisting you in updating the required General Plan elements.
Sincerely,
Christine Boles, Architect
Principal
cc. Michelle Kenyon, City Attorney
Planning Commission Members
From: Karen Clark [ ]
Sent: Monday, March 7, 2022 1:07 PM
To: Public Comment [[email protected]]
Subject: DEIR Comments
[CAUTION: External Email]
March 7, 2022
To City staff and Council members:
I am writing to offer my comments on the Draft Environmental Impact Report. I am writing as a citizen of Pacifica, with the experience of having lived here for 17 years in a hillside area bordering open space in Linda Mar.
First of all, there is much to applaud in the DEIR and General Plan. I want to particularly highlight that “open space and trail system expansion” is foremost in the plan, as well as sustainable development and practices. When I read this report, in its overview, it describes the Pacifica I wanted to move to 17 years ago—a place with reasonable density, gorgeous hills and overlooks, and a wonderful place to raise children.
However, in reading the DEIR it seems that some major issues have been glossed over and/or completely ignored. I am very concerned about the following areas:
1. Residential Development Projections
2. Hillside Preservation District
3. Annexation of Unincorporated San Mateo County land
4. Tribal Cultural Resources
5. Fire Danger Maps
6. Wildlife Corridor Maps
7. Traffic
Residential Development Projections
To begin with, this draft report only has a scope of 990 additional housing units. Pacifica is supposed to build 1842 housing units in the next 8 years as determined by RHNA. I don't understand how this report is valid when all the areas that are explored and defined in a 1000 page report only are reporting on HALF the number of projected homes, many of which may have two or more people in them. Whether this is new residents or current Pacificans moving into new units, this affects everything in terms of traffic, utilities, city resources, and the effects on wildlife and surrounding open space.
In addition, with the passing of SB9 and SB10, it appears that the numbers should be even higher given that lots can be split and multiple residents can live in each new unit. I am not finding any reference to these numbers in this environmental draft report, which makes it look as if it was written in 2014 and never updated except for a few new maps and a new cover page.
Hillside Preservation District and Annexation
I am pleased to see that the city has prioritized keeping the Hillside Preservation District zoning regulations. However it seems that the city is constantly granting variances to this, which sort of negates having the zoning at all. I am particularly concerned about areas of Linda Mar near my neighborhood, and the proposed Linda Mar Woods development.
The entire area near my house is marked as potential landslide area. I am glad to see the inclusion of geotechnical studies required for any site development in hillside areas.
It seems that there may be loopholes when it comes to zoning new areas of unincorporated San Mateo. I was particularly alarmed to see reference to Shamrock Ranch and potential annexation, subdivision and lot development mentioned. These are crucial areas to keep as open space.
Tribal Consultation Guidelines
Under the area where the DEIR is discussing SB 18, which requires that the city consult with relevant Native American tribes about the impact of the general plan, I find it unacceptable to say there were “no responses” from tribal contacts and to leave it that. Who was contacted? How? Was it an email that may or may not have gone to the correct person? Was there any follow-up? I find it unconscionable that there has not been more effort to include Native peoples and their input besides “there was no response.” Wildfire
This report does not have recent data. The opening paragraphs in this section do not give any data since 2013 for San Mateo County, which is outrageous given the CZU fire in 2020. The last listed wildfire in Pacifica is also incorrect, as there have been fires in east Sharp Park, above Oceana High School, and one off Fassler above the Rockaway Beach neighborhood, all since 2015. The area south of Higgins Way, which is in area of proposed development with an application currently at the Planning Department, is listed as an extreme fire area by Cal Fire:
https://osfm.fire.ca.gov/media/6526/fhszs_map41.jpg
However, the maps in the DEIR do not show this at all. Figure 3.14-1 shows only a few spots of high threat, when in fact the entire area is an extreme fire danger. It is unconscionable to prepare an environmental report that doesn't fully explore this greatest danger to all of Pacifica residents. Given the forest, filled with eucalyptus, that surrounds the neighborhoods of Linda Mar, Pedro Point, and Park Pacifica (as well as Vallemar and Rockaway Beach), it is imperative that the DEIR gets this right.
If this is highlighted properly, in turn, then the evacuation routes must be detailed and improved as well.
With the addition of the listed 990 units (but really 1842, as described above), which may be ADUs, huge developments as proposed for Linda Mar or above Vallemar, it is extremely unclear how people will evacuate in a fire. It is a Paradise, California situation waiting to happen.
Wildlife Corridor Maps
The map of Sensitive and Critical Habitat, Figure 3.7-3, seems completely inadequate and useless. To say that the ONLY wildlife corridor in Pacifica is from Milagra Ridge over to Sharp Park is absurd and does not seem researched at all. Pacifica's location to the hundreds of acres of open space, including Montara and San Pedro Mountains, Sweeney Ridge, and Mori Point indicate that much more attention should be paid to this issue in this environmental report.
I can speak to my area of Linda Mar. The old San Pedro Mountain Trail is regularly used by all kinds of animals and bobcat and mountain lion scat is often left on the trail. Recently the the city of Pacifica has put up signs recently acknowledging mountain lion activity at the start of the trail at the end of Higgins Way.
Figure 3.7-3 is completely inadequate as it pertains to Linda Mar. The area off Adobe, parts of Shamrock Ranch.. All of the land off of Old San Pedro Mountain Road is not listed as a wildlife corridor, when local walkers and cyclists have recorded video of seeing bobcats, mountain lions, and other mammals using the trails and living in the woods of San Pedro Mountain.
Parking and Traffic
This area seems really outdated and includes little information as to how Pacifica traffic has changed since the pandemic. The numbers for the beach parking at Pacifica State Beach are really low, and do not indicate the level of insanity that we as citizens experience every weekend as throngs of people come and fill the lots (half the time not paying anything), park on side roads, and leave their trash everywhere.
In addition, once again given that the required housing unit number is DOUBLE what is listed here, I don't understand how these numbers for traffic are viable. More people equal more traffic and increased danger when it comes to evacuation on the one roadway we have in and out of the city—Highway 1.
It seems like this has been glossed over, particularly with lines like CI-G-7, which states, “In consultation with Caltrans, seek solutions to ease the traffic congestion that occurs on Highway 1 near Reina del Mar, Fassler and Linda Mar intersections.” [I should point out that this statement is ridiculous given the Planning Department already has applications in review that are adding HUNDREDS of homes and people to these exact areas.]
But in closing, I would like to say several things: one, how grateful I am that they city is updating its General Plan, and two) that the effort made in this DEIR is for the most part admirable. But please, for the sake of the General Plan and the liability of the city for the next twenty years, do the right thing:
Adjust the projections for ALL areas to raise the housing units to 1842 required by RHNA. That means include figures for increased traffic, pollution, land use, drain on utilities and biological resources.
Update the maps, particularly for wildfire, landslides, and biological resources.
Update the narrative in those corresponding areas above so it matches the maps and tables.
Only then can we use it with the General Plan to be a useful and guiding document.
Thank you for your time.
Sincerely.
Karen Clark
Pacifica, CA 94044
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.
From: Gail Benton Shoemaker [ ]
Sent: Tuesday, March 1, 2022 1:55 PM
To: Public Comment [[email protected]]; Murdock, Christian [[email protected]]
Subject: DEIR Comments
[CAUTION: External Email]
Dear Mr. Murdock,
As a Tree City USA, Pacifica has committed 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 several issues such as Heritage Tree Ordinance violations, 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 i-Tree 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 expansion 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 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, Gail Benton Shoemaker
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From: Suzanne Moore [ ]
Sent: Thursday, March 3, 2022 1:09 PM
To: Public Comment [[email protected]]
CC: Suzanne Moore [ ]
Subject: DEIR feedback specific to housing
[CAUTION: External Email]
1. Development of supportive housing, special needs, all incomes, all stages of life. 3-]-37 Supportive Housing. Facilitate opportunities to incorporate innovative design and program features into affordable housing developments, such as on-site health and human services, community gardens, car-sharing, and bike facilities. Support the development of projects that serve homeless and special needs populations. page 233 - 3-G-12 Housing Opportunity. Support development of a diverse range of housing opportunities suitable for people of all incomes, abilities, and stages of life.
QUESTION: an increased inclusionary zoning of 20%, similar to East Palo Alto, would provide more low income units. Can Pacifica commit to an increase? Please comment.
2. Expand our existing tool box
Pacifica's DEIR relies heavily on relationships with for-profit contractors: infill development, density bonus, small lot consolidation, density/height proposals, in-lieu parking fees. I consider these as well-established and necessary tools in the tool box.
QUESTION:
how can we create other important tools?
1)displacement protection,
. 3-I-36 Displacement Indicators. Monitor indicators such as change in share of low- income households, average rent and sales price, supply of affordable units, and evictions and foreclosures within the Sharp Park Planning Area.
QUESTION: What mitigation does the City plan to reduce displacement and assure that residents are compensated for moving costs and/or find housing at their prior rent? A rental registry will provide much-needed data about current occupancy, rates, availabilities, communication source, and method for ascertaining displacement. Please comment. 2) a preservation model,
. 3-I-35 Preserve Affordability. Preserve and expand affordable housing in Sharp Park with the following actions:
e Provide funds to renovate older buildings in exchange for rent restrictions; e Encourage the integration of deed-restricted affordable units within housing developments;
e Discourage the conversion of older rental apartments to condominiums.
QUESTION: limits Air B&B conversion of housing from long-term housing. Long term rental residents have been evicted for unit conversion to Air B&B. Pacifica could limit conversions if vacancy rates are below 5%. Pacifica could also create a transparent database that provides permits dispensed. Please comment.
QUESTION: a dedicated city housing funding source has been necessary in other communities to participate in housing preservation. In my opinion, it is imperative for Pacifica to create this fund. Ways to fund it include transfer tax, commercial linkage fees, vacancy tax. Please comment.
QUESTION: Long-term rentals have been evicted for significant repairs. Better tenant protection could include evidence that permits have been pulled in advance of the eviction and tenant relocation benefits in the form of market-rate first, last, and deposit. Please comment.
3) ways for tenants to become owners (HEART, TOPA/COPA), QUESTION: these models have been successful in other communities to create homeownership at affordable levels and provide a model for affordability in perpetuity. Can Pacifica investigate this as an option to adopt to include first right to purchase? Please comment.
4) funding sources and relationships with nonprofits for low-income housing? QUESTION: a dedicated city housing funding source has been necessary in other communities to participate in collaboration with nonprofits. In my opinion, it is imperative for Pacifica to create this fund. Ways to fund it include transfer tax, commercial linkage fees, vacancy tax, landlord tax. Please comment.
3. Discrepancy in proposed units vs RHNA goals
page 7 - Approximately 14,520 housing units currently exist in the Planning Area.
Implementation of the Proposed Project is estimated to result in approximately 990 additional housing units.
QUESTION: I understand there are potential penalties for adopting a plan which does not meet specified RHNA goals. Explain why this projection will not put our community at risk?
4. Regarding the Local Coastal Plan:
page 169 - Although the LCLUP is a separate planning document, the LCLUP policies and relevant narratives are included in the General Plan Update to ensure coordination between the two documents. The City has prepared a draft of the LCP Update in 2019, approved by the City in 2020, and which is currently under review for certification by the California Coastal Commission.
page 212 - The Coastal Act calls for certain land uses within the Coastal Zone to have priority over other uses: recreation and visitor-serving uses, fishing, boating, and other coastal-dependent uses, and public works and industrial facilities needed to support priority uses.
QUESTION: What is the status of the Local Coastal Plan, how can consistency between documents be assured?
5. An All City Specific Transportation Demand Management Program Our DEIR prioritizes building within transit corridors. Waivers for parking construction are considered as incentives for contractors.
QUESTION: a TDM Program could evaluate and provide funding for anticipated city growth and create much-needed transit foundational to city functioning. Please comment.
6. Assuring new construction is in areas free of high hazards: fire, landslides, coastal erosion etc
The DEIR has maps of fire, landslides, coastal erosion that are outdated. Others in our community have already brought this to the City's attention. As we create our General Plan and our future vision for Pacifica, safety is a priority. Please comment on updating maps and resources to assure safety in construction of new housing. --
Suzanne Moore
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From: Cherie and Bruce [ ]
Sent: Tuesday, March 8, 2022 4:59 PM
To: Public Comment [[email protected]]
Subject: DEIR LCP Comments
Attachments: 2022-03-08_Chan-Ferry_LCP_Comments.pdf
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--
Cherie Chan
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pg. 1
Dear Mr. Murdock,
We are writing to you again to voice our concerns over the proposed changes to the Land Use designation in the Pedro Point Basin (aka the San Pedro Ave Site) from Visitor‐Serving Commercial Uses to a new Residential Mixed‐Use Designation. I urge you to listen to your my neighbors—who have consistently advocated against this ill‐advised and potentially dangerous Land Use Change. This change commits the City of Pacifica towards an avoidable battle against its own Citizens, Science, the California Coastal Commission, and the rising tides of the Pacific Ocean.
Proposing to change the basic framework of our City’s long‐term land use designation with the aim of “fixing” the affordable housing crisis with new development in a seasonal wetlands subject to frequent flooding and tsunami inundation is a sham designed to maximize profits in the short‐run, while leaving the City and its Citizens to clean up the inevitable disaster.
Inexplicably putting the city at substantial financial and legal risk benefits only one person‐‐the land owner‐‐who purchased the swamp in 1997, well after the Coastal Act was passed and the 1980 Local Coastal Land Use Plan and General Plan were adopted, at the expense to all Pacifica Citizens and Visitors.
Below are the many reasons documented below, we describe how the City has continued to bias its decisions towards the desire of one landowner to modify a known wetlands to maximize short‐term financial gains at profound expense and risk to the City, the Environment, its Residents, and all who wish to enjoy and recreate at or near California’s Coast.
Sincerely Yours,
Cherie Chan and Bruce Ferry
San Pedro Avenue
Contents
Understanding the Baseline Land Uses ........................................................................................................ 2 The Land is Currently Designated Commercial Recreation................................................................... 2 The City’s Proposed Residential Mixed‐Use Designation is Incompatible with ESHA .................................. 2 Pacifica’s Proposed CRMU Designation fails to meet the basic statutes of the Coastal Act ........................ 4 The City has Failed in its Obligation to Satisfy Section 30006 of the Coastal Act: Public Participation by Excluding Facts and Participation Presented by the Pedro Point Community ............................................. 6 Conservation Shall Be Prioritized in the Wetlands ........................................ Error! Bookmark not defined. pg. 2
Understanding the Baseline Land Uses
The Land is Currently Designated Commercial Recreation
Under the current approved 1980 Local Coastal Plan, permissible land uses are described as the following:
“The designated land use for this area is commercial with emphasis on coastal related and/or visitor-serving uses. By combining all of the parcels in the area between Danmann and San Pedro Avenue, Highway 1 and the railroad berm and developing them as an integrated project along a realigned San Pedro Avenue, this small, oceanside commercial center could be rejuvenated and expanded to become an attractive visitor destination, as well as provide for neighborhood retail needs" … adding a cultural center for performing arts and an attractive motel could, if carefully designed, enhance the appearance of this area and provide visitor services near the shoreline. …
Small scale, rustic design and ample landscaping throughout the commercial development would complement the existing attractive design elements in the Pedro Point area. Adequate public access through the development to the shoreline and a general orientation to coastal related/visitor-serving uses within the project would be appropriate in ·this location. 1’ As described by the PPCA’s hired consultant, Richard Grasetti who has submitted his testimony today, the currently‐allowed land use caps development at a floor area ratio (FAR) of 0.2, which means that total development footage cannot exceed 20% of the site area. In contrast, the proposed Land Use Designation,2
as excerpted below, represents a radical change which will increase density by 2.5 times, and will compromise an entire community’s quality of life, the public’s access to one of the Bay Area’s best family‐friendly beginner surfing beaches, and preclude the opportunity sustainable visitor‐serving jobs while greenlighting development on an Environmentally Sensitive Habitat.
The City’s Proposed Residential Mixed‐Use Designation is Incompatible with ESHA
The DEIR inexplicably claims that 70 houses will be added (Table 2.4‐2: Additional Housing Units by Land Use Type of the Draft EIR at page 2‐22) and that 100 jobs would be created (Table 2.4‐3) through this land use change; yet, as discussed by the PPCA, the City fails to provide any analysis to show how this could be accomplished, and create the requisite Environmental Impact Report which addresses these proposed changes.
Rather, the City proposes a new The Coastal Residential Mixed Use (CRMU) with an FAR of 5.0, two and a half times greater than the current density, to align with this flyer, which the current property owner has been distributing, without any input from the PPCA, although the PPCA has attempted, on several occasions, to present the property owner with commercially‐viable Recreational uses for the Field, such as Open‐Air dining, a Food Truck Festival, a Drive‐In Movie Event, and Food trucks. 1 Available at: http://www.cityofpacifica.org/civica/filebank/blobdload.asp?BlobID=2293 Pedro Point begins on page C‐54, electronically page 63. 2 On Electronic Packet Page 195: the actual page numbers of the PDF file are obscured, but I infer it to be page 1‐
29. pg. 3
pg. 4
Pacifica’s Proposed CRMU Designation fails to meet the basic statutes of the Coastal Act
The table below summarizes how the proposed Coastal Residential Mixed Use designation as applied in Pedro Point Field fails to meet the basic statutes of the Coastal Act.
Coastal Act Policy Coastal Residential Mixed Use [CRMU] Section 30006: Public Participation “the public has a
right to fully participate in decisions affecting coastal planning, conservation and development; that
achievement of sound coastal conservation and
development is dependent upon public understanding
and support; and that the continuing planning and
implementation of programs for coastal conservation
and development should include the widest opportunity
for public participation.”
FAIL: The Pedro Point Community has consistently
opposed the introduction of mixed‐Use land use
designations in the Pedro Point Field; but it has not
been heard.
See more below.
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) [conflict] public safety, military security. protection of fragile coastal resources,
(2) [redundant shore access]
(3) [conflict] agriculture
CONSTRAINT OR FAIL: Mixed residential land use
will constrain the 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
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.
FAIL: Residential development precludes
recreational use and development or conservation
in a critical wetlands.
Recreational opportunities in the neighborhood on
alternate sites are precluded: steep hillslopes,
saturated residential development.
The Pedro Point Field is less than a one‐minute
walk away from Linda Mar Beach: “The most well‐
loved and well‐used beach in Pacifica!”3
Note that the community has welcomed and
encouraged allowable economic benefits from his
property such as rentals from food trucks, rentals,
or its pre‐existing use as a Golf Range.
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.
FAIL:
Private residential development and general
commercial development are allowed to have
priority over and exclude visitor‐serving
commercial recreational development.
3 The most well-loved and well-used beach in Pacifica!” From the City of Pacifica’s Website:
https://www.cityofpacifica.org/depts/rec_department/parksbeaches/beach_and_park_info_and_rules/linda_mar _(pacifica_state_beach)/default.asp
pg. 5
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.
FAIL: Residential development density range would
require fill and drainage of seasonal wetlands and
degrade ESHA wetlands.
See Testimony of Dr. Peter Baye, submitted to the
Council on July 7, 2014 and posted at
pedropoint.org/the‐pedro‐point‐field
Section 30242. Lands suitable for agricultural use;
conversion
All other lands suitable for agricultural use shall not be converted to nonagricultural uses
CONFLICT: Residential—both horizontal and
vertical‐‐development would require placement of
pad fill (flood protection; 100 yr floodplain) and
drainage) precluding agricultural uses. (Adjacent
strip of land between the Pedro Point Field and the
berm was previously used for a Llama and an Emu)
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…
CONFLICT: Residential development would infill the
last open space in coastal lowlands from Linda Mar
to Pedro Point.
Vertical Development would greatly obstruct
existing views and enjoyment of the ocean.
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. […]
FAIL. Most of field lies approximately 15‐17 feet in
elevation above Mean Sea Level (MSL), only about
3‐5 feet above the marsh and high tide beach at
the mouth of San Pedro Creek. Residential
development requires flood protection and
drainage.
Wave runup to the field depends on the non‐
engineered privately owned berm which is not
maintained by Pacifica. Residential development
would likely require armored flood protection
structures as sea level rises.
Alluvial soils (historical wetland) of the field have
the same relative liquefaction (earthquake shaking)
potential as diked bay muds and marshes in San
Francisco Bay, and are located in a Tsunami
Evacuation Zone.
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
FULL CONFLICT. Residential development is not
coastal‐dependent, and would infill the seasonal
wetlands in the lowland floodplain of the field.
pg. 6
reasonable proximity to the coastal‐dependent uses
they support.
Environmental Justice
Equitable coastal access is encompassed in and
protected by the public access policies in Chapter 3
of the Coastal Act. The Coastal Act’s mandates to
provide maximum access and recreational
opportunities for all, and to protect, encourage,
and provide lower‐cost visitor and recreational
opportunities embody fundamental principles of
environmental justice.
CONFLICT:
“Pacifica is home to some of the San Francisco
Bay area’s best surfing beaches. Linda Mar
State Beach is one of the most popular
beginner surfing spots in the San Francisco
area”4 This is also the premier family‐friendly
break within a short distance from the San
Francisco Bay Area.
The City has Failed in its Obligation to Satisfy Section 30006 of the Coastal Act: Public Participation by Excluding Facts and Participation Presented by the Pedro Point Community
Section 30006 of the Coastal Act also states that “the public has a right to fully participate in decisions affecting coastal planning, conservation and development; that achievement of sound coastal conservation and development is dependent upon public understanding and support; and that the continuing planning and implementation of programs for coastal conservation and development should include the widest opportunity for public participation.” The residents of Pedro Point have consistently acted in good faith to work with the City and the Owner to propose a Land Use Designation which considers the unique coastal nature and reflects our concerns over residential development on this lowest‐lying parcel in the neighborhood, both as a united neighborhood and by individual neighbors.
The DEIR claims at page 16 that
The Proposed Project was developed in response to policy direction provided by the City Council and the Planning Commission as well as community concerns identified through an extensive public participation and outreach program, including newsletters, community workshops and public meetings in 2008-2010, and additional outreach 2019-2021.
Indeed, we attended many of these workshops, including the Pedro‐Point Specific workshop held at Soul Grind in the summer of 2019. The City’s own consultant noted that neighborhood’s strong preference for sustainable, Open Space, and natural recreation‐based land‐uses: the City’s proposed Land use Change to CRMU boldly rejects the community’s input.
4 Website of the Pacifica Chamber of Commerce and Visitor Center: http://visitpacifica.com/index.php?page=16 pg. 7
Below are letters from past Pedro Point Community Association presidents: Danny Estrella (2011) expresses the community’s strong support for a land use designation which retains uses of the field as‐ is. Bruce Ferry (2013) details the extensive steps the Community has taken to facilitate meaningful dialogue, and Joanne Gold who again expresses a retention of Commercial Recreation or Conservation Uses. These letters have been followed with hostility from decision‐makers. pg. 8
Letter from Danny Estrella, PPCA President, 2011
pg. 9
pg. 10
Letter of Bruce Ferry, 2013 PPCA President, Documenting extensive Community Feedback
pg. 11
pg. 12
Letter from Joanne Gold, 2014 PPCA President
pg. 13
This evidence, supported by expert testimony, continues to fall on deaf ears, bias, and even hostility, as pg. 14
evidenced in this letter from our current Councilmember.
From: "Vaterlaus, Sue" >
Date: February 24, 2020 at 9:57:58 AM PST
To: Joanne Gold >
Subject: RE: Appeal of Planning Commission Decision - 2/24/20 City Council Agenda Item
Yes we are charged to represent all Pacificans, not just the residents of Pedro Point who continually use items that are not always accurate to describe the Calson Property. Have you ever heard the term taking?
The Calsons want more and you want nothing. These numbers were brought out at a study session with planning and council and it seems like a good compromise to me at this time although again i will wait to see what comes to light at the meeting . It will depend on new information.
Furthermore, an internal memo from the former coordinator of the General Plan Update to the City’s Planning Director, the City has known that the Pedro Point Fields is a wetlands which needs to be properly mapped, and should not be upzoned..
pg. 15
pg. 16
We join the chorus of other Pacificans and experts in exhorting you to update this fatally‐flawed Draft EIR, and start with an honest baseline which reflects existing uses and conditions.
Sincerely Yours,
Cherie Chan and Bruce Ferry
San Pedro Avenue
From: Christine Boles [
Sent: Sunday, March 6, 2022 4:37 PM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]; Bier, Mary [[email protected]]; Woodhouse, Kevin [[email protected]]; Bigstyck, Tygarjas [[email protected]]; Wehrmeister, Tina [[email protected]]
Subject: DEIR Public Comment Letter #4 Fire and Climate Change Vulnerability Attachments: Christine Boles Comment Letter #4.pdf
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Please see attached letter and feel free to reach out to me with any questions.
Mayor Pro-Tem Bigstyck, I opted to copy you because increased fire risks and evacuation planning are critical to your district.
Sincerely,
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“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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1 DATE:
TO:
March 6, 2022
Christian Murdock, AICP
Deputy Director of Planning
City of Pacifica Planning Department
540 Crespi Drive, Pacifica, CA 94044
RE: City of Pacifica General Plan and DEIR Comments, letter #4 - Fire Hazards: CEQA Required Conclusions Cannot be Verified - Climate Change Vulnerability Assessments, Adaptation and Resiliency Planning is Missing Dear Mr. Murdock,
As I read the DEIR Chapter 3.14 Wildfire and General Plan Chapters 8.5 Fire Hazards and 8.6 Public Safety and Emergency Management, I am again concerned that we are using old data, and that the required CEQA analysis to determine less than significant impacts have not been properly analyzed, leaving residents and properties at increased risks of fire and of being trapped by not being able to evacuate when necessary.
1. My comments are based on the January release for the DEIR as I had already annotated it prior to the new release the week of February 14th of a revised DEIR. I would like to request a detailed analysis of whether other changes were made with the new document issue, beyond the addition of a Table of Contents and the deletion of the duplicated Fire Hazard Chapter.
2. Starting on page 1 of Chapter 3.14, note that the numbering is not typical of other DEIR Chapters. I would have expected 3.14-1, not just 1.
3. On page 1, the DEIR says, “In California, most wildfire damage occurs in wildland urban interface areas, where homes and woodland vegetation are directly adjacent. The majority of wildfires are started by human activity, such as campfires, fireworks, faulty electrical facilities, and residential and agricultural burning, but wildfires can also be incited by natural causes like lightning strikes.” These sections of the DEIR and General Plan do not include any maps of Wildland Urban Interface Zones. OPR provides free data for mapping these areas. Planning consultants Terrel Watt and Jared Ikeda took the GIS date from OPR and made a map of Pacifica’s WUI zones – see below.
Please clarify why the City chose not to follow OPR guidance on this issue, or provide the appropriate map with freely obtained best currently available data as required by CEQA. New guiding and mitigation measure policies will need to be written based on this information as WUI designations relate to specific building code requirements for construction. Legal and illegal fireworks should also be addressed with mitigation measures given the high fire risk they pose and the city’s current inability to enforce the use of illegal fireworks. 2 4. The 2010 Existing Conditions and Key Issues Report that informed the 2014 draft General Plan discusses wildland urban interface zones and makes the following recommendations on pages 5-65 and 5-91
Please clarify how these mitigation measures are incorporated into the 2022 DEIR and Draft General Plan and modify DEIR policies and mitigation measures as required to comply with these recommendations.
3 5. Page one of the DEIR says, “About two-thirds of Pacifica is undeveloped, and nearly half is protected open space. This undeveloped land is mainly on the rugged ridges that form the City’s eastern edge and descend down to the ocean between Pacifica’s valley communities. Coastal scrub is the predominant vegetation type, interspersed with annual grassland. Significant areas of eucalyptus forest and mixed woodland are present in eastern Sharp Park and on Cattle Hill and San Pedro Mountain.” Please add “and southern edge” to this description as our entire southern border is also composed of rugged ridges with high fire risk and a lot of highly flammable eucalyptus.
6. Continuing on Page 1 is a discussion of Very High Fire Hazard Severity Zones, which is a separate overlay created by Cal Fire to map likely burn areas in a certain period of time. The DEIR says, “As shown on Figure 3.11-2, in Section 3.11, Hazardous Materials and Fire Hazards, 470 acres along the southwestern perimeter within the Sphere of Influence are designated as Very High FHSZs (VHFHSZs).” And yet there are no VHFHSZ areas indicated on this map. Please amend map as required in concert with Cal Fire requirement. Please note that the 2014 draft General Plan Fire Hazards map on the right shows extensive VHFHSZ in the southern edge and in the center of Pacifica, some of which is in Local Responsibility Areas (LRA). Please explain the discrepancies in these maps.
Please confirm requirements for site planning, defensible space and construction means and methods, which are different for sites with this designation. New guiding and mitigation measure policies will need to be written.
Figure 3.11.2 of current DEIR missing VHFHSZ 2014 Draft GP with VHFHSZ shown hatched 4 7. Continuing on page 1 the DEIR states, “Most of the land within the VHFHSZs is an urban reserve or park, and land adjacent to these areas that is within city limits is low- and very-low density residential development. Per the 2021 MJ-LHMP, Pacifica had no population or structures within very high, high, or moderate wildland fire severity zones. Nevertheless, these fire severity zones are on the periphery of developed areas in Pacifica and could present a fire risk to development within the city.” We know the Multi-Jurisdictional Local Hazard Mitigation Plan was not properly updated for fire risk in 2021, City Manager Woodhouse and then Mayor Beckmeyer admitted as much at the council meeting on November 21, 2021 when it was adopted, so please delete those references. No accurate map of fire hazards was presented in the LHMP and since adoption and filing with the county, all fire maps were removed in the current documents on the county website. The LHMP therefore cannot be used as source material for the DEIR or Safety Element.
We also cannot know if Pacifica has no population or structures in VHFHSZ areas without accurate maps. Please update the maps and provide a detailed analysis of structures in these land designations.
The 2010 Existing Conditions Report and Key Issues Report copied below shows significant portions of the city, included some developed areas with buildings such as Higgins Way, Adobe Drive and Grand Avenue in Very High Fire Hazard Severity Zones. This designation also seems to affect the proposed Pacifica Highlands project. Please correct the discrepancies between the text and the maps and update the maps as necessary.
5 In fact the 2010 Existing Conditions Report on page 5-63 states:
8. On page 2, the DEIR states, “All of the VHFHSZs within the Planning Area are designated State Responsibility Areas (SRA), where the State of California is financially responsible for the prevention and suppression of wildfires, while the NCFA has primary responsibility for Local Responsibility Areas (LRA) within the City limit.” Again, we cannot know if Pacifica’s VHFHSZ areas are all in SRA areas without accurate maps. Please update the maps and provide a detailed analysis and breakdown of any areas in LRA responsibility areas and correct the DEIR and General Plan as required.
9. On page 2 the DEIR also states, “Based on past occurrences (note only dates through 2015 are mentioned) and the geography, weather patterns, and vegetation in the region, it is highly likely that wildfires will continue to occur in San Mateo County.” While this is true, the city fails to analyze the increased fire risks from extended droughts and climate change that has plagued the entire state of California and that has altered our local climate patterns in the last 15 years. These all have a high degree of probability of compounding our risks of wildfire in our coastal region, as was seen by the CZU Lightening Complex fire in August 2020 in coastal San Mateo County. Please add data from this event and clarify how increasing fire risk dangers are analyzed and mitigated in this DEIR and General Plan.
10. According to a recent report from the United Nations Environment Program, risk of extreme wildfires will increase 14% by 2030 and 30% by 2050. They conclude that nations spend too much time fighting fires and not enough preventing them. Also, the latest West Coast Plover Conference has reported that coastal fog has decreased 30%. We can’t expect fog protection for our highly burnable Eucalyptus trees as we go into the future. We need serious wildfire alternatives AND escape routes other than Highway 1. Please clarify how these recent and pertinent studies that apply to Pacifica’s microclimate and fire risk changes will be incorporated into the DEIR and General Plan.
11. I spoke with Dave Sapsis, a Wildland Fire Scientist at Cal Fire on 2/18/22. He indicated that Cal Fire was currently updating fire maps in Local Responsibility (LRA) areas and the drafts would be issued for review in May 2022. These studies will have major changes to current approved maps due to the dramatic changes in fire patterns in California the last few years with climate change induced drought and related weather pattern changes. Language should be added that refers to these new policies so that the General Plan Safety Element can be revised to properly address our current fire risks once the new maps are adopted. A General Plan amendment may be necessary in 2023. Cal Fire is also working at the request of many municipalities to tighten the restrictions for high fire hazard areas in relation to increased housing density allowed under SB9. This will also be important language to add to protect Pacifica once these policies are finalized and is currently specifically relevant to Pacifica Highlands, Linda Mar Woods and Cape Breton, and potentially to the four projects already submitted under SB9. 6 12. Dave Sapsis of Cal Fire also gave me the link to their previous analysis of High Fire Severity Zone mapping in Pacifica from 2008. It can be found at this link:
https://osfm.fire.ca.gov/media/6801/fhszl06_1_map41.pdf Screenshot is included below:
Please note all the red and orange fire risk areas, many of which are in LRA areas. While some of this data can be negotiated with North County Fire, a response to my outstanding PRA document request 22-26 that I believe was prematurely closed, would provide insight into NCFA’s positions that were apparently negotiated with Cal Fire to lower the actual fire risks in current maps. Given climate change and increased fire risks the last 15 years, the actual risk today has significantly changed since the current maps were adopted, as evidenced by the CZU Lightening Complex, and it would be reasonable to include this map for the DEIR and GP Safety Element until the new LRA maps are available from Cal Fire this spring.
13. Page 4 of the DEIR states, “NCFA has established the following service ratio and response time standards:
• Service ratio standard: one responder per 1,500 population • Response time standards for fire service: Four-minute travel time to 90 percent of calls for fire service, and eight-minute travel time for all apparatus on-scene for fire calls for service. • Response time standard for Emergency Medical Services (EMS): Under seven-minute travel time (6:59) for first response to 90 percent of calls.” There is no source or date given for this information, please confirm both and provide the data in an appendix to the DEIR.
7 14. To follow up on the item above, the following data should be provided to ensure that required levels of service can be met:
a. Recent census information to confirm Pacifica’s population. b. Number of responders currently working in Pacifica
c. Current information about level of service and response times mapped to all the areas of Pacifica. As previously indicated in Comment Letter #3, the General Plan Existing Conditions and Key Issues Report dated July 2010 is outdated and deficient in addressing response time as traffic data shows that traffic in Pacifica has increased significantly since 2010. d. Identify completed and proposed new construction since 2010 with location mapping to clarify which fire stations are impacted by current and projected growth beyond what was assessed in 2010.
e. Full buildout calculations including required RHNA numbers.
15. Further down on page 4 the DEIR it says, “2008 study determined that the Vallemar, West and East Fairway Park, Rockaway Beach, and Rockaway neighborhoods in central Pacifica are beyond four-minute travel distance from northern San Mateo County fire stations, corresponding with the standard response time for firstdue fire apparatus. The full assignment response time standard cannot be met in Pacifica from Vallemar south.” This section references a 2008 “Emergency Services Consulting”. Please provide a link or a copy of the report from this consulting effort and hopefully more recent consultant data given our increased population and traffic issues.
16. The bottom of page 4 states that “Population growth will increase existing deficiencies in service delivery. The Fire Authority considers the City’s geography to be the limiting factor for delivery of fire service. According to NCFA, a third, mid-point station in Pacifica with a truck and engine company has been discussed for some time. The area that currently does not meet first-response time standards currently has a low density of development, and so it has fewer persons and structures threatened by fire. However, a new station would be needed if the central part of Pacifica were to experience substantial new development, for example at the Quarry site.” There are several other development projects currently proposed and being reviewed in this area across from the quarry, including Pacifica Highlands. This site is in a red zone, noted as highest fire risk in the map shown in item 11. Analysis should be required for this and other future projects in the quarry and on adjacent sites to determine the point at which a new fire station will be required. The DEIR should add guiding policies and mitigation measures to ensure that fire service levels can start to be met with the construction of a new fire station. The Land Use Element Maps should also be updated to include a proposed location for a new fire station.
17. Page 5 of the DEIR states that, “Since 2005, the California Building Code (CBC) (CCR Title 24, Part 2) has required that all new buildings located in any Fire Hazard Severity Zone in SRAs, or any Very High Fire Hazard Severity Zone in LRAs, use building materials approved for use in wildland/urban interface areas.
Subsequent editions of the code have specified certain roof coverings, fire resistive wall and ceiling-floor assemblies, wall finish materials, hardware, insulation, and other building materials for use in high fire hazard areas.” The state code requires not just new buildings, but remodels or additions to existing buildings of a certain size also be required to meet these requirements. The DEIR and General Plan should be updated accordingly to include requirements for existing buildings. 8 18. Page 6 of the DEIR states, “Pacifica’s HMP is an annex of San Mateo County’s Multi-Jurisdictional Local Hazard Mitigation Plan (MJ-LHMP), most recently updated in 2021. The plan identifies the City’s hazards and provides strategies for preventing hazards and minimizing damage. The plan ranks wildfire as a medium risk concern, under geologic and hydrologic hazards, and identifies several mitigation actions for wildland fires in Pacifica. These include updating the City’s Emergency Operations Plan; pursuing opportunities to preserve and protect critical transportation infrastructure; and developing and delivering business programs and public outreach programs to promote resiliency and community preparedness.
See previous comments about inadequacy of Pacifica’s LHMP. Pacifica’s current LHMP on the county website was modified after the City Council Meeting where the document was approved and now neglects to include ANY fire hazard mapping.
https://cmo.smcgov.org/sites/cmo.smcgov.org/files/documents/files/San%20Mateo%20HMP%20- %20Volume%20II%20-%20Final%20083016.pdf
Please provide a link to Pacifica’s current Emergency Operations Plan and provide detailed information about when an update can be expected.
19. Page 6 of the DEIR states, “The Pacifica All Hazards & Evacuation Plans, updated in 2019, provides steps that should be considered and taken in case of evacuation. It grants authority and responsibilities to centralized emergency management and divides the City of Pacifica into 14 evacuation zones, each of which has its own evacuation operations plan, detailing evacuation routes, critical sites, traffic concerns, and refuge areas.” There is no link or citation for these documents here or in the Bibliography.
20. The 2010 Existing Conditions and Key Issues Report also states:
The DEIR does not contain analysis for road capacity, nor maps for evacuation. Please note that this is also a basic requirement of Safety Elements as defined in Government Code section 65302 (g) 1. “(g) (1) A safety element for the protection of the community from any unreasonable risks associated with the effects of seismically induced surface rupture, ground shaking, ground failure, tsunami, seiche, and dam failure; slope instability leading to mudslides and landslides; subsidence; liquefaction; and other seismic hazards identified pursuant to Chapter 7.8 (commencing with Section 2690) of Division 2 of the Public Resources Code, and other geologic hazards known to the legislative body; flooding; and wildland and urban fires. The safety element shall include mapping of known seismic and other geologic hazards. It shall also address evacuation routes, military installations, peakload water supply requirements, and minimum road widths and clearances around structures, as those items relate to identified fire and geologic hazards.” The DEIR and Safety Element do not meet all the requirements listed in (g)(1). Please add the necessary information and analysis and recirculate for proper public and agency review. 9 21. Government Code Section 65302 (g) 3 also requires the following:
“Upon the next revision of the housing element on or after January 1, 2014, the safety element shall be reviewed and updated as necessary to address the risk of fire for land classified as state responsibility areas, as defined in Section 4102 of the Public Resources Code, and land classified as very high fire hazard severity zones, as defined in Section 51177. This review shall consider the advice included in the Office of Planning and Research’s most recent publication of “Fire Hazard Planning, General Plan Technical Advice Series” and shall also include all of the following:
(A) Information regarding fire hazards, including, but not limited to, all of the following:
(i) Fire hazard severity zone maps available from the Office of the State Fire Marshal. (ii) Any historical data on wildfires available from local agencies or a reference to where the data can be found. (iii) Information about wildfire hazard areas that may be available from the United States Geological Survey. (iv) General location and distribution of existing and planned uses of land in very high fire hazard severity zones and in state responsibility areas, including structures, roads, utilities, and essential public facilities. The location and distribution of planned uses of land shall not require defensible space compliance measures required by state law or local ordinance to occur on publicly owned lands or open space designations of homeowner associations. (v) Local, state, and federal agencies with responsibility for fire protection, including special districts and local offices of emergency services.
(B) A set of goals, policies, and objectives based on the information identified pursuant to subparagraph (A) for the protection of the community from the unreasonable risk of wildfire. (C) A set of feasible implementation measures designed to carry out the goals, policies, and objectives based on the information identified pursuant to subparagraph (B), including, but not limited to, all of the following:
(i) Avoiding or minimizing the wildfire hazards associated with new uses of land. (ii) Locating, when feasible, new essential public facilities outside of high fire risk areas, including, but not limited to, hospitals and health care facilities, emergency shelters, emergency command centers, and emergency communications facilities, or identifying construction methods or other methods to minimize damage if these facilities are located in a state responsibility area or very high fire hazard severity zone. (iii) Designing adequate infrastructure if a new development is located in a state responsibility area or in a very high fire hazard severity zone, including safe access for emergency response vehicles, visible street signs, and water supplies for structural fire suppression.
(iv) Working cooperatively with public agencies with responsibility for fire protection. (D) If a city or county has adopted a fire safety plan or document separate from the general plan, an attachment of, or reference to, a city or county’s adopted fire safety plan or document that fulfills commensurate goals and objectives and contains information required pursuant to this paragraph.” Please provide the required analysis and data and write new appropriate policies and mitigation measures in the DEIR and General Plan for existing and new development in fire hazard zones.
22. On page 7, of the DEIR, Impact Analysis, it says, “Implementation of the Proposed Project could have a significant impact if located in or near state responsibility areas or lands classified as very high hazard severity zones” and then proceeds to list the possible impacts. Without proper maps of lands classified as Very High Fire Hazard Severity Zones this analysis cannot be done at this point. The maps must be fixed, 10 analysis redone, and the information recirculated for public and agency review. Please confirm the City’s intended process and timetable for updating this critical life safety information and required mitigations.
23. Further on age 7, it says, “Consideration is given to potential increases in development in WUI zones, development in proximity to the VHFHSZ in the City’s Sphere of influence, new impervious surface area, erosion associated with future development-related construction activities, hazards associated with wildfire, as well as proposed policies intended to minimize the impacts of growth on fire services and emergency evacuation access.” Please provide a detailed explanation of how this “consideration was given”. I have seen no analysis in the DEIR of fire hazards for possible development in the city’s Sphere of Influence on San Pedro Mountain for example.
24. Further on page 7, under Methodology and Assumptions, the DEIR says, “Subsequent CEQA review at the project level may be required to determine whether significant environmental effects would result from growth that may create additional demand for emergency services and critical infrastructure. Project-level review will occur when proposed development plans are prepared.” My understanding is that this is considered deferred analysis, which is not legally allowed under CEQA. Please provide a detailed analysis with input from North County Fire on the specific allowable development increases under existing conditions of two fire stations. How many new units can be built without compromising existing services, and in which areas of town can these be built? As shown in the 2010 Existing Conditions and Key Issues map fire services were already compromised in 2010 in the communities of Rockaway, Vallemar and Park Pacifica.
Development projects that were built since 2010 or that are currently under construction, have further compromised these levels of service, like Connemara, 801 Fassler, Harmony@1 and the new hotels in Rockaway.
At what point is a third fire station triggered? How many units? In what locations? Where might this new fire station be built, and is the funding secured? Is a new fire station required under Project buildout of 990 units? Under RHNA of 1982 units? Under actual possible maximum buildout, which I do not see calculated anywhere in these documents?
We cannot continue to further endanger the public by allowing project after project to be approved without a full understanding of the cumulative impacts that reduce the levels of service that North County Fire is able to provide.
25. On pages 9 and 10, Proposed policies that reduce the impact:
A. LU-1-25 Rockaway Quarry Plan does not mention the need for a new fire station. Please amend as necessary, adding references to SA-I-91.
B. CI-G-7 “Congestion on Highway 1. In consultation with Caltrans, seek solutions to ease the traffic congestion that occurs on Highway 1 near the Reina Del Mar, Fassler Avenue, and Linda Mar Boulevard intersections. Strive for the greatest benefit with the least environmental impact possible.” This is a deferred measure, which is not allowed under CEQA, especially if the measure can do harm, such as by preventing the timely response of emergency services.
C. CI-I-9 “SR 1 Improvements Between South of Fassler and North of Reina del Mar.
Continue to work with the California Department of Transportation (Caltrans) and the San Mateo County Transportation Authority (SMCTA) to improve operations along SR 1.” This is a deferred measure, which is not allowed under CEQA, especially if the measure can do harm, such as by preventing the timely provision of emergency services.
11 D. CI-I-10 Manor Drive Overcrossing Improvements
According to an email Deputy Director of Public Works, Sam Bautista, sent to Vicki Sundstrom on 2/16/22 this project will take at least 6 years to complete, see below. I also know it will necessitate public input and there is already quite a lot of controversy as many residents are opposed to the new freeway onramp at Milagra. Please add policy language that prohibits large scale development that decreases levels of service for traffic, evacuations routes, and fire access until such improvements and traffic mitigation measures have been completed.
E. CI-I-18 “Vehicle Level of Service on Roadways Included in the Congestion Management Program. Accept an LOS E on SR 1 and SR 35, consistent with the C/CAG Congestion Management Program (CMP), in planning improvements.” Please provide a link to Pacifica’s Current Congestion Management Plan so that we can review assumptions as well as data.
Table 3.3-4 shows some intersections on SR1 and SR 35 already have existing levels of service of D and E, some of which are expected to worsen under plan buildout. Plan buildout only considers 990 additional units of housing, and does not include current RHNA requirements of 1892 units which are required in January 2023, and does not include all potential buildout under the proposed project with current ADU laws, much less SB9 and SB10. Please confirm how the city plans to ensure that levels of service of E are not exceeded under full potential buildout, how this will be monitored over time as new projects are built, and what mitigation measures to improve traffic and firefighting service times on these major evacuation routes will be undertaken if levels of service fall below E. 12 F. “CI-I-19 Vehicle Level of Service for Other Roadways and Intersections. For all roadways and intersections not included in the CMP network, strive to balance reducing VMT with maintaining LOS D for vehicles during peak periods.”
Please note in the chart above that some non-CMP intersections already exceed level D service, and several others are projected to worsen to levels E and F under the proposed project during peak periods. And again, this does not include actual full buildout. This tells me that perhaps certain parts of town cannot be rezoned to increase density per the project buildout until major improvements to transportation and evacuation routes are undertaken and completed. Please provide detailed analysis and overlays of land use analysis with traffic levels of service to confirm environmental impacts of increased traffic near these critical intersections. The DEIR and GP should include additional language with limitations to new development tied to improvements of traffic to ensure compliance with CEQA for less than significant impacts. Again, as these issues affect emergency evacuation routes, these policies could potentially cause harm, and therefore deferred analysis is not allowed.
G. CI-I-26 “Emergency Access. Require developers to incorporate emergency access needs consistent with standards in Title 10 of the Municipal Code.” Please clarify if this measure includes both on and offsite analysis of emergency access and evacuation routes.
H. “SA-G-11 “Disaster Preparation. Make infrastructure investments, enforce regulations, and disseminate information that will improve disaster response and recovery, with the goal of minimizing damage to people and property.” This language seems very vague and not enforceable. Please clarify how disaster preparation will be implemented in detail so that damage to people and property is minimized.
I. SA-I-35 “Critical Transportation Infrastructure. The City will pursue opportunities to preserve, protect, or relocate critical local transportation infrastructure, or provide alternative access, to mitigate against isolation and economic loss, and to ensure public safety.” Again, vague, non-enforceable language, cannot be considered a real mitigation measure without details and analysis. 13 J. SA-I-91 “Response Time. Support efforts by North County Fire Authority to meet its response time standards throughout the City.” As shown below from the 2010 Existing Conditions and Key Issues Report, NCFA’s response time standards were already exceeded in 2009 in several parts of town including Rockaway, Vallemar and Park Pacifica. Please clarify how the City of Pacifica will provide additional resources for a new fire station, new equipment for the taller buildings in Sharp Park, etc, that will allow NCFA to be able to start to meet their standards in all parts of Pacifica. 14 K. SA-I-104 “Areas that Lack Emergency Access. Develop a plan to widen critical rights-of-way that do not provide adequate clearance for emergency vehicles. For areas that are not feasibly accessible to emergency vehicles, develop a contingency plan for reaching and evacuating people in need of treatment. This initiative should include a plan to open access to or otherwise serve the Pedro Point, Fassler/Rockaway, and the Vallemar neighborhoods.”
“Develop a plan” is a deferred mitigation measure and cannot be used for critical life safety issues like emergency egress per CEQA requirements. Please provide a plan as part of this plan, especially given the increased development of housing the city is proposing as part of this Project in Pedro Point.
L. 6-I-4 “Fire Services and Height. Work with PFD to ensure fire services have the capacity to serve four- and five-story buildings prior to construction of buildings of that height.” I think you mean NCFA and not PFD. Also, should we not be certain that they can serve four and five story buildings before we approve the rezoning to allow these height increases? Again, this seems like deferred analysis of a critical life safety impact, which is not allowed per CEQA. These proposed height increases are not only in Sharp Park, but in other areas where Mixed Use Center Zoning has been added, such as Crespi in Linda Mar adjacent to the Community Center.
25. Chapter 7 of the DEIR states that North County Fire last issued responses on August 9, 2009. Please confirm the latest date of their review and comments of this DEIR and Draft General Plan and provide copies of the latest information and comments from North County Fire in an appendix to the General Plan so the public, local and state agencies have access to this data and information.
26. Chapter 3.11 Hazards and Hazardous Materials also discusses wildfire risks and evacuation routes.
Figure 3.11-2 neglects to show fire hazard risk in Local (LRA) or Federal (FRA) responsibility areas.
Please amend figure to add this information.
15 27. Page 3.11-12 of the DEIR under the subheading California Wildland Hazard/Building Code seems to quote several outdated sources. Please update as needed per current codes and sources.
28. Page 3.11-13 Again discusses the MJ-LHMP. This text includes language about the threat of landslides on Highway 1 that have the potential to block critical evacuation routes. Please 1) add this information to the landslide maps and 2) propose action and mitigation measures to address this risk.
29. Impact Analysis Criteria 6 - Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
Again, please provide links to these documents so we can evaluation whether the proposed project may impact these plans.
30. Impact Analysis Criterion 7: Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands.
And below on page 3.11.14 in the Impact Summary, it says, “In addition, the exposure of people or structures to wildland fires as a result of the Proposed Project is not expected to occur. The potential of the 16 creation of hazards or exposure to hazardous materials under the Proposed Project remains less than significant with adherence to existing regulations and implementation of the policies of the Proposed Project.” Nothing I have seen in the Fire Chapters provides a clear path to be able to jump to these conclusions that the Project will not have significant impacts to create additional fire hazard and evacuation risks.
Please update document to properly analyze risks and then provide a detailed explanation to justify a less than significant impact.
31. Again, I object to Page 3.11-23 and 24 which states that no mitigation measures are required to address wildfire risk.
“3.11-7 Implementation of the proposed Pacifica General Plan would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires. (Less than Significant) Impact of the General Plan
As described above, wildfire hazard is minimal in most of Pacifica within city limits because it is mostly urbanized.”
Without proper maps and updated analysis of fire risk, we cannot at this point clearly state that there is no additional wildfire risk posed by the Proposed Project. The experience of the last several years is that urbanized areas are decidedly not protected from wildfires.
32. SA-I-92 Adequate Peakload Water Supply. Work with the Water District to maintain adequate water supply for firefighting, including capacity for peakload under a reasonable worst case wildland fire scenario, to be determined by the North County Fire Authority. Again, under CEQA law, this analysis cannot be deferred. What is our peak load and do we have the capacity to build the Proposed Project while maintaining and adequate amount of backup water for firefighting?
33. Under SB 379 and California Government Code Section 35602, a climate change vulnerability assessment must be undertaken, not just for sea level rise, but for other increased climate change related hazards such as wildfire, flooding, landslides, and coastal erosion. I have not seen this analysis in the DEIR except in relation to sea level rise. Under SB379, cities and counties within California are required to integrate climate adaptation into their general plans by January 1, 2022. As Pacifica recently adopted a new Local Hazard Mitigation Plan in November 2021, this work must be done as part of the General Plan Safety Element update. Please see Alliance of Regional Collaborative for Climate Adaptation for a description of what is required.
I’ve also copied the text of California Government Code Section 35602(g) (4) for reference here below.
Please clarify when this work will be done and the Safety Element appropriately updated. “(4) Upon the next revision of a local hazard mitigation plan, adopted in accordance with the federal Disaster Mitigation Act of 2000 (Public Law 106-390), on or after January 1, 2017, or, if a local jurisdiction has not adopted a local hazard mitigation plan, beginning on or before January 1, 2022, the safety element shall be reviewed and updated as necessary to address climate adaptation and resiliency strategies applicable to the city or county. This review shall consider advice provided in the Office of Planning and Research’s General Plan Guidelines and shall include all of the following:
(A) (i) A vulnerability assessment that identifies the risks that climate change poses to the local jurisdiction and the geographic areas at risk from climate change impacts, including, but not limited to, an assessment of how climate change may affect the risks addressed pursuant to paragraphs (2) and (3). (ii) Information that may be available from federal, state, regional, and local agencies that will assist in developing the vulnerability assessment and the adaptation policies and strategies required pursuant to subparagraph (B), including, but not limited to, all of the following:
(I) Information from the internet-based Cal-Adapt tool. 17 (II) Information from the most recent version of the California Adaptation Planning Guide. (III) Information from local agencies on the types of assets, resources, and populations that will be sensitive to various climate change exposures.
(IV) Information from local agencies on their current ability to deal with the impacts of climate change. (V) Historical data on natural events and hazards, including locally prepared maps of areas subject to previous risk, areas that are vulnerable, and sites that have been repeatedly damaged. (VI) Existing and planned development in identified at-risk areas, including structures, roads, utilities, and essential public facilities.
(VII) Federal, state, regional, and local agencies with responsibility for the protection of public health and safety and the environment, including special districts and local offices of emergency services. (B) A set of adaptation and resilience goals, policies, and objectives based on the information specified in subparagraph (A) for the protection of the community.
(C) A set of feasible implementation measures designed to carry out the goals, policies, and objectives identified pursuant to subparagraph (B), including, but not limited to, all of the following:
(i) Feasible methods to avoid or minimize climate change impacts associated with new uses of land. (ii) The location, when feasible, of new essential public facilities outside of at-risk areas, including, but not limited to, hospitals and health care facilities, emergency shelters, emergency command centers, and emergency communications facilities, or identifying construction methods or other methods to minimize damage if these facilities are located in at-risk areas.
(iii) The designation of adequate and feasible infrastructure located in an at-risk area. (iv) Guidelines for working cooperatively with relevant local, regional, state, and federal agencies. (v) The identification of natural infrastructure that may be used in adaptation projects, where feasible. Where feasible, the plan shall use existing natural features and ecosystem processes, or the restoration of natural features and ecosystem processes, when developing alternatives for consideration. For purposes of this clause, “natural infrastructure” means using natural ecological systems or processes to reduce vulnerability to climate change related hazards, or other related climate change effects, while increasing the long-term adaptive capacity of coastal and inland areas by perpetuating or restoring ecosystem services. This includes, but is not limited to, the conservation, preservation, or sustainable management of any form of aquatic or terrestrial vegetated open space, such as beaches, dunes, tidal marshes, reefs, seagrass, parks, rain gardens, and urban tree canopies. It also includes systems and practices that use or mimic natural processes, such as permeable pavements, bioswales, and other engineered systems, such as levees that are combined with restored natural systems, to provide clean water, conserve ecosystem values and functions, and provide a wide array of benefits to people and wildlife.
(D) (i) If a city or county has adopted the local hazard mitigation plan, or other climate adaptation plan or document that fulfills commensurate goals and objectives and contains the information required pursuant to this paragraph, separate from the general plan, an attachment of, or reference to, the local hazard mitigation plan or other climate adaptation plan or document.
(ii) Cities or counties that have an adopted hazard mitigation plan, or other climate adaptation plan or document that substantially complies with this section, or have substantially equivalent provisions to this subdivision in their general plans, may use that information in the safety element to comply with this subdivision, and shall summarize and incorporate by reference into the safety element the other general plan provisions, climate adaptation plan or document, specifically showing how each requirement of this subdivision has been met. 18 (5) Upon the next revision of the housing element on or after January 1, 2020, the safety element shall be reviewed and updated as necessary to identify residential developments in any hazard area identified in the safety element that do not have at least two emergency evacuation routes.
(6) After the initial revision of the safety element pursuant to paragraphs (2), (3), (4), and (5), the planning agency shall review and, if necessary, revise the safety element upon each revision of the housing element or local hazard mitigation plan, but not less than once every eight years, to identify new information relating to flood and fire hazards and climate adaptation and resiliency strategies applicable to the city or county that was not available during the previous revision of the safety element.
(7) Cities and counties that have flood plain management ordinances that have been approved by FEMA that substantially comply with this section, or have substantially equivalent provisions to this subdivision in their general plans, may use that information in the safety element to comply with this subdivision, and shall summarize and incorporate by reference into the safety element the other general plan provisions or the flood plain ordinance, specifically showing how each requirement of this subdivision has been met.
(8) Before the periodic review of its general plan and before preparing or revising its safety element, each city and county shall consult the California Geological Survey of the Department of Conservation, the Central Valley Flood Protection Board, if the city or county is located within the boundaries of the Sacramento and San Joaquin Drainage District, as set forth in Section 8501 of the Water Code, and the Office of Emergency Services for the purpose of including information known by and available to the department, the agency, and the board required by this subdivision. (9) To the extent that a county’s safety element is sufficiently detailed and contains appropriate policies and programs for adoption by a city, a city may adopt that portion of the county’s safety element that pertains to the city’s planning area in satisfaction of the requirement imposed by this subdivision. (h) (1) An environmental justice element, or related goals, policies, and objectives integrated in other elements, that identifies disadvantaged communities within the area covered by the general plan of the city, county, or city and county, if the city, county, or city and county has a disadvantaged community. The environmental justice element, or related environmental justice goals, policies, and objectives integrated in other elements, shall do all of the following:
(A) Identify objectives and policies to reduce the unique or compounded health risks in disadvantaged communities by means that include, but are not limited to, the reduction of pollution exposure, including the improvement of air quality, and the promotion of public facilities, food access, safe and sanitary homes, and physical activity. (B) Identify objectives and policies to promote civic engagement in the public decisionmaking process. (C) Identify objectives and policies that prioritize improvements and programs that address the needs of disadvantaged communities.
(2) A city, county, or city and county subject to this subdivision shall adopt or review the environmental justice element, or the environmental justice goals, policies, and objectives in other elements, upon the adoption or next revision of two or more elements concurrently on or after January 1, 2018.
(3) By adding this subdivision, the Legislature does not intend to require a city, county, or city and county to take any action prohibited by the United States Constitution or the California Constitution. (4) For purposes of this subdivision, the following terms shall apply:
(A) “Disadvantaged communities” means an area identified by the California Environmental Protection Agency pursuant to Section 39711 of the Health and Safety Code or an area that is a low-income area that is disproportionately affected by environmental pollution and other hazards that can lead to negative health effects, exposure, or environmental degradation.
(B) “Public facilities” includes public improvements, public services, and community amenities, as defined in subdivision (d) of Section 66000.
19 (C) “Low-income area” means an area with household incomes at or below 80 percent of the statewide median income or with household incomes at or below the threshold designated as low income by the Department of Housing and Community Development’s list of state income limits adopted pursuant to Section 50093 of the Health and Safety Code. (Amended by Stats. 2021, Ch. 225, Sec. 9. (AB 9) Effective January 1, 2022.) Again, it is in all our interests to complete a proper General Plan update as soon as possible. I maintain that these draft documents will need to be revised, the major errors and omissions fixed, current source data and related city documents provided, and then the documents recirculated so that the public and other reviewing agencies can start a proper review of the documents.
Thank you and please feel free to reach out to me with any questions.
Sincerely,
Christine Boles, Architect
Principal
Cc: Honorable Mayor Mary Bier
Mayor Pro-Tem Bigstyck
Tina Wehrmeister, Planning Director
Kevin Woodhouse, City Manager
[email protected]
From: Christine Boles [ ]
Sent: Wednesday, February 9, 2022 10:52 AM
To: Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Woodhouse, Kevin [[email protected]]; Bier, Mary [[email protected]]; Public Comment [[email protected]]; O'Neill, Mike [[email protected]]
Subject: DEIR question abotu technical studies
[CAUTION: External Email]
Good morning Christian,
I understand from Vicki Sundstrom that no new technical studies were found in the public records to assess our traffic conditions as part of this DEIR update, but I wanted to confirm that with you.
It seems odd because DKS Associates is noted as a source in 2020 in the DEIR - see screenshot below. Please clarify.
Were any other technical studies required or prepared as part of the CEQA process to inform the DEIR? The NOP on page 14 says "The environmental assessment will utilize the most current CEQA Guidelines and for each issue area, including global warming and greenhouse gases/climate change."
A city planner friend tells me that you would normally find these technical studies in an appendix, but there is no appendix. I was pointed to Los Angeles County that had recently updated their general plan as a good example as they have a lot of the same issues we do with sensitive biology, steep hillsides, coastal erosion and sea level rise. Their website shows all these appendices and detailed technical documents. Am I missing something?
Thank you, my brain hurts trying to make sense of all this! Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.
From: Christine Boles [ ]
Sent: Sunday, January 16, 2022 9:02 PM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]; Wehrmeister, Tina [[email protected]] Subject: DEIR question
[CAUTION: External Email]
Good evening Christian,
I read the agency comments on the EIR NOP today and wondered if there were written responses to those?
I’m also really having trouble navigating the EIR. I couldn’t find a detailed index anywhere.
Right now I’m specifically looking for information in the EIR on greenhouse gas emissions as called for in BAAQMD’s NOP comment letter.
1013 pages is too much to have to keep scrolling through on each topic I want to research… Help please! Thank you!
Christine
--
Christine
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From: Christine Boles [ ]
Sent: Thursday, February 17, 2022 10:41 AM
To: Murdock, Christian [[email protected]]
CC: Public Comment [[email protected]]; Wehrmeister, Tina [[email protected]]; Bier, Mary [[email protected]]; Woodhouse, Kevin [[email protected]]; O'Neill, Mike [[email protected]] Subject: DEIR questions about new traffic data and new documents released [CAUTION: External Email]
Thank you Christian, but now I am more confused... Shouldn't this traffic data have been made available from the start of the 45 days as it impacts several sections of the DEIR? Now I feel like I have to go back and review the Land Use, Transportation, Air Quality, Greenhouse Gases and Noise sections again instead of moving on to review other sections as I had planned in my limited time. I would think other agencies like the Bay Area Air Quality Management District would have wanted that data too. Does this not trigger a new 45 day review period? And I appreciate the Council's extension of the deadline on Tuesday, but I have not noticed an email sent to the Plan Pacifica mailing list to alert people to the extension. Can you do that please? And will you also notify the state and local agencies?
Same for the new pdfs that were quietly issued this week - can you send out a notification? I see some changes were made, like deleting the duplicate Wildfire Chapter. Were other changes made? How do we know? I noticed the date of the old DEIR document pdf and the new one are the same, January 7, 2022, but the State Clearing House, SCH numbers are different. The old one was 2020089010 and the new one is 2012022046. What does that mean? Does it indicate a whole new document?
I need some clarification as soon as possible and I am sure I am not the only one.
Thank you,
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
On Mon, Feb 14, 2022 at 10:33 PM Murdock, Christian <[email protected]> wrote:
Christine,
We have posted the traffic volumes and modeling data gathered in 2018 and 2019 in support of the Plan Pacifica process on the Project Documents page.
Regards,
Christian
CHRISTIAN MURDOCK, AICP
DEPUTY DIRECTOR OF PLANNING
CITY OF PACIFICA | PLANNING DEPARTMENT
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 738-7341 | [email protected]
From: Christine Boles < >
Sent: Wednesday, February 9, 2022 10:52 AM
To: Murdock, Christian <[email protected]>; Wehrmeister, Tina <[email protected]>; Woodhouse, Kevin <[email protected]>; Bier, Mary <[email protected]>; Public Comment <[email protected]>; O'Neill, Mike <[email protected]>
Subject: DEIR question abotu technical studies
[CAUTION: External Email]
Good morning Christian,
I understand from Vicki Sundstrom that no new technical studies were found in the public records to assess our traffic conditions as part of this DEIR update, but I wanted to confirm that with you.
It seems odd because DKS Associates is noted as a source in 2020 in the DEIR - see screenshot below. Please clarify.
Were any other technical studies required or prepared as part of the CEQA process to inform the DEIR? The NOP on page 14 says "The environmental assessment will utilize the most current CEQA Guidelines and for each issue area, including global warming and greenhouse gases/climate change."
A city planner friend tells me that you would normally find these technical studies in an appendix, but there is no appendix. I was pointed to Los Angeles County that had recently updated their general plan as a good example as they have a lot of the same issues we do with sensitive biology, steep hillsides, coastal erosion and sea level rise. Their website shows all these appendices and detailed technical documents. Am I missing something?
Thank you, my brain hurts trying to make sense of all this! Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.
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: Rick Nahass [ ]
Sent: Thursday, February 3, 2022 2:15 PM
To: Beckmeyer, Sue [[email protected]]; Bier, Mary [[email protected]]; _City Council Group [[email protected]]; Coffey, Sarah [[email protected]]; Woodhouse, Kevin [[email protected]]; O'Neill, Mike [[email protected]]; Public Comment [[email protected]]; Vaterlaus, Sue [[email protected]]; Bigstyck, Tygarjas [[email protected]]; Wehrmeister, Tina [[email protected]] CC: David Canepa [ ]; ;
Subject: DEIR The General Plan and Herding Cats
[CAUTION: External Email]
To: Pacifica City Staff and Council
Cc:
• Mid-coast Council cause I complained about having no say in the Connect the Coastside plan
• David Canepa’s office cause he might have some sway with the MTC It wasn’t until I spent 15 years as a project manager at Visa in Foster City that I understood and learned how to keep some of the world’s most brilliant engineers and scientists engaged on delivery while managing changes their wandering curious minds invented along the way.
Pacifica City staff employees have spent over a decade engaging with residents and utilizing public governance processes to pull together content for creating our long term City plans.
The current state of Pacifica’s planning documents does a grave disservice to our most capable and dedicated staff
• To release a poorly formatted online pdf DEIR that is logistically difficult to access, difficult to navigate and cannot be referenced (standard search, copy/paste functionality is broken.)
• To release a General Plan with no schedule, no provision for managing priority and risk nor recommendations for how to accommodate change • To have an end date for final approval with no process on how to get there.
After the 45 day public evaluation period, the documents must be reworked for a second public ‘period of review.’
• City staff to figure out how to generate clean documentation like 99% of all other San Mateo County lead agencies.
• City staff to declare a date in the sand (e.g. Aug 15, 2022) when this focused project documentation review must complete and work backwards to develop realistic achievable tasks and schedule for that date, no matter what the letter of the law is.
• City staff to work with Council to select 3-6 (sic) of the hundreds of elements in the GP to prioritize those elements for more detailed planning by assessing effort vs impact vs other attributes city staff determines is best for assessing. This gives city staff focus and purpose. It breaks the failure of management who make the chronic excuse that city staff is overworked or has too little time. In this way management can support city staff in this more focused endeavor and let the brilliance of city staff shine.
If you should go this way, I would want one of those prioritized elements to be bus regional transit. If it is not, I may not like it, but I will understand, because based on city staff assessment I would see that it might be a higher priority to focus on the quarry or the frogs (doesn’t it always seem to be about the frogs?). And when it’s time to prioritize what to go deep on NEXT year (periodic prioritization might be spelled out in the GP) me and the rest of us will cajole, lobby, justify what we think is important and you, City staff, plus council will make the final decision on what’s next. You will LEAD.
Now that I have you here let me provide you with some anecdotal attributes you might use for a deeper dive on a regional bus GP element
• How does this solve an imminent issue - possibly reduces VMT and makes Pacifica better able to comply with state housing allocation levels or makes Pacifica better able to justify different housing allocation levels. • How does the text in the GP empower our leadership to make Pacifica more competitive for funding. Mike O’Neill is on the Board of Directors as documented in the current San Mateo Countywide Transportation Plan 2040. How does the GP element empower Mike to be the biggest baddest cat in the room, backed by our local and county supervisors, to drive C/CAG to support Pacifica initiatives to the MTC?
• How does this affect residents outside our jurisdiction? Would people on the mid coast, Connect the Coastside, benefit and might we engage them to find out? Somehow we need to change our governance practices to manage, simply, our priorities and focus to let the residents across all spectrums who care, want to conduct business or development do and deliver the justifications for their passions to the very capable and creative city staff.
Be a cat.
Meow,
Rick Nahass
Pacifica
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From: Suzanne Moore [ ]
Sent: Friday, March 4, 2022 10:58 AM
To: Public Comment [[email protected]]
CC: Suzanne Moore [ ]
Subject: DEIR, overlay incentives, and renewal of Growth Ordinance [CAUTION: External Email]
Hello to City Staff
I see in our DEIR that overlays are a suggested way to incentivize building. Although I do not have a background to thoroughly understand pros/cons, I understand that, by identifying areas in overlay zones, contractors may be drawn to bid on projects within the zone.
It seems that areas on transportation corridors with pre-existing construction, in areas free from high risk for erosion/landslides/fires/quakes, are all areas that deserve to be designated as overlay zones. I would appreciate more community and city input to better explain this incentive.
Retaining Hillside Protection and habitat corridors are high community priorities. Renewal of the Growth Control Ordinance which expires in June should occur. Please comment. --
Suzanne Moore
--
Suzanne Moore
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From: Dustin M [ ]
Sent: Tuesday, January 18, 2022 7:58 PM
To: Public Comment [[email protected]]
Subject: Details regarding the new General Plan
[CAUTION: External Email]
Hello Mr. Murdock,
Can you please illustrate in detail the proposal for changing the City’s single height requirement with one that changes by neighborhood, topography and other relevant factors. Please describe in detail the new proposed height requirement policy referenced in LU-I-19.
I see that this policy is based on community input. How can I participate in this conversation? Best,
Dustin McGahan
President
Little Feet Renovation Inc.
“visionary sculptural transformations”
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From: Patton, Arlene [ ]
Sent: Wednesday, March 2, 2022 4:12 PM
To: Murdock, Christian [[email protected]]
CC: Wehrmeister, Tina [[email protected]]; O'Connor, Bonny [[email protected]]
Subject: Draft G.P., DEIR, S.P.S.P Minor Comments
Hi Christian,
First, apologies for using the City e-mail address for personal comments. I tried sending my compliments to City Council using my personal e-mail but the City server is bouncing back my email. I forwarded to Sarah for distribution to Council and City staff.
First, my compliments on the work. As I've said before, the documents are very, very good. I appreciate the hard work City staff has put into this endeavor and I am so sorry that so many members of the public are so disrespectful and rude. Twenty years ago when I was a government staffer I had my fair share of rude members of the public but nothing like City staff has experienced. My hat is off to you all for staying so professional.
What follows are minor comments and a few more questions. The purpose of sending these to you is to do some document clean up and to be helpful.
My only serious, but obviously personal, comment is the removal of GGNRA designation for the Pedro Point Headlands for all of the figures throughout all three documents. I know this has been used in the past but it's not accurate and from an Open Space lens not helpful. We (the City as well as the Open Space Committee) should be pursuing transfer of the property to all possible entities and not hope that the GGNRA will rescue us some day.
The rest of my comments are minor corrections.
DGP:
4-4
Undeveloped and Vacant Land: typo of acreage in first sentence 4-9
Mixed Use Center: Typo in third sentence
Commercial Uses: Could you define the term "As of Right"? I think I understand what it means but am not sure.
4-32
LU-I-6: First sentence typo regarding acres per dwelling unit. I'm sure some Pacificans would love 1010 acres per dwelling unit!
5-2
4th paragraph "For trips from Pacifica more people drive to Caltrans..." should be Caltrain. 5-5
Photo caption "SamTrans provides a Park-n-Ride...". Caltrans owns this site. SamTrans used to have a MOU but with the City's parking fee program I would have to think the City must be maintaining this site.
5-23
Paragraph starting with "GGNRA's Sweeny Ridge Trails...Baquiano Trail" should be change to "Ahni Trail joining Baquiano Trail".
5-28
Funding for Bike facilities: "Pursue potential funding from San Mateo County.." probably should be San Mateo County Transportation Authority
5-32
Transit Oriented Development: This parcel is actually owned by Caltrans and is under a MOU with SamTrans. It was one of the properties I managed on behalf of SamTrans. As you know, Caltrans has a field office on part of the property and SamTrans uses it as a bus layover area.
Any change of use would have to take in consideration relocation of these uses. 6-20
OC-I-27
Extend the Baquiano Trail ...and Ahni Trail down Fassler...as part of the Ohlone-Portola Heritage Trail..."
Finally, there's a picture of Nick's parking lot with a caption regarding Beach Parking. I think it's in the DEIR but for the life of me I can't find it again. I've assumed that this parking lot is private parking. If so, a better picture would be to either use the South or North Rockaway parking lot.
That's it. Great job!
Arlene
From: Clif Lawrence [ ]
Sent: Sunday, January 16, 2022 1:12 PM
To: Woodhouse, Kevin [[email protected]]; _City Council Group [[email protected]]; Wehrmeister, Tina [[email protected]]; Murdock, Christian [[email protected]]
Subject: Draft General Plan 2022 - "Contents" - NOT FOUND [CAUTION: External Email]
Draft General Plan 2022
entries in Table Of Contents... NOT FOUND
• FIGURES A-1, A-2,A-3,A-4.... In fact NO section "A"
• TABLE 10-1.... NO SECTION '10'
Previous City efforts were friendlier.
• There is no inter-active index.
• Vast majority of "sources" 2009 .... why? That's 12 years ago (good for scotch...not civic docs)
• D&B lists themselves as "source" on many graphic
materials, when their source is also credited. So why is D&H a "source"? Did they make some modifications to
the doc they got elsewhere? If they made modifications, why did they not tell us what they changed, and the source for that "additional data"?
Was the City aware that in 2017 OPR created templates and links to assist Cities and others to update their general Plans? The DEIR ... well... for starters...(initial reactions)
1. It's presented as ONE BLOB FILE...
1. NO Table of Contents, No Interactive Index
2. It feels like it was intended to obfuscate its contents.
2. It swelled from 600+ pages to 1000+ pages
3. The 2014-2015 presentation was at least broken into a series of properly labeled files.
In any other time, I would say this was a tragic effort to thwart public involvement. But today 35% of the county is going to end the Earth's oldest democracy...and a mad man in North Korea wants to send us a nuclear bomb.
What's the connection?
This presentation does not appear to have any assistance to public involvement. It another case of disenfranchising "We The People"
Regards,
Clifford Lawrence
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: Stan Zeavin [ ]
Sent: Wednesday, March 2, 2022 10:46 AM
To: Public Comment [[email protected]]
Subject: episodic erosion and erosion rates
[CAUTION: External Email]
https://cityofpacifica.egnyte.com/dl/VMaTQXxRdS
p 469 0f 1001
Chapter Three: Settings, Impacts, and Mitigation Measures
3.6: Geology, Soils, and Seismic Risk
Landslides and Slope Failure
(references USGS report dated 1997)
p.470
Beaches and Erosion
“The long-term average erosion rate for cliffs in this general area is roughly
0.2m/year” “…1997-98 winter storms caused 50 years of erosion,” removal of 12 homes (References USGS reports from1983 and 2005)
2015 three 300 block apartment bldgs evacuated/demolished (2evacuated 2009-2010) >Replace out-dated information. In order for Pacificans to make decisions about development that will have a long-term benefit to our beautiful coastal town we need to understand the real risks. Shoreline recession along the coast has continued for thousands of years. Pacifica’s cliffs consist primarily of alluvial sediments, poorly consolidated sandstones, and are topped in many places by 10 feet of uncemented dune sand.
No single average rate of erosion can adequately represent the repeated episodic erosion events that have shaped our coast. Moffatt and Nichol February 2022 study for Pacifica estimates an average bluff recession along Esplanade from 1943 to 2020 of 0.5 feet/year to 2.5 feet/year.
Dramatic examples of extreme erosion include:
• During the 1983 storms 100 feet was lost from the northwest corner of the Pacific Skies Mobil Home Park. (Griggs and Savoy, Living with the California Coast, Duke University, Durham, N.C., 1985) • In 1998 bluff retreat mapped by USGS since 1956 caused the removal of twelve homes from the 500 block of Esplanade following 30 feet of erosion over two weeks. (Lajoie and Mathieson, USGS, 1998)
• At the Lands End Apartments (now Oceanaire) 100 feet of their seaward lawn dropped off during one storm in 2009. See before and after photos (courtesy of a Land’s End owner) below.
> The Moffatt and Nichols report prepared for the 400 Esplanade Infrastructure Preservation Project, February 2022, is thoroughly researched and contains useful maps, graphs and information that are appropriately up-to-date and would serve Pacifica well if incorporated into the GP/SPSP/DEIR. As M&N notes, Sea Level Rise will increase erosion rates in the future.
Thanks for the opportunity to comment,
Margaret Goodale
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From: Christine Boles [ ]
Sent: Monday, January 31, 2022 3:59 PM
To: Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Public Comment [[email protected]] CC: Woodhouse, Kevin [[email protected]]; Bier, Mary [[email protected]] Subject: Existing Conditions Reports/Traffic Studies for GP/EIR? [CAUTION: External Email]
Good afternoon Christian and Tina,
The DEIR references two Existing Conditions Reports, one done in 2010 and one done in 2019 for Sharp Park.
I think I found the one for Sharp Park here, please confirm this is current. https://www.planpacifica.org/spsp-ecr
I cannot find the one for the whole city that was discussed at a public hearing in September 2010.
Can you forward that to me or should I file a PRA request? And can you confirm if any updates were done for the city wide studies? I'm currently specifically looking for more recent traffic studies as 2010 was before the tunnel opened.
Thank you and I appreciate a quick response as our review time is so limited.
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“Do your little bit of good where you are; it's those little bits of good put together that overwhelm the world.” - Desmond Tutu
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.
From:
Sent: Sunday, January 30, 2022 3:46 PM
To: Murdock, Christian [[email protected]]
CC: Public Comment [[email protected]]
Subject: Extending the Pacifica General Plan Review Date [CAUTION: External Email]
Please consider extending the review deadline , by at least a couple of months, of this very extensive and, not very well organized document. I have just recently become aware of this huge report, which will take me some time to review. Several of my neighbors would also like more time to review.
Thank you ,
Patricia R. McGregor
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From: Stan Zeavin [ ]
Sent: Tuesday, March 8, 2022 2:37 PM
To: Public Comment [[email protected]]; _City Council Group [[email protected]]; Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]; Murdock, Christian [[email protected]]; 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]]
Subject: Flooding in DEIR/Safety Element from Margaret Goodale Attachments: Flooding -Shoreline Protection.docx
[CAUTION: External Email]
Honorable Council, Commission and staff,
Below and attached, please find my seventh and final GP/SPSP/DEIR comment letter. Having reviewed only about a quarter of the documents due to their inaccessibility, I am grateful to the many volunteers with knowledge and expertise who have worked patiently and diligently to review the documents.
Thanks you for your attention,
Margaret Goodale
Shoreline Protection Programs
New DEIR
>> San Pedro Creek was completely reconfigured from west of the convalescent hospital to the mouth, not just restored. The creek banks were not eroding in the stretch that was reconfigured. The intent was to achieve 100 year flood protection from San Pedro Creek flooding.
However, western Linda Mar continues to flood from storm drain and sewage overflow. Current calculations for sewer capacity based on 3.7 inches of rainfall do not consider how climate change can be expected to increase the likelihood of higher rainfall and runoff.
The simultaneous occurrence of high tide, serious storm surge, and the extreme rains that can be expected with climate change will again put the creek at risk of flooding. The rains alone can overwhelm the storm/sewer system even with the “retention” tank functioning, as happened in October, 2021, and on previous occasions when the pumps have failed.
Safety Element
Document page 14 (8_14)
Coastal Flooding ……..
Shoreline Protection Programs
West Linda Mar …. [creek restoration] achieved 100-year flood protection for the nearby community.
To address the remaining flood threat to homes and businesses, the City also removed the most vulnerable structures.
>> Document must accurately reflect all Linda Mar flooding history: 1962, 1972, 1983, 1996(?), 2014, October, 2021
>> Managed retreat at the beach and reconfiguration of the creek do not protect Linda Mar homes from continued overflows of storm drains and sewers during predicted increasingly frequent rains.
>> Continued fluvial flooding of homes must be addressed.
Document page 15 (8-15)
Figure 8-4: Flood Zones
• 1% Annual Chance of flooding for much of Linda Mar north and south of San Pedro Creek is a gross misrepresentation. See history! • 1% Annual Chance of flooding for Beach Boulevard and Shoreview is underestimated. Homes routinely have water wash into garages/yards.
Climate change and sea level rise will increase the likelihood of flooding. • 1% Annual Chance of flooding at Rockaway needs revision after restaurant windows were broken by waves in 2017.
Document page 16 (8-16)
Increased Coastal Flooding from Potential Sea Level Rise • This very important section should be updated using more recent modeling from the California Ocean Protection Council and continuing studies
Document page 17 (8-!7)
SA-G-3 Sea Level Rise Adaptation. Establish policies to minimize the risk to persons and property posed by potential sea level rise.
• The very real risk to Pacifica from sea level rise dictates the necessity of planning for and managing inevitable future adaptation and retreat. • Utilize the accurate hazard/vulnerability report funded by a grant from the CCC in 2018, and include the necessary information
Document page 21 (8-21)
Guiding Policies
SA-I-29 Sea Level Rise Adaptation Plan.
• It is absolutely necessary that the most recent and dependable sea level rise projections be used in every decision about the coastal zone and those areas of Linda Mar that are predicted by COSMOS to flood in the future. In addition, to avoid costs to residents and for future litigation, the city must take every precaution to follow California State law and Coastal Commission guidance. We can hope for the best but we must protect the city and plan for the worst.
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.
Shoreline Protection Programs
New DEIR
>> San Pedro Creek was completely reconfigured from west of the convalescent hospital to the mouth, not just restored. The creek banks were not eroding in the stretch that was reconfigured. The intent was to achieve 100 year flood protection from San Pedro Creek flooding. However, western Linda Mar continues to flood from storm drain and sewage overflow. Current calculations for sewer capacity based on 3.7 inches of rainfall do not consider how climate change can be expected to increase the likelihood of higher rainfall.
The simultaneous occurrence of high tide, serious storm surge, and the extreme rains that can be expected with climate change will again put the creek at risk of flooding. The rains alone can overwhelm the storm/sewer system even with the “retention” tank functioning, as happened in October, 2021, and on previous occasions when the pumps have failed.
Safety Element
Document page 14 (8_14)
Coastal Flooding ……..
Shoreline Protection Programs
West Linda Mar …. [creek restoration] achieved 100-year flood protection for the nearby community.
To address the remaining flood threat to homes and businesses, the City also removed the most vulnerable structures.
>> Document must accurately reflect all Linda Mar flooding history:
1962, 1972, 1983, 1996(?), 2014, October, 2021
>> Managed retreat at the beach and reconfiguration of the creek do not protect Linda Mar homes from continued overflows of storm drains and sewers during predicted increasingly frequent rains. >> Continued fluvial flooding of homes must be addressed.
Document page 15 (8-15)
Figure 8-4: Flood Zones
• 1% Annual Chance of flooding for much of Linda Mar north and south of San Pedro Creek is a gross misrepresentation. See history! • 1% Annual Chance of flooding for Beach Boulevard and Shoreview is underestimated. Homes routinely have water wash into garages/yards. Climate change and sea level rise will increase the likelihood of flooding.
• 1% Annual Chance of flooding at Rockaway needs revision after restaurant windows were broken by waves in 2017.
Document page 16 (8-16)
Increased Coastal Flooding from Potential Sea Level Rise • This very important section should be updated using more recent modeling from the California Ocean Protection Council and continuing studies
Document page 17 (8-!7)
SA-G-3 Sea Level Rise Adaptation. Establish policies to minimize the risk to persons and property posed by potential sea level rise.
• The very real risk to Pacifica from sea level rise dictates the necessity of planning for and managing inevitable future adaptation and retreat.
• Utilize the accurate hazard/vulnerability report funded by a grant from the CCC in 2018, and include the necessary information Document page 21 (8-21)
Guiding Policies
SA-I-29 Sea Level Rise Adaptation Plan.
• It is absolutely necessary that the most recent and dependable sea level rise projections be used in every decision about the coastal zone and those areas of Linda Mar that are predicted by COSMOS to flood in the future. In addition, to avoid costs to residents and for future litigation, the city must take every precaution to follow California State law and Coastal Commission guidance. We can hope for the best but we must protect the city and plan for the worst.
From: Remi Tan [ ]
Sent: Saturday, January 15, 2022 5:14 PM
To: Murdock, Christian [[email protected]]; _City Council Group [[email protected]]; Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]; Public Comment [[email protected]]; Berman, Lauren [[email protected]]; Hauser, Samantha [[email protected]]; Nibbelin, John [[email protected]]; Leal, David [[email protected]]; Godwin, James [[email protected]]; Domurat, George [[email protected]]; Ferguson, Alex [[email protected]]; O'Connor, Bonny [[email protected]] Subject: Fw: 2022-01 Pacifica General Plan - Public Comment Draft - Comments - Housing [CAUTION: External Email]
Resending the comments as I got some bouncebacks. and .cc the City Council and key staff too.
Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment ----- Forwarded Message -----
From: Remi Tan < >
To: [email protected] <[email protected]>; o'[email protected] <o'[email protected]>
Sent: Saturday, January 8, 2022, 11:47:52 AM PST
Subject: 2022-01 Pacifica General Plan - Public Comment Draft - Comments - Housing Chris and Bonnie: I have the following comments on the draft public comment General Plan The planned housing quantity of 990 units by 2035 is inadequate and does not cover the job creation of 1,470 jobs by 2040 and is also short of the 1,892 RHNA required housing units to be built by 2031. (See excerpts from the Jan 2022 Public Comment Draft General Plan and the ABAG RHNA.) Also given that the majority of the jobs projected to be created are in the retail and service sectors (which is in line with the proposed increase in tourism), and these jobs are typically low paying, we need to add much more housing and most of this should be affordable housing.
Given the recent astronomical rise in Pacifica real estate values, Pacifica needs to increase housing quantities beyond the RHNA allocation to stabilize prices by increase supply to meet demand.. The City should work with other Bay Area cities and counties and ABAG to engage a study by an economist that would analyze job creation and population increase in the Bay Area and determine the amount of housing that needs to be built in Pacifica (and the Bay Area) not only to accommodate the new jobs within commutable distance and population growth but to stabilize rising prices by building enough housing so that demand and supply are equalized.
This new housing should be accounted for in the new General Plan and should be located near transit stops and shopping centers to reduce traffic, and not located on hillsides and toes of hills subject to landslide, in erosion vulnerable coastal edges, or in areas prone to flooding or high tide inundation to avoid loss of life and property due to more severe weather and sea level rise caused by global warming. This may require increase in density and height limits near the transit and shopping centers to accommodate the housing.
Given the dire rising cost situation with housing, and with all the effort and public input in the new General Plan and subsequent zoning updates, all housing projects as well as commercial projects should have asof-right zoning that minimizes additional public, planning commission and city council hearings and meetings to expedite the planning process and the city should coordinate with the Coastal Commission to make sure the General Plan and zoning is designed to make CC approval as of right too.
The city should have an expedited permit process in place and coordinate this expedited permit process with the Coastal Commission for housing locations in the Coastal Zone. Housing projects with high affordability should be top priority in permit expediting Please advise on next steps plans to take in incorporating increased housing and the above measures into the new General Plan.
Thank you and Best Regards,
Remi Tan, AIA, LEED AP BD+C
Architecture, Green/Sustainability Consulting, and Real Estate Investment Pacifica, CA 94044
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From: O'Connor, Bonny [[email protected]]
Sent: Tuesday, March 8, 2022 5:01 PM
To: Public Comment [[email protected]]
Subject: FW: Comments on the Draft General Plan
Attachments: The Rock Comments to General Plan Ammendment - Google Docs.pdf From: Patrick I. Mora [ ]
Sent: Tuesday, March 8, 2022 4:58 PM
To: Murdock, Christian <[email protected]>
Cc: O'Connor, Bonny <[email protected]>
Subject: Comments on the Draft General Plan
[CAUTION: External Email]
Patrick Mora
MORA ARCHITECTS
San Francisco, CA 94103
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.
Mora Architects
Planning Engineering
San Francisco, CA 94103
March 8, 2022
Christian Murdock
Deputy Director of Planning
Planning Department
City of Pacifica
540 Crespi Drive
Pacifica CA 94044
COMMENTS TO THE DRAFT GENERAL PLAN AMENDMENT
PURPOSE
To acknowledge the efforts by the Planning Department, City Council Members, Planning Commissioners, Consultants, and the General Public to produce a comprehensive draft that is now scheduled for review and adoption.
GENERAL PLAN LAND USE DESCRIPTION
Commercial
Potential commercial uses that the City might attract, including visitor-serving commercial, retail commercial, office, heavy commercial and light industrial.
Mixed residential and commercial uses are allowed when the dwelling units are located above the commercial uses.
Analysis and comments:
Please see enclosed diagrams with possible locations of commercial and residential.
Type I Residential over commercial, as stated in the general plan.
May apply only to level, flat sites, fronting a street with pedestrian activity. It works well in a situation where the building commercial frontage at ground level is cohesive.
Type II Separate commercial and residential buildings, where the pedestrian activities and visitor serving commercial interact at pedestrian level, without the separation in different levels.
Example would be Main Street Half Moon Bay south end, where U-shaped courts with fountains provide rest areas for visitors and locals.
Type III Hybrid interaction between commercial and residential. An arrangement where there’s residential over commercial and commercial over residential. To adapt to unusual conditions and slopes, where the standard specified residential over commercial arrangement would be difficult to implement. Or where the strict application of the code would not render the desired results in terms of practicality, business success, views, aesthetics and neighborhood coherence.
PARKING FOR RESIDENTIAL UNITS
Visitor Parking Where the code requirement is an extra parking space for every four residential units.
Suggested to provide one parking space for approximately every six units, not for visitors but for service, maintenance, manager calls, emergency vehicles or contractors.
Experience shows that most visitors parking spaces are being used by the same residents or tenants for additional vehicles and not by visitors. Whereas a designated yellow zone for service parking may serve a better purpose.
General Parking Where the code requirement is two off street parking spaces for a typical two-bedroom unit.
Most communities are moving towards electric powered vehicles and public transportation. Even densely populated cities are not requiring off street parking.
Examples would be the requirements for an ADU close to transportation, where the ADU would not need its own off street parking space that could take valuable land or space that could be used for open space, greenery, or more housing if feasible.
BUILDING HEIGHT LIMITATION
Code required height must not exceed 35’-0”.
This limitation has applied to all growth from the beginning. Now we face different challenges. If we wish to have some of our hills preserved then we must accept growth and in fill development where it is allowed,
A bonus in the height limitation may add an extra floor, where appropriate, to a 3-story existing fabric that could look too uniform or tedious for a vibrant city.
Terraces and balconies above could provide life and texture to streets that are in the process of becoming favorite for strolls or outings.
Architectural features that partially increase the height are often allowed and encouraged.
Example, the Clock Tower on Old County Road
Connected Buildings - Height Computation
Where two or more buildings are connected the height might be measured not from the lowest point of the lower building, but rather from the lower ground level of each individual building
A compound of individual buildings allowed to be measured in this way may offer potential uses that encourage visitor serving commercial and tourist attractions that otherwise could go unexplored.
Perhaps the connection can be limited to a percentage of the face of each connected building.
Pacifica is a jewel in the rough. All of us who come in contact, as professional, residents, or visitors would like to protect it and enhance it. Well planned development by educating the community must always be a part of local growth.
The work of Pacifica Planners is underestimated but much respected and appreciated by all of us.
Respectfully,
Patrick I. Mora
Architect
enclosure: Commercial-Residential Relationship Diagram
R
R
C
TYPE II
C
R
R
R
C
TYPE III
R
R
C C
R
R
35'-0"
35'-0"
35'-0"
35'-0"
TYPE I
MIXED-USE COMMERCIAL AND
RESIDENTIAL OPTIONS 35'-0"
view
walk
architectural
feature
grade
From: O'Connor, Bonny [[email protected]]
Sent: Wednesday, March 9, 2022 12:24 PM
To: Public Comment [[email protected]]
Subject: FW: DEIR Comments Ltr #3
Attachments: deir comments to murdock ltr 3 vcarmichael..doc From: Victor Carmichael [ ]
Sent: Wednesday, March 9, 2022 12:03 PM
To: O'Connor, Bonny <[email protected]>
Subject: Fwd: DEIR Comments Ltr #3
[CAUTION: External Email]
Bonny, I don't Christian Murdock's email so I am sending this to you .
I sent this in after close of business yesterday assuming the 03/08 deadline for comments on the GP DEIR was the calendar end of that day. It it bounced back as undeliverable. I spent a lot of time on it and I hope it can be included with the other DEIR comments.
Thank you, Victor
---------- Original Message ----------
From: Victor Carmichael < >
To: "[email protected]" <[email protected]> Date: 03/08/2022 8:35 PM
Subject: DEIR Comments Ltr #3
Dearing Planning Dept:
Attached is my third comment letter re: the GP DEIR.
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Victor Carmichael 03/08/22
Pacifica, CA 94044
TO: Christian Murdock AICP
Deputy Director
City of Pacifica Planning Department
540 Crespi Drive
Pacifica CA 94044
RE: General Plan DEIR Comments
Chapter 3.6 Geology, Soils and Seismic Risk - Ltr # 3
I have commented extensively on geology related issues in my Comment Ltr #2. However this section, Chapter 3.6 Geology, Soils and Seismic Risk, is very much related since it specifically focuses, on among other related issues geological concerns, coastal erosion.
Since coastal erosion is an ongoing and controversial issue here in Pacifica, it might have made more sense to treat it as a separate entity rather than combine it with two less timely issues, Soils and Seismic Risk. .In any case I was glad to the two ravines that I brought up my Comment Ltr # 2 were included in the Figure 3.6-3 although dismissively called “Gullies”.
In working through the material in this Chapter 3.6 I tried to zero in on matters that I believed were the most important. However I found the organization somewhat disjointed with much that was relatively agreed upon and prosaic crowding out what we hoped the GP-DIER process would confront.
In any case I found the section titled Beaches and Coastal Erosion ( Pg 3.5-14) contained useful and interesting information. Northern California's and specifically San Mateo County coastline's it turns out is especially susceptible to severe erosion as well as slope failure. It says our long term rate of cliff erosion is “roughly 0.2m/year”. And sometimes it happens all at once, like the loss of 50' in one year (1997-98). Other more recent major collapses were mentioned like the 2016 losses on Esplanade Avenue. It goes on to state that the Pacifica 2021 Annex to the San Mateo Countys Multijurisdictional Local Hazard Mitigation Plan (MJ-LHMP) identifies coastal erosion as the top hazard in Pacifica. Also noted was that at least eight significant coastal erosion events have occurred since 1997. All of thisis, of course, before SLR was a burning issue.
The section, Effects of Sea Level Rise (Pg 3.5-17), opens with this stark pronouncement: “Sealevel rise resulting fromglobal climate change isprojected tocausemore extensive erosion ofbeaches,dunes, bluffsandcliffs.” Later in that section a study is cited that states a majority of dune coastline is currently accreding but this process will dramatically reverse between 2050 and 2100. However the bluffs will continue to erode and the erosion will increase dramatically between 2025 and 2050. That is certainly within our planning horizon.
Then they warn :
“It is important to reiterate that these models are approximate, and not meant to be used for parcel-specific land use planning. These models indicate that there could be new risks of erosion along the length of Pacifica’s coastline in areas that are not currently exposed to wave action erosion, which could impact all of the coastal neighborhoods and coastal habitats.” (underline added)
In the next section, Shoreline Protection Programs, soft pedals things with some good but old news regarding the successful effort in 2002 to purchase and remove houses at Pacifica State Beach – 'managed retreat' before it was demonized. Finally there is very cursory coverage of our revetment status and the need for repair of the battered seawall on Ocean Ave.
Here, as my focus has been is on the DEIR's treatment of coastal erosion issues, I have respond on several Policy Elements that I found specifically pertain to that area of concern.
CO-I-46 Pg 6-36
Shoreline Protection. Continue to prohibit new development requiring shoreline alterations.
Shoreline-altering construction such as revetments, breakwaters, groins, channels, seawalls, cliff retaining walls and similar structures is permitted only when required to serve coastal-dependent uses or to protect existing structures arid public beaches in danger of erosion. Such structures, where permitted must be designed to eliminate or mitigate impacts onlocalshoreline sand supply.
The problem is not more revetments. The Coastal Commission has long since prohibited new ones. The problemis enforcement(Pacific Villa?) and maintenance. Once it's as harmful and illegal it is, here to stay. The problem once a rock revetment (or seawall) is in they are allowed to be maintained . So they continue in perpetuity to rob the beaches of their sand while the ocean often gets around the revetment and continues to eat into the bluff anyway.
OSCF 1-16 Pg 3.6-36
NorthernCoastal Bluffs.Promote the permanent conservation of private land on the Northern Coastal Bluffs to protect sensitive natural communities and protect against coastal erosion. Managed protected land together with adjacent GGNRA land.
The remaining private land north of the GGNRA protected land probably in little danger of development as it is facing a losing battle with erosion. But it is gratifying that the DEIR recognizes its value. If that were only the case with the Fish and Bowl properties just east of the bluffs.
SA- I-12 Pg .6-32
Bluff Drainage and Erosion. The City will pursue feasible funding mechanisms to investigate areas that may be significantly contributing to groundwater flows to the bluffs and determine whether improving drainage and/or reducing irrigation could reduce bluff erosion. Measures to improve drainage and reduce over-watering shall be communicated to the public and property owners as part of existing water conservation outreach programs, and included as conditions on new development where applicable.
This element bears directly on the concerns I addressed in Comments Ltr #2 with respect to the Fairmont West coastal bluff (Northern Coastal Bluffs) and their relationship to land areas east of the bluffs.
Summary
While much of the material presented regarding coastal erosion in Chapter 3.6 Geology, Soils and Seismic Risk is solid and science based, there probably are more recent available data. Nevertheless, what it here is enough for action. But a call for action is not what this document contains.
What is plainly obvious is that this DEIR is not calling to task the General Plan for its lack of dealing with one of most critical and central issues facing Pacifica, policy for confronting SLR driven coastal erosion. Pacifica is a coastal community in the direct path of SLR. Already we have had preview of it with our rapidly eroding shoreline due our location and geology. But it will get worse. Yet we are acting very ostrich-like to let the GP-DEIR become a politically driven documents rather than use this opportunity to move forward with something that addresses the future. This DEIR should be reportting the environmental implications of the General Plan especially in relation to the Climate Crisis and SLR. It is not. It is not even close. If it were, this section and all of its policy elements would look much different. This is sad because this may be our only opportunity to get it right.
From: Woodhouse, Kevin [[email protected]]
Sent: Sunday, February 6, 2022 10:04 PM
To: Murdock, Christian [[email protected]]
CC: Wehrmeister, Tina [[email protected]]
Subject: FW: DEIR The General Plan and Herding Cats
Christian, making sure this comment gets to your collection.
Thx,
Kevin
From: Rick Nahass < >
Sent: Thursday, February 3, 2022 2:15 PM
To: Beckmeyer, Sue <[email protected]>; Bier, Mary <[email protected]>; _City Council Group <[email protected]>; Coffey, Sarah <[email protected]>; Woodhouse, Kevin <[email protected]>; O'Neill, Mike <[email protected]>; Public Comment <[email protected]>; Vaterlaus, Sue <[email protected]>; Bigstyck, Tygarjas <[email protected]>; Wehrmeister, Tina <[email protected]> Cc: David Canepa <d >; ;
Subject: DEIR The General Plan and Herding Cats
[CAUTION: External Email]
To: Pacifica City Staff and Council
Cc:
• Mid-coast Council cause I complained about having no say in the Connect the Coastside plan
• David Canepa’s office cause he might have some sway with the MTC It wasn’t until I spent 15 years as a project manager at Visa in Foster City that I understood and learned how to keep some of the world’s most brilliant engineers and scientists engaged on delivery while managing changes their wandering curious minds invented along the way.
Pacifica City staff employees have spent over a decade engaging with residents and utilizing public governance processes to pull together content for creating our long term City plans.
The current state of Pacifica’s planning documents does a grave disservice to our most capable and dedicated staff
• To release a poorly formatted online pdf DEIR that is logistically difficult to access, difficult to navigate and cannot be referenced (standard search, copy/paste functionality is broken.)
• To release a General Plan with no schedule, no provision for managing priority and risk nor recommendations for how to accommodate change • To have an end date for final approval with no process on how to get there.
After the 45 day public evaluation period, the documents must be reworked for a second public ‘period of review.’
• City staff to figure out how to generate clean documentation like 99% of all other San Mateo County lead agencies.
• City staff to declare a date in the sand (e.g. Aug 15, 2022) when this focused project documentation review must complete and work backwards to develop realistic achievable tasks and schedule for that date, no matter what the letter of the law is.
• City staff to work with Council to select 3-6 (sic) of the hundreds of elements in the GP to prioritize those elements for more detailed planning by assessing effort vs impact vs other attributes city staff determines is best for assessing. This gives city staff focus and purpose. It breaks the failure of management who make the chronic excuse that city staff is overworked or has too little time. In this way management can support city staff in this more focused endeavor and let the brilliance of city staff shine.
If you should go this way, I would want one of those prioritized elements to be bus regional transit. If it is not, I may not like it, but I will understand, because based on city staff assessment I would see that it might be a higher priority to focus on the quarry or the frogs (doesn’t it always seem to be about the frogs?). And when it’s time to prioritize what to go deep on NEXT year (periodic prioritization might be spelled out in the GP) me and the rest of us will cajole, lobby, justify what we think is important and you, City staff, plus council will make the final decision on what’s next. You will LEAD.
Now that I have you here let me provide you with some anecdotal attributes you might use for a deeper dive on a regional bus GP element
• How does this solve an imminent issue - possibly reduces VMT and makes Pacifica better able to comply with state housing allocation levels or makes Pacifica better able to justify different housing allocation levels. • How does the text in the GP empower our leadership to make Pacifica more competitive for funding. Mike O’Neill is on the Board of Directors as documented in the current San Mateo Countywide Transportation Plan 2040. How does the GP element empower Mike to be the biggest baddest cat in the room, backed by our local and county supervisors, to drive C/CAG to support Pacifica initiatives to the MTC?
• How does this affect residents outside our jurisdiction? Would people on the mid coast, Connect the Coastside, benefit and might we engage them to find out? Somehow we need to change our governance practices to manage, simply, our priorities and focus to let the residents across all spectrums who care, want to conduct business or development do and deliver the justifications for their passions to the very capable and creative city staff.
Be a cat.
Meow,
Rick Nahass
, Pacifica
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From: Coffey, Sarah [[email protected]]
Sent: Wednesday, March 2, 2022 2:57 PM
To: Public Comment [[email protected]]
Subject: FW: Draft General Plan, DEIR, Sharp Park Specific Plan From: < >
Sent: Wednesday, March 2, 2022 2:54 PM
To: _City Council Group <[email protected]>; Coffey, Sarah <[email protected]>; [email protected]
Cc: Woodhouse, Kevin <[email protected]>; [email protected]; Murdock, Christian <[email protected]>; [email protected]
Subject: Draft General Plan, DEIR, Sharp Park Specific Plan [CAUTION: External Email]
Dear City Council:
First, thank you for the 15 day extension. I finally finished reading all three documents on Monday. Staff and Council have done a remarkable job on this long and difficult task and it is very, very good. I have a few minor comments which I will send to staff under separate cover. I am especially pleased with the addition of several parcels to the Hillside Preservation Designation for both safety and natural resource protection.
I also want to point out that Staff has been very responsive to my various questions and I want to commend them on their professionalism.
Finally, I want to express appreciation for this process. I have learned so much about the city in which I live.
Sincerely,
Arlene Patton
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From: O'Connor, Bonny [[email protected]]
Sent: Wednesday, February 2, 2022 10:32 AM
To: Public Comment [[email protected]]
Subject: FW: Finally, a searchable EIR with interactive TOC From: Pete Shoemaker [ ]
Sent: Wednesday, February 2, 2022 10:30 AM
To: 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]>
Cc: Wehrmeister, Tina <[email protected]>; Murdock, Christian <[email protected]>; O'Connor, Bonny <[email protected]>; Woodhouse, Kevin <[email protected]> Subject: Finally, a searchable EIR with interactive TOC [CAUTION: External Email]
Planning Commissioners,
Here is the link to the file we should have had all along: Searchable EIR download. We have uncompressed the file, which allows it to be searched and cut & pasted, and added internal links so that it has a one-click, interactive TOC. It is located on my Google Drive and easily downloaded, as you can see for yourself. It’s too big for Google to scan or preview, but it is the exact same document the City issued.
Have you spent much productive time looking over the EIR before this? Like most of us, you probably tried to do your duty but gave up after being overwhelmed and confused—because the document the Planning Department gave us is unusable, and everyone knows it. We’ve been given the minimum time to look it over and we’ve already lost half of that. Can't you see why we’re asking for an extension?
You’ve volunteered you time on this Commission because you care about our community, and we’ll all very grateful. I know you want to do your jobs well and analyze this document as best you can. You need to have ample time to do this, so please, join with us and ask for more time. Demand it, as you are a critical link in the approval chain.
We understand that the Planning Department has been understaffed and dealing with Covid and relocation issues. But that doesn’t excuse issuing a substandard document—one of the most important to our city—and rushing it through. It’s enough that we citizens have to spend hours of time filling in for the Planning Department. We should at least get acknowledgment and have our reasonable request for more time honored.
Pete Shoemaker
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From: Wehrmeister, Tina [[email protected]]
Sent: Thursday, January 20, 2022 5:26 PM
To: Murdock, Christian [[email protected]]; Michelle Kenyon [BWS Law] [ ]
CC: Woodhouse, Kevin [[email protected]]
Subject: FW: Fragmentation MUST stop
Attachments: IMG_4606.jpg; IMG_0186.jpg; IMG_0187.jpg
Hi all – see comment below. Ms. Macias mixes GP and TBD Talbot comments. I was going to respond that we received an accepted her comments on these projects.
Tina Wehrmeister
Planning Director/Asst. City Manager
City of Pacifica
650.339.3978
www.cityofpacifica.org
From: Necesse < >
Sent: Wednesday, January 19, 2022 4:57 PM
To: Wehrmeister, Tina <[email protected]>
Subject: Fragmentation MUST stop
[CAUTION: External Email]
Dear Tina,
What transpired last night is concerning and I am forwarding a copy of an email to Mayor Bier below. I had no intention of speaking on the project, I only wanted to comment on the General Plan update. Because it was a public hearing, it captured my attention and I pulled up the parcel map. I was stunned by the map and scrambled to prepare a comment. Wildfire was one part of my concern (this parcel is very similar to the one behind me and we had a fire that threatened our homes on the 4th of July a few years ago.) The parcel behind me is one of many already fragmented parcels and as a result, we have many forms of wildlife using the streets and side yards as corridors to get between these fragments and out to open space. The fragmentation issue warrants the attention of the decision makers in our City.
Please take a look at the circled areas on the attachments. We are in the midst of a General Plan update and I was told we are only allowed four amendments per year. So, the draft presented for public comment is one, the amendment with this project would be another. So that limits us to two more amendments to our general plan for the remainder of 2022? That really restricts our ability to approve the plan and make amendments rapidly vs delaying the approval of the entire plan.
We have a map of the vegetation that pairs with the EIR. We also have a map of the sensitive and critical habitat that also pairs with the EIR. So, now look at the project that was just approved. The PC decision landlocked greenspace and fragmented it. I am not opposed to new construction, I welcome it, but what this odd project did was perch a house in HPD, with a variance and an amendment to the GP while cutting off a corridor that was never even analyzed: how this could be CEQA exempt? There is video footage of a mountain lion using the space less than 700 feet away from this project. This is an active wildlife corridor.
Looking at this in context of other developments, what type of precedent does this set? We are allowing fragmentation of sensitive and critical habitat so why wouldn’t any other developer legally challenge a PC decision that deprived them of doing the same thing? The consequences of such an amendment to the General Plan are severe and have broader implications. I am very hopeful that in your capacity as our Planning Director you would have some jurisdiction over this major issue affecting our city particularly in how it could impact the BOV project and the one by the Montessori School too. I have emailed each council member to take a look at this concern, OSPAC says it is out of their jurisdiction. Now it is in the hands of council and the staff who helps shape the decisions. PLEASE take a good look at this and consider the consequences to our City with a General Plan Amendment such as this.
The Planning Commission just approved a project that fragmented high habitat value as identified in the new General Plan and referenced in the existing General Plan.
I am providing a resource to peruse. We need to focus carefully on the issue of fragmentation in our General Plan update. We need to add to our maps to identify the corridors currently in use and write a plan for prevention and mitigation of fragmentation http://wildlife.org/wpcontent/uploads/2016/04/FS_WildlifeHabitatFragmentation_FINAL.pdf I appreciate your time.
Respectfully submitted,
Erin
Sent from Mail for Windows
From:
Sent: Wednesday, January 19, 2022 12:37 PM
To: [email protected]
Subject: Fragmentation MUST stop
Dear Mayor Bier,
I am appealing to you because I know you are very interested in our natural environment. I attended the planning commission meeting last night to comment on the General Plan update. There was a public hearing on the agenda so I looked up the parcel out of curiosity. I was not planning on speaking, but I was stunned that the City was amending the General Plan and approving a variance for a project at the top of Talbot.
The approval of a single family home last night, “fragmented” a connector between open space in what has already been identified as high value open space threatened by fragmentation. This is a really big deal. They landlocked greenspace. Not one planning commissioner flinched last night. It’s very disturbing that this is not a concern of our appointed Planning Commissioners.
We have a General Plan update in front of us. This MUST be addressed in our General Plan and in the EIR. What is the point of having a Hillside Preservation District and planning and land use codes along with ordinances and policies if we toss them out the window when architects and developers convince our staff and officials to legally change the playing rules – amending the general plan and approving a variance to accommodate a developer: let that sink in!
I am truly stunned this took place last night. PLEASE help advocate for our draft General Plan to stop fragmentation and prevent the amendment of our General Plan, policies and ordinances to accommodate developers.
In summary, the Planning Commission approved a single family home that cuts off wildlife from nearly 4 acres of open space. Somehow this project claims it was CEQA exempt. I cannot believe this is even possible. If you look at the diagram of the parcel map you will notice the blue highlighted parcel. That is a steep hillside and a house perched upon it, it cuts off parcel A from parcel B and now animals now must go through the side yards of that parcel, 722 Talbot or 712 Canyon. The first two diagrams are from our proposed General Plan Update.
More fragmentation of these high value greenspaces means animals have less space to breed, hunt, roam, find refuge, raise their young and they will be forced into private residences, public roads and into dangerous encounters with humans, pets and cars.
I created these visuals to help you understand what I am talking about. I hope it helps. Please feel free to ask for clarification.
Respectfully submitted,
Erin Macias, Linda Mar
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From: O'Connor, Bonny [[email protected]]
Sent: Wednesday, January 19, 2022 12:03 PM
To: Public Comment [[email protected]]
Subject: FW: Palmetto Ave questions
-----Original Message-----
From: elizabeth rubenstein [ ]
Sent: Saturday, January 8, 2022 8:54 AM
To: O'Connor, Bonny <[email protected]>
Subject: Palmetto Ave questions
[CAUTION: External Email]
Good morningI love the proposals for improving Palmetto Ave! We have long needed a cohesive design and leadership to create a vital downtown area.
Wondering how this development is impacted by current managed coastal retreat plans? and
Where are all those mature trees coming from?
Thank you
-elizabeth rubensteinpark pacifica
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From: Woodhouse, Kevin [[email protected]]
Sent: Tuesday, January 18, 2022 3:22 PM
To: Murdock, Christian [[email protected]]
Subject: FW: Sharp Park plan comments
Attachments: problem no solution.jpg; The Draft General Plan PDF is not indexed Just in case this comment doesn't find its way to you separately.
Kevin
-----Original Message-----
From: City Manager <[email protected]>
Sent: Tuesday, January 18, 2022 3:20 PM
To: Woodhouse, Kevin <[email protected]>; Coffey, Sarah <[email protected]>; Wehrmeister, Tina <[email protected]>; Martin, Monique <[email protected]> Subject: FW: Sharp Park plan comments
Hi all,
We received this email and the attached email in the City Manager inbox from a resident, Peter, who has some comments about the General Plan.
He's sent them to the Public Comment email, but has also sent them directly to the Councilmembers as well, so I wanted to get them in front of you all if they have any questions.
Thanks!
Shelby
-----Original Message-----
From: peter k < >
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
[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,_NdQbVx X6SQCsmTldFJcURFWI0RYNcJuRM7H_n638B49D6RKAAnGfK4qFk_MFkovYFlvZTNymh2ryC1e0vyYfe80O 1o5i2DBd-Td5WBwKQ,,&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.
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: peter k
Sent: Tuesday, January 18, 2022 2:37 PM
To: _City Council Group; City Manager
Subject: The Draft General Plan PDF is not indexed
[CAUTION: External Email]
You can't click on section headings to jump to the corresponding page.
This looks a lot like a deliberate attempt to sabotage public comment.
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: Wehrmeister, Tina [[email protected]]
Sent: Tuesday, February 15, 2022 3:07 PM
To: Murdock, Christian [[email protected]]
Subject: FW: STOP sprawl.
Please see the GP/SP comment below.
Tina Wehrmeister
Planning Director/Asst. City Manager
City of Pacifica
650.339.3978
www.cityofpacifica.org
-----Original Message-----
From: david patton < >
Sent: Tuesday, February 15, 2022 12:09 PM
To: Wehrmeister, Tina <[email protected]>
Subject: STOP sprawl.
[CAUTION: External Email]
Dear Tina.
Yes for Sharps Park and Montara Mountain.
Thank you. And thanks for the response.
David Patton.
-----Original Message-----
From: Wehrmeister, Tina <[email protected]>
Sent: Monday, February 14, 2022 10:28 PM
To: david patton < >
Subject: RE: Email via City Web Site
Thank you for your comment. Am I correct that this is a comment on the General Plan and Sharp Park Specific Plan? I'll make sure your comment is in the record.
Tina Wehrmeister
Planning Director/Asst. City Manager City of Pacifica
www.cityofpacifica.org
-----Original Message-----
From: david patton < >
Sent: Monday, February 14, 2022 10:04 PM
To: Wehrmeister, Tina <[email protected]>
Subject: Email via City Web Site
[CAUTION: External Email]
Dear Tina.
Please do not allow urban sprawl in our quaint beach community. It will bring traffic and noise like you can’t imagine…. We like our town the way it is. I need my right to “quiet enjoyment” David Patton
Sent from my iPad
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CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.
From: Sue Digre [ ]
Sent: Tuesday, March 8, 2022 4:14 PM
To: Public Comment [[email protected]]
Subject: Fwd: ***(DEIR PACIFICA..Comments
[CAUTION: External Email]
Second sending. Ay 4:14,3 08 22
---------- Forwarded message ---------
From: Sue Digre < >
Date: Tue, Mar 8, 2022, 4:00 PM
Subject: Fwd: ***(DEIR PACIFICA..Comments
To: Sue Digre < >
From: Sue Digre < >
Date: Tue, Mar 8, 2022, 3:16 PM
Subject: Fwd: DEIR PACIFICA..Comments
To: Sue Digre < >
Thank you
Here it is .4pm
DEIR Pacifica. Comments from Sue Digre 3 04 2022.
Executive Summary Section.
1. "The Proposed Project " was developed in response to policy direction by...as well as community concerns .."
..Report to Residents in the DEIR for full disclosure and for comparison purposes. who the City is determing are Stakeholders.
..State the % of input from each designated stakeholder.
A Gen Plan is supposed to be a Constitution for residents of a City. It is their choice of who, what they want to be.
IF we are mistaken , a clarification is necessary.
......
2. Diversity of Housing.
"The Plan aims ...and ensure adequate housing options for people of all ages & incomes by providing enough sites at a higher density....
Input:
That is a sweeping statement buried in the paragraph and calls for a dramatic change from the operative ,long respected GP.
Explain how it is appropriate to increase the height of buildings beyond the usual 35' in the designated Historical Area.
We are determing the chatacter of our Community. This statement is buried in a paragraph appears disrespectful to the electorate
Input:
..Infrastructure Improvements.
Nothing is mentioned about 21st Century traffic management strategies .
The City negotiated for and got two. The GP should addess that and be dedicated to ensuring that they are operative accountable as expected.
( CalTrans insisted that they were capable and we had to abandon a potential contract with Rhythmn Emgineering.)
The GP should indicate that the City needs to insist on procuring more ITS signals to keep traffic moving through the City, through the Tunnel and through Midcoast.
The GP should state that the City collaborate with midcoast and CalTeans & County for the most effective mobility management.
If the movement of traffic is not consistent there will ne negative CO2 and other health consequences.
3. Protections from Natural Hazards. E-3@@
...The.GP should state that Our Commumity vision & goals must be grounded on data that was produced in the most recent dates .Presently that would be 2022. .
If that data is not available from reliable sources immediately, then the GP should state that once new data is available it will be studied and applied as an update to the certified GP. (The present 1980 GP did have an 1981 update in it.)
..The date of data used for this GP should be the most recent scientific.data available and must state the date and source.
4. Public input too must be based on the most recent scientific data available today . ..Outreach must be made to inform the public of the most recent data and the city should enable public dialogue of the most recent data.
5.The GP should state that Ample funding should be used to ensure a thorough outreach to the Public at large and to enable Public Dialogue at Public Forums .
Digital media is important but equally important is outreach to non-techy persons and nonmobile persons throughout tge City.
6. The Gen Plan should also incorporate such best practices in its policies.
7. Sharp Park Specific Plan p E-4
Again this section is a bit disengenuous ,dismissive of the Public Voice and the Voter.
Ch 3."...where significant change may be expected to occur...." ...A change in height limit from 35ft to 5 stories high is in the Draft Sharp Park Plan.
And this 5 story high density is to.be built in a City designated HISTORICAL area.
A City draft Gen Plan must be very transparent to the Public at large, the Voters, before it is adopted and.for Public Dialogue
A Gen Plan is a local constitution for the residents.
Ch 5. P E4 &5
"...compatibility with existing development.."
...Once again the Sharp Park Draft plan determines that 5 story high density buildings will be in the already City designated Historical area of Pacifica.
This language in p E4&E5 lacks clarity and full information. ..Table ES-1...housing units..
Source: C/CAG TDM DEPT FINANCE
Imput
...Wait..A GP is the Constitution for Pacifica residents/ voters .
The electeds of OUR Community should stand up for Voter's Rights.
The Source for our constitution is Our Voice.
The State can speak for itself outside of this document.
The rights of Voters is protected by the US Constitution & by the California Constitition. ..The local Constitution, the chosen Gen Plan must be in agreement with the US Constitution.
The local Voter rights should not be mandated away by Electeds in Sacramento. ...Re housing:
....Those of us who consistently worked hard for years and years for inclusionary housing ,for TRULY AFFORDABLE Housing also want.to.protect ths civil rights of Voters to work things out together with truth and civility.
E5
INPUT
..The present operative GP.1980 states that the City is " built out"! Again, this is writing in The i update of the Gen Plan of 1980 does not address facts.
The operative GP 1980 is clear,
the City is " built out".
**There are extreme negative impacts if this fact is not made know and addressed. ..Address the fact that in 1980 the GP declared that Pacifica was built out. that data honestly, clearly, fairly and publically.
E6
...Alternatives to the " Proposed Gen Pl" p E-6
Alternative 1. Strong Center at Quarry Site.
Imput:
...On what basis can this following deduction be made??? Quote
"...and the least amount of development on underutilized sites elsewhere." Input
This section makes a lot of assumptions without explanation.
It is somewhat confusing.
And actually the last 3 sentences make Alternative 1 to be the most ideal But there is a a question, what does the following statement mean?: "..facilitating higher-density housing at appropriate locations".
...What qualifies as "appropriate locations"
E8
Alternative 2 also sounds ideal.
Input
One confusion, it uses the term " redevelopment". The technical term, REDEVELOPMENT was cancelled by the State. So this is a very confusing statement .
Clarify it.
***This statement also makes no acknowledgement that the Quarry can only build residences IF there is a Vote of the People.
**This fact about the need for.a Public Vote for the Quarry must be expressed clearly. The Voice of the Voter's must be protected.
E8
No Project Alternative.
Input
This is confusing & inaccurate.
Again it makes no mention of ths existence of a Voter requirement.
It also alludes to " large sections of Pacifica are designated as 'Special Area'...." And
It states " ...including recent proposals to limit development at the Quarry site..." Both are very confusing statements.
..the GP DREIR need to be transparent.
The requirement that any housing must be allowed only by Public vote is essential. It is true data.
It is in the operative Gen Plan of 1980.
..This other language suggests that " Special Areas" are negative designations.
But they are in the operative Gen Plan 1980, because the Public wanted them. The type of writing must be transparent.
The City must protect and enable the Public Vote, not ignore , negate or circumvent the facts . *** The GP must define what "Special Area" means. List where, what the existing "Special Areas" are in the operative Gen Plan 1980.
E8 Transportation.
...Input
Without traffic being able to.move consistently there wll.be negative impacts. C02 and othee health issues
Input: The 21C Intelligent Traffic Strategies/Signals should be acknowleged to exist and where and their function described.
..The GP should be clear abour the City being proactive about achieving adequate public transportation in, around and through Pacifica. It should require a follow through marketing plan too.
Coastal Concerns.
Input
.. Constant drainage from the coastal ranges must be acknowledged and explained as to how it affects coastal erosion.
..The GP should direct.the City to be responsible in facing planning for potential funding coasts to adjust to coastal erosion and maintenance.
..The GP should direct the City to learn about Insurance best practices and provide that timely imformation to assure comonsense stewardship on the part of City decision makers , planners , tax payers, private property owners and businesses.
E8
Input
Land Use, define "Sphere of Influence and list the sites.
E9
Input
The GP should make clear that there is
..on-going drainage from the coastal range contributes to hillside & coastal erosion ES3
CD-1-14 Design Review.
Input
Where should the present Hillside Preservation District District be noted? ..The updated GP should be clear too and represent the will of the People, OUR Community. ....The GP.update should be clear.like The 1980GP is clear about the importance of Hillsides, ridges , trees and neighborhoods, to our sense of character , who,we are & aspire to be and to our economic sustainability because of it.
Noise.
Input
..NEGATIVE NOISE impacts are HEALTH ISSUES.
...The GP should direct the City to.monitor all.noise causing sources carefully and alert residents & neighborhoods to.pending negative impacts.
..the GP should be clear about negative noise having being a definite HEALTH Hazard ..the GP should clearly address Air flight patterns that can affect residents, historical, large parks, cultural, school and visitor serving areas .
(The FAA was supposed to contact cities regarding such areas prior to agreeing to the NextGen plans. There are no records to show that they did).
New technologies are being researched today for planes ( super sonics, vertical vehicles), and flight plans .
The same for autos and trucks.
..There will be negative environmental impacts to our residents and our visitor serving economy again if GP does not set clear goals to.monitor and be engaged in oversight & accountability. ..our GP should include incorporating up to date equipment to monitor noise measurements and standards that avoid prople from being exposed to negative Health Impacts. .. The GP.should be clear that flights are up.high over Pacifica ,out over the Ocean away from our shores and hills.
Thank
You.
Sue Digre
3 08 2022
4pm
Sorry I have troubles with technology & no.hard copy
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: Sue Digre [ ]
Sent: Tuesday, March 8, 2022 4:03 PM
To: Public Comment [[email protected]]; Sue Digre (Contact) [[email protected]]
Subject: Fwd: ***(DEIR PACIFICA..Comments
[CAUTION: External Email]
---------- Forwarded message ---------
From: Sue Digre < >
Date: Tue, Mar 8, 2022, 4:00 PM
Subject: Fwd: ***(DEIR PACIFICA..Comments
To: Sue Digre < >
Thank you
Here it is .4pm
DEIR Pacifica. Comments from Sue Digre 3 04 2022.
Executive Summary Section.
1. "The Proposed Project " was developed in response to policy direction by...as well as community concerns .."
..Report to Residents in the DEIR for full disclosure and for comparison purposes. who the City is determing are Stakeholders.
..State the % of input from each designated stakeholder.
A Gen Plan is supposed to be a Constitution for residents of a City. It is their choice of who, what they want to be.
IF we are mistaken , a clarification is necessary.
......
2. Diversity of Housing.
"The Plan aims ...and ensure adequate housing options for people of all ages & incomes by providing enough sites at a higher density....
Input:
That is a sweeping statement buried in the paragraph and calls for a dramatic change from the operative ,long respected GP.
Explain how it is appropriate to increase the height of buildings beyond the usual 35' in the designated Historical Area.
We are determing the chatacter of our Community. This statement is buried in a paragraph appears disrespectful to the electorate
Input:
..Infrastructure Improvements.
Nothing is mentioned about 21st Century traffic management strategies .
The City negotiated for and got two. The GP should addess that and be dedicated to ensuring that they are operative accountable as expected.
( CalTrans insisted that they were capable and we had to abandon a potential contract with Rhythmn Emgineering.)
The GP should indicate that the City needs to insist on procuring more ITS signals to keep traffic moving through the City, through the Tunnel and through Midcoast.
The GP should state that the City collaborate with midcoast and CalTeans & County for the most effective mobility management.
If the movement of traffic is not consistent there will ne negative CO2 and other health consequences.
3. Protections from Natural Hazards. E-3@@
...The.GP should state that Our Commumity vision & goals must be grounded on data that was produced in the most recent dates .Presently that would be 2022. .
If that data is not available from reliable sources immediately, then the GP should state that once new data is available it will be studied and applied as an update to the certified GP. (The present 1980 GP did have an 1981 update in it.)
..The date of data used for this GP should be the most recent scientific.data available and must state the date and source.
4. Public input too must be based on the most recent scientific data available today . ..Outreach must be made to inform the public of the most recent data and the city should enable public dialogue of the most recent data.
5.The GP should state that Ample funding should be used to ensure a thorough outreach to the Public at large and to enable Public Dialogue at Public Forums .
Digital media is important but equally important is outreach to non-techy persons and nonmobile persons throughout tge City.
6. The Gen Plan should also incorporate such best practices in its policies.
7. Sharp Park Specific Plan p E-4
Again this section is a bit disengenuous ,dismissive of the Public Voice and the Voter.
Ch 3."...where significant change may be expected to occur...." ...A change in height limit from 35ft to 5 stories high is in the Draft Sharp Park Plan.
And this 5 story high density is to.be built in a City designated HISTORICAL area.
A City draft Gen Plan must be very transparent to the Public at large, the Voters, before it is adopted and.for Public Dialogue
A Gen Plan is a local constitution for the residents.
Ch 5. P E4 &5
"...compatibility with existing development.."
...Once again the Sharp Park Draft plan determines that 5 story high density buildings will be in the already City designated Historical area of Pacifica.
This language in p E4&E5 lacks clarity and full information. ..Table ES-1...housing units..
Source: C/CAG TDM DEPT FINANCE
Imput
...Wait..A GP is the Constitution for Pacifica residents/ voters .
The electeds of OUR Community should stand up for Voter's Rights.
The Source for our constitution is Our Voice.
The State can speak for itself outside of this document.
The rights of Voters is protected by the US Constitution & by the California Constitition. ..The local Constitution, the chosen Gen Plan must be in agreement with the US Constitution.
The local Voter rights should not be mandated away by Electeds in Sacramento. ...Re housing:
....Those of us who consistently worked hard for years and years for inclusionary housing ,for TRULY AFFORDABLE Housing also want.to.protect ths civil rights of Voters to work things out together with truth and civility.
E5
INPUT
..The present operative GP.1980 states that the City is " built out"! Again, this is writing in The i update of the Gen Plan of 1980 does not address facts.
The operative GP 1980 is clear,
the City is " built out".
**There are extreme negative impacts if this fact is not made know and addressed. ..Address the fact that in 1980 the GP declared that Pacifica was built out. that data honestly, clearly, fairly and publically.
E6
...Alternatives to the " Proposed Gen Pl" p E-6
Alternative 1. Strong Center at Quarry Site.
Imput:
...On what basis can this following deduction be made??? Quote
"...and the least amount of development on underutilized sites elsewhere." Input
This section makes a lot of assumptions without explanation.
It is somewhat confusing.
And actually the last 3 sentences make Alternative 1 to be the most ideal But there is a a question, what does the following statement mean?: "..facilitating higher-density housing at appropriate locations".
...What qualifies as "appropriate locations"
E8
Alternative 2 also sounds ideal.
Input
One confusion, it uses the term " redevelopment". The technical term, REDEVELOPMENT was cancelled by the State. So this is a very confusing statement .
Clarify it.
***This statement also makes no acknowledgement that the Quarry can only build residences IF there is a Vote of the People.
**This fact about the need for.a Public Vote for the Quarry must be expressed clearly. The Voice of the Voter's must be protected.
E8
No Project Alternative.
Input
This is confusing & inaccurate.
Again it makes no mention of ths existence of a Voter requirement.
It also alludes to " large sections of Pacifica are designated as 'Special Area'...." And
It states " ...including recent proposals to limit development at the Quarry site..." Both are very confusing statements.
..the GP DREIR need to be transparent.
The requirement that any housing must be allowed only by Public vote is essential. It is true data.
It is in the operative Gen Plan of 1980.
..This other language suggests that " Special Areas" are negative designations.
But they are in the operative Gen Plan 1980, because the Public wanted them. The type of writing must be transparent.
The City must protect and enable the Public Vote, not ignore , negate or circumvent the facts . *** The GP must define what "Special Area" means. List where, what the existing "Special Areas" are in the operative Gen Plan 1980.
E8 Transportation.
...Input
Without traffic being able to.move consistently there wll.be negative impacts. C02 and othee health issues
Input: The 21C Intelligent Traffic Strategies/Signals should be acknowleged to exist and where and their function described.
..The GP should be clear abour the City being proactive about achieving adequate public transportation in, around and through Pacifica. It should require a follow through marketing plan too.
Coastal Concerns.
Input
.. Constant drainage from the coastal ranges must be acknowledged and explained as to how it affects coastal erosion.
..The GP should direct.the City to be responsible in facing planning for potential funding coasts to adjust to coastal erosion and maintenance.
..The GP should direct the City to learn about Insurance best practices and provide that timely imformation to assure comonsense stewardship on the part of City decision makers , planners , tax payers, private property owners and businesses.
E8
Input
Land Use, define "Sphere of Influence and list the sites.
E9
Input
The GP should make clear that there is
..on-going drainage from the coastal range contributes to hillside & coastal erosion ES3
CD-1-14 Design Review.
Input
Where should the present Hillside Preservation District District be noted? ..The updated GP should be clear too and represent the will of the People, OUR Community. ....The GP.update should be clear.like The 1980GP is clear about the importance of Hillsides, ridges , trees and neighborhoods, to our sense of character , who,we are & aspire to be and to our economic sustainability because of it.
Noise.
Input
..NEGATIVE NOISE impacts are HEALTH ISSUES.
...The GP should direct the City to.monitor all.noise causing sources carefully and alert residents & neighborhoods to.pending negative impacts.
..the GP should be clear about negative noise having being a definite HEALTH Hazard ..the GP should clearly address Air flight patterns that can affect residents, historical, large parks, cultural, school and visitor serving areas .
(The FAA was supposed to contact cities regarding such areas prior to agreeing to the NextGen plans. There are no records to show that they did).
New technologies are being researched today for planes ( super sonics, vertical vehicles), and flight plans .
The same for autos and trucks.
..There will be negative environmental impacts to our residents and our visitor serving economy again if GP does not set clear goals to.monitor and be engaged in oversight & accountability. ..our GP should include incorporating up to date equipment to monitor noise measurements and standards that avoid prople from being exposed to negative Health Impacts. .. The GP.should be clear that flights are up.high over Pacifica ,out over the Ocean away from our shores and hills.
Thank
You.
Sue Digre
3 08 2022
4pm
Sorry I have troubles with technology & no.hard copy
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: Pete Shoemaker [ ]
Sent: Thursday, February 17, 2022 1:46 PM
To: Public Comment [[email protected]]
Subject: Fwd: Appreciation and clarification
[CAUTION: External Email]
Begin forwarded message:
From: Pete Shoemaker < >
Subject: Appreciation and clarification
Date: February 17, 2022 at 11:28:55 AM PST
To: "Bigstyck, Tygarjas" <[email protected]>, [email protected], [email protected], "Beckmeyer, Sue" <[email protected]>, "Bier, Mary" <[email protected]>
Councilmembers,
I appreciate your voting for the DEIR review extension on Monday. I feel I have done enough proactive work to warrant you taking time to read my email below.
I want to get past the emotion and see clearly what’s happened over the past month and why it’s important to analyze it.
1. The City issued the DEIR on Jan. 7. It was essentially unusable, not a legitimate document for public review, as we’ve all talked about.
2. People immediately protested, and on Jan. 13 I sent out the video that pointed out the difficulties and showed what needed to be done (how to make an interactive table of contents, etc.).
3. The City, with City Manager as spokesperson, defended the document and repeatedly said that there would be no extension. People’s frustration mounted, and angry emails were sent to Council and staff.
4. I spent hours of my time doing repetitive word-processing to create a workaround document that would be reviewable, and everyone who was trying to do a review was very appreciative.
5. Outside agencies also noted the inadequacies of the DEIR, with Fish and Wildlife asking for an extension, which was denied.
6. Finally, with the support of Council, an extension was granted on Feb. 14, one month after my video.
7. In his remarks before the extension vote, the City Manager casually mentioned that there was a new, upgraded document with interactivity. I’ve looked this over, and it is exactly the format that we’ve asked for all along. The table of contents itself is 12 pages long, including Figures and Tables, reaffirming the complexity of the DEIR and how absurd it is to expect someone to review such a document without an index or ability to search.
8. This document is the first legitimate DEIR the City has issued, therefore the 45-day review period should begin anew on Feb. 14. As it currently stands, with the extension deadline of March 8, the public will have 22 days to review a legitimate document, less than half the legally-required minimum.
Is this in the best interest of the community of Pacifica? Will this help us solve the serious challenges that face us? This is my whole focus.
My questions to you are, "How much staff time did it take to turn the original unusable document into the usable one?"; and “Why was this new document not issued right away instead of 30 days later, losing valuable review time and increasing public frustration, mistrust and socalled “staff abuse”? Word-processing software is set up to automatically produce an interactive TOC, as I showed in my video. I know that the DEIR was set up that way because in that ill-advised “fix” when they put out the 23 separate Word files, you can see it. You can open any of those files, put the cursor at the beginning, then click on the TOC menu and a fully interactive TOC will appear. I know that I could have created that new DEIR in less than an hour, because I did it the hard way in about 8 hours. Why did it take staff 30 days?
Someone, and all signs point to the City Manager, made a decision to defend the original mistake instead of admitting it and correcting it right away. They prioritized saving face over the greater good of the community, causing anger and polarization in the community and embarrassing us to other cities and agencies. And THAT’s why I’m going on about this. Because it’s very likely that this will continue to happen unless this person is held responsible.
Sincerely,
Pete
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From: Christine Boles [ ]
Sent: Sunday, January 16, 2022 12:38 PM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]
Subject: Fwd: Fire Risk and Pacifica's General Plan
Attachments: NOA - Distribution List - 20220110.pdf
[CAUTION: External Email]
Sending this in as an official comment since it was already forwarded to you and City Manager Woodhouse.
---------- Forwarded message ---------
From: Christine Boles < >
Date: Fri, Jan 14, 2022 at 12:06 PM
Subject: Fire Risk and Pacifica's General Plan
To: < >, James Kremer < >
Good afternoon Deputy Chief Kavanaugh,
I'm copying my colleague, James Kremer, a Pacifica Resident and Doctor of Science, on this email as he has also done a lot of research on Pacifica's fire risks as part of last year's San Mateo County Local Hazard Mitigation Plan update.
Thank you so much for speaking with me yesterday. I was very surprised that you mentioned not having seen any draft documents of the General Plan Safety Element cross your desk since you started work in this position about a year and a half ago (did I get that right?). The City specifically lists the North Coast Fire District as one of the key stakeholder agencies.
I actually got a hold of the Planning Department's Distribution list for the General Plan and strangely North County Fire is not on it...see attached. I've just emailed Christian Murdock and Kevin Woodhouse to see if this might be an oversight.
In terms of the fire maps I mentioned yesterday in the Safety Element, here is the current map from the recently released General Plan, which seems to only show fire danger in state responsibility areas.
And here is the map from the previous 2014 draft Safety Element that seems like it actually has real data, though it seems somewhat dated from 2004/2009 based on the source information at the bottom. Is this current data?
I am guessing that the city realized that Cal Fire is updating maps for LRA areas as you said, but instead of using current maps and adding a note indicating that they should be updated when they are available from Cal Fire, they mistakenly neglected to include any information...
This obviously needs your department's input as soon as possible as it affects other sections of the General Plan, like the Land Use Element, which identifies potential land uses and areas of growth. I believe these will need your agency's detailed review as well. How can we start to plan for growth without first understanding our hazards?
Would you, or someone at Cal Fire be able to help us understand what the focus of the LRA updates are and get an opinion of what type or degree of changes to the current Pacifica data/maps might be likely given the increasing drought conditions? If there is something that may well alter the Pacifica maps in a substantive way, we may need to add some policy statements added to the General Plan.
If your department is feeling overwhelmed with reviewing Pacifica's 1000 page EIR and other General Plan documents in the remaining 39 day period, then I'd encourage you to make that known right away to Mr. Murdock. Other agencies may have similar issues.
For example, if you're not up to speed/sufficiently aware due to major processing time gaps, and thereby need more time to get up to speed and review, you could request time extensions. Perhaps the pandemic's effect on your own staffing and resource availability also makes this short review process difficult.
Jim and I would love to speak with you further once your agency has had a chance to look over and digest some of this information.
Thank you so much for your service to our town! I know you are looking out for our safety as well as that of your firefighters!
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“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
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Agency/Individual Street Address 1 Street Address 2 City State ZIP Email Association of Bay Area Governments 375 Beale Street Suite 800 San Francisco CA 94105-2066 AT&T [email protected]
Bay Area Air Quality Management District 375 Beale Street Suite 600 San Francisco CA 94105 [email protected] California Coastal Commission 455 Market Street Suite 228 San Francisco CA 94105 [email protected] California Department of Fish and Wildlife (Bay Delta Region) 2825 Cordelia Road Suite 100 Fairfield CA 94534 [email protected] California Department of Transportation (District 4) P.O. Box 23660 Oakland CA 94623-0660 [email protected] California Department of Toxic Substances Control 1001 I Street Sacramento CA 95814-2828 California Governor's Office of Planning & Research 1400 Tenth Street Sacramento CA 95814 City and County of San Francisco (Planning Department) 1650 Mission St Unit 400 San Francisco CA 94103 [email protected] City and County of San Francisco (Recreation and Parks Department) McLaren Lodge 501 Stanyan Street San Francisco CA 94117 [email protected] City of Daly City (Economic and Community Development Department) 333 90th Street Daly City CA 94015 [email protected] City of Half Moon Bay (Community Development Department) 501 Main Street Half Moon Bay CA 94019 [email protected] City of San Bruno (Community and Economic Development Department) 567 El Camino Real San Bruno CA 94066 [email protected] City of South San Francisco (Economic & Community Development Department) 315 Maple Avenue South San Francisco CA 94080 [email protected] City/County Association of Governments 555 County Center 5th Floor Redwood City CA 94063 [email protected] Comcast 153A Serramonte Ctr Daly City CA 94015
County of San Mateo Planning & Bldg. Dept. 455 County Center 2nd Floor Redwood City CA 94063 [email protected] County of San Mateo Parks Department 455 County Center 4th Floor Redwood City CA 94063-1646 [email protected] County of San Mateo Public Works Department 555 Bradford St. Redwood City CA 94063 [email protected] Federal Aviation Administration (Western-Pacific Region) 777 S. Aviation Blvd. Suite 150 El Segundo CA 90245 Golden Gate National Recreation Area Fort Mason Building 201 Upper Fort Mason San Francisco CA 94123 Jefferson Union High School District 699 Serramonte Blvd. Suite 100 Daly City CA 94015 [email protected] Lozeau Drury LLP 1939 Harrison Street Suite 150 Oakland CA 94612 Metropolitan Transportation Commission 375 Beale Street Suite 800 San Francisco CA 94105-2066 National Marine Fisheries Service (West Coast Regional Office) 1201 Northeast Lloyd Portland OR 97232 North Coast County Water District 2400 Francisco Blvd. Pacifica CA 94044 [email protected] Pacific Gas & Electric 275 Industrial Rd. San Carlos CA 94115 Pacifica School District 375 Reina Del Mar Pacifica CA 94044 [email protected] Recology 2305 Palmetto Ave. Pacifica CA 94044
San Francisco Bay Regional Water Quality Control Board 1515 Clay St Suite 1400 Oakland CA 94612 San Francisco Public Utilities Commission 525 Golden Gate Avenue San Francisco CA 94102 [email protected] San Mateo County Airport Land Use Commission 555 County Center 5th Floor Redwood City CA 94063 [email protected] San Mateo County Clerk 555 County Center Attn: Special Services Redwood City CA 94063 San Mateo County Mosquito and Vector Control District 1351 Rollins Rd Burlingame CA 94010 [email protected] San Mateo County Office of Education 101 Twin Dolphin Drive Redwood City CA 94065-1064 [email protected] San Mateo County Transit District (SAMTRANS) 1250 San Carlos Ave. P.O. Box 3006 San Carlos CA 94070-1306 San Mateo County Transportation Authority 1250 San Carlos Ave. P.O. Box 3006 San Carlos CA 94070-1306 [email protected] United States Coast Guard (Commander, 11th District) Coast Guard Island Building 52 Alameda CA 94501-5100 [email protected] US Army Corps of Engineers (San Francisco District) 450 Golden Gate Ave 4th Floor San Francisco CA 94102 [email protected] US Fish and Wildlife Service 650 Capitol Mall Suite 8-300 Sacramento CA 95814 [email protected] From: Woodhouse, Kevin [[email protected]]
Sent: Tuesday, January 25, 2022 6:37 PM
To: Murdock, Christian [[email protected]]
Subject: Fwd: GP, SPSP, DEIR
Comment to log.
Kevin
From: Woodhouse, Kevin <[email protected]>
Sent: Tuesday, January 25, 2022 6:36:14 PM
To: Stan Zeavin < >
Subject: Re: GP, SPSP, DEIR
Thx Margaret, I understand your perspective, but engaged citizens began reviewing and commenting immediately upon release of the documents Jan 7.
I've cc'd Christian Murdock here to log your comment.
Kevin
From: Stan Zeavin < >
Sent: Tuesday, January 25, 2022 6:28:44 PM
To: Woodhouse, Kevin <[email protected]>
Subject: Re: GP, SPSP, DEIR
[CAUTION: External Email]
Thanks, Kevin.
When all accessible tools are finally at hand, that would be the appropriate time to BEGIN a public review period for engaged citizens who wish to perform their civic duty.
Margaret Goodale
On Tuesday, January 25, 2022, 03:24:54 PM PST, Woodhouse, Kevin <[email protected]> wrote:
Stan, please know that the City has made the Microsoft Word versions available on the website, PlanPacifica.org. I announced this last night at the City Council meeting. You can download chapters quickly, search or cut and paste to your heart’s content, ultimate accessibility. We’ve also begun making the PDF Table of Contents of the GP and SPSP interactive. Just wanted you to be up to date. You may want to listen to my statement form last night, available on the meeting recording on YouTube.
Kevin
From: Stan Zeavin < >
Sent: Tuesday, January 25, 2022 2:39 PM
To: [email protected]; Bigstyck, Tygarjas <[email protected]>; Vaterlaus, Sue <[email protected]>; O'Neill, Mike <[email protected]>; Beckmeyer, Sue <[email protected]>
Cc: Woodhouse, Kevin <[email protected]>; Wehrmeister, Tina <[email protected]>; Clay Lambert <c >
Subject: GP, SPSP, DEIR
[CAUTION: External Email]
Honorable Mayor and Council,
In 2014, I sat at a round cafeteria table at IBL along with many other people at that and other tables who were there to discuss the new draft General Plan. If you read a little way into the current set of plans you may have noticed a photo of me at that meeting. In 2014, however, far less information was available about the climate and ocean conditions that seem suddenly to be upon us. Many of us who attended that meeting are paying even better attention now as we see more of the effects of these changes.
If you have bothered to read the current documents released late Friday night January 7, you encountered the same problems of inaccessibility that we did. If you did not immediately give up, you no doubt share the frustration experienced by those of us attempting to understand how Pacifica will respond to the very real challenges of the future.
Does it matter to you that attempting to search for or correlate topics in the DEIR to the GP without even a table of contents, becomes ridiculously complicated? How were you able to fully understand the differing references and source dates between the GP, SPSP and the DEIR?
I ask that you show some respect for the citizens who elected you and do not breech their trust. If you force staff to meet your artificial timeline and goal, you have betrayed all of us as well as future Pacificans.
Council, you can still fix this impossible situation and allow staff to do their best work. • Cancel the 45 day public review period.
• Reorganize the DEIR with a table of contents.
• Make it searchable.
• Cross-check the dates for the most current studies.
• Give staff time to make the documents accessible then rerelease them.
PLEASE consider the concerns of those of us who love Pacifica and want the best for us all.
Sincerely,
Margaret Goodale
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From: Vicki Sundstrom [ ]
Sent: Tuesday, March 8, 2022 4:36 PM
To: Public Comment [[email protected]]
Subject: Fwd: Pacific DEIR review
Attachments: Pacifica DEIR.pdf
[CAUTION: External Email]
Comments on Pacifica's DEIR.
Regards,
Vicki
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March 4, 2022
Christian Murdock
Deputy Planning Director
City of Pacifica,
Regarding - Pacific DEIR – SCH 2020089010/2012022046
Dear Mr. Murdock:
Enclosed please find my comments, notes and feedback on the Pacifica’s DEIR with respect to the General Plan Update.
1. Based on page 1-3 of Plan Pacifica DEIR, the existing condition and key issues report was published in July 2010. It is not clear in reviewing the DEIR if or when the existing conditions, specifically traffic and parking data and related analysis were updated to 2019 (pre-pandemic) conditions. Please clarify which portions of the report have accounted for the traffic & parking growth through 2019 and if mitigation measures are based on 2019 conditions.
2. E-13: Design guidelines are referenced. The design guidelines found on the Pacifica website dated 1990 are obsolete and have not served Pacifica well. Additionally, the guidelines do not reference standards or codes. They could, in lacking specificity, contribute to engineering and environmental compliance issues.
3. There is an error in the DEIR with respect to growth in the housing units. At the San Mateo County Housing seminar (April 2021), both you and Josh presented housing growth requirement of 1892 units. Whereas the DEIR indicates 990. Please clarify which is correct.
Also please explain where this growth is planned for if this document is to take us into 2040.
With respect to the circulation element -
4. See appendix A, a table prepared based on Caltrans traffic census. While the population in Pacifica has grown by 3%, traffic has grown from 13% to 57%. The DEIR clearly indicates existing conditions based on 2010. Given the substantial growth in traffic volumes, any traffic analysis, conclusions and mitigation measures are not usable.
5. Traffic intersections included in the DEIR address the intersections along highway 1 but there is no analysis for any local streets in Pacifica. Local intersections are experiencing increasing congestion, some meriting traffic (signals and signs) warrant analysis. The traffic roadway system, as a whole, is failing to deliver adequate level of service – with or without the project.
6. Given that community engagement meeting for the General Plan took place in 2009, the community in current day Pacifica was not engaged in the cirulation element to discuss the priorty of addressing the traffic and related safety concerns in Pacifica. Please explain how this will be rectified.
7. The deterioration of many Pacifica local street has effectively lowered the capacity and level of service. This too is not accounted for in any analysis based on 2010 “existing conditions”.
Please explain how this will be accounted for.
8. See Appendix D, please explain why existing condition level of services have changed with 4/21 & 2/22. Also please explain why locations have changed.
9. Implementation of complete
streets and mode shift to bicycles
require additional study before
being included in these
documents. Implementation of
‘complete streets’ to support mode
shift to bicycle usage is not a
viable congestion management
solution for Pacifica. Given: - Pacifica terrain and lack of local roadway network
connectivity between
communities will not allow for
enough of a mode shift to
allow any significant improvements
to traffic congestion. - Unless Pacifica wishes to implement an e-bike program, bike mode shift is
only successful on flat terrains for
rides within 7 miles or 20 minutes. - Implementation of complete streets (separate bike facilities specifically),
while admirable, will contribute to
substantial roadway capacity issues
on many Pacifica streets. And it will
result in inadequate emergency access on some streets. - Between on-street parking, bike lanes and existing traffic, traffic congestion will increase and further impact evacuation/emergency response routes. - On-street parking and dedicated bike facilities are not compatible – cities that have implemented bike facilities safely and successfully have done so by eliminating bike parking or providing substantial buffers to separate the two.
10. With respect to the complete streets design approach, LOS must be maintained or improved while implementing complete streets. Guidelines and standards as implemented by the State of California or better are to be utilized in the implementation of the program.
11. Between visitors and increased car
ownership, Pacifica on-street
parking utilization has increased.
Visitor parking in private lots (Taco
Bell, Grocery Outlet etc) has also
increased. The data provide does
not account for the overflow of
parked vehicles into residential
area or vice versa. Conduct a
parking utilization studies to review
on-street & off-street (private and
public) parking capacity and
utilization. Account for future
growth into 2040. Plan for
displaced parking and parking
growth in each Pacifica
neighborhood.
12. With respect to Congestion Management Program & Transportation Demand Management– - Pacifica lacks a Congestion Management Plan, as required by the State and the County.
Pacifica has not observed required traffic analysis in the permitting process to understand congestion attributed to any development or change. Nor does Pacifica conduct traffic counts or analysis to understand traffic changes. All of which add to not having any measures in place for such a program – which ultimately is why Pacifica continues to see unmitigated traffic growth/congestion. - Transportation Demand Management goals and objectives are based on roadway system capacity, existing demand, and project related growth. The municipality must establish the goals (percentage trip reduction in general and during peak periods, parking rations), it is up to the project or business to develop programs that meet the required goals. Traffic impact fees are assessed on any trips over the established goal.
The programs do not work without clearly defined goals (trip reduction), overage fees and monitoring. - Given the roadway capacity constraints and limited financial resources available to Pacifica to address said constraints, all projects (non residential, residential, schools, churches etc) should be subject to some transportation demand management measures, parking ratios and traffic impact fees. - Monitoring is required by the State. Implement traffic count and speed monitoring programs via intelligent transportation technology.
San Mateo County CMP 2021
- Free parking is the biggest deterrent to Transportation Demand Management Programs and should be considered as an option both for Congestion Management and Economic Development. - Stated TDMs options read like a textbook of available strategies rather than targeted policy to meet objectives. Please provide targeted strategies appropriate to our community and identify programs based on type of property (residential, commercial, etc)
13. Circulation element – How does the city plan to reduce congestion on roadways before reducing roadway capacity to implement complete streets?
14. Before subjecting Commuter Trip Reduction programs expenses onto employers in Pacifica, please quantify how many people commute long/er distances to Pacifica and would use said programs. Also quantify how many of these jobs can be done remotely. These programs appear to add cost to doing business in Pacifica without any real impact to congestion.
15. Given that the Sharp Park Specific Plan related community meetings were limited to Sharp Park, the items stated below should be addressed with the greater Pacifica as it relates to all of Pacifica.
16. At the time the GPU/DEIR were issued for review (3/2022), Pacifica is looking at a budget shortfall for a few years to come, has paid fines for sewer spills, and is looking at increasing sewer rates. The City of Pacifica did not have the funds to adequately prepare this report with current data. Pacifica cannot financially accomplish much of what is stated in this report, including addressing any of the hazards we have, with or without the project. Any development in hazardous areas should include policy to hold the City of Pacifica harmless for loss of life should hazards occur. Developer, realtors and homeowners in the new developments should fund safety and maintenance programs.
17. Any policy that limits access to the coast by residents, please explain how the City will work with the residents to address access issues.
Fire response/Safety
18. Evacuation routes/Implementation of the Proposed Project would not result in adequate emergency access. With or without project, there is inadequate emergency access in Pacifica unless all the roads are cleared (see 8/21/2022 press release). While clearing the road may have been an option during the pandemic, it will not also be possible. Also clearing the roads for emergency access would prohibit evacuations. The planned update does not address existing (2022) reality, nor does it address 2040 conditions
19. Fire map discrepancies
There are discrepancies between the fire risk maps in these documents and those published by the state and PGE. They have been provided in Appendix C. Please explain. How will this be rectified?
20. Why does the map fire risk map shown in the Pacifica documents only show in color the state owned risk areas?
21. Please elaborate on how response time will be improved. This should be accounted for in this GPU and DEIR. Without addressing this concern, there is a significant impact to emergency response from this project and related development.
22. Conservation Element, Wetlands
Preservation – implement citywide
policy to train staff to recognize
wetlands. Implement policy and
fines in support of preservation.
23. There is not enough information in the DEIR or GPU to substantiate that the implementation of the proposed project would not interfere with the movement of wildlife. Please explain how the sea wall planned at Sharp Park impacts sea life. Given that the existing conditions are from 2010 and much has changed, please explain how existing conditions will be addressed.
24. May policies (examples below) are ambiguous and require further definition. Actions such as “support”, “work with”, “continue coordination” have left us with a community that is sitting in traffic and please be specific. What action, to accomplish what and the timeline. I recently spoke to Sam Bautista about the Manor Bridge repairs and he gave me CalTrans schedule but the traffic is bad and continues to get back and there are no interim measures for at least the next 4 years – that kind of “coordination” really doesn’t fix anything. Please also provide clarity on how much funding is required and realistically what can and can be accomplished based on Pacifica’s finances. Use SMART methodology to clearly define objectives.
Examples from San Luis Obispo –
Please let me know you’d like to discuss any of these comments further.
Regards,
Vicki Sundstrom
Appendix A
Appendix B.
Appendix C
Posted on Pacifica website – 4/2021
In DEIR
Discrepancies in analysis for the
same locations. Also one location
has been eliminated.
Appendix B
Appendix C –
Map discrepancies in risk areas.
San Mateo County
PGE
Pacifica DEIR/GPU
San Luis Obispo – TDM policy and monitoring program
Belmont – Residential TDM
From: Necesse [ ]
Sent: Tuesday, January 18, 2022 3:08 PM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]
Subject: General Plan and DEIR comments
[CAUTION: External Email]
General Plan Draft
Area of Concern: 7-35 identifies increased wildfire risk. 8-35 identifies responsibility. Figure 8-7 maps State Responsibility Areas.
Comment: The City of Pacifica should include a map of our own high risk zones in the General Plan and formulate a long term plan for homeowners to create defensible space to increase the chances of successfully protecting life and property. Currently, there are large groves of unmanaged eucalyptus trees and areas with dead, diseased and dying trees and vegetation. These areas cannot be accessed by fire engines or firetrucks and hoses must be connected and carried down hills. The lack of accessibility to these sites threatens life and property. From what I see in the General Plan draft and associated policies in the DEIR, there is no plan to address this other than NCFA education and outreach: in the 25 years I have lived here, NCFA nor the City of Pacifica have addressed the eucalyptus groves in my neighborhood nor required the property owner to create defensible space. One unmanaged property creates risks for larger geographic areas. The City places this burden on adjacent homeowners to go after neighbors civilly and requires expensive arborist reports from residents who have concerns (email between Erin Macias and the City of Pacifica on file.) The absence of a plan to address these high risk conditions is evident in the General Plan Draft and in the language found in the DEIR on pages E-136 through E-140.
Area of Concern: 8-37 identifies areas within Pacifica that are a challenge for fire response.
Comment: This is based on a 14 year old study. This study does not consider the volume of new homes and built south of the tunnel and more commuters added to our roadways. It also does not factor in the rapidly growing and unmanaged groves of eucalyptus trees. The Tom Lantos Tunnel was opened in 2013. The traffic after opening the new tunnel increased dramatically in the past 8-9 years and the challenge for fire suppression has changed.
Area of Concern: DEIR Wildfire: CI-G-7 Congestion on Highway 1.
Comment: There is no avoiding the congestion as the vote was taken and the road cannot be widened and we have no control over the volume of development south of Pacifica. “Strive for the greatest benefit with the least environmental impact possible” does not provide the plan, framework, or identify the possible impact. This does not factor in the tunnel’s impact on congestion since the study and the steady increase in commuter traffic with more development south of Pacifica. What can be done to the existing infrastructure and Sweeney Ridge trail systems to create an emergency evacuation route? The connection between the trail system and certain residential streets would provide for weekend/holiday use of a recreational path so residents and visitors can walk or bike into Pacifica without the need for cars while at the same time offering a much needed evacuation route. The environmental impact of paving an existing trail would be minimal.
Area of Concern DEIR Wildfire: CI-I-15 Strategies to Reduce School Related Peak Hour Auto Congestion Comment: staggering times does not eliminate congestion, it increases the length of the congestion along SR1. The only solution to reduce school related peak hour auto congestion is to work with the PSD and JUHSD to adopt a formula for neighborhood schools where residents within a specific radius of a school campus are guaranteed enrollment into that school (so they can walk and bike to school, thus eliminating commuting by car entirely.) The auto congestion from school related traffic is a direct source of air pollution (gas powered vehicles) and also Toxic Air Contaminants (diesel work trucks used to commute students) as identified in table 3.3-4 on page 3.3-12 and 3.3-13 Staggering traffic does not do anything to relieve the congestion problem on SR1 in the event of a wildfire during these peak hours, it only exacerbates the problem.
The Environmental Impact of an inadequate Wildfire section in the General Plan is concerning and includes but is not limited to loss of life for humans and animals, loss of habitat for humans, wildlife including protected and endangered species, contaminated soil, contaminated water (ocean, ground, creeks, marshes/wetlands, and the San Pedro Watershed overall,) air pollution, and other permanent consequences too lengthy to list here.
The DEIR says to simply update the Emergency Plan without any specific language as to what that entails. Please provide me with a copy of the existing emergency plan pertaining to wildfires in the City of Pacifica.
Erin Macias, Linda Mar
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From: Rick Nahass [ ]
Sent: Sunday, January 30, 2022 5:14 PM
To: Public Comment [[email protected]]; _City Council Group [[email protected]]; Coffey, Sarah [[email protected]]; Bier, Mary [[email protected]]; Bigstyck, Tygarjas [[email protected]]; Vaterlaus, Sue [[email protected]]; O'Neill, Mike [[email protected]]; Beckmeyer, Sue [[email protected]]
Subject: General Plan and DEIR Public Comments Jan 30
Attachments: DEIR_GP_PublicCommentsNahass2022_01_30.docx [CAUTION: External Email]
Dear Christian Murdock and Pacifica City Council Members, Please find attached my preliminary public comment on the Pacifica Draft EIR and General Plan.
Regards,
Rick Nahass
, Pacifica, CA 94044
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January 30, 2022 DEIR General Plan VMT Public Comments RN 1 To: DEIR Public Comments, Pacifica City Council
From: Rick Nahass, , Pacifica
Subject: DEIR General Plan VMT Public Comments
Thanks for providing the DEIR in word format, I can now copy/paste directly from the DEIR content instead of re-typing. Please find my comments below:
There are two problems regarding transportation in the DEIR: (a) there are no details on how the elements/bullets (e.g., CI-I-13) were determined and used to calculate changes to Vehicle Miles Travelled (VMT) and (b) those calculations ONLY include “Land Use” and not “Circulation” elements. See the highlighted items table below from the General Plan-Sharp Park Draft EIR - 4 Alternatives section.
Table 4.2-3: PACIFICA VMT METRICS BY SCENARIO
Alternative No Project1Preferred2 Alternative 1 Alternative 2 Home-Based VMT 576,861 (-6.1%) 617,804 (0.5%) 607,896 (-1.1%) 619,281 (0.8%) Population 40,154 (3%) 42,887 (10%) 42,314 (8.6%) 42,457 (8.9%) VMT/capita 14.37 (-8.9%) 14.41 (-8.6%) 14.37 (-8.9%) 14.59 (-7.5%) HBW VMT 148,982 (42.5%) 160,884 (53.9%) 142,074 (35.9%) 145,772 (39.5%) Employment 7,264 (24.4%) 7,316 (25.3%) 7,317 (25.3%) 6,550 (12.1%) HBW VMT/emp 20.51 (14.6%) 21.99 (22.9%) 19.42 (8.6%) 22.26 (24.4%) * numbers in the brackets indicate percent growth or reduction compared to the 2015 baseline. 1 2Reflects Proposed Project Update
Source: C/CAG 2020 Travel Demand Model, C/CAG and DKS Associates, 2021.
Pacifica has no formal Transportation Demand Management (TDM) Program but relies on the San Mateo County Congestion Management Plan (CMP) which is late in transitioning to VMT per Senate Bill SB 743, which was required to happen by July 2020.
Once Pacifica does create separate TDM Program documents then VMT should be used as the primary metric for evaluating and prioritizing action. Both LOS and VMT in the DEIR serve the purpose of highlighting the state of traffic congestion on state route 1 in Pacifica.
Formally Pacifica TDM currently rolls up to the San Mateo County 2040 TDM where the following bullets on page 121 “Proposed RTP Projects” mention Pacifica [my commentary in brackets]:
• Manor Drive Overcrossing Improvement and Milagra On-Ramp Project – [RickN - Also partially mentioned in Pacifica Bike and Ped Plan]
• Route 1 San Pedro Creek Bridge Replacement and Creek Widening Project - [RickN - this was already done but remains as a proposed project. Might a pedestrian underpass be added for safely traversing under state route 1 as a project in a Pacifica TDM] • Palmetto Avenue Streetscape Project
January 30, 2022 DEIR General Plan VMT Public Comments RN 2 • Construct Route 1 (Calera Parkway) northbound and southbound lanes from Fassler Avenue to Westport Drive in Pacifica – [RickN - This was part of the Caltrans state route 1 widening proposal which was turned away by citizens. It’s good that it is STILL on the County TDM 2040 plan, because we might still be able to have Caltrans convince the citizenry to either widen or reconfigure the busiest intersections in Pacifica according to US DOT and Caltrans, Vallemar and/or Rockaway, based on sound VMT metrics.] The following are suggested General Plan changes that should be referenced in the DEIR.
General Plan Section 5.1 Circulation Framework
TDM is mentioned in the General Plan, but no action/element/policy calls out for the creation of a separate TDM plan. Add the implementation policy element:
• CI-I-x Transportation Demand Management Program. Formally establish a comprehensive Transportation Demand Management (TDM) program that reduces Vehicle Miles Traveled (VMT)/Single-Occupant Vehicle trips by supporting transit and improves the safety and mobility for Pacifica residents, businesses, and visitors by recommending a suite of projects, policies, and programs to address current and future transportation conditions.
The above policy should also be included in Section 4 Land Use. Some details might be included, for example other cities require every new development project to consider VMT. For single residents it might be “not applicable” with a check box, but for larger multi-unit sites, depending on size, the ask for providing VMT impact might increase.
General Plan Section 5.2 Existing Travel Patterns
Add the implementation policy element:
• CI-I-X Equitable and Accessible Public Transit Develop and document a breakdown of public transportation usage by paratransit riders and those that cannot drive (elderly, students, low income, etc.) Include the relationship between who depends on transit vs who if anyone uses public transit, because they choose to not use other forms of transit.
General Plan Section 5.3 Roadway Network and Planned Improvements The EIR and General Plan should specifically state that all off and on ramps (arterial roads) to state route 1 are vehicle prioritized and should be upgraded to provide bicycle and pedestrian safety. There are issues with the following statement because it omits on/off ramp safety • (also in DEIR Page 3-2 Arterials) “Along certain arterials, notably Palmetto Avenue, Esplanade Avenue, and sections of Oceana Boulevard, Paloma Avenue and Manor Drive, the pedestrian environment is prioritized”
o The most evident example of this omission is in the recommendation on pages 61 and 87 of the Pacifica approved Bicycle & Pedestrian Master Plan (Feb 2020) for reconfiguring the Palmetto Avenue Highway 1 ramp and crosswalk.
January 30, 2022 DEIR General Plan VMT Public Comments RN 3 General Plan Section 5.4 Pedestrian and Bicycle Network Add the implementation elements:
• CI-I-XX Reconfigure the State Route 1 Palmetto South on Ramp near the Milagra overpass to allow safe bicycle and pedestrian crossing (e.g., hard left and right turns and stop signs before entering the highway)
• CI-I-XX Connect and maintain bicycles and pedestrian trails from Linda Mar to the Mori Point trail ending at the Devil’s slide trail to create a seamless connection to the midcoast trails south. This allows bicycles and pedestrians to bypass the narrow road leading to the tunnels south.
General Plan Section 5.5 Public Transportation and Demand Management There should be separate elements for local vs regional public transportation. SamTrans is responsible for operating local public transit, and the Metropolitan Transit Commission (MTC) is responsible for ‘facilitating’ regional bus transit.
Update element CI-I-50 Transportation Demand Management to use VMT metrics and thresholds or to wait until the CMP migrates from LOS to VMT, because all agency calls for project transit, environment and land use funding in California will be prioritized based on VMT.
Also consider moving this element to the General Plan Section 5.1 Update the following element with the highlighted text:
• CI-G-17 Improved Public Transit. Advocate for SamTrans locally, the MTC regionally and other public transit providers to improve transit service and facilities, to enable trips to be made without use of a car. In particular, advocate for the expansion of public transit services and facilities to improve public access and recreation opportunities along the coast.
Current law, SB 743, calls for “land use and transportation planning decisions and investments that reduce vehicle miles traveled (sic VMT) and contribute to the reductions in greenhouse gas emissions required in the California Global Warming Solutions Act of 2006 (Division 25.5 (commencing with Section 38500) of the Health and Safety Code). Similarly, the California Complete Streets Act of 2008 (Chapter 657 of the Statutes of 2008) requires local governments to plan for a balanced, multimodal transportation network that meets the needs of all users of streets, roads, and highways for safe and convenient travel.” The text goes on to prioritize qualification for VMT as “within one-half mile of a major transit stop or high-quality transit corridor included in a regional transportation plan.” And provides this definition “a highquality transit corridor means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.”
Assuming DEIR VMT calculations are based on the proximity of the population to BART and Caltrans (both high-quality transit corridors), the biggest impact to reducing VMT in the DEIR Land Use and Housing and Alternatives sections would be to add the Add the following element to the General Plan with references in the DEIR:
January 30, 2022 DEIR General Plan VMT Public Comments RN 4 • CI-I-xx Regional Coastside Bus Corridor Request from the MTC priority to facilitate and prioritize the establishment of a high-quality regional bus corridor on state route 1 from Half Moon Bay into Marin County in compliance with Senate Bill SB 743. Interpret weekend congestion hours as included in the SB 743 definition of “commute hours.” An additional transit element should be added for Shuttles on Sharp Park Road should a transit corridor be eventually established:
• CI-I-xx Sharp Park Road Public Transit. Work with the SMCTA to support and promote direct bus/shuttle routes on Sharp Park Road east to Skyline College, Caltrain, San Bruno/SSF BART and SFO Airport.
And finally, not related to Circulation…
General Plan Section 7.5 Energy and Greenhouse Gases
Add the following element on Solar Power to the General Plan:
CO-I-xx Encourage Solar and Renewable Battery Storage. Promote the use of battery storage for local renewable energy generation, such as solar, where energy generation exceeds immediate need. Support and promote technologies, such as power sharing via micro-grid, introduced by public utilities (e.g., PGE) and other public and private entities.
From: Necesse [n ]
Sent: Tuesday, January 18, 2022 11:36 AM
To: Murdock, Christian [[email protected]]
CC: Public Comment [[email protected]]
Subject: General Plan and DEIR
[CAUTION: External Email]
Area of Concern: Creating a New Civic Center p.6-32
Comment: The impact of creating a New Civic Center contradicts the General Plan to develop affordable housing and affordable rental units (page 4-16) because the cost will be passed on to the taxpayers in the form of bonds or other means of taxation, the result is higher rents and less affordability in the City. A centrally located Civic Center further has a direct environmental impact as it increases air pollution by creating additional traffic that also exacerbates ingress and egress in Pacifica during an emergency. It also risks disruption to all city services and risks major loss of records in the event of a natural disaster event such as an earthquake, tsunami or fire. All your eggs in one basket is not a good strategy.
Area of Concern: Implemented policies Linda Mar regarding expanding the Pacifica Community Center (p.3-5) and Creating a New Civic Center (p.6-32)
Comment: there is no update to the general plan that recognizes or plans for the modernization within its existing footprint for the least environmental impact. Expanding implies extending use of the Community Center parcel outside the building footprint. Expanding the Community Center to add a park and more recreational outdoor space creates more traffic, parking problems, and directly impacts the adjacent wetlands with litter and trespass onto environmentally sensitive areas. There is a need to maintain these existing buildings and modernize them so services are fairly and evenly distributed across the city providing equitable access to all residents. The suggestion to include a teen center adjacent a wetlands has a negative environmental impact as the skate park does now. The litter generated and blowing around the parking area and in the wetlands is an ongoing problem. The need to commute to a centrally located facility generates pollution, affects traffic and contributes to the concerns of ingress and egress in an emergency and cuts off critical services to our most vulnerable populations.
Erin Macias, Linda Mar
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From: Christine Boles [
Sent: Thursday, January 20, 2022 12:12 PM
To: _City Council Group [[email protected]]; Berman, Lauren [[email protected]]; Godwin, James [[email protected]]; Leal, David [[email protected]]; Nibbelin, John [[email protected]]; Hauser, Samantha [[email protected]]; Ferguson, Alex [[email protected]]; Domurat, George [[email protected]]; Murdock, Christian [[email protected]]; Woodhouse, Kevin [[email protected]]; Wehrmeister, Tina [[email protected]]; Public Comment [[email protected]]
Subject: General Plan and EIR data inconsistencies and review difficulties [CAUTION: External Email]
Good morning City Council and Planning Commission Members and City Staff, I am aware that Pete Shoemaker recently sent you all an enlightening video about the issues many of us are having in accessing and reviewing the General Plan documents. There were also a few comments at Tuesday's Planning Commission hearing during oral communications that Council Members might want to listen to as well. I hope there will be more clarifying information forthcoming by next Monday's Council meeting.
On Sunday, I actually spent three hours trying to understand one issue related to climate change and greenhouse gasses that is of great interest to me. I documented my process below to give you a glimpse into how difficult this work is.
I’m having trouble ascertaining whether the city is using up to date scientific data, so I thought to research one item, Greenhouse gasses (GHD) as that is one section that the city identified as needing to be updated. In fact the Bay Area Air Quality Management District, BAAQMD, commented during the NOP about this in particular, see image below.
This was my morning for the last few hours…
The EIR has a Bibliography, let’s see what it says.
Chapter 6, oh look, it lists the documents referenced and even provides links, how helpful! Scroll for BAAQMD, huh? only one document from 2010, a source inventory…no mention of the documents required in the letter.
Ok, well, let’s look at the source inventory. Darn the link does not work. Go through a BAAQMD internet search and find the current document. What’s the date? Published in 2014 from 2011 data.
https://www.baaqmd.gov/about-air-quality/research-and-data/emission-inventory/climateforcing-pollutants So, the Bibliography is wrong, but maybe the GP is right. I go to the GP to see what it says.
From the index it looks like chapter 7-5 Energy and Greenhouses gasses might be right. Scroll scroll scroll…
Got it. Read it, it’s short! Still looking for references to 2017 documents, don’t see anything about the Clean Air Plan here either…
Ok, let’s look for BAAQMD’s Source inventory of Greenhouse Gas Emissions. Here it is in the first paragraph. What date did they use?
The first paragraph on 7-35 mentions 2008, wait, that’s old.
The next page mentions inventory reports through 2017, good…ok this refers to BAASQA’s report 2014(from 2011 data) Good that’s current, maybe they just forgot to update the first paragraph and the bibliography, keep reading, it is a short section after all.
Ok, on the last page, the table at the bottom also refers to a BAAQMD study; what is it and when was it done? Hmm, it doesn’t say…but wait, the heading describes it as data from 2006! I’m ready to give up…wait I’ve come this far, let’s try to see this through. Ok, maybe the General Plan is just not updated for Greenhouse Gas Emissions, but surely the correct information is in the EIR. Let’s look at the index of the EIR and see if we can find that section.
Oh wait, there is no index…
Scroll scroll…
Wait, I’m so lucky, one of my friends actually made a rough index of the 1013 page DEIR with page numbers for me - I actually have an advantage that other residents and agencies don't have - I have to figure out how to share this with the public, maybe tomorrow...
??? Maybe chapter 3? Impacts and Mitigation Measures Sounds good. OMG that chapter is 603 pages long...Lets see if there is a sub index on page 199.
Scroll scroll, Chapter 3 should be right behind 2.58. Screenshot - wait, the title isn't even the same as the index on page 158! Land Use Population and Housing? That's not what I want...
Did I actually accomplish anything in the three hours I just donated to the city, no. And I have such a splitting headache that I can’t focus anymore. If I can’t do this and this is my line of work, what does this mean for the average Pacifican? It sure feels like the city does not really want our input…
Mayor Bier, Mayor Pro-Tem Bigstyck and City Council members, we are counting on you to ensure that the public can be properly engaged. That is your primary job as our elected representatives and it is completely in your power to instruct staff to do so. I urge you to have staff update the documents to break them up to manageable sizes and to provide indexes as well as a proper bibliography.
It is in all of our interests to complete a proper update of the General Plan as soon as possible that can guide us through our next 20+ years. For example, Vista Mar becomes HPD in this update and that is in my personal interest! HPD language is strengthened in this document, wonderful! But that is not enough for me to ignore things like greenhouse gasses, missing fire risk information for my neighbors near San Pedro Mountain, or missing sea level rise information for my neighbors in Sharp Park.
You have a willing pool of free labor! Let the public help you make sure these documents are up to date and consistent. If the documents are not, then I'm afraid it could leave the city exposed to legal challenges by developers, environmental groups and residents. I am not a lawyer, but from what I understand, legal challenges to the General Plan and EIR could be directly against the city, not through a developer's project, so the city may not be shielded. I assure you that none of the Pacificans I've spoken with want to go there. But I also assure you that we are not willing to allow these documents to stay in their current form. Approval of these documents as they stand would be:
• a disservice to our community, to the creatures we share this land with, and even to the developers we want to court
• a slap in the face to all the people affected by our previous disasters as we seem to have not learned from our history
• a threat to current and future residents for a lack of analysis and understanding of our hazards
• and an affront to all of us taxpayers for all the money we have paid to staff and consultants over the years for this update.
So what would the process look like to update some of these major issues like missing fire maps? Has the fire department even reviewed this draft before it was issued? The EIR says North County Fire was interviewed in 2009! So much has changed since then with climate change and droughts. I need updated fire information before I can understand proposed land use changes and properly review that section of the GP. Would this happen before the public hearings start? Would state agencies also need to be given more time to review major changes? I really have no idea and I am not getting answers to these basic process questions from planning staff or the City Manager.
Again, I hope to hear your thoughts on these issues at Monday's City Council Meeting, even though the General Plan is unfortunately not on the agenda.
Sincerely and with gratitude for your service to our community, Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“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: Christine Boles [ ]
Sent: Thursday, February 10, 2022 4:12 PM
To: Wehrmeister, Tina [[email protected]]; Murdock, Christian [[email protected]]; Bier, Mary [[email protected]]; Woodhouse, Kevin [[email protected]]
CC: Public Comment [[email protected]]
Subject: General Plan Buildout Question
[CAUTION: External Email]
Hi again Christian,
I am trying to understand the calculation of Buildout per the draft General Plan. See screenshot below from Page 4-29. The whole DEIR is based on this maximum buildout number to assess environmental impacts for a project of 990 new units, so I wanted to clarify how these numbers were obtained.
I am assuming that you have in your files or in Dyett & Bhatia's the detailed calculations that informed these numbers that would list specific properties and their acreage that were included in each of these land use categories.
If I need to file another PRA request, please let me know specifically what to ask for so I can better guide poor Sarah.
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“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: Sunday, January 16, 2022 11:37 AM
To: Public Comment [[email protected]]
Subject: General Plan Comment - Pedro Point
[CAUTION: External Email]
Hi, in the general plan you show the open area bound by Danmann and San Pedro avenue as zoned for residential/commercial and open for building up to 5 or so structures per acre.
Based on the official California Tsunami Hazard Area Map that property is located directly in the hazard zone. The recent Tonga tsunami is a warning that building here would be a very bad idea. I don’t want to see people die or property destroyed next time there’s a tsunami in Pacifica.
See attached for details
Jim Louderback (he/him)
GM – VidCon -
The magic of online creators in real life.
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From: Bill [ ]
Sent: Monday, February 21, 2022 1:08 PM
To: Murdock, Christian [[email protected]]
Subject: General Plan comment
[CAUTION: External Email]
2/21/22
Hi Christian,
Oceana Blvd needs a bike lane, esp for high school students. It's now unsafe for cyclists to share the road with cars in both directions as well as parked cars.
Painting "bike lane" on the street does not make it safe.
Pacifica should enforce the Vehicle Code so cars are not blocking sidewalks.
We need more diverse transportation options.
Bill Collins
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From: Necesse [ ]
Sent: Thursday, January 20, 2022 12:48 AM
To: Murdock, Christian [[email protected]]
CC: Public Comment [[email protected]]
Subject: General Plan Comments
[CAUTION: External Email]
Concern: City is operating on a Sewer Master plan that is outdated and inadequate.
Comments: Revision of a master plan is necessary to meet the ongoing needs of the community. We are operating on a master plan that is already outdated and does not mandate sewer lateral replacement that directly contributes to contamination of fresh water sources in the City of Pacifica and places a higher burden on our wastewater treatment plant. Lateral replacement is being mandated in many cities where residents have a specified number of years to comply. The slow methods in our plan will never be achieved in our lifetimes.
Environmental impact: the impact of leaking laterals is a recognized major concern for the City of Pacifica. The repaving project and the consequential disturbance of these newly repaved or resurfaced roads to do infrastructure repairs as is evidenced by poor planning on Crespi Drive in late 2021/early 2022 and was avoidable. Digging adversely affects underground freshwater sources, and may exacerbate lateral problems on surrounding properties; it generates gravel, dirt and dust that ends up in the storm drains and in wastewater collection systems. The patch jobs from these repairs damage the newly paved/resurfaced streets creating uneven wear again and shortening the life of the resurfacing work. This adds more contaminants and exacerbates problems with our old infrastructure.
Concern: the absence of an emergency response plan to prevent flooding and SSOs in the Sewer Master Plan
Comments: Preventing SSO’s should be a high priority of our General plan because we have been sued and fined over this issue. The EQ basin does not prevent flooding and does not stop raw sewage from entering the public right of way. We need a written comprehensive emergency response plan as other cities have adopted.
The environmental impact is absent from the DEIR.
Recommendations:
1. Require periodic review and amendments to the Sewer Master Plan so it is kept current
2. Actively seek federal and state funding to address these critical infrastructure problems we face
3. Require the creation of an emergency response plan to prevent both flooding and SSOs during wet weather events
4. Revise the Assurance Alternatives of the sewer master plan to change the language from private lateral replacement as a “disadvantage” and change it to an “advantage.”
5. Mandate sewer lateral replacement city-wide and offer repaving prioritization as an incentive to streets in full compliance
6. Create a long term lateral plan by residential district beginning with areas with more orangeburg pipe and areas with the highest I/I
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From: Suzanne Buckley [ ]
Sent: Wednesday, February 9, 2022 12:04 PM
To: Murdock, Christian [[email protected]]
Subject: General Plan comments
[CAUTION: External Email]
Hi Christian
I am one of the many Pacifica residents chiming in to ask for a re do of the Draft Environmental Plan recently released. It is an ill conceived document and really challenging to read - and I am a professional educator and editor.
Please listen to the many responses of our community. We need a General Plan that is workable, reflective of the current time and the future - and respects the wishes of our citizens.
I also request that examples of successful plans from other cities be included for review. It is always best to be able to compare and contrast so that lay people can make informed decisions.
Thanks so much.
Suzanne Buckley
Pacifica CA 94044
A happy Pacifican - and tax payer - for over 40 years.
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From: Necesse [ ]
Sent: Thursday, January 20, 2022 12:48 AM
To: Murdock, Christian [[email protected]]
CC: Public Comment [[email protected]]
Subject: General Plan Comments
[CAUTION: External Email]
Concern: City is operating on a Sewer Master plan that is outdated and inadequate.
Comments: Revision of a master plan is necessary to meet the ongoing needs of the community. We are operating on a master plan that is already outdated and does not mandate sewer lateral replacement that directly contributes to contamination of fresh water sources in the City of Pacifica and places a higher burden on our wastewater treatment plant. Lateral replacement is being mandated in many cities where residents have a specified number of years to comply. The slow methods in our plan will never be achieved in our lifetimes.
Environmental impact: the impact of leaking laterals is a recognized major concern for the City of Pacifica. The repaving project and the consequential disturbance of these newly repaved or resurfaced roads to do infrastructure repairs as is evidenced by poor planning on Crespi Drive in late 2021/early 2022 and was avoidable. Digging adversely affects underground freshwater sources, and may exacerbate lateral problems on surrounding properties; it generates gravel, dirt and dust that ends up in the storm drains and in wastewater collection systems. The patch jobs from these repairs damage the newly paved/resurfaced streets creating uneven wear again and shortening the life of the resurfacing work. This adds more contaminants and exacerbates problems with our old infrastructure.
Concern: the absence of an emergency response plan to prevent flooding and SSOs in the Sewer Master Plan
Comments: Preventing SSO’s should be a high priority of our General plan because we have been sued and fined over this issue. The EQ basin does not prevent flooding and does not stop raw sewage from entering the public right of way. We need a written comprehensive emergency response plan as other cities have adopted.
The environmental impact is absent from the DEIR.
Recommendations:
1. Require periodic review and amendments to the Sewer Master Plan so it is kept current
2. Actively seek federal and state funding to address these critical infrastructure problems we face
3. Require the creation of an emergency response plan to prevent both flooding and SSOs during wet weather events
4. Revise the Assurance Alternatives of the sewer master plan to change the language from private lateral replacement as a “disadvantage” and change it to an “advantage.”
5. Mandate sewer lateral replacement city-wide and offer repaving prioritization as an incentive to streets in full compliance
6. Create a long term lateral plan by residential district beginning with areas with more orangeburg pipe and areas with the highest I/I
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From: Necesse [ ]
Sent: Wednesday, January 19, 2022 10:40 PM
To: Murdock, Christian [[email protected]]
CC: Public Comment [[email protected]]
Subject: General Plan Comments
[CAUTION: External Email]
One of the main concerns I have with the DEIR and GP for Public Comment is the difficulty in aligning the sections of the two documents. When something is missing from the DEIR and is mentioned in the GP, there is no section of the DEIR to reference in my comments. It is very difficult to search both documents and the absence of indexes or a glossary makes this cumbersome for the public to review and comment.
I am reviewing the Section of the General Plan related to Biological Resources and the policies and mitigation measures associated with that section, but from my lenses there are no policies or mitigation measures in place or proposed that adequately address the wildlife corridors and the very serious issue of fragmentation. This gets a brief nod in the documents and fragmentation is only listed in three places in a 1013 page document.
Concern: Wildlife Movement Corridors found on page 7-23 of the Draft General Plan, “Corridors typically range from 100 to 400 feet in width, within which habitat is continuous and suitable for wildlife movement.”
Comment: Corridors (as a general term) do not ‘typically range from 100 to 400 feet in width’ and I would like to know where this data originates. Corridors depend on various factors and should not be generalized in such a manner. The environmental impact of the limitations of the section ‘wildlife movement corridor’ is not contained in the EIR. “While a wildlife movement corridor is needed somewhere within the area designated on Figure 7-3, the entire area need not be designated as a wildlife movement corridor.” This is not addressed in the EIR and it is necessary to identify them or they are not afforded protection unless there is a species that warrants protection. On page E-70 high habitat value threatened by fragmentation is mentioned under CO-I-33 but there is only one identified wildlife corridor in the entire General Plan. The Gypsy Hill wildlife corridor is one of many and all of these are threatened by fragmentation without appropriate guiding and implementing policies in place.
Recommendations:
1. Extend the comment period until a reasonable outreach is made to the community.
2. Better define the term wildlife movement corridor and appropriately represent the different types of wildlife corridors in the City of Pacifica: birds, small mammals and amphibians as one, and larger animals as another.
3. Include the goal of mapping out wildlife movement corridors in Pacifica. The absence of such a goal is also absent of its environmental impact.
4. Adopt policies that require developers to mitigate IN PACIFICA when their projects adversely impact parcels within the City limits and disallow any trading or exchange of environmental credits for projects outside Pacifica (in other words, if they damage habitat in Pacifica, they should be required to restore habitat in the city limits not in some other state or city.)
5. Establish a committee to Identify sites and habitats in our city or within our scope of influence that developers can restore or mitigate (to accomplish #4.)
6. Require wide buffer zones on parcels that abut open space regardless if animals using the parcel have special designations: the interactions between species and open space is complex.
7. Adopt strong policies and expand the influence of OSPAC to prevent fragmentation of greenspaces within the city and between public and privately held lands.
Respectfully submitted,
Erin Macias, Linda Mar
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From: Rick Nahass [ ]
Sent: Sunday, February 20, 2022 4:17 PM
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
[ ]; ; H
Subject: General Plan DEIR and VMT Mitigation Bank
Attachments: VMT_ExchangeCorridor.xlsx
[CAUTION: External Email]
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) SB-743 environmental impact mandate.
• For each new housing unit require a 1 time developer fee based on miles to the nearest high quality transit stop (e.g., $2100 x 6 miles to Colma BART = $12,600 per unit) • For each new housing unit require a yearly owner fee (tariff) based on miles to the nearest high quality transit stop (e.g. $160 x 6 miles to Colma BART = $960 per year) • SB-743 definition says "a high-quality transit corridor means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours." Add specifications 'specific' to the coastside, for example: Limited stops (3 from HMB to Montara, 2 in Pacifica to BART, possibly continuing to GG Bridge), Coastside 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
, Pacifica 94044
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Fee Unit
New Development Tariff to Compensate for VMT
SB-742 distance to high quality transit Corridor
Requred
Tariff Housing Units
Higgins Way 125
One time Developer Fee per unit per VMT $2,100 Rockaway Beach 50 Yearly Fee per unit per VMT $160 Sharp Park 990
Other 727
Total
Only play with these two values to change RHNA ABAG 1892 dollars in the restof spreadsheet
Housing Units
Higgins Way 125
Rockaway Beach 50
Sharp Park 990
Other 727
Total
RHNA ABAG 1892
If there existed a High Qualit
G
VMT
$2,100 $160
Miles to
Colma BART
VMT Miles
Calculation
Capital Funding for
Transit
Yearly Operations
Funding for Transit
One Time
Developer
Fee per Unit
(Cap)
9.3 8 $2,100,000 $160,000 $16,800
6.9 6 $630,000 $48,000 $12,600
4.9 4 $8,316,000 $633,600 $8,400
7 6 $9,160,200 $697,920 $12,600
Average Average
7.0 6 $23,839,200 $1,816,320 $12,600
Miles to
Pacifica
Stop
VMT Miles
Calculation
Capital Funding for
Transit
Yearly Operations
Funding for Transit Unit Cap
2.5 2 $525,000 $40,000 $4,200
0 0 $0 $0 $0
0 0 $0 $0 $0
1.5 1.5 $2,290,050 $174,480 $3,150
Average Average
1.0 0.875 $3,476,550 $264,880 $1,838
Fee x Units x VMT Fee x 1 Unit
re existed a High Quality Traffice Stop (per SB743) at Rockaway and Sharp Park - 2 stops in Pacifica ONLY.
Gives Developers Incentive to promote route 1 corridor
Yearly Fee Per
owner Unit
(Ops)
$1,280
$960
$640
$960
$960
Unit Ops
$320
$0
$0
$240
$140
Fee x 1 Unit
ONLY.
From: Mark Hubbell [ ]
Sent: Tuesday, March 8, 2022 5:13 PM
To: Public Comment [[email protected]]
Subject: General Plan DEIR Comments
Attachments: GENERAL PLAN DEIR COMMENTS.pdf
[CAUTION: External Email]
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 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 there are many grant funding programs 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 Treat 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.” Thank all of you on The City Staff for your service!
Best,
Mark
From: Judy Yamahiro [ ]
Sent: Wednesday, January 26, 2022 3:58 AM
To: Public Comment [[email protected]]
Subject: General plan documents need fixing
[CAUTION: External Email]
Hello,
Please fix the documents as Mr. Shoemaker described via next door Linda Mar to make them more easily accessible and please extend the deadline for review.
As a resident, my tax dollars are being used to compose this document and all residents deserve good value for our tax dollars.
Thank you for your consideration of this important request, Judy Yamahiro
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From: Christine Boles [ ]
Sent: Saturday, January 29, 2022 8:39 PM
To: Beckmeyer, Sue [[email protected]]; Berman, Lauren [[email protected]]; Bier, Mary [[email protected]]; Christine Boles [ ]; Domurat, George [[email protected]]; Ferguson, Alex [[email protected]]; Godwin, James [[email protected]]; Hauser, Samantha [[email protected]]; Leal, David [[email protected]]; Murdock, Christian [[email protected]]; Nibbelin, John [[email protected]]; O'Neill, Mike [[email protected]]; Public Comment [[email protected]]; Vaterlaus, Sue [[email protected]]; Wehrmeister, Tina [[email protected]]; Woodhouse, Kevin [[email protected]] Subject: General plan documents public comment
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Dear City Council, Planning Commission and city staff,
I tried working with the word documents today in parallel with the pdfs and it just added to the cumbersome, time consuming task you have so disrespectfully dumped on the public. Page numbers don’t even match. Now I have to scroll thorough multiple windows at once, with a third window for writing my comments and a fourth window for checking references online, because so many are outdated.
I think I made it through 5 whole pages of the DEIR on seismic risks today and already have two pages of comments. Only 1008 pages to go…
Do you not understand that we actually want to help you improve these documents so that the General Plan can be properly used for the next 20 years? The many errors and inconsistencies in these documents leave the city exposed to litigation not just by the public and environmental groups, but also by developers. Is that the legacy and risk this council wants to leave the city saddled with? As Tygar said so eloquently at the last Council meeting, this is your decision, and you need take the responsibility. The buck stops with you; Staff is just waiting for the word from the 5 of you, who were elected to represent us. Remember your names will be on this document for posterity.
And planning commissioners, please, you have a voice too. Have you started your own review? Are these documents good enough for you and for those who will follow you in those seats to do the jobs to ensure the public and our environment are protected? Can you please put the General Plan discussion on your agenda for February 7? I really want to hear what you think.
We’ve already been waiting 43 years, we can wait a few more months. Do the right thing. Fix the documents into one searchable pdf, provide an index, update the bibliography and links, and reset the clock.
Thank you,
Christine Boles
--
Christine
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From: Christine Boles [ ]
Sent: Friday, January 7, 2022 10:12 AM
To: Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Woodhouse, Kevin [[email protected]]; _City Council Group [[email protected]]; Public Comment [[email protected]] Subject: General Plan documents?
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Dear Mayor Bier, Mayor Pro Tem Bigstyck, Council and staff, Both the Tribune and the City’s website say the General Plan review process starts today, but I can’t find the documents on the city website. The links given are circular. Can you confirm that the review process will be extended as necessary so that we have the full minimum 45 days? https://www.cityofpacifica.org/civicax/filebank/blobdload.aspx?t=62428.95&BlobID=19363 Please confirm when the documents will be made available.
I am really disappointed to read that there will be no public launch giving an overview of the documents and explaining how residents and businesses can best contribute. My guess is that most Pacificans don’t even know what a General Plan is, much less understand its importance.
The fact that after 40+ years the General Plan release is not even an item for discussion on the City Council’s agenda for Monday leads me to believe that the city lacks the desire for public education and engagement on the future vision of our city.
I understand that staff resources are limited and that the City Manager would want to minimize their time and expense, but Council Members, I ask you as elected representatives to question whether this is the right decision. It is obviously your call to make, not that of staff.
Respectfully,
Christine Boles
--
Christine
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From: Michelle Pitt [ ]
Sent: Thursday, February 17, 2022 10:21 AM
To: Public Comment [[email protected]]
Subject: General Plan for Pacifica
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After watching a Docu-Series on Netflix, Down To Earth, where they traveled around the world for healthy and sustainable ways to live I have put together this bulleted list of what I hope for the future of this town based on what I saw
Greenery walls along with every building Site, rooftops, sidewalks, or gathering areas.
No plastic water bottles, no plastic anything
Filtered Water fountains everywhere
Sustainable building
Carbon sequestering gardens
More walking/biking/shuttle options
Energy efficiency, those small windmills,
Communities to live, work and shop in the same center or Live, shop, and access to smart commuting
Sorry, I have not yet reviewed the plan but I will look specifically at these areas within the next few days. I will also sign up for email notifications.
Thank you for your allowing my comments.
Regards,
Michelle Pitt
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From: Keatinganderson [ ]
Sent: Tuesday, March 8, 2022 11:40 AM
To: Murdock, Christian [[email protected]]
Subject: General plan input and concerns
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To Christian Murdock and whom else it may concern,
I am writing with some input and concerns about the general plan.
The walking path that connects Pacifica is a wonderful asset to all of the communities in our city and so many visitors to our area. I am grateful for its ease of accessibility from nook to neighborhood and all of it’s beautiful views and stretches in between.
My concerns come from those neighborhoods that are intersected by the path, and how we can best direct the public's use, with the least impact on the people who live here. My specific concerns are about the verbiage and lack of continuity between areas in the Pedro Point district, that leave room for interpretation as well as some confusion and possible misuse of private properties in this plan.
Here is a list of my concerns.
1. Pg. 97, LU-I-28 PedroPoint Shopping Center.
“Maintain beach access along Shoreside Drive.”
Shoreside Drive is a privately owned “driveway” that enables it’s resident’s to access their homes by car and foot, there is no public access point here. I believe the access you are indicating is the San Pedro Creek access at the north east end of the shopping center parking lot. This is the safest, most convenient, least impactful, and only public access South of the San Pedro Creek. The public (especially visiting Public) should have clear signage directing them towards this access. By using the terms "access along Shoreside Drive” you give the impression that there is public access on or at Shoreside Dr.
LU-I-29 Undeveloped San Pedro Ave site.
"Establish a Coastal Recreational Mixed use zoning district." I am opposed to any rezoning of this property without further study, updated EIR reports and traffic reports, and neighbors, and until the safety (or lack of) for ingress and egress by current Pedro Point residents is addressed. This is a one way in, one way out community which has been held hostage in the past when a tragedy has occurred. If there is any unforeseen issue, where San Pedro Ave is blocked anywhere before Danman Ave, there is no other way out for a majority of the community.
I am concerned about the weight of new development here, the amount of cars and people this will bring, and how this small area can handle it. I plea for deep consideration that you listen to and consider all residents of the neighborhood, and for you to truly weigh out and choose the least impactful designation.
2. Pg. 153, 6.2
-Coastal trail
Where is the precise location of this "connection and improved segment" you refer to throughout this plan? The use of differing names and terminology for the same site and or or landmark is confusing and not suitable language for a City plan to be adopted and be referred to for clarity for years to come. It is equally unclear on the 6-2 Trail System map on pg. 152, way to much room for interpretation. I have given more detail on these concerns below.
3. Pg. 155, OC-I-25 Implementing Policies
-Coastal Trail at Devil’s Slide and Between Pacifica and Devil’s Slide I am concerned about the verbiage used in connecting the Pedro Point Shopping center path and Devils slide trailhead. The wording is unclear and image of the trail map 6-2 pg. 152 clearly shows Grand Ave., but not the shopping center. Are you planning to keep the trail in front of the shopping center where it should stay go bring it behind through multiple layers of private property and into our residential area? There is no reason to have the trail continue west, through the privately owned shopping center, along the privately owned Shoreside Drive, through the privately owned field, to end at San Pedro Ave., and The Anchor Inn. This is all Privately owned, and the “Colts Property “ section of the Devils slide trail does not begin here, it begins at the South East side of Ace Hardware.
I am with hopes that the trail is developed, crossing SanPedro Ave., from the ocean side path to the Mountian side trail, where the path nears it’s end and turns towards the ocean. well before Ace Hardware. There is a long straight-away on the frontage road section of San Pedro ave. here, with a clear view of, and for, all oncoming traffic. On the Hwy 1 side there is a “No parking” zone, and a well used path under the highway that connects with the Old Coast Rd. If at this point, there was a crosswalk and sidewalk created, pedestrians could easily and safely cross over the frontage road in clear view of all oncoming traffic, to access both the Devil Slide and headland trail as well as the Old Coast Road. Please see image below.
Possible path to trail connection at PP Shopping center
4. Pg. 157, Figure 6-3: Coastal Access
#24 “Improve new segment of coastal trail along former railroad berm.” The only existing railroad berm ends near the end of Shoreside Dr. A privately owned drive. This again needs to be more clear, are you meaning on the East side of San Pedro Creek or where the old Fassler house once stood? There was old railroad berm there at one point but has eroded to almost beach level. What and where is this “New segment “ you are referring to? This statement leaves much room for interpretation as well as possibly directing the public towards and through private property for no reason. This trail needs to end at the San Pedro Creek outlet, thoughtfully dissuading parking in, and trampling through, this single entrance and exit neighborhood. The map seems to show it staying adjacent to Hwy 1, which makes sense however the language does not match the map.
5. Pg. 159 Table 6.5: Coastal Access Points
#24 North Side PedroPoint Shopping Center
#25 Ocean Shore Railroad Berm
This coincides with my concerns stated above.
#24 Again you state “ Improve new segment of Coastal Trail along former railroad berm”. Where exactly are you referring to, the map and description do not match. #25, "Ocean Shore Railroad Berm", is also referred to as "Shoreside Drive” in other segments of this plan, these two are one in the same, yet the titles are used as if they are different points. This is confusing and lacks continuity and clarity. This land is privately owned and has never had public beach access, but because of the use of “Railroad Berm”, the exact location and section of trail you are referring to is muddled, leaves room for interpretation. There is confusion, frustration and sometimes anger from the public, as well as residents, who do not have knowledge and or signage giving them the proper direction to tread lightly, on publicly designated trails and accesses, while respecting and avoiding the privately owned property. There should not be any new "improved segment" through privately owned land, although signage is greatly needed.
6. Pg. 162, OC-I-40 Policies
-Implementing Policies
-Maintenance of Public Coastal Access
Require a public or private entity to be responsible for required public access ways. Until such an entity agrees to be responsible for liability and maintain maintenance of such access ways, they are not required to be open for public use. Dedicated public access ways should be designated to provide views as well as access connections or along the shore.
Shoreside Dr. Has been designated as an overlook point, ( I apologize for not having the exact table to give you) which creates overuse and dangerous conditions for the public as well as residents of this privately owned area. The incredible number of visitors has increased at an alarming, overwhelming rate in the past two years of the pandemic. The impact on those who live there, most of whom are elders, has had a chrushing impact to their emotional and mental health, as well as creating a physically dangerous situation for them as well as the general public. People climbed up and between houses, used the private decks and paths as bathrooms, allowed kids and dogs to run THROUGH the homes and yards, left litter, dangerously parked and blocked the one way narrow dirt driveway, preventing our ingress/egress. We were vocal to the city during that time, and were given cones and temporary signage to alert visitors and protect the property with. These measures were respected by only a small few. We were also asked by Pacifica PD, during beach closures, to try and eliminate any arteries of access that might be used to get to the beach in order to support their efforts.
This has been and continues to be a constant struggle.
The families who live her, should not be required or "be responsible for liability and maintain maintenance” of this area for the pleasure of others many of whom are completely unaware others who feel entitled to its use. Please do not advertise this as a public area.
Thank you for this opportunity, let's keep our residents and visitors on our beautiful trails, off private land and keep them, and the property owners safe.
Thank you for your time and thoughtfulness on these matters, Shona Keating
Pacifica
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From: Christine Boles [ ]
Sent: Tuesday, January 11, 2022 11:31 AM
To: Murdock, Christian [[email protected]]; Wehrmeister, Tina [[email protected]]; Public Comment [[email protected]] Subject: General Plan OPR distribution list
[CAUTION: External Email]
Good morning Christian and Tina,
Could you please forward a copy of the instructions to the State Clearinghouse, OPR along with the distribution list to responsible and optional agencies that will be reviewing the City's DEIR? I can file an official document request if you prefer.
Thank you,
Christine Boles, Architect
Beausoleil Architects
Pacifica, CA 94044
“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: Friday, February 11, 2022 2:46 PM
To: Murdock, Christian [[email protected]]; Public Comment [[email protected]]
Subject: General Plan Review extension date
[CAUTION: External Email]
Greetings,
I am writing to you again to ask that the time to review and accept comments on the General Plan be extended beyond the February 21st deadline. I, and several others, need more time to read all of the large amount of material.
Thank you,
Patricia R. McGregor
Pacific Manor
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From: Alex Strachan [ ]
Sent: Wednesday, January 19, 2022 8:31 PM
To: Public Comment [[email protected]]
Subject: General Plan Update Public Review Draft (January 2022 Version)| Public Comments Requested by 2/21/2022
[CAUTION: External Email]
Hello, First off, the document is pretty hard to navigate. If you need help putting together hyperlinked documents, i'm more than willing to help.
Regards Alex.
--
Alex Strachan
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From: penny keating [ ]
Sent: Tuesday, March 8, 2022 6:37 PM
To: Murdock, Christian [[email protected]]
Subject: General Plan up-date
[CAUTION: External Email]
Dear Planners, I know I’m a little late on getting these comments in. I thought the deadline was 3/22/20. Neverthe-less, I doubt that I will add anything that other Shoreside Neighbors have not already stated. However having lived here more than 50 years I believe I have a little experience with the area and should not neglect this opportunity to add my perspective.
The Old Railroad Berm also known as Shoreside Dr. is a privately owned driveway that is of a delicate (though gritty) nature and cannot serve the greater general public without safety issues as well as degradation to either the public or this somewhat frail area.
Particularly through the pandemic but also growing due to other trends, the south end of San Pedro Beach has been overwhelmed overt he past several years. This south end is separated from the Pacifica State Beach by the San Pedro Valley Creek and is a rather private and delicate area. The old railroad berm is merely compacted earth which is subject to erosion as in crumbling along its edge from end to end. To direct any of the general public to that area is to cause unnessessary harm to that area and potentially to the public encouraged to access it.
No. 25 should not encourage the public to this area. A small earthen path for the owners of the property has been abused by a large number of individuals from all over and even outside the Bay Area.
Neither the City nor the resident’s are willing or able to take the responsibility of liability and thus should not be in a public plan.
No area of the old Railroad Berm, Shoreside Dr., should be used for access or Bluff top viewing due to these issues.
I am also against making decisions on use of the Calson Field until traffic challenges are remedied. Pedro Point is particularly victim to any emergency especially focused at the entrance/exit to our hillside area.
I know that other of my neighbors have offered much more eloquent suggestions for how the coast path can be handled as well as other suggestions.
I just want to add my voice to the protection of this area and the public.
With Appreciation,
Penelope Keating
Pacifica, Ca. 94044
P.S. I would be happy to speak with anyone wanting a clearer picture of this sensitive area.
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From: Kathi Porter [ ]
Sent: Wednesday, January 19, 2022 10:21 AM
To: Public Comment [[email protected]]
Subject: General Plan
[CAUTION: External Email]
I tried to read the new General Plan, couldn’t really get to any content other than photos. I have heard it can be challenging to navigate once you find some information. We all want what’s best for our city, and need to have some input. Please make corrections so that we all can navigate this very important information.
Thank You
Kathi Porter
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From: DEBORAH LYNCH [ ]
Sent: Monday, January 17, 2022 11:46 PM
To: Public Comment [[email protected]]
Subject: General Plan/EIR
[CAUTION: External Email]
I’m trying to read the General Plan and the EIR that the City made available last week. If the goal was to make it as tedious and frustrating to use, mission accomplished. I am trying to do what is right as a resident of Pacifica. The very least you can do is make that a bit easier for us but making it user friendly. No index or search functions? Really? Please correct this and do it in a timely fashion. There are lots of us interested in being informed on what is in the 1013 page document. I’m still scrolling through it, but there is no reason it should have been made this difficult to navigate.
I’m sure you have people on staff that can correct this issue.
Thank you,
Debbie Young Lynch
Sent from Deb’s iPad
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From: ellen.natesan ]
Sent: Sunday, March 6, 2022 6:31 PM
To: Murdock, Christian [[email protected]]
Subject: GP and DEIR Comments
Attachments: Natesan_PGP_Comments_March_2022.pdf
[CAUTION: External Email]
Hello Christian, Here is my comment letter on the Pacifica General Plan and associated Draft Environmental Impact Report. Please let me know if you have any trouble with the attached file. I would be happy to talk to you or your consultants to answer questions or provide more information if that would be helpful. Thank you very much! Ellen 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.
Christian Murdock, AICP
Deputy Director of Planning
Planning Department
540 Crespi Drive
Pacifica, CA 94044
Thank you for the opportunity to comment on Pacifica’s Draft General Plan and Draft Environmental Impact Report. These documents are a significant accomplishment for Pacifica. I appreciate and agree with the priority placed on protecting the beautiful open spaces and unique natural resources found in Pacifica. I know this is a shared value among Pacifica’s residents. It is why I moved here.
I am pleased to have this opportunity to offer my professional expertise to improve planning outcomes in my hometown of Pacifica. I have over 20 years of professional experience as an ecologist, and for the past 15 years I have been responsible for developing measures to protect natural resources during construction, as well as responsibility for many large and complex ecological restoration projects in the Bay Area. The comments I am providing below are derived from my experience and knowledge, but also benefit from expertise and input from many remarkable other professionals, including other residents of Pacifica.
In my comments below, I provide some specific suggestions in the form of suggested edits.
These are shown in red underline for suggested additions and red-strikethrough for suggested deletions. I have tried to provide an explanation and justification for each of these edits. If you have any questions about my recommendations, or would like additional resources or references, please let me know.
Thank you for your continued hard work on these important documents.
Sincerely,
Ellen Natesan, Ph.D.
Pacifica, CA 94044
General Comment - DEIR and GP Policy Discrepancies
The policies in the General Plan do not always match those in the DEIR. Not only are there textual differences, but the numbering seems to have changed. For example – CO-G-10 appears as a policy about “Other Environmentally Sensitive Areas” on page E-70 of the DEIR but also as a policy about “Trees” on page 3.3-34 of the DEIR. CO-I-26 in the DEIR is a “Sanitary Sewer Discharge” policy but CO-I-26 in the General Plan is about “Protection of Biological Resources with New Development.”
When I inquired about these discrepancies to the Pacifica Planning Department, I was instructed (in an email from Christian Murdoch dated January 29, 2022) to use the Policies in the General Plan as the basis for my comments. My comments below are therefore focused on the versions of the Policies found in the General Plan. Where possible I have attempted to refer to the corresponding policy in the DEIR. All of my comments should also be considered to be comments to the DEIR, except where I specify “General Plan Only.” Policy OC-G-5 – Open Space Preservation - DEIR and General Plan Recommended Edits:
Open Space Preservation. Preserve open space that protects natural resources, visual amenities, and public health and safety.
The top priority areas for conservation are beaches, oceanfront bluffs, ridgelines, hillsides areas adjacent to existing open space, and areas that support critical wildlife important habitat for special status and endangered species. See Figure 6-1.
Rationale:
The way this is written it is overly narrow. There are many special status plants, wildlife, and butterflies found in Pacifica with no designated critical habitat. Critical habitat has a specific and narrow legal meaning that would currently only apply to California red-legged frog within the planning area. The intent of this policy should be to protect important habitat for all special status species, whether or not the Fish and Wildlife Service has formally designated critical habitat. The word “critical” should not be used to avoid confusion. Please also see my comments on Policy CO-G-7 below.
Policy OC-I-28 - Highway 1 Over-Crossing at Mori Point - General Plan Only Recommended Edits:
Highway 1 Over-Crossing at Mori Point. Support the development of a new wildlife friendly over-crossing between Shelldance Nursery and Mori Point, in coordination with GGNRA and Caltrans to enhance visitor facilities in Pacifica. Pacifica should also encourage GGNRA and Caltrans to place wildlife barriers at strategic locations in this area to reduce roadkill and risk of wildlife collisions on Highway 1. Underpasses such as the Calera Creek underpass could potentially be modified to improve wildlife passage and connectivity between habitats. Pacifica should encourage Caltrans to improve these structures whenever these road segments are upgraded or replaced. As an interim alternative, strengthen signage and safe connections to the existing Sharp Park Golf Course undercrossing in the East Fairway Park neighborhood.
Rationale:
Highway 1 is a prominent feature running through Pacifica that has heavy traffic which is built at-grade with insufficient safety barriers and insufficient over- and under- passes. Currently, getting across Highway 1 presents dangers to both humans and wildlife. Safety improvements (for both people and wildlife) should be addressed whenever the opportunity presents itself, which is most likely to be when Caltrans is doing maintenance or upgrades. A safe crossing allowing people to safely cross Highway 1 and connect trails above Shelldance Nursery and Mori Point is urgently needed. It is likely that such a structure could be made in a way to be useable to at least some wildlife, particularly larger mammals. Pacifica should work with Caltrans and encourage them to identify the most dangerous areas (Mori Point being a good example of this) and install safe crossing structures for people and wildlife.
Policy CO-G-7 - Protect Habitat for Special Status Wildlife - DEIR and General Plan Recommended Edits:
CO-G-7 Protect Habitat for Special Status Wildlife and Critical Habitat. Conserve and protect indigenous threatened, endangered, and other special status species by preserving critical habitat that is important for the protection of these species.
Habitat can be protected by allowing very limited or no development, by identifying habitat areas as top priorities for permanent conservation, and by managing public land to ensure species protection.
Rationale:
The term “critical habitat” has a specific regulatory meaning, namely, habitat that has been designated as critical habitat by the United States Fish and Wildlife Service. Many special status wildlife species, including those listed as threatened or endangered by the Fish and Wildlife Service and California Department of Fish and Game, do not have designated critical habitat.
Currently, the only species with critical habitat designated in the project area is California redlegged frog. California red-legged frog is definitely not the only special status species in Pacifica with a need for habitat protection. The intent of this policy should be to protect important habitat for all special status species, and so the term “critical habitat” should not be used to avoid confusion.
Policy CO-G-10 – Trees – DEIR and General Plan (note also appears as Policy CO-G-9 in DEIR)
Recommended Edits:
*NOTE – this policy should be edited in both the DEIR and General Plan. The numbering seems to be incorrect in the DEIR and so the numbers should also be updated in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.
CO-I-10 Trees. Conserve trees and encourage native forestation and planting of appropriate trees and vegetation in areas identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan. In areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan, limit planting of trees to riparian areas or other areas known to have historically supported trees, to avoid impacts to special status plant and animal habitat, to non-tree dominated plant communities (such as prairie, chaparral, and wetlands), and to the invertebrates and wildlife that depend on these habitats.
Rationale:
In general, the trend on the San Francisco Peninsula has been towards increased afforestation rather than deforestation. Most of the region’s sensitive and special status species depend on grassland and shrubland communities, which are being lost through time to afforestation.
Planting trees (even native trees) should be considered an impact except in the narrow circumstances of urban planting or planting in areas known to historically support trees. For more background information on these ecological trends see the Peninsula Watershed Historical Ecology Study here:
https://www.sfei.org/documents/peninsula-watershed-historical-ecology-study Policy CO-I-1 - Creek Protection and Restoration - DEIR and General Plan Recommended Edits:
*NOTE – The edits below are to the version of Policy CO-I-1 in the General Plan which is different from the version of Policy CO-I-1 in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.
CO-I-1 Creek Protection and Restoration. Maintain, protect, and restore Pacifica’s creeks, including San Pedro, Calera, Sanchez, and Milagra creeks, as environmental and aesthetic resources. Actions will include, but are not limited to:
• Continuing restoration efforts along San Pedro Creek to improve conditions for steelhead by removing obstacles to fish passage, placing rock weirs to facilitate fish passage, and by monitoring the effectiveness of these projects;
• Partnering with local organizations, such as the San Pedro Creek Watershed Coalition, Go Native, the Pacifica Land Trust, and others, on restoration efforts; • Exploring opportunities to collaborate with other agencies and organizations on stream restoration and riparian habitat restoration along Sanchez and Calera creeks; • Enforcing restrictions on the planting of invasive species near creek areas; • Identifying and working with property owners to take advantage of unique opportunities where human active use (e.g., through trail development) would enhance creek appreciation without disrupting ecological function;
• Requiring a minimum of 100-foot set- backs from the top of creek banks, or from the outer edge of riparian vegetation, where it exists, for development proposed adjacent to creeks, in keeping with City regulations and Best Management Practices. Exceptions to such buffer requirements should be supported by a biological report demonstrating that the adjusted buffer, in combination with incorporated siting, design or other mitigation measures, shall prevent impacts that significantly degrade the creek. A Qualified Hydrologist with professional experience evaluating natural creek geomorphology shall evaluate the potential for impacts in coordination with a Qualified Biologist with professional experience evaluating the riparian and freshwater aquatic ecosystems found in the project area. This analysis shall be provided in writing and shall consider impacts to creek form and function, aquatic species, and to riparian habitat. Buffer adjustments should also be limited to where the entire subject legal lot is within the buffer or where it is demonstrated that development outside the buffer would have a greater impact on the creek.
Rationale:
Analysis of potential for impacts of a development adjacent to a creek channel should be performed by someone with knowledge and experience analyzing creek hydrology and geomorphology. A biologist alone would not be able to predict the changes to creek form and function which will drive any biological impacts. A biologist however is needed to understand potential for impacts to special status species, riparian communities, and creek aquatic habitats.
The results of the analysis should be available in the form of a report or memo to staff, Planning Commission, and the public.
Policy CO-I-11 - Protect Water Quality through Best Management Practices - DEIR and General Plan
Recommended Edits:
CO-I-11 Protect Water Quality through Best Management Practices. Continue to require the use of best management practices to reduce water quality impacts from construction and development. Measures include:
• Site Design and Source Control. Ensure that all new development incorporates site design and source control BMPs into the project design in order to pre- serve the infiltration, purification, and retention functions of each site’s natural drainage systems, and to prevent or minimize the runoff of pollutants, sediments, waste, and pathogens from the site.
• Construction Pollution Control. Require all construction projects to adopt measures to avoid when possible, or minimize erosion and runoff of pollutants and sediments from construction-related activities, and to limit activities that result in the disturbance of land or natural vegetation.
• Construction projects will be required to use appropriate erosion prevention techniques, sediment control measures, and best management practices in accordance with City specifications and the San Mateo Countywide Water Pollution Prevention Program. • Treatment Control. Require that new development implement treatment control BMPs (or structural treatment BMPs) where the combination of site design and source control BMPs is not sufficient to protect water quality and comply with applicable water quality permits.
• Site Design and Source Control. Ensure that all new development incorporates site design and source control BMPs into the project design in order to preserve the infiltration, purification, and retention functions of each site’s natural drainage systems, and to prevent or minimize the runoff of pollutants, sediments, waste, and pathogens from the site.
• Runoff Capacity Management: Ensure that new developments do not cause flooding for communities downstream. Evaluate downstream drainage capacity for runoff that cannot be captured on-site during large storm events (100 year storms). If a development will increase peak runoff volumes during large storms (because of increased impervious surfaces or other factors), downstream capacity improvements should be part of the project, using a design standard of 100 year storm.
Stormwater treatment systems must meet the numeric sizing criteria established in the NPDES Permit, and must be operated and maintained in compliance with the NPDES Permit.
Rationale:
New developments should not cause downstream flooding. For example, new developments in the San Pedro Creek watershed should consider flooding at Adobe Drive, which is already prone to flooding during large storm events. The water conveyance capacity at Adobe Drive should be increased as a part of any new development project that would increase peak runoff to prevent the project from causing flooding in the neighborhood in the vicinity of Adobe Drive and San Pedro Creek. When undersized water conveyance structures like this are overtopped during storms, there is increased risk to the creeks of streambank failures, sedimentation, and a flush of contamination (such as from motor oil, tire wear particles, and litter) washing into the creeks.
Climate change is expected to increase the frequency of atmospheric rivers and high intensity precipitation events and so designing to a 100 year storm standard is a bare minimum. This measure might be more appropriate as a standalone new mitigation/policy.
Policy CO-I-26 – Protection of Biological Resources - General Plan and DEIR (see Policy CO-I-27 in DEIR)
Recommended Edits:
*NOTE –This Policy does not appear in the DEIR (and it should), however Policy CO-I-27 in the DIER may be an earlier version of this policy. This policy should be added to the DIER.
Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.
CO-I-26 Protection of Biological Resources with New Development or Other Earth Disturbing Projects. Protect sensitive habitat areas and special-status species through implementation of the following measures:
1. Discourage development and/or buildout in critical habitat of special status species habitat during the development review process in a manner consistent with Policy CO-G7.
2. Pre-construction pConduct plant and wildlife surveys prior to vegetation clearing or earth disturbing activities: Project applicants shall engage a qualified biologistQualified Botanist and Qualified Wildlife Biologist (as defined below) to conduct presence/absence biological surveys for sensitive plant and wildlife species prior to construction adjacent to or within identified special status communities and other sensitive areas identifiedcommencement of work in areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan. If special status species are identified, the qualified biologist shall consult with the California Department of Fish and Wildlife (CDFW) and establish no-disturbance buffers around avian nests, bat roosts, dusky footed woodrat nests, sensitive plant communities, special status plants, and sensitivespecial status butterfly host plants, wetlands, or other sensitive and special status natural resources to avoid disturbance and direct impacts to these resources during construction. If no special status species or plant communities are detected during surveys, then construction-related or earth disturbing activities may proceed. Nesting birds, in particular, are protected by two means; they receive protection under the Migratory Bird Treaty Act, and nesting raptors (in the order Falconiformes or Strigiformes) are protected under the State Fish and Game Code, §3503.5.
3. Incorporate bird, bat, and wildlife impact avoidance measures into vegetation removal activities. Prior to felling, prune trees to increase detectability of nesting birds, and disturb trees (eg. with axe or chainsaw) and then observe for 10-15 minutes. Near San Francisco garter snake or California red-legged frog habitat, tall vegetation can be cut to 1 foot in height to improve visibility for biologists and encourage wildlife to move out of the area, and then cleared to the ground.
4. Require biological resource assessments be conducted prior to approval for any development within 300 feet of creeks, wetlands, or other areas not identified as “Urban and Non Urban with Little or No Habitat Value” sensitive habitat areas shown on Figure 7-3 of the proposed General Plan.
5. Require on-site monitoring of biological resources by a qualified biologist throughout the duration of construction activity.
5.6.For projects taking place in areas not identified as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the proposed General Plan, require that equipment arrive on site for construction visibly clean of dirt and organic matter to minimize the risk of introducing new plant pathogens, pests, or invasive plants to the area.
Prior to approval and prior to any earth disturbance, grading, grubbing, vegetation clearing, staging or other temporary or permanent project-associated impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3, a Qualified Botanist will conduct pre-project botanical surveys to determine the potential for impacts to special status plants, plant communities, or special status butterfly (such as Mission blue butterfly) host plants.
The Qualified Botanist shall conduct botanical field surveys in a manner which maximizes the likelihood of locating special status plants and sensitive natural communities that may be present.
The botanical survey must take place during the appropriate season during which the target species can be readily detected and accurately identified. Botanical surveys should generally take place while target plants are in bloom. Multiple years of surveys may be required to accurately assess the location of or determine the absence of short-lived plant species or plants species with a persistent seed bank. Botanical field surveys should be floristic in nature, meaning that every plant taxon that occurs in the project area is identified to the taxonomic level necessary to determine rarity and listing status.
A Qualified Botanist must meet the following requirements:
• Knowledge of plant taxonomy and natural community ecology; • Familiarity with plants of the region, including the plants targeted for survey and any special status plants (or host plants of special status insects) that may occur in the survey area;
• Familiarity with natural communities of the region, including California Sensitive Natural Communities;
• Experience with the CNDDB, BIOS, and Survey of California Vegetation Classification and Mapping Standards;
• Experience conducting floristic botanical field surveys; • Familiarity with federal, state, and local statutes and regulations related to plants and plant collecting; and
• Experience analyzing the impacts of projects on native plant species and sensitive natural communities.
If a project will involve earth disturbance, grading, grubbing, staging or other temporary or permanent impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the General Plan, a Qualified Wildlife Biologist will survey for special status wildlife species and their habitat. A qualified wildlife biologist must be familiar with identification of essential physical and biological features for special status wildlife species, including space for individual and population growth and for normal behavior; cover or shelter; food, water, air, light, minerals, or other nutritional or physiological requirements; sites for breeding and rearing offspring; and habitats that are protected from disturbances or are representative of the historical geographical and ecological distributions of the species.
A Qualified Wildlife Biologist must meet the following requirements:
• Demonstrated professional experience identifying all of the target wildlife species at all life history stages;
• Experience and knowledge of the natural history, habitat affinities and wildlife species needs;
• Familiarity with federal, state, and local statutes and regulations; and • State and federal handling permits (as needed).
Rationale:
See explanation for CO-I-27 edits below.
Policy CO-I-27 - Page E-65 of DEIR and Page 7-26 of General Plan Recommended Edits:
*NOTE – The edits below are to the version of Policy CO-I-27 in the General Plan which is different from the version of Policy CO-I-27 in the DEIR. Since the governing document is the General Plan, the DEIR version should be deleted and replaced with the text below to ensure consistency between the two documents.
CO-I-27 Verification of Environmentally Sensitive Habitat Areas (ESHA) within the Coastal Zone and identification of sensitive habitats or special status species that should be protected outside of the Coastal Zone. Prior to any proposed development or other earth disturbing project in an ESHA or potential ESHAin areas not identified as “Urban and Non Urban with Little or No Habitat Value” Figure 7-3 of the proposed General Plan, require that a habitat survey be conducted by a Qqualified Bbotanist or Qualified Wildlife Bbiologist. The habitat survey will verify whether the site is an ESHA or has special status under CEQA, and document the extent of the sensitive resources, document potential negative impacts to the habitat, and recommend appropriate mitigation measures. Verification of an ESHA or special status plant communities, plant or animal species, or habitat shall be based on the following considerations:
• Presence of natural communities identified as rare by the California Department of Fish and Wildlife (determined by a state rarity ranking of S1 to S3). • Recorded or potential presence of plant or animal species designated as rare, threatened or endangered under State or federal law.
• Recorded or potential presence of plant or animal species for which there is compelling evidence or rarity, such a designation of 1B (rare or endangered in California or elsewhere) or 2 (rare, threatened, or endangered in California, but more common elsewhere) by the California Native Plant Society.
• Presence of coastal waterways.
• Presence of drainages or wetlands.
• Integrity of the habitat and its connectivity to other natural areas.
Prior to approval and prior to any earth disturbance, grading, grubbing, vegetation clearing, staging or other temporary or permanent project-associated impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3, a Qualified Botanist will conduct pre-project botanical surveys to determine the potential for impacts to special status plants, plant communities, or special status butterfly (such as Mission blue butterfly) host plants.
The Qualified Botanist shall conduct botanical field surveys in a manner which maximizes the likelihood of locating special status plants and sensitive natural communities that may be present.
The botanical survey must take place during the appropriate season during which the target species can be readily detected and accurately identified. Botanical surveys should generally take place while target plants are in bloom. Multiple years of surveys may be required to accurately assess the location of or determine the absence of short-lived plant species or plants species with a persistent seed bank. Botanical field surveys should be floristic in nature, meaning that every plant taxon that occurs in the project area is identified to the taxonomic level necessary to determine rarity and listing status.
A Qualified Botanist must meet the following requirements:
• Knowledge of plant taxonomy and natural community ecology; • Familiarity with plants of the region, including the plants targeted for survey and any special status plants (or host plants of special status insects) that may occur in the survey area;
• Familiarity with natural communities of the region, including California Sensitive Natural Communities;
• Experience with the CNDDB, BIOS, and Survey of California Vegetation Classification and Mapping Standards;
• Experience conducting floristic botanical field surveys; • Familiarity with federal, state, and local statutes and regulations related to plants and plant collecting; and
• Experience analyzing the impacts of projects on native plant species and sensitive natural communities.
If a project will involve earth disturbance, grading, grubbing, staging or other temporary or permanent impacts to areas not mapped as “Urban and Non Urban with Little or No Habitat Value” in Figure 7-3 of the General Plan, a Qualified Wildlife Biologist will survey for special status wildlife species and their habitat. A qualified wildlife biologist must be familiar with identification of essential physical and biological features for special status wildlife species, including space for individual and population growth and for normal behavior; cover or shelter; food, water, air, light, minerals, or other nutritional or physiological requirements; sites for breeding and rearing offspring; and habitats that are protected from disturbances or are representative of the historical geographical and ecological distributions of the species.
A Qualified Wildlife Biologist must meet the following requirements:
• Demonstrated professional experience identifying all of the target wildlife species at all life history stages;
• Experience and knowledge of the natural history, habitat affinities and wildlife species needs;
• Familiarity with federal, state, and local statutes and regulations; and • State and federal handling permits (as needed).
Rationale:
This policy is currently redundant to CO-I-31 and CO-I-26. It probably would make sense to combine these, however, if it is required to have a separate policy specific to ESHA under the Coastal Act, I have added the same recommended language to both CO-I-26 and CO-I-27. Preproject (and pre-approval) biological survey requirements should be the same inside and outside of the Coastal Zone in Pacifica since special status species and plant communities have high potential to occur in Pacifica both within and outside of the Coastal Zone. Figure 7-3 of the General Plan is an appropriate figure to use, and all of the areas not mapped as “Urban and NonUrban with Little or No Habitat Value” have sufficient potential for rare and special status species and their habitats to require a biological survey.
Any earth disturbing activity, and even off-road access in some cases, has the potential to damage or destroy sensitive habitat and species. For example, Mission blue butterfly is on or near its host plants in some life stage year-round, even when the host plant is dormant, low to the ground, and difficult to detect. “Take” of this endangered species could occur by any activity that would crush or destroy the host plants. Earth disturbing activities also have the potential to destroy the seed bank of special status plant species. Pacifica should consider any earth disturbing project-related activities to require biological surveys prior to authorization.
Planners and project applicants should be aware that biological surveys for special status plants and butterfly host plants often have a seasonally narrow window during which they can take place and plan accordingly. For example, Western leatherwood (Dirca occidentalis) a CRPR 1B.2 shrub found in Pacifica, is generally difficult to identify outside of January or February, while some grassland annual plants may not be identifiable until mid-summer. A project proposed in late-summer without biological surveys in hand may need to wait until the following summer so that surveys can be completed. Anticipating this need and performing surveys proactively will prevent project delays and reduce frustration on the part of applicants. A coordinated voluntary program for private landowners to pay into and participate in a coordinated larger-scale biological resource survey would be very valuable. Qualifications for a Qualified Botanist and Qualified Wildlife Biologist should be spelled out explicitly since the effectiveness of this Policy hinges on the professional qualifications of these individuals.
For additional supporting information see:
https://www.cnps.org/wp-content/uploads/2019/10/Bot-Cert_2018-CDFW-Plant-andVegetation-Survey-Protocols-LR.pdf CO-I-32 – Monitoring Requirements – General Plan and DEIR (not found in DEIR) Recommended Edits:
*NOTE – This policy is an extremely important component of impact reduction and it should be added as a mitigation requirement to the DEIR.
CO-I-32 - Restoration and Monitoring Requirements. Require a Restoration and Monitoring Proposal for any proposed habitat restoration or mitigation. The Proposal should describe the methods and practices to be employed, and include:
• A clear statement of the goals of the restoration or mitigation for all habitat types; • Sampling of reference habitat, with reporting of resultant data; • Designation of a qualified biologist as the Restoration or Mitigation Manager responsible for all phases of the restoration;
• A specific grading plan, if the topography must be altered; • A specific erosion control plan, if soil or other substrate will be disturbed during restoration, which should utilize erosion control materials free of invasive species (including invasive plant seeds), plastic microfibers and materials that are free of weed seeds, pests, pathogens, and other invasive species;
• An invasive species introduction avoidance plan to minimize introduction of new weeds, pests, or pathogens to the site. This should include
o a plan to clean equipment and vehicles before they arrive on site, and inspections to confirm that equipment and vehicles are free of soil, organic material, and vegetative debris prior to entering the work site,
o a plan to reject seed lots that contain invasive species that are not already present on the site or adjacent areas so they will not introduce new invasive species to the area, and
o a plan to require that all imported organic materials such as mulch, compost, and erosion control materials be free of new invasive species including invasive plants, animals, pests, or pathogens;
• A weed eradication plan designed to eradicate existing a specified list of target weeds (non-native invasive plant species expected to interfere with the restoration goals such as all CalIPC high and moderate species that form monocultures) and control future invasion by exotic species maintaining target invasive plant cover below 5% total absolute cover site-wide of target invasive plant species (unless restoration goals or reference sites justify a higher percent cover);
• A planting plan based on the natural habitat type using seeds wherever possible and using best management practices for avoiding introduction of plant pests and pathogens if container plants must be used;
• An irrigation plan that describes the method and timing of watering and ensures removal of watering infrastructure by two years prior to the end of the monitoring period; • An interim monitoring plan with annual reporting and a 5 year minimum reporting period with performance goals, assessment methods, and a schedule; and • A final monitoring planperformance criteria to determine whether the restoration has been successful.
Rationale:
Restoration is an extremely important component of impact mitigation and this measure should be robust (and in the DEIR!). Ecological restoration is complex and difficult and if done poorly, not only will fail, but can actually have significant impacts to surrounding natural areas.
Incorporating the specific added guidance I suggest above into the DEIR will help these restoration projects be successful.
Many erosion control materials contain plastics. The natural fibers in these materials degrade, while the plastic fibers do not. These bundles of loose plastic fibers pose wildlife entrapment hazards for special status and non-special status wildlife. For more information see:
https://documents.coastal.ca.gov/assets/water-quality/permits/WildlifeFriendly_Netting_in_Erosion_&_Sediment_Control-Factsheet_r5_Sept_2016.pdf Not all invasive species can be controlled, for example, some Cal-IPC high and moderate nonnative perennial grasses generally grow intermixed with native plant species in such a way that controlling them could be excessively destructive and undermine the success of a restoration project. Non-native invasive plant species should be selected for control depending on controllability, presence in San Mateo County (not just the site), and the restoration goals. Once selected, presence of these target species should be maintained so that the sum-total of the absolute cover by all target invasive plant species is less than 5% absolute cover. This is an achievable objective that keeps the seed bank, rhizomes, or other propagules of invasive plant species sufficiently under control so that the native plant species have room to become established.
To make sure the restoration plantings are self-sustaining, the irrigation should be stopped 2 years before the end of the performance monitoring period. Although I did not include this in the Policy as an edit, there should also be some restriction on replacement planting or re-seeding efforts during the final years of the performance monitoring period to ensure that the site is selfsustaining, however, you don’t want to disallow replanting completely since it can be a valuable site management strategy that improves outcomes.
Introducing a new invasive plant species, plant pest or pathogen to a restoration site has the potential to not only undermine the success of the restoration project but devastate surrounding natural areas. Planting should be done using direct seeding (not rooted plants) as much as possible to avoid unintentional introduction of invasive species. Imported materials should be free of invasive species to the degree possible as well and equipment and vehicles should be inspected as they arrive on site and only allowed to enter if they are free of organic matter. Also see my comments on CO-I-36 below.
Best management practices for avoiding spread of plant pathogens during restoration projects can be found here:
http://www.suddenoakdeath.org/welcome-to-calphytos-org-phytophthoras-in-nativehabitats/#WG More information about how restoration activities have introduced destructive plant pathogens into natural areas in California and the Bay Area can be seen here:
https://www.mdpi.com/1999-4907/11/12/1291
Policy CO-I-36 – Minimizing Introduction of Invasive Plant Species Through Plantings (see CO-I-38 of DEIR)
CO-I-36 Minimizing Introduction of Invasive Plant Species Through Plantings. Encourage planting of locally appropriate native plants directly from seed. If direct seeding is not possible, encourage sourcing of plants from nurseries which use techniques that minimize the risk of accidental introduction and spread of invasive species (such as, plant pests, plant pathogens, and invasive insects). Prohibit the use of invasive plant species (i.e., any California Invasive Plant Council (Cal- IPC)-listed species with a status of high or moderate, or identified such as locallythreatened under the limited, alert, or watch status).
Rationale:
Planting rooted plants grown in containers is a surprisingly risky activity. It is easy to accidentally introduce and spread invasive species. Invasive species that can move in plant containers include plant disease, plant pests, and other invasive invertebrate species. For example, Argentine ants thrive in plant nurseries and while they don’t attack plants, they do displace native ants where they are introduced.
Use of container plants in restoration has been documented as an introduction pathway for plant pathogens in California and the Bay Area. For more information see Phytophthora Introductions in Restoration Areas: Responding to Protect California Native Flora from Human-Assisted Pathogen Spread at the link below:
https://www.mdpi.com/1999-4907/11/12/1291
Best practices for avoiding spread of plant pathogens during restoration projects can be found here:
http://www.suddenoakdeath.org/welcome-to-calphytos-org-phytophthoras-in-nativehabitats/#WG Policy CO-I-37 – Beach Grooming – DIER and General Plan (See DEIR CO-I-39) Recommended Edits:
Note: The numbering seems to be incorrect in the DEIR, the numbering in the DEIR should be updated to reflect the numbering in the General Plan
Policy CO-I-37 – Beach Grooming. Work with the State of California, GGNRA, and other partners in the management of beaches in Pacifica to ensure biological resources are NOT adversely affected by beach grooming. Specifically, protect beach wrack (the piles of plant and animal debris that wash ashore), which plays an important role in the beach ecosystem.
Rationale: This appears to be a typo.
Policy SA-I-95 DEIR and General Plan
Recommended Edits:
Plan Review in Fire-Prone Areas. Continue to request the North County Fire Authority participation in plan review of new buildings in potentially fire-prone areas. New construction in fire prone areas shall be required to incorporate appropriate additional fire protections to minimize risk of fire and to minimize the need for fuel reduction, vegetation clearing, and destruction of habitat in adjacent wildland areas. Potentially fire prone areas are shown in Figure 8-7 of the General Plan.
*NOTE – Figure 8-7 of the General Plan must be updated to show the fire hazard throughout the study area (for more information see my comment on Figure 8-7 below).
Rationale:
It should be clear to planners when this measure should be implemented. A map would be the clearest way to show what areas are potentially fire prone and where Policy SA-I-95 would be applicable and required. Requiring new structures to be designed to be as fire resistant as possible would protect surrounding open space areas and reduce potential future cost to Pacifica (and society more broadly) in two ways: (1) by reducing the likelihood that structures are a source of ignition and cause of a-seasonal, overly frequent, or otherwise unnatural wildfire, and (2) by reducing the need to remove fuels (plants) from natural areas to protect structures. Fuel breaks are expensive to maintain, of limited efficacy in many situations, and can be destructive of natural habitats. It is better to build new structures to resist and withstand fire.
San Pedro Creek watershed – Page 3.5-4 of DEIR
Recommended Edits: Please add two more special status fish species to the list for San Pedro Creek
• Pacific lamprey (Entosphenus tridentatus) which is a CDFW Species of Special Concern and is mentioned in the General Plan as being present in San Pedro Creek; and • northern tidewater goby (Eucyclogobius newberryi) which has been detected in San Pedro Creek (Sutter and Kinziger, 2019) and is listed as Endangered under federal ESA by the Fish and Wildlife Service
Annual Grasslands - Page 3.7-2 of DEIR and Page 7-16 of General Plan Recommended Edits:
Annual Grasslands
Annual gGrasslands in Pacifica often occur most often in a mosaic pattern with coastal scrub and are dominated by non-native annual grass species and a variety of other non-native weeds. The presence of these grasslands in Pacifica is limited and generally occurs in highly disturbed areas.
Damage to grasslands is a result ofSome of Pacifica’s grasslands have been damaged by unauthorized vehicle activity, which resulting in off-road trails on hillsides. Many of Pacifica’s grasslands contain a mix of native and non-native grasses and forbs. Although some of the grasslands in Pacifica have been highly disturbed, other grasslands within Pacifica are known to support red fescue (Festuca rubra) prairie, and intact stands of California fescue (Festuca californica), needle grass (Stipa pulchra), Pacific reed grass (Calamagrostis nutkaensis), and blue wild rye (Elymus glaucus). The grasslands and prairies within Pacifica are also known to support a number of special status rare plant species. The grassland communities in Pacifica have not been surveyed extensively, however, grasslands in coastal California are known to support a high native component of native perennial grass species relative to inland California grasslands.
Grasslands provide essential basking, foraging, and sheltering habitat for reptiles and amphibians including the federally protected (Threatened) California red-legged frog, and state and federally protected (Endangered) San Francisco garter snake. Grassland communities with higher proportions of native species support more complex biological community of insects, over a wider range of seasonal conditions, and are therefore a better source of food for insectivorous wildlife such as adult California red-legged frog and Sierran tree frog, which are both important prey species for the San Francisco garter snake.
Rationale:
Referring to the grasslands within the study area as “annual” and “highly disturbed” presumes a low ecological value that is misleading and inaccurate. Pacifica’s grasslands and prairies, like almost all of California’s grasslands, do contain non-native annuals, however, many of these areas within Pacifica contain a significant component of native grassland and forb species. The grasslands and prairie in Pacifica provide essential refugia for native, rare, and special status grassland plant species in addition to habitat for special status wildlife.
For more information about the relative importance and rarity of grasslands in California, please also see the California Native Grassland Association (CNGA) website which points out, “To date, our state has already lost 99% of our native grasslands. With only 1% of our native grassland remaining statewide it is critical that we protect every remaining acre.” https://cnga.org/Conservation#:~:text=The%20California%20Native%20Grassland%20Associati on,UC%20Santa%20Cruz%20East%20Meadow.&text=To%20date%2C%20our%20state%20ha s,99%25%20of%20our%20native%20grasslands
In the absence of a complete survey of existing grasslands within the study area, this DEIR should not assume the absence of remnant patches of special status grasslands (CDFW designated California Sensitive Natural Communities) or special status native grassland and forb species.
Grasslands typically are complex and can contain within them mosaic patterns at a very fine scale that can only be detected through appropriately timed botanical surveys in the field.
Grassland communities with a native component should be prioritized for protection when possible over communities that are exclusively non-native.
The following species are ranked as California Rare Plants in CalFlora and are present or likely to be present in Pacifica. Although these species are mostly only documented in protected areas of Pacifica, the lack of observations in unprotected areas are likely due to lack of surveys rather than lack of actual presence on privately owned lands.
1. Centromadia parryi ssp. parryi, a dicot, is an annual herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 1B.2 (rare, threatened, or endangered in CA and elsewhere). Present Mori Point, Aramai Point
2. Chorizanthe cuspidata var. cuspidata, a dicot, is an annual herb that is native to California, and endemic (limited) to California.
California Rare Plant Rank: 1B.2 (rare, threatened, or endangered in CA and elsewhere).
3. Leptosiphon rosaceus, a dicot, is an annual herb that is native to California. California Rare Plant Rank: 1B.1 (rare, threatened, or endangered in CA and elsewhere).
4. Silene scouleri ssp. scouleri, a dicot, is a perennial herb that is native to California, and also found elsewhere in western North America. Present PPH
California Rare Plant Rank: 2B.2 (rare, threatened, or endangered in CA; common elsewhere)
5. Arabis blepharophylla, a dicot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.3 (limited distribution).
Present PPH* and Milagra Ridge
6. Erysimum franciscanum, a dicot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.2 (limited distribution) Present PPH* and Milagra Ridge
7. Piperia michaelii, a monocot, is a perennial herb that is native to California, and endemic (limited) to California. California Rare Plant Rank: 4.2 (limited distribution).
Present PPH* and Aramai Point
See also Appendix below for a list of native grassland species that have been observed in Pacifica and documented in the iNaturalist database.
Vegetation Map - Figure 3.7-1 - Page 3.7-4 of DEIR & Figure 7-2 on Page 7-15 of General Plan
Recommended Edits:
Change the label on the legend and map from “Annual Grasslands” to “Grasslands/Prairie.” Update the landscape and vegetation map using recent GIS layers available for San Mateo County through the Fine Scale Vegetation Map and Landscape Database Project. See links and explanation below.
Rationale:
The term “Annual Grasslands” is an inaccurate and misleading title for the grasslands and prairie in the study area. Pacifica’s grasslands and prairie, like almost all of California’s grasslands do contain non-native annuals, however, many grasslands within Pacifica contain remnant patches of native grassland communities, as well as individual native grassland and forb species. These grasslands are essential refugia for native, rare, and special status grassland species. Re-labeling to “Grasslands/Prairie” would be a more accurate label for the grasslands in the study area that reflects our currently incomplete knowledge and the potential for important native biotic communities to occur within these areas.
For more information about the importance of using the correct terminology in CEQA documents for Grassland and Prairie see:
PRAIRIES AND GRASSLANDS: WHAT’S IN A NAME? by Glen Holstein):
https://cnps.org/wp-content/uploads/2018/03/FremontiaV39.2_39.3.pdf More accurate mapping data is available for Pacifica as a part of recent work to develop landform and fine scale vegetation maps for San Mateo County. Updating the map with this upto-date data would provide a more accurate and defensible basis for this General Plan and EIR.
For more information and access to this data, please see the websites below. https://www.nps.gov/articles/vegetation-mapping-projects-underway.htm https://www.nps.gov/articles/000/new-draft-lifeform-map-available-for-san-mateo-county.htm Comment on the Regulatory Setting (in General Plan and DEIR) Please cross check and update special status of species named in the conservation chapters and include all special status species found in Pacifica. Specific examples include:
• tricolored blackbird is listed as Threatened under California ESA and is mentioned in the General Plan as present in Pacifica but its special status is not mentioned • Pacific lamprey is a CDFW Species of Special Concern and is mentioned in the General Plan as present in San Pedro Creek but its special status is not mentioned • monarch butterfly was not mentioned but is a candidate for listing under federal ESA and is likely present in Pacifica
• mountain lion is not mentioned and is a candidate species under California ESA • northern tidewater goby (Eucyclogobius newberryi) has been detected in San Pedro Creek (Sutter and Kinziger, 2019) and is listed as Endangered under federal ESA by the Fish and Wildlife Service and should be mentioned (currently is not mentioned in the General Plan or DEIR)
Fire Hazards and Public Safety Services - Figure 6.11-3 on page 3.11-4 of DEIR and Figure 8-7 on Page 8-36 of General Plan
Recommended Edits:
Please expand the fire hazard mapping to include all undeveloped areas in the plan area. This figure currently has no information about fire hazard outside of the State Responsibility Area, which means there is no information shown for most of the plan area. This should be corrected.
The GIS layers available for San Mateo County through the Fine Scale Vegetation Map and Landscape Database Project include a 5 m fuels model as well as LiDAR slope data. These should be combined to generate a basic fire hazard map for the undeveloped portions of Pacifica.
Additional refinements could be added later. This fire hazard map should be calibrated to use similar criteria for hazard classifications used by CalFire so the mapping is consistent throughout the plan area. This map should be reviewed by the North County Fire Authority prior to finalization. For more information about the 5 m fuels and LiDAR data see links below. https://www.nps.gov/articles/vegetation-mapping-projects-underway.htm https://www.nps.gov/articles/000/new-draft-lifeform-map-available-for-san-mateo-county.htm Appendix
Additional native species below are confirmed in Pacifica’s grassland/prairie communities according to iNaturalist, Calflora, and as compiled by *Kramer Botanical, Vascular Plant Species within the Pedro Point Headlands Trail Improvement and Restoration Project Area, February 2016.
https://www.calflora.org//app/ipl?vrid=ce891&bloom=t
https://www.inaturalist.org/check_lists/3273-Mori-Point-Check- List?iconic_taxon=47126&without%5B%5D=page&without%5B%5D=q
https://www.inaturalist.org/check_lists/5529-Milagra-Ridge-Check- List?iconic_taxon=47126&without%5B%5D=page&without%5B%5D=q Native plants commonly present on grassland/prairie in Pacifica Alliaceae Allium dichlamydeum Coast Onion
Anacardiaceae Toxicodendron diversilobum Pacific Poison Oak Apiaceae Angelica hendersonii Henderson's Angelica
Daucus pusillus American Wild Carrot
Heracleum maximum Cowparsnip
Lomatium utriculatum Lomatium
Sanicula arctopoides Footsteps of Spring
Sanicula crassicaulis Pacific Sanicle
Agavaceae Chlorogalum pomeridianum Wavy-leafed Soap Plant Dipterostemon capitatus Blue Dicks
Triteleia laxa Ithuriel's Spear
Asteraceae Achillea millefolium Common Yarrow
Anaphalis margaritacea Pearly Everlasting
Centromadia parryi ssp. parryi Papoose Tarplant 1B.2
Cirsium occidentale Cobweb Thistle
Circium quercetorum Brownie Thistle
Grindelia stricta Pacific Gumplant
Lasthenia californica Goldfields
Lasthenia minor Coastal Goldfields
Layia platyglossa Tidytips
Madia sativa Coast Tarweed
Pseudognapthalium californicum California Cudweed
Pseudognaphalium ramosissimum Pink Everlasting
Solidago velutina ssp. californica Goldenrod
Symphyotrichum chilense Pacific Aster
Wyethia angustifolia Narrowleaf Mule-Ears
Boraginaceae Amsinckia menziesii Coast Fiddleneck
Phacelia californica California Phacelia
Phacelia malvifolia Stinging Phacelia
Brassicaceae Arabis blepharophylla Coast Rockcress 4.3
Erysimum franciscanum San Francisco Wallflower 4.2
Caryophyllaceae Silene scouleri ssp. scouleri Scouler Catchfly 2B.2 Convolvulaceae
Calystegia purpurata ssp
purpurata Smooth Westerng Morning glory
Calystegia subacaulis Hill Morning Glory
Curcurbitacea Marah fabacea California Manroot
Marah oregonus Coast Manroot
Fabaceae Astragalus nuttallii Bladder Pod
Lupinus nanus Sky Lupine
Lupinus variicolor Varied Lupine
Lupinus albifrons Silver Lupine
Lupinus bicolor Miniature Lupine
Vicia gigantea Giant Vetch
Iridaceae Iris douglasiana Douglas Iris
Iris longipetala Central Coast Iris
Sisyrinchium bellum Western Blue-eyed Grass
Lamiaceae
Clinopodium douglasii (Satureja
douglasii) Yerba Buena
Monardella villosa Coyote Mint
Stachys bullata Hedgenettle
Salvia spathacea Hummingbird Sage
Liliaceae Calochortus albus White Fairy-lantern
Fritillaria affinis Checker Lily
Toxicoscordion fremontii Fremont's Deathcamus
Malvaceae Sidalcea malviflora Checkerbloom
Onagraceae Clarkia rubicunda Ruby Chalice Clarkia
Taraxia ovata Sun Cup
Orchidaceae Piperia michaelii Michael's Rein orchid 4.2 Orobanchaceae
Castilleja densiflora ssp
densiflora Dense Flower Owl Clover
Castilleja exserta ssp exserta Purple Owl's Clover
Castilleja wightii Wight’s Paintbrush
Orobanche californica ssp
californica California Broomrape
Triphysaria pusilla Dwarf Owl's Clover
Papaveraceae Eschscholzia californica California Poppy
Plantaginaceae Plantago erecta Dotseed (Dwarf) Plantain Poaceae Agrostis pallens Leafy Bentgrass
Agrostis exarata Spike Bentgrass
Bromus carinatus California Brome
Bromus sitchensis var. maritimus Maritime Brome
Calamagrostis nutkaensis PacificReed Grass
Danthonia californica California Oatgrass
Deschampsia cespitosa Tufted Hair Grass
Elymus glaucus ssp. Glaucus Blue Wild Rye
Elymus triticoides Beardless Wild Rye
Festuca californica California Fescue
Festuca rubra Red Fescue
Hordeum brachyantherum Meadow Barley
Hordeum depressum Dwarf Barley
Koeleria macrantha Junegrass
Leymus triticoides Beardless Wildrye
Melica californica California Melicgrass
Melica torreyana Torrey's Melica
Stipa pulchra Purple Needlegrass
Stipa lepida Foothill Needlegrass
Poa unilateralis San Francisco Bluegrass
Polemoniaceae Navarretia squarrosa Skunkweed
Leptosiphon rosaaceus Rose Leptosiphon 1B.1
Polygonaceae Eriogonum latifolium Seaside Buckwheat
Chorizanthe cuspidata sp
cuspidata San Francisco Spineflower 1B.2
Portulacaceae Calendrinia ciliata Red Maids
Ranunculaceae Ranunculus californicus California Buttercup Rosaceae Acaena pinnatifida Biddy-biddy, Sheepburr
Horkelia californica California Horkelia
Rubus ursinus Califonria Blackberry
Themidaceae Triteleia laxa Ithuriel's spear
From: John Keener [ ]
Sent: Thursday, February 17, 2022 11:02 AM
To: Public Comment [[email protected]]; Murdock, Christian [[email protected]]
Subject: GP comments from Pacifica Land Trust
Attachments: GPUupdateLetter.doc
[CAUTION: External Email]
Hi Christian and others,
Attached are comments on the General Plan Update from the Pacifica Land Trust. They mostly concern trails and land ownership.
Thank you for the opportunity to comment.
Best regards,
John Keener
President, Pacifica Land Trust
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.
Pacifica Land Trust
Pacifica, CA 94044
February 17, 2022
To whom it may concern,
The board of the Pacifica Land Trust has the following comments on and proposed changes to the General Plan Update. They center around inaccuracies regarding trails at Pedro Point Headlands. The current text is shown in bold.