Cities Index.
Attachment B - Summary Table With All Suggested Modifications

Pacifica City Council
November 13, 2023

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Attachment B - Summary Table With All Suggested Modifications
Meeting
November 13, 2023
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Pacifica City Council
Original file
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Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 2 24 2.1 Parks and
Open Space
Sandy beach areas; including properties that are fully on beaches or coastal dunes or bluffs;
New text
2 26 2.2 Coastal
Development
Review
These exemptions are generally set
forth in Section 30610 of the PRC and
Sections 13252, 13252, and 13250 of
the California Code of Regulations
(CCR)
These exemptions are generally set
forth in Section 30610 of the PRC and
Sections 13252, 13253, and 13250 of
the California Code of Regulations
(CCR).

Typo Correction
2 26 2.3 LD-I-2: Land
Divisions in the
Coastal Zone
N/A Prohibited on properties that are
within the Coastal Vulnerability Zones,
unless the resulting parcels are set
aside for conservation, or unless the
resulting parcels can be developed
consistent with the LCP.

Restates Coastal Act
prohibition on intensifying
land use/subdividing land in
hazard areas.
2 26 2.4 LD-I-3: Coastal
Development
Permit
Findings
N/A In advance of updating the
Implementation Plan for conformance
with the policies of this 2023 Land Use
Plan, the policies of the Land Use Plan
shall provide the standard of review
for any proposed new development,
including where these policies are
more protective of ESHA and other
coastal resources and maximizing
public access as consistent with the
Coastal Act.

Resolves potential conflicts
during transition period
following LCLUP certification
until General Plan and zoning
(Implementation Plan, or IP)
is updated.
2 35 2.5 Central
Pacifica
Coastal Zone
Any development of the Quarry site
will require detailed evaluation of
biological resources to ensure that
sensitive habitat and wetlands are
protected; the likely footprint of
development could be much smaller
than the area designated.

Any development of the Quarry site
will require detailed evaluation of
biological resources to ensure that
sensitive habitat and wetlands are
protected; and should be sited and
designed to minimize coastal hazard
risks in accordance with policies in
Chapter 5 and 6 of the LUP. The likely
footprint of development could be
Restates coastal
development requirements
related to hazards and refers
to the relevant Chapters 5
and 6 of the LCLUP.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary much smaller than the area
designated.
2 40 2.6 LD-I-14:

Promenade
Area and
Beach
Boulevard
Property
Enhance the Promenade area as a local
community and tourist destination.

Enhance the Promenade area as a local
community and tourist destination,
while also ensuring that it adequately
responds to and addresses coastal
hazard considerations consistent with
the LCP.

Policy as amended that could
impact development on the
site - To be discussed
2 40 2.6 LD-I-14:

Promenade
Area and
Beach
Boulevard
Property
The preferred use is a hotel if market
conditions allow, but other appropriate
uses will include a conventional
commercial/residential mixed-use
project with cafes, restaurants, retail,
and upper-level housing. The mix of
uses for any non-hotel project shall
emphasize uses that are of interest to
visitors and that generate revenues for
the City.

Appropriate uses could include a hotel
or conventional commercial/residential
mixed-use project with cafes,
restaurants, retail, and upper-level
housing, if such uses are deemed
appropriate considering coastal
hazards and the required protections
for coastal resources. The mix of uses
for any proposal shall emphasize uses
that are of interest to visitors and that
generate revenues for the City.

Eliminates hotel as preferred
use, but hotel is allowed
2 40 2.7 LD-I-16:

Rockaway
Quarry Site
Enable the responsible development
and environmental conservation of the
Quarry Site.

Enable the responsible development
and environmental conservation of the
Quarry Site, considering the potential
coastal hazard constraints (including
but not limited to bluff erosion, slope
stability, and flooding), as well as the
biological constraints (specific to
sensitive species, environmentally
sensitive habitat areas, and wetlands)
and coastal resource protection more
broadly.

Restates coastal
development requirements
related to hazards and
biological resources
protections.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 2 40 2.7 LD-I-16:

Rockaway
Quarry Site
Allowable development should provide
City revenues substantial public open
space, and commercial uses and public
spaces attractive to both visitors and
local residents.

Allowable development should provide
community benefits, including
substantial public open space, and
commercial uses and public spaces
attractive to both visitors and local
residents.

Revised City revenues to
community benefits.
2 41 2.8 LD-I-20:

Undeveloped
San Pedro
Avenue Site
Establish a Coastal Residential Mixed
Use zoning district to allow small-scale
visitor-oriented commercial uses as a
stand-alone project without any
residential development, or small-scale
visitor-oriented commercial uses with
residential development at a density
range of three to five units per gross
acre. Housing may be clustered, and
uses may be mixed vertically or
horizontally. Residential uses may be
constructed attached to or detached
from commercial uses, provided the
overall site contains both commercial
and residential uses. Development
must include public coastal access and
must provide public open space.

Establish a Coastal Residential Mixed
Use zoning district to allow small-scale
visitor-oriented commercial uses as a
stand-alone project without any
residential development, or small-scale
visitor-oriented commercial uses with
some low density residential
development. Housing may be
clustered, and uses may be mixed
vertically or horizontally. Residential
uses may be constructed attached to
or detached from commercial uses,
provided the overall site contains both
commercial and residential uses.

Deletes specified density
range for the San Pedro Ave
site.
41 2.8 LD-I-20:

Undeveloped
San Pedro
Avenue Site
Establish a Coastal Residential Mixed
Use zoning district to allow small-scale
visitor-oriented commercial uses as a
stand-alone project without any
residential development, or small-scale
visitor-oriented commercial uses with
residential development at a density
range of three to five units per gross
acre. Housing may be clustered, and
uses may be mixed vertically or
horizontally. Residential uses may be
constructed attached to or detached
Development must include public
coastal access, provide public open
space, and consider all biological
constraints.

Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary from commercial uses, provided the
overall site contains both commercial
and residential uses. Development
must include public coastal access and
must provide public open space.
2 42 2.9 LD-I-26:

Enhanced
Visitor Node
Create a visitor-oriented commercial
and hospitality node at Rockaway
Beach and on developable portions of
the Rockaway Quarry site which
contains distinctive design, uses, and
recreational opportunities.

Taking all site constraints into account,
create a visitor-oriented commercial
and hospitality node at Rockaway
Beach and on developable portions of
the Rockaway Quarry site which
contains distinctive design, uses, and
recreational opportunities.

Restates coastal
development requirements
related to considering site
constraints such as coastal
hazards.
2 43 2.10 Development
Capacity and
Projections
As noted above, the Quarry site’s
development capacity may be further
reduced by site-specific analyses of
geotechnical and biological.

As noted above, the Quarry site’s
development capacity may be further
reduced by site-specific analyses of
geotechnical and biological constraints.

Typo Correction
2 48 2.11 LD-I-27: Public
Service
Priorities
Ensure that needs generated by
development or uses permitted over
the planning period are adequately
served by existing and planned public
works facilities.

Ensure that needs generated by
development or uses permitted over
the planning period are adequately
served by existing and planned public
works facilities, and plan for the
maintenance, operation, expansion
and improvement to public facilities
considering threats from coastal
hazards. Support studies that evaluate
the condition of critical facilities,
especially public works infrastructure
that has been identified as vulnerable
to hazards. Studies shall include
alternatives analyses for potential
retrofit, improvements, relocation, or
other considerations.

Requires analysis of
alternatives for potential
retrofit or relocation but
does not mandate relocation.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 2 49 2.12 LD-I-37: Public
Services for
New
Developments
N/A Public Services for New Development.

Development shall only be approved if
it can be shown that it can be
accommodated by adequate and
sustainable public services (including in
terms of water, sewer, and circulation)
without any significant impacts to
coastal resources. Public service
development shall be limited to levels
that are sufficient to accommodate
LCP consistent development, including
at buildout, and shall not be allowed if
it would be growth inducing past that
threshold.

New policy applicable to new
development. As proposed,
the policy may impact
infrastructure that serves
areas outside the Coastal
Zone - To be discussed
3 55 3.1 Coastal Access
Points
Maintain public parking as part of
redevelopment of City-owned 2212
Beach Boulevard property.

Maintain public parking as part of
redevelopment of City-owned 2212
Beach Boulevard property and
maintain lateral access along Beach
Boulevard to the Pier.

Adds requirement for lateral
access
3 57 3.2 Coastal Access
Points
N/A Conduct a prescriptive rights study. Requires additional study 3 57 3.2 Coastal Access
Points
N/A Conduct a prescriptive rights study. Requires additional study Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 3 59 3.3 PR-I-8:

Temporary
Events
N/A Only temporary event meeting all the
above criteria shall require coastal
development permit review, however,
the Planning Director may also exclude
from permit requirements temporary
events meeting all the above criteria
when:
• The fee is for preferred seating only
and more than 75% of the provided
seating capacity is available free of
charge for general public use; or,
• The event is held on sandy beach
area in a remote location with minimal
demand for public use, and there is no
potential for adverse effect on
sensitive coastal resources; or
• The event is less than one day in
duration; or
• The event has previously received a
coastal development permit and will
be held in the same location, at a
similar season, and for the same
duration, with operating and
environmental conditions essentially
the same as those associated with the
previously-approved event.

The Planning Director (or the Coastal
Commission’s Executive Director if the
Planning Director’s determination is
challenged) may determine that a
temporary event, even an event that
New policy text.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary might otherwise not require a coastal
development permit per this section
above, shall require a coastal
development permit if he/she
determines that unique or changing
circumstances exist relative to the
particular temporary event that have
the potential for significant adverse
impacts on coastal resources. Such
circumstances may include, but shall
not be limited to, the following:
• The event, either individually or
together with other temporary events
scheduled before or after the
particular event, precludes the general
public from use of a public recreational
area for a significant period of time; or
• The event and its associated activities
or access requirements will either
directly or indirectly impact
environmentally sensitive habitat
areas, rare or endangered species,
significant scenic resources (including
as mapped on the LCP Land Use Plan
maps or as determined during project
review), or other coastal resources; or
• The event is scheduled between
Memorial Day weekend and Labor Day
and would restrict public use of
roadways or parking areas or
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary otherwise significantly impact public
use or access to coastal waters; or
• The event has historically required a
coastal development permit to address
and monitor associated impacts to
coastal resources.Temporary events
located solely within the Coastal
Commission’s original coastal
development permit jurisdiction area
require review and determination of
coastal development permit
requirement or temporary event
exemption from the Coastal
Commission
3 61 3.4 PR-I-12:

Coastal Access
Point South of
San Francisco
RV Park
Lateral access along the bluffs should
be provided from this coastal access
point to City- and Coastal Commissionrequired public access at San Francisco RV Park to the north, and to properties
to the south upon future
redevelopment.

Lateral access along the bluffs as well
as vertical trail improvements should
be provided from this coastal access
point to City- and Coastal Commissionrequired public access at San Francisco RV Park to the north, and to properties
to the south upon future
redevelopment.

Inclusion of vertical trail
improvements.
3 69 3.5 PR-I-24: Sharp
Park
Support the continued operation of
golf at Sharp Park Golf Course
consistent with redeveloping source
protection, natural hazard, and coastal
vulnerability policies, and support
development of additional recreational
uses in upland portions of the Park
located outside the Coastal Zone east
of Highway 1.

Support the continued operation of
golf at Sharp Park Golf Course
consistent with redeveloping source
protection, natural hazard, and coastal
vulnerability policies, existing CDP
terms and conditions, and support
development of additional recreational
uses in upland portions of the Park
located outside the Coastal Zone east
of Highway 1.

Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 3 73 3.6 PR-G-11: Trail
System
Expansion
Expand the trail system in Pacifica to
create a connected trail network with
communitywide links to open space
and recreation facilities, as shown on
Figure 3-3.

Expand the trail system in Pacifica to
create a connected trail network with
communitywide links to open space
and recreation facilities, as shown on
Figure 3-3, and to enhance and
augment California Coastal Trail
connections and connectivity.

Adds requirement for
California Coastal Trail
3 85 3.7 PR-I-57:

Roadway
Retrofits
Roadway retrofits will require
additional analysis.

Roadway retrofits will require
additional analysis, such as coastal
hazard concerns in areas within the
Coastal Zone.

Clarification
3 86 3.8 PR-I-60:

Roadway
Abandonment
/Vacation and
Public Access
Do not abandon, vacate, or render
unusable any City-owned right-of-way,
unless necessary for reasons of public
safety or environmental conservation.

Whenever public roadways are
proposed to be abandoned, assess the
value of maintaining public pedestrian
and/or bicycle access, especially where
coastal access can be maintained or
improved. Abandonment/vacation of
any public rights-of-way that may
negatively affect coastal resources or
public access to the sea will require a
coastal development permit. Any
public right-of-way that cannot be
maintained in a condition suitable for
public use shall be offered to another
public agency or private association
that agrees to maintain the right-ofway for public use.

Do not abandon, vacate, or render
unusable any City-owned roadways
and/or rights-of-way, unless necessary
for reasons of public safety or
environmental conservation.

Whenever public roadways and/or
rights-of-way are proposed to be
abandoned, assess the value of
maintaining public pedestrian and/or
bicycle access, especially where coastal
access can be maintained or improved.

Abandonment/vacation of any public
roadways and/or rights-of-way
requires a coastal development permit,
which shall only be approved if coastal
resources can be protected in as good
or better conditions as exist at the time
of permit evaluation, and subject to
terms and conditions to ensure the
public’s interests are maintained
moving forward.

Amended to include Cityowned roadway
4 96 4.1 Surface Water Some of the watersheds drain directly into the ocean, while other feed one of
five.

Some of the watersheds drain directly
into the ocean, while other feed one of
five creeks.

Typo Correction
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 4 99 4.2 Wetlands N/A Importantly, wetlands in the coastal zone only need meet one parameter
(i.e., hydrology, hydric soils, or
hydrophytic species) to be considered
a wetland, as differentiated from three
parameter delineations which require
all three to be present (e.g., ACOE
delineations).

Clarification
4 101 4.3 ER-I-1: Creek
Protection and
Restoration.

Requiring a minimum of 100 feet
setbacks from the top of creek banks,
or from the outer edge of riparian
vegetation, where it exists, for
development proposed adjacent to
creeks, in keeping with City regulations
and Best Management Practices.

Exceptions to such buffer requirements
should be supported by a biological
report demonstrating that the adjusted
buffer, in combination with
incorporated siting, design or other
mitigation measures, shall prevent
impacts that significantly degrade the
creek. Buffer adjustments should also
be limited to where the entire subject
legal lot is within the buffer or where it
is demonstrated that development
outside the buffer would have a
greater impact on the creek.

Requiring a minimum of 100 feet
setbacks from the top of creek banks,
or from the outer edge of riparian
vegetation, where it exists, whichever
is further, for development proposed
adjacent to creeks, in keeping with City
regulations and Best Management
Practices. The 100-foot buffer may be
reduced by the minimum necessary (1)
to avoid a taking (for private
development), or (2) to provide
required public services (for public
development), provided that the
buffer is as close to 100 feet as
possible, and no less than 50 feet in
any case, and provided that creek
resource impacts are avoided as much
as possible, and unavoidable impacts
commensurately mitigated, all as
conclusively demonstrated by a
qualified biologist to the satisfaction of
the City, USFWS, and CDFW.

Amended text to clarify
exceptions. - To be discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 4 102 4.3 ER-I-1: Creek
Protection and
Restoration.

N/A Permitted uses within buffer zones are
limited to uses dependent on the
resources within these areas and their
buffer zones (i.e. habitat management
and restoration, scientific research and
educational activities, and lowintensity public access and recreation).

Temporary disruption (e.g. less than six
months) for the construction,
alteration, repair, and maintenance of
existing or newly permitted facilities or
structures is allowed if there are no
feasible alternatives, the disruption
area is restored to its pre- disruption
state or better within one year from
the initial point of impact and there is
no significant ground disturbance.

New policy text. - To be
discussed
4 106 4.4 Plant
Communities
and Wildlife
Habitats
Plant communities and habitats found
in Pacifica are briefly described below
and depicted in Figure 4-2, Vegetation.

The EIR for the General Plan and Local
Coastal Land Use Plan Update includes
a more detailed description of each of
these communities and habitats. The
listed species and habitats here are not
intended to preclude the possibility
that other species or habitat occur
within Pacifica. Species identified with
various plant communities or habitats
are not necessarily in the Planning
Area. Some of these communities are
recognized as “special status
communities,” or provide critical
habitat for special status species.

Plant communities and habitats found
in Pacifica are briefly described below
and depicted in Figure 4-2, Vegetation.

The map is illustrative and for
information purposes only; site-specific
biological studies are required as part
of proposed development review to
determine the presence and extent of
plant communities and habitat. The
mapped communities and habitats are
not intended to preclude the
possibility that other communities or
habitat occur within Pacifica, nor to
definitively conclude that. The plant
communities or habitats identified are
present as indicated, rather the map is
a tool to help identify areas where
further evaluation for biological issues
may be relevant.

Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 4 107 4.5 Annual
Grasslands
Annual Grasslands Grasslands Generalizes language
4 107 4.5 Annual
Grasslands
Northern coastal scrub habitat is found
on undeveloped slopes, often in a
mosaic with annual grasslands.

Northern maritime chaparral, a specialstatus community, is included in this category. Northern coastal scrub is
dominated by either coyote brush or
California sagebrush, depending on
slope aspect.

Northern coastal scrub habitat is found
on undeveloped slopes, often in a
mosaic with grasslands. Northern
maritime chaparral, a special-status
community, is included in this
category. Northern coastal scrub
dominated by either coyote brush or
California sagebrush, primarily
depending on slope aspect.

Generalizes language
4 108 4.6 Seasonal
Wetlands and
Ponds
Seasonal Wetlands and Ponds Wetlands and Ponds Generalizes language 4 108 4.6 Seasonal
Wetlands and
Ponds
Seasonal Wetlands occur in smaller
drainages and localized depressions,
forming ponds or flowing water, and
are underlain by saturated soils during
the winter and spring. Seasonal
wetlands also occur along the banks
and sediments that accumulate in
creeks, Wetlands in Pacifica are found
along riparian areas, drainages, along
the coast, and as fresh and brackish
water marshes (such as on the Sharp
Park Golf Course). Vegetation and
wildlife found in wetlands varies with
water characteristics, inundation
patterns, surrounding habitat, and
level of disturbance.

Wetlands occur in smaller drainages
and localized depressions, forming
ponds or flowing water. Wetlands also
occur along in creeks, riparian areas,
drainages, along the coast, and as fresh
and brackish water marshes (such as
on the Sharp Park Golf Course).

Vegetation and wildlife found in
wetlands varies with water
characteristics, inundation patterns,
surrounding habitat, and level of
disturbance.

Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 4 109 4.6 Special-Status
Species

SPECIAL-STATUS SPECIES IN SEASONAL

WETLANDS AND PONDS
The California red-legged frog, San
Francisco garter snake, Leech’s skyline
diving beetle, San Francisco forktail
damselfly, Tomales isopod, western
pond turtle, and bristly sedge are
special-status species that may be
found
in wetlands around Pacifica. The
wetlands in Sharp Park are also known
to support saltmarsh common
yellowthroat. Seasonal wetlands and
ponds at Mori Point and Sharp Park
Golf Course to support the California
red-legged frog as well as the San
Francisco garter snake.

SPECIAL-STATUS SPECIES IN

WETLANDS AND PONDS
The California red-legged frog, San
Francisco garter snake, Leech’s skyline
diving beetle, San Francisco forktail
damselfly, Tomales isopod, western
pond turtle, and bristly sedge are
special-status species that may be
found
in wetlands in and around Pacifica. The
wetlands in Sharp Park are also known
to support saltmarsh common
yellowthroat. Seasonal wetlands and
ponds at Mori Point and Sharp Park
Golf Course also known to support the
California red-legged frog as well as the
San Francisco garter snake.

Generalizes language
4 110 4.7 N/A N/A Dune habitat includes areas with sandy substrates proximate to the marine
environment and may range from bare
to vegetated with species typical of
foredune and dune scrub communities,
including non-natives such as ice plant
and invasive grasses. Dune form
topography may or may not be
evident, depending on the condition of
the dune and past land use or
invasions, but may be readily restored.

While most dunes occur near sea level,
there are several examples of perched
dune systems atop bluffs in Pacifica,
where aeolian forces have created the
substrate and processes appropriate to
support dune vegetation. All areas that
meet this definition of Dunes are
categorically considered ESHA.

New text - To be discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 4 112 4.8 Potential
Environmentall
y Sensitive
Habitat Areas
(ESHAs)
Figure 4-3 identifies potential ESHAs in
the Planning Area. Potential ESHAs
include all designated critical habitat
for Endangered or Threatened Species;
special status communities10; and
areas designated as “other potential
Environmentally Sensitive Habitat
Areas”.

Figure 4-3 identifies potential ESHAs in
the Planning Area in three general
categories: wetland, stream/riparian,
and other terrestrial ESHAs. These
potential ESHAs include all current
designated critical habitat for
Endangered or Threatened Species;
known special status communities10;
and areas designated as “other
potential Environmentally Sensitive
Habitat Areas”. Figure 4-3 is meant to
serve as a flag for further studies to be
undertaken when development is
proposed. However, the map is
illustrative and for information
purposes only; site-specific biological
studies are required as part of
proposed development review to
determine the presence and extent of
ESHA and its required buffer zone. And
other information than Figure 4-3 may
dictate the need for such studies as
well (e.g., site evaluation, other studies
nearby, etc.), even if the area is not
mapped as potential ESHA on Figure 4-

3. Clarification
4 116 4.9 ER-G-6:

Coastal
Environment
and Special
Species Status
Communities
Conserve and protect beaches, sand
dunes, coastal bluffs, and special status
communities, particularly the Coastal
bluff scrub on the northern bluffs.

Conserve and protect beaches, sand
dunes, coastal bluffs, and special status
communities, particularly the Coastal
bluff scrub on the northern bluffs.

Prohibit development in coastal dunes
to preserve dune formations,
vegetation, and wildlife habitats.

Prevent overuse in dune areas by
mechanisms such as restricting parking
and directing pedestrian traffic
New text/Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary through signage and sand fencing to
areas capable of sustaining such use.

Prohibit motor vehicles in dune areas
except for emergency purposes, and
prohibit motor vehicles in non-dune
beach areas except for emergency and
essential maintenance purposes and
where previously coastal permitted.
4 116 4.10 ER-G-7: Creeks
and Riparian
Areas as
Habitat
Protect year-round creeks and
their riparian habitats.

Protect year-round and intermittent
creeks and
their riparian habitats.

Clarification
4 117 4.11 ER-I-21:

Protection of
Biological
Resources with
New
Development
2) Pre-construction plant and wildlife
surveys: Project applicants shall
engage a qualified biologist to conduct
presence/absence biological surveys
for sensitive plant and wildlife species
prior to construction adjacent to or
within identified special status
communities and other sensitive areas
identified in Figure 4-3. If special status
species are identified, the qualified
biologist shall consult with the
California Department of Fish and
Wildlife (CDFW) and establish nodisturbance buffers around the special status specie to avoid disturbance and
direct impacts to these resources
during construction. If no special status
species are detected during surveys,
then construction-related activities
may proceed. Nesting birds, in
particular, are protected by two
means; they receive protection under
the Migratory Bird Treaty Act, and
nesting raptors (in the order
2) Pre-construction plant and wildlife
surveys: Project applicants shall
engage a qualified biologist to conduct
presence/absence biological surveys
for sensitive plant and wildlife species
prior to construction adjacent to or
within areas identified as potential
ESHAs on Figure 4-3, or as otherwise
indicated and needed. If special status
species are identified, the qualified
biologist shall consult with the
California Department of Fish and
Wildlife (CDFW) and establish nodisturbance buffers around the special status specie to avoid disturbance and
direct impacts to these resources
during construction. If no special status
species are detected during surveys,
then construction-related activities
may proceed. Nesting birds, in
particular, are protected by two
means; they receive protection under
the Migratory Bird Treaty Act, and
nesting raptors (in the order
Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary Falconiformes or Strigiformes) are
protected under the State Fish and
Game Code, §3503.5.

Falconiformes or Strigiformes) are
protected under the State Fish and
Game Code, §3503.5.
4 117 4.11 ER-I-21:

Protection of
Biological
Resources with
New
Development
3) Require biological resource
assessments be conducted prior to
approval for any development within
300 feet of creeks, wetlands, or other
sensitive habitat areas shown on
Figure 4-3 of the General Plan.
3) Require biological resource
assessments be conducted prior to
approval for any development within
300 feet of creeks, wetlands, or other
sensitive habitat areas. Such
assessment shall identify means to
avoid impacts to any such resources
(including through siting, design, and
LCP required buffers), and means of
enhancing resources and providing
offsetting and commensurate
mitigation for unavoidable impacts
that are LCP allowable.

Clarification; however,
reference to Figure should
not be deleted.
4 117 4.11 ER-I-21:

Protection of
Biological
Resources with
New
Development
4) Require on-site monitoring of
biological resources by a qualified
biologist throughout the duration of
construction activity.
4) Require on-site monitoring of
biological resources by a qualified
biologist throughout the duration of
construction activity and afterwards,
should approval conditions warrant.

Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 4 118 4.12 ER-I-23:

Verification of
ESHA
N/A Historical evidence of ESHA Adds new sub-policy under Verification of ESHA
4 118 4.13 ER-I-24:

Management
of ESHA
• Buffer areas shall be established
around all sensitive resources,
providing a minimum of 100 feet, and
varying as needed to account for
feeding, breeding, nesting, and other
habitat requirements. Exceptions to
such buffer requirements should be
supported by a biological report
demonstrating that the adjusted
buffer, in combination with
incorporated siting, design or other
mitigation measures, will prevent
impacts that significantly degrade the
ESHA and will be compatible with the
continuance of the ESHA. Buffer
adjustments should also be limited to
where the entire subject legal lot is
within the buffer or where it is
demonstrated that development
outside the buffer would have a
greater impact on the ESHA.
• Buffer areas shall be established
around all ESHA, providing a minimum
of 100 feet, and may be expanded as
needed to account for feeding,
breeding, nesting, and other habitat
requirements. The 100-foot buffer may
be reduced by the minimum necessary
(1) to avoid a taking (for private
development), or (2) to provide
required public services (for public
development), provided that the
buffer is as close to 100 feet as
possible, and no less than 50 feet in
any case, and provided that ESHA
resource impacts are avoided as much
as possible, and unavoidable impacts
commensurately mitigated, all as
conclusively demonstrated by a
qualified biologist to the satisfaction of
the City, USFWS, and CDFW.

Clarification to comply with
Coastal Act provision. - To be
discussed
4 118 4.13 ER-I-24:

Management
of ESHA
• Alteration of landforms, removal of
vegetation, impervious surfaces, noise,
light, and glare shall be minimized.
• Alteration of landforms, removal of
vegetation, impervious surfaces, noise,
light, and glare shall be minimized as
much as possible.

Amended text to clarify
exceptions.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 4 119 4.14 ER-I-28:

Construction
during Nesting
Season
If site work or construction occurs
during the nesting season (February 1
through August 31), then preconstruction breeding bird surveys shall be performed by a qualified
wildlife biologist prior to any site
disturbance to ensure that no nests
will be disturbed or destroyed during
Project implementation. If an active
nest is found sufficiently close to work
areas to be disturbed by construction
activities, then the biologist shall
create a no-disturbance buffer of 250
feet around passerine nests and a 500
foot buffer around raptor nests. Workfree buffer zones shall be maintained until after the breeding season or until
after the qualified biologist determines
the young have fledged (usually late
June through mid-July).

Nests initiated during active
construction would be presumed to be
unaffected by the activity, and a buffer
zone around such nests is not
necessary. However, nests shall be
flagged and construction activity shall
avoid killing and/or injuring nesting
birds.

If site work or construction occurs
during the nesting season (February 1
through August 31), then preconstruction breeding bird surveys shall be performed by a qualified
wildlife biologist prior to any site
disturbance to ensure that no nests
will be disturbed or destroyed during
Project implementation. If an active
nest is found sufficiently close to work
areas to be disturbed by construction
activities, then the biologist shall
create a no-disturbance buffer of 250
feet around passerine nests and a 500
foot buffer around raptor nests. Workfree buffer zones shall be maintained until after the breeding season or until
after the qualified biologist determines
the young have fledged (usually late
June through mid-July).

Deletes text
4 120 4.15 ER-I-30:

Protection of
the California
Red-Legged
Frog and San
Francisco
Garter Snake
To minimize disturbance, require all
grading activity within 100 feet of
aquatic habitat shall be conducted
during the dry season (May 1 through
October 15) to protect California redlegged frog and San Francisco garter snake. A qualified biologist shall
conduct presence/absence surveys for
Allowed construction activity with the
potential to impact California redlegged frogs and San Francisco garter snake shall be conducted during the
dry season (May 1 through October 15)
to protect California red-legged frog
and San Francisco garter snake. In such
cases a qualified biologist shall conduct
Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary California red-legged frog and San
Francisco garter snake prior to
construction in or adjacent to riparian
areas, grasslands near ponds/wetlands,
or other sensitive habitat. Any
individuals identified shall be treated in
consultation with USFWS. Construction
shall follow accepted procedures for
exclusion and avoidance of California
red-legged frog and
San Francisco garter snake and their
habitat. Additionally, the biologist shall
supervise the installation of exclusion
fencing along the boundaries of the
work area, shall conduct
environmental awareness training for
construction workers, and shall be
present during initial vegetation
clearing and ground-disturbing
activities.
presence/absence surveys for
California red-legged frog and San
Francisco garter snake prior to
construction in or adjacent to riparian
areas, grasslands near ponds/wetlands,
or other sensitive habitat. Any
individuals identified shall be treated in
consultation with USFWS. Construction
shall follow accepted procedures for
exclusion and avoidance of California
red-legged frog and
San Francisco garter snake and their
habitat. Additionally, the biologist shall
supervise the installation of exclusion
fencing along the boundaries of the
work area, shall conduct
environmental awareness training for
construction workers, and shall be
present during initial vegetation
clearing and ground-disturbing
activities.
4 121 4.16 ER-I-39: Bowl
Site
Establish appropriate zoning for the
“Bowl” site along the east side of
Palmetto Avenue in Fairmont West for
Planned Development to ensure site
planning that clusters development,
avoiding potential flooding or
geotechnical hazards and protecting
open space resources.

Establish appropriate zoning for the
“Bowl” site along the east side of
Palmetto Avenue in Fairmont West for
Planned Development to ensure site
planning that clusters development,
avoiding potential flooding or
geotechnical hazards and protecting
open space resources, and taking all
other coastal resources site constraints
into consideration.

Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 5 132 5.1 Natural
Hazards
Ensuring the safety of community
members, through protection from
hazards, is an essential service of
public agencies and a critical priority
for maintaining community health. The
purpose of the Natural Hazards
chapter is to establish goals and
policies to mitigate the potential
impacts from natural and man-made
hazards that pose a threat to public
health, and safety.

Ensuring the safety of community
members, through protection from
hazards, is an essential service of
public agencies and a critical priority
for maintaining community health. The
purpose of the Natural Hazards
chapter is to establish goals and
policies to mitigate the potential
impacts from natural and man-made
hazards that pose a threat to public
health, safety, and coastal resources.

Clarification
5 133 5.2 Coastal Bluffs A bluff is a high bank or bold headland with a broad, precipitous, sometimes
rounded cliff face overlooking a plain
or body of water.

Deleted Deletes text
5 140 5.3 NH-G-1:

Reduce Risk
Minimize risks of property damage and
personal injury posed by geologic and
seismic hazards.

Protect coastal resources, and
minimize risks of property damage and
personal injury posed by geologic,
seismic and coastal hazards.

Clarification
5 141 5.4 NH-I-9: Erosion
Prevention
Require erosion prevention of hillside
areas by revegetation or other
acceptable methods.

Deleted Deletes text - To be discussed
5 142 5.5 NH-I-10:

Geotechnical
Studies
• Within 50 feet of a bluff edge. • Within 300 feet of a bluff edge in Coastal Vulnerability Zones.

Amends policy to include
Coastal Vulnerability Zones.
5 142 5.5 NH-I-10:

Geotechnical
Studies
Geotechnical studies shall identify any
geologic hazards affecting the
proposed project site, any necessary
mitigation measures, and a statement
of the site’s suitability for the proposed
development and whether or not it will
be safe from geologic hazard for its
expected life.

Geotechnical studies shall identify any
geologic hazards affecting the
proposed project site, any necessary
mitigation measures, and a statement
of the site’s suitability for the proposed
development and whether or not it will
be safe from geologic hazard for its
anticipated life.

Amended to be consistent
with new definitions
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 5 143 5.6 NH-I-17: New
Development
in Coastal Zone
• Not accelerate the need for a
shoreline structure or increase the
likelihood of a future seawall beyond
the existing development’s expected
life; • Not violate required coastal
resource setback provisions.

Small improvement projects are
exempt, including improvements that
would increase height, bulk or floor
area by less than ten percent.
• Not violate required coastal resource
setback provisions.

Clarification
5 144 5.7 Flood Zones Flood hazards mapped by FEMA to
support the development of Flood
Insurance Rate Maps (FIRMs) generally
identify areas of greater flood risk (100
and 500 year events) in the lower
reaches of the main stream channels,
and the risk of coastal flooding along
the shoreline. Flood zones based on
the FIRMs are shown in Figure 5-3.

Flood hazards mapped by FEMA to
support the development of Flood
Insurance Rate Maps (FIRMs) generally
identify areas of greater flood risk (100
and 500 year events) in the lower
reaches of the main stream channels,
and the risk of coastal flooding along
the shoreline, although they do not
account for climate change or sea level
rise, and thus should be reviewed in
conjunction with Appendix B (“Coastal
Zone Vulnerability Maps”). Flood zones
based on the FIRMs are shown in
Figure 5-3.

Clarification
5 147 5.8 NH-G-2:

Development
in Hazardous
Areas
Protect development in 100-year
floodplains and tsunami hazard zones
with (e.g. flood damage prevention
programs).

Site and design development in 100-
year floodplains and tsunami hazard
zones to minimize hazard risk without
the need for armoring (e.g. flood
damage prevention programs).

Clarification
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 5 148 5.9 NH-I-24: Flood
Hazard
Reduction
Flood Hazard Reduction. Continue to
comply with the Flood Damage
Prevention Ordinance in the Municipal
Code.

Deleted Deletes policy - City's Flood
Prevention Ordinance is not
currently certified by CCC
5 148 5.10 NH-I- 26: Flood
Control
Maintenance
Regularly maintain flood control
structures, including, but
not limited to drainage channels,
pipes, culverts, and stream beds.

Regularly maintain flood control
structures, including, but
not limited to drainage channels,
pipes, and culverts.

Deletes text - Significant
areas in Pacifica are serviced
by creeks as critical
stormwater infrastructure. -
To be discussed
5 148 5.11 NH-I-27: Flood
Control
Structures
Require flood control devices that alter
streams to incorporate best mitigation
measures whenever feasible, and only
permit them where no other method
for protecting existing structures in the
flood plain is feasible, where such
protection is necessary for public
safety, or to protect existing
development.

Require flood control devices that alter
rivers and streams to incorporate the
best mitigation measures feasible, and
only permit them where no other
method for protecting existing
structures in the flood plain is feasible,
where such protection is both
necessary for public safety, including
for water supply, and to protect
existing development, or where the
primary function is the improvement
of fish and wildlife
habitat.

Amends policy to include
rivers, water supply, and
mention of fish and wildlife
habitat.
5 148 5.12 NH-I-31:

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

Site critical public facilities including
hospital and healthcare facilities,
emergency shelters, police and fire
stations, and emergency
communications facilities outside of
the tsunami evacuation zone, and 100-
year flood plains, and other portions of
the Coastal Vulnerability Zone over the
anticipated life of the development.

Amends policy to include
Coastal Vulnerability Zones.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 153 5.13 NH-I-35:

Development
Review
Review development proposals to
ensure that they incorporate
appropriate fire-mitigation measures,
including adequate provisions for
evacuation, access by emergency
responders, and vegetation clearances
that don’t impact ESHAs or wetlands.

Review development proposals to
ensure that they incorporate
appropriate fire-mitigation measures,
including adequate provisions for
evacuation, access by emergency
responders, and vegetation clearances
that don’t impact ESHAs or wetlands or
their associated buffers, unless
undertaken consistent with the City’s
ESHA and wetlands policies.

Amends policy to expand
considerations of ESHA
buffers
154 5.14 NH-I-39:

Vegetation
Management
Promote and support the North County
Fire Authority’s Vegetation
Management Program to reduce
urban/wildland interface fire hazards.

Promote and support the North County
Fire Authority’s Vegetation
Management Program to reduce
urban/wildland interface fire hazards,
if consistent with the LCP.

Amends policy to require LCP
consistency
6 156 6.1 Coastal
Resilience
The purpose of this chapter is to
provide policies which protect existing
development from the hazard of sea
level rise and which guide the design of
new development to respond to sea
level rise during the economic life of
the project. Topics covered in this
element include sea level rise
projections, transfer of development
rights (TDR), repair and replacement of
existing shoreline protection structures
(e.g., sea walls), and establishment of
appropriate site design measures for
new development. Protection of
property rights is an important theme
in this chapter.

The purpose of this chapter is to
provide policies which protect existing
development from the hazard of sea
level rise and which guide the design of
new development to respond to sea
level rise during the anticipated life of
the project. Topics covered in this
element include sea level rise
projections, transfer of development
rights (TDR), repair and replacement of
existing shoreline protection structures
(e.g., sea walls), and establishment of
appropriate site design measures for
new development.

Amends text to align with
new definitions. Deletes text
about "protection of
property rights." - To be
discussed.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 157 6.2 Coastal Act
Policies
Therefore, the policies focus on
protection and armoring of the
shoreline and reassessment of the
adaptation plan in the future. The
policies do not include managed
retreat as an adaptation strategy
unless and until a future Local Coastal
Land Use Plan amendment and public
input process culminates in supporting
the strategy.

Therefore, the policies focus on
protecting beaches and the natural
shoreline while also allowing for
protection and armoring of the
shoreline for specific limited
circumstances as provided for within
the Coastal Act and reassessment of
the adaptation
plan in the future.

Coastal Act provision
6 163 6.3 Vulnerability
Assessment -
Pacific
Institute Study
However, because the Coastal
Vulnerability Zone Maps show
significant erosion for areas that are
protected by existing shoreline
protection structures, the Maps
highlight the importance of the existing
structures and the vital need for them
to be maintained to protect those
vulnerable areas.

Deleted Deletes text related to the
City's perspective on the
Vulnerability Assessment. To
be discussed.
6 164 6.4 Adaptation
Plan
The cost-benefit analysis section of the
Adaptation Plan was not adopted or
approved by the City of Pacifica. The
purpose of the cost benefit analysis
was to provide information regarding
various sea level rise scenarios and
adaptation options and was not
intended to prescribe specific
adaptation policies. The cost-benefit
analysis shall not be used for any
future purpose by the City of Pacifica
or its planning processes, including
implementation of the Local Coastal
Program, public infrastructure
investment, permitting or other
regulatory purposes.

Deleted Deletes a factual statement
about the cost-benefit
analysis not being adopted
by the City. To be discussed.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 166 6.4 Adaptation
Plan
The findings of the Adaptation Plan are
just one of the considerations that
were used to develop the Coastal
Resilience policies below and, as
discussed, the Coastal Resilience
policies focus on protection and
armoring of the shoreline and
reassessment of the Adaptation Plan in
the future.

The findings of the Adaptation Plan are
just one of the considerations that
were used to develop the Coastal
Resilience policies below and, as
discussed, the Coastal Resilience
policies focus on protection and
armoring of the shoreline for specific
limited circumstances as provided for
within the Coastal Act and
reassessment of the Adaptation Plan in
the future.

Clarification
6 166 6.4 Adaptation
Plan
Therefore, changes to the cost-benefit
analysis in a manner to discourage
managed retreat as suggested by some
public commenters detailed below
would be unnecessary since the
Coastal Resilience policies do not
include managed retreat as an
adaptation strategy. As noted earlier in
this section, the cost-benefit analysis
prepared for the Adaptation Plan shall
not be used for any future purpose by
the City of Pacifica or its planning
processes.

Deleted Deletes a factual statement
about the cost-benefit
analysis. To be discussed.
6 166 6.4 Adaptation
Plan
The Adaptation Plan was prepared to
inform City decision making about a
variety of sea level rise adaptation
policies, but does not include or dictate
the ultimate policies selected by the
City. Although managed retreat
alternatives are analyzed in the
Adaptation Plan in accordance with the
City’s grant agreement with the CCC,
these analyses do not, in themselves,
equate to a managed retreat policy. To
the contrary, the City has rejected
Deleted Deletes a factual statement
about the City's
consideration of managed
retreat. To be discussed.

Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary managed retreat as a sea level rise
adaptation policy in this LCP and
managed retreat could only become
the policy of the City subsequent to a
future amendment to the LCP.
6 167 6.5 CR-I-1:

Vulnerability
Identification
and Mapping
Notwithstanding the Coastal
Vulnerability Zone Maps, site-specific
hazard mapping and assessment may
be required as part of the individual
development review process for
properties within the City’s Coastal
Vulnerability zones.

Notwithstanding the Coastal
Vulnerability Zone Maps, site-specific
hazard mapping and assessment may
be required as part of the individual
development review process for
properties within the City’s Coastal
zone.

Amends policy to include
Coastal Vulnerability Zones.
6 168 6.6 CR-I-2: Sea
Level Rise
Adaptation
Plan
Adaptation alternatives evaluated in
the Adaptation Plan that are not
specifically expressed in these Coastal
Resilience policies shall not be
implemented without an amendment
to the LCP, public notice, and
opportunity for public input.

Deleted Deletes text
6 168 6.6 CR-I-2: Sea
Level Rise
Adaptation
Plan
b. All project impacts on coastal
resources are mitigated to the
maximum extent feasible through the
City’s Shoreline Mitigation Program
(Coastal Resilience Policy CR-I-5) or
consistent with Coastal Resilience
Policy CR-I-59.
b. All project impacts on coastal
resources are avoided, and where
unavoidable, minimized and mitigated
to the maximum extent consistent with
Coastal Resilience Policy CR-I-59.

Amends policy to prioritize
avoidance of coastal resource
impacts
6 168 6.6 CR-I-2: Sea
Level Rise
Adaptation
Plan
c. The project will not pose
unacceptable risks to life or property
or otherwise create a nuisance; and
c. The project will not pose
unacceptable risks to life or property
for the anticipated life of the
development or otherwise create a
nuisance;
Clarification to align with
proposed added definition of
"anticipated life"
6 168 6.6 CR-I-2: Sea
Level Rise
Adaptation
Plan
d. The project will not encroach on
public trust lands.
d. The project will not encroach on
public trust lands for the anticipated
life of the development; and
Clarification to align with
proposed added definition of
"anticipated life"
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 168 6.6 CR-I-2: Sea
Level Rise
Adaptation
Plan
N/A e. The project is designed to assure
stability and structural integrity absent
the need for shoreline protective
devices.

Coastal Act provision
6 168 6.7 CR-I-3:

Monitoring
Shoreline
Change
The monitoring program shall include
yearly (minimum) shoreline and bluff
edge surveys and also establish
thresholds for reassessing the City’s
Adaptation Plan.

The monitoring program shall include
biannual (minimum following winter
and summer) shoreline and bluff edge
surveys and also establish thresholds
for reassessing the City’s Adaptation
Plan.

Amends policy to require
additional monitoring. New
direction may be too
burdensome on City
resources. - To be discussed
6 169 6.8 CR-I-5:

Shoreline
Mitigation
Program
Within three years of certification of
the LCP Land Use Plan update, the City
shall adopt a Shoreline Mitigation
Program to address the coastal
resource impacts of existing and future
shoreline protection projects in the
City.

Within three years of certification of
the LCP Land Use Plan update, the City
shall adopt a Shoreline Mitigation
Program to address the coastal
resource impacts of existing and future
shoreline protection projects in the
City, and it shall be submitted to the
Coastal Commission for certification as
an LCP amendment.

Requires LCP amendment to
incorporate shoreline
mitigation program
6 169 6.8 CR-I-5:

Shoreline
Mitigation
Program
Until the adoption of a Shoreline
Mitigation Program, coastal resource
impacts shall be mitigated in
accordance with CR-I-59.

Until the adoption of a Shoreline
Mitigation Program by the City and
subsequent certification by the Coastal
Commission, coastal resource impacts
shall be mitigated in accordance with
CR-I-59.

Requires LCP amendment to
incorporate shoreline
mitigation program
6 170 6.9 CR-I-8: 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.

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, while
avoiding (and where unavoidable
minimizing and mitigating) impacts to
coastal resources, including public
access and recreation, to the maximum
Clarification to comply
Coastal Act provision
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary extent feasible, and being consistent
with prior permit conditions and/or
legal obligations pursuant to the
California Coastal Act.
6 170 6.10 CR-I-9: Hazard
Prone
Infrastructure
The City will preserve, protect, or
relocate hazard prone infrastructure to
maintain critical services.

The City will preserve, protect, or
relocate hazard prone infrastructure to
maintain critical services and protect
coastal resources, including if required
by prior permit conditions and/or legal
obligations pursuant to the California
Coastal Act.

Clarification to comply
Coastal Act provision
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 170 6.11 CR-I-15:

Shoreline
Protection
Structures
N/A Shoreline Protection Structures.

Shoreline protection structures shall be
avoided except that existing shoreline
protection structures may be
maintained or new shoreline
protection structures constructed to
protect existing structures in danger
from erosion if found to be the least
environmentally-damaging alternative,
impacts to beach, public access and
recreation, and other coastal resources
are fully mitigated consistent with CR-I5 and CR-I-59, and compliant with any prior permit conditions and/or legal
obligations pursuant to the California
Coastal Act . Allow shoreline protection
structures for the public road and
sewer line existing structures if
necessary and consistent with Policies
CR-I-56 and CR-I-57, other LCP policies,
and the Coastal Act. New development
on blufftops shall comply will all LCP
setback policies, including CR-I-44.

Reorganization of Document
6 171 6.12 CR-I-16: Beach
Nourishment
N/A Beach Nourishment. Evaluate the
feasibility of using beach nourishment,
in conjunction with sand retention
structures (see artificial headlands
concept in the Adaptation Plan) as
described in CR-I-55, to reduce
shoreline protection structure
maintenance requirements and
maintain beaches of at least 100 feet in
width on average. If feasible and
approved through a coastal
development permit, secure funding
and implement as soon as possible.

Reorganization of Document
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary Repeat as necessary. Mitigate all
adverse impacts and monitor
effectiveness over time.
6 171 6.13 Sub-area
Policies and
Programs
Where applicable, the titles of the
policies in this subsection detail when
the policy should be implemented. For
example, CR-I-15 Shoreline Protection
Structures (0-1 foot SLR or 260-foot
offset from bluff toe to infrastructure)
should be implemented when 0 to 1
foot of sea level rise or a 260-foot bluff
offset is experienced. The bluff offset is
measured distance between the edge
of the bluffs and the asset (e.g.,
infrastructure, development). These
triggers do not account for regulatory
permitting, approvals, or financing;
therefore planning should be done in
advance of the triggers.

Deleted Reorganization of Document
6 171 6.13 Sub-area
Policies and
Programs
Generally, for all lands within the 2050
Pacific Institute erosion hazard zone,
utilities, roadways and other public
infrastructure should be floodproofed
unless other adaptation alternatives
are implemented and performing well.

Generally, for all lands within the
Coastal Vulnerability zones, utilities,
roadways and other public
infrastructure should be floodproofed
unless other adaptation alternatives
are implemented and performing well,
and only if consistent with LCP and
Coastal Act policies.

Amends text to use Coastal
Vulnerability Zones
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 172 6.13 Sub-area
Policies and
Programs
In addition, the City should, when
appropriate, evaluate and pursue
floodproofing infrastructure that may
be currently exposed to coastal erosion
and flooding to reduce the
consequences of under-performance
of protection measures (CR-I-61).

In addition, the City should, when
appropriate, evaluate and pursue
floodproofing infrastructure that may
be currently exposed to coastal erosion
and flooding to reduce the
consequences of under-performance
of protection measures, only if such
floodproofing infrastructure is the least
environmentally damaging feasible
alternative and consistent with LCP
and Coastal Act policies (CR-I-61).

Coastal Act provision
6 172 6.13 Sub-area
Policies and
Programs
The City’s overall approach for new
development is to minimize or avoid
current and projected future coastal
hazards through siting and design. At
the same time, managed retreat is not
included in any of the near-term
policies. Managed retreat would be
reconsidered if feasibility and
monitoring warranted, as detailed in
Coastal Resilience Policies CR-I-3 and
CR-I-4.

The City’s overall approach to address
coastal hazards is through siting and
design of new development to be out
of harm’s way and to limit shoreline
armoring as much as possible,
including to help preserve and protect
the City’s shoreline and beaches.

Amends text related to
managed retreat. To be
discussed.
6 173 6.14 CR-I-15:

Shoreline
Protection
Structures (0-
1foot SLR or
260 foot offset
from bluff toe
to
infrastructure)
Shoreline Protection Structures (0-1
foot SLR or 260-foot offset from bluff
toe to infrastructure). Shoreline
protection structures shall be avoided
except that the existing shoreline
protection structures may be
maintained or new shoreline
protection structures constructed to
protect existing structures in danger
from erosion if found to be the least
environmentally-damaging alternative,
impacts are fully mitigated consistent
with CR-I-5, and compliant with any
prior permit conditions and/or legal
Deleted Reorganization of Document
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary obligations pursuant to the California
Coastal Act . Allow shoreline protection
structures for the public road and
sewer line existing structures if
necessary and consistent with Policies
CR-I-56 and CR-I-57, other LCP policies,
and the Coastal Act. New development
on blufftops shall comply will all LCP
setback policies, including CR-I-44.
6 173 6.15 CR-I-16: Beach
Nourishment
(2 feet SLR or
260-foot offset
from bluff toe
to
infrastructure).

Beach Nourishment (2 feet SLR or 260-
foot offset from bluff toe to
infrastructure). Evaluate the feasibility
of using beach nourishment, in
conjunction with sand retention
structures (see artificial headlands
concept in the Adaptation Plan) as
described in CR-I-55, to reduce
shoreline protection structure
maintenance requirements and
maintain beaches of at least 100 feet in
width on average. If feasible and
approved through a coastal
development permit, secure funding
and implement as soon as possible.

Repeat as necessary. Mitigate all
adverse impacts and monitor
effectiveness over time.

Deleted Reorganization of Document
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 174 6.16 CR-I-18:

Shoreline
Protection
Structures (0-1
foot SLR or
220-foot offset
from bluff toe
to
infrastructure
or
development)
Shoreline Protection Structures (0-1
foot SLR or 220-foot offset from bluff
toe to infrastructure or development).

Maintain existing or construct new
shoreline protection structures to
protect existing public infrastructure
structures, including between Bill
Drake Way and Manor Drive. Allow
private property owners to maintain
existing or construct new shoreline
protection structures if allowed
pursuant to Policies CR-I-56 and CR-I57, and if consistent with prior permit conditions and/or legal obligations
pursuant to the California Coastal Act,
and require mitigation of beach, public
access and recreation and other
coastal resource impacts, consistent
with CR-I-5 or CR-I-59, as necessary.

Deleted Reorganization of Document
6 174 6.17 CR-I-19: Beach
Nourishment
(0-1 foot SLR
or 220-foot
offset from
bluff toe to
infrastructure
or
development)
Beach Nourishment (0-1 foot SLR or
220-foot offset from bluff toe to
infrastructure or development).

Evaluate the feasibility of using beach
nourishment, in conjunction with sand
retention structures (artificial
headlands concept) as described in CRI-55, to reduce shoreline protection structure maintenance requirements
and maintain beaches of at least 100
feet in width on average. If feasible
and approved through a coastal
development permit, secure funding
and implement as soon as possible.

Mitigate all adverse impacts and
monitor effectiveness over time.

Deleted Reorganization of Document
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 175 6.18 CR-I-20:

Shoreline
Protection
Structures (0-1
feet SLR or 70-
foot offset
from bluff toe
to
development
or
infrastructure).

Shoreline Protection Structures (0-1
feet SLR or 70-foot offset from bluff
toe to development or infrastructure).

Private landowners may maintain,
expand, or construct new shoreline
protection structures to protect
existing structures in danger from
erosion, consistent with CR-I-2 and any
prior permit conditions and/or legal
obligations pursuant to the California
Coastal Act.

Deleted Reorganization of Document
6 175 6.19 CR-I-21: Beach
Nourishment
(0-2 feet SLR
or 70-foot
offset from
bluff toe to
development
or
infrastructure).

Beach Nourishment (0-2 feet SLR or
70-foot offset from bluff toe to
development or infrastructure).

Evaluate the feasibility of using beach
nourishment, in conjunction with sand
retention structures (artificial
headlands concept), to reduce
shoreline protection structure
maintenance requirements and
maintain beaches of at least 100 feet in
width on average. If feasible and
approved through a coastal
development permit, secure funding
and implement as soon as possible.

Repeat as necessary. Mitigate all
adverse impacts and monitor
effectiveness over time.

Deleted Reorganization of Document
6 175 6.20 CR-I-22: Flood
Protection (1
feet SLR)
Flood Protection (1 feet SLR). Enable
property owners to modify
development structures (e.g., elevate a
residence) to manage impacts of wave
run-up and overtopping of bluff face.

Flood Protection. Enable property
owners to modify development
structures to manage impacts of wave
run-up and overtopping of bluff face
provided such modifications are
consistent with the LCP and any prior
permit conditions and/or legal
Generalize policy
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary obligations pursuant to the California
Coastal Act.
6 177 6.21 CR-I-23: Sharp
Park Golf
Course
Sharp Park Golf Course. Strongly
support the City and County of San
Francisco’s maintenance of the Sharp
Park Golf Course berm and armoring,
consistent with the Coastal
Development Permit issued by the
California Coastal Commission,
including adaptation planning for the
course, and protecting public access.

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

Deleted Deletes policy text. To be
discussed.
6 177 6.22 CR-I-24:

Shoreline
Protection
Structures (0
feet SLR)
Shoreline Protection Structures (0 feet
SLR). Maintain existing or construct
shoreline protection structures to
protect existing public infrastructure
structures if consistent with Policies
CR-I-56 and CR-I-57. Extend the Beach
Boulevard seawall to the Sharp Park
Golf Course berm if consistent with
Policies CR-I-56 and CR-I-57.

Deleted Reorganization of Document
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 177 6.23 CR-I-25:

Structure
Elevation (0-2
feet SLR)
Maintain existing or construct
shoreline protection structures if
consistent with Policies CR-I-56 and CRI-57 to limit wave overtopping unless beach nourishment strategies are
effective in reducing wave run-up on
the backshore. Elevate development
structures if consistent with Policy CRI-61 as necessary to mitigate flood damage, consistent with height
limitations. Elevations of wave run-up
and associated development
thresholds shall be determined via a
site-specific study.

Maintain existing or construct
shoreline protection structures if
consistent with Policies CR-I-56 and CRI-57, and with any prior permit conditions and/or legal obligations
pursuant to the California Coastal Act
to limit wave overtopping unless beach
nourishment strategies are effective in
reducing wave run-up on the
backshore. Elevate development
structures if consistent with Policy CRI-61, and with any prior permit conditions and/or legal obligations
pursuant to the California Coastal Act
as necessary to mitigate flood damage,
consistent with height limitations,
determined via a site-specific study.

Clarification to comply with
Coastal Act provision. - To be
discussed
6 177 6.24 CR-I-26: Beach
Nourishment
(0-1 feet SLR)
Beach Nourishment (0-1 feet SLR).

Pursue beach nourishment and sand
retention structures to reduce
shoreline protection structure
maintenance requirements and
provide beach resources. Encourage
the City and County of San Francisco to
nourish the beach fronting the Sharp
Park Golf Course berm to maintain
beach widths.

Deleted Reorganization of Document
6 177 6.25 CR-I-27: Flood
Protection (0
foot SLR)
(0 foot SLR). Deleted Generalize policy
6 178 6.26 CR-I-28: Flood
Protection (3
feet SLR).
(3 feet SLR). Deleted Generalize policy
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 178 6.27 CR-I-29:

Shoreline
Protection
Structure
Shoreline
Protection
Structures (0
feet SLR).

Shoreline Protection Structure
Shoreline Protection Structures (0 feet
SLR). Maintain existing or construct
new shoreline protection structures
along the north cove for public safety
and hazard reduction if consistent with
Policies CR-I-56 and CR-I-57.

Deleted Reorganization of Document
6 178 6.28 CR-I-30:

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

Deleted Generalize policy
6 178 6.29 CR-I-31: Public
Access (0 feet
SLR).
(0 feet SLR). Deleted Generalize policy
6 178 6.30 CR-I-32: Beach
Nourishment/
Public Access
(0 feet SLR).

Beach Nourishment/Public Access (0
feet SLR). Plan and implement beach
nourishment for Rockaway Beach.

Monitor and measure performance
and any reduction of shoreline
protection structure maintenance
needs. Establish mechanisms through
the City’s Shoreline Mitigation Program
(CR-I-5) to receive and use beach
impact mitigation funds from other
sub-areas of the City.

Deleted Reorganization of Document
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 180 6.31 CR-I-35:

Shoreline
Protection (2 ft
SLR or 100 foot
offset from
shoreline to
infrastructure).

Shoreline Protection (2 ft SLR or 100
foot offset from shoreline to
infrastructure). Evaluate beach
conditions and consider future
shoreline protection to protect existing
parking structures and the existing
Linda Mar stormwater and wastewater
pump station structures as necessary.

Deleted Reorganization of Document
6 180 6.32 CR-I-37: Beach
Nourishment
(2 ft SLR or 100
foot offset
from shoreline
to
infrastructure).

Beach Nourishment (2 ft SLR or 100
foot offset from shoreline to
infrastructure). Evaluate beach
conditions and implement beach
nourishment as necessary to maintain
a 100-foot buffer seaward of the sewer
force main and/or Highway 1. Repeat
nourishments as needed.

Deleted Reorganization of Document
6 180 6.33 CR-I-38: Flood
Protection (0
feet SLR).
(0 feet SLR). Deleted Generalize policy
6 180 6.34 CR-I-39: Flood
Protection (2
feet SLR or
100-foot offset
from shoreline
to
infrastructure).
(2 feet SLR or 100-foot offset from
shoreline to infrastructure).

Deleted Generalize policy
6 180 6.35 CR-I-40:

Groundwater
Management
(0-2 feet SLR).
(0-2 feet SLR). Deleted Generalize policy
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 181 6.36 CR-I-41:

Shoreline
Protection
Structure
Upgrades.

Shoreline Protection Structure
Upgrades. Allow maintenance of
existing or new shoreline protection
structures to reduce hazards and
resource impacts if consistent with
Policies CR-I-56 and CR-I-57. Mitigate
impacts consistent with the City’s
Shoreline Mitigation Program (CR-I-5),
or CR-I-59, as necessary.

Deleted Reorganization of Document
6 181 6.37 CR-I-42: Flood
Protection (0-1
feet SLR).
(0-1 feet SLR). Deleted Generalize policy
6 181 6.38 CR-I-43:

Technical
Reports.

Development proposed on the
shoreline shall include coastal
engineering, geomorphology and other
relevant technical reports unless onsite hazards already identified in a recent Coastal Vulnerability Zone Map
or assessment approved within the last
five years are adequate for evaluating
and ensuring compliance with the LCP,
including through use of permit
conditions to address any uncertainty.

Development proposed in Coastal
Vulnerability Zones shall include
coastal engineering, geomorphology
and other relevant technical reports
unless on-site hazards already
identified in a recent Coastal
Vulnerability Zone Map or assessment
approved within the last five years are
adequate for evaluating and ensuring
compliance with the LCP, including
through use of permit conditions to
address any uncertainty.

Applicability to Coastal
Vulnerability Zones
6 181 6.38 CR-I-43:

Technical
Reports.
• consider the impacts from the medhigh projection (CalNRA & OPC 2018) of sea-level rise for the anticipated
duration of the proposed
development;
• consider the impacts from the medhigh projection (CalNRA & OPC 2018; or similar precautionary projections as
reflected in future updated statewide
guidance) of sea-level rise for the
anticipated life of the proposed
development;
Reflects that best available
science may change over
time.
6 181 6.38 CR-I-43:

Technical
Reports.
• demonstrate that the development
will avoid (or if unavoidable, minimize)
impacts from coastal hazards to the
maximum extent feasible; and
• demonstrate that the development
will avoid (or if unavoidable, minimize)
impacts from coastal hazards for the
anticipated life of the proposed
development without reliance on any
Amended policy may impact
Pacifica's dense development
pattern - To be discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary existing or future shoreline protection
devices;
6 181 6.38 CR-I-43:

Technical
Reports.

N/A • demonstrate that the factor of safety
for blufftop development will be
greater than or equal to 1.5 for static
conditions and greater than or equal to

1.1 for seismic conditions; and
Clarification
6 181 6.39 CR-I-44: Siting
and Design.

New development on vacant shoreline
property shall be sited and designed to
be safe from erosion, bluff failure,
wave run-up, flooding and other
coastal hazards for at least 100 years
without shoreline protection,
considering projected sea level rise and
other climate change effects to be
determined from best available science
and current guidance at the time of
approval of the proposed
development, as demonstrated by sitespecific analyses and/or technical reports. Permit approvals shall prohibit
shoreline protection structures for the
authorized development, require the
property owner to record an
acknowledgement that the
development does not qualify as an
existing structure entitled to
construction of a shoreline protection
structure under Coastal Act Section
30235 and a waiver of any rights to
such protection, and where necessary
require a removal and restoration plan,
including bonding for large projects, to
New development in Coastal
Vulnerability Zones shall be sited and
designed to be safe from erosion, bluff
failure, wave run-up, flooding and
other coastal hazards for at least 100
years without shoreline protection,
considering projected sea level rise and
other climate change effects to be
determined from best available science
and current guidance at the time of
approval of the proposed
development, as demonstrated by sitespecific analyses and/or technical reports. Permit approvals shall prohibit
shoreline protection structures for the
authorized development, require the
property owner to record an
acknowledgement that the
development does not qualify as an
existing structure entitled to
construction of a shoreline protection
structure under Coastal Act Section
30235, and any other laws, that waive
any rights to such protection structures
that might exist, and that, where
necessary, requires a removal and
restoration plan, including bonding for
Applicability to Coastal
Vulnerability Zones
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary avoid future shoreline protection
structures or project failure.
large projects, to avoid future
shoreline protection structures or
project failure.
6 182 6.40 CR-I-45:

Assumption of
Risk by Private
Landowners.

Permit approvals of development on
the shoreline shall require the
applicant to: record a deed restriction
requiring the owner to assume liability
and indemnify and hold the City
harmless, and make other
acknowledgments relating to the risks
of development on the property.

Permit approvals of development in
Coastal Vulnerability Zones and
Tsunami Evacuation Zones shall
require the applicant to: record a deed
restriction requiring the owner to
assume liability and indemnify and
hold the City, its officers, agents, and
employees harmless, including any
injury and/or damage from coastal
hazards in connection with the
permitted development;
unconditionally waive any claim of
damage from coastal hazards against
the City; waive rights to future
shoreline armoring; acknowledge the
development may need to be removed
and the site restored in response to
future hazard conditions; and to
assume all responsibility for any
adverse effects to property caused by
the permitted project and/or need for
removal or relocation of development.

Applicability to Coastal
Vulnerability Zones. - To be
discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 183 6.41 CR-I-49:

Substantial
Modifications
to Existing
Structures.

Substantial Modifications to Existing
Structures. When a proposed physical
improvement to an existing structure
would constitute a Substantial Exterior
Structural Modification (SESM), as
defined, the portion of the project
constituting a SESM shall be
undertaken consistent with the LCP
and, if applicable, the Coastal Act,
including but not limited to Policies CRI-43 and CR-I-44. Any portion of the existing structure that remains and
which is determined to be legally
nonconforming with an LCP standard,
including bluff setbacks or other
hazard criteria, shall not be modified to
increase the degree of nonconformity.

Substantial Structural Modifications.

When proposed modifications to an
existing structure constitute a
Substantial Structural Modification
(SSM), as defined, such proposed
development shall correct any existing
legal nonconformities and shall be
undertaken consistent with the LCP
and the Coastal Act, including but not
limited to Policies CR-I-43 and CR-I-44.

Amended to exclude Existing
Structures and address
existing legal
nonconformities - To be
discussed
6 183 6.42 CR-I-51:

Habitat Sea
Level Rise
Migration
Buffers.

A sea level rise buffer area shall be
added to require new development
habitat buffers if necessary to allow for
the migration of wetlands and other
coastal habitats caused by sea level
rise over the anticipated duration (i.e.,
economic life) of the development.

Habitats include all wetlands, riparian,
intertidal/shoreline and terrestrial
environmentally sensitive habitat areas
(ESHAs) as defined by the Coastal Act.

The sea level rise projection
considered shall be determined for the
type of development from CalNRA and
OPC (2018) guidance or the latest
update.

An additional sea level rise buffer area
shall be added to required habitat
buffers if necessary to allow for the
migration of wetlands and other
coastal habitats caused by sea level
rise over the anticipated life of the
development. Habitats include all
wetlands, riparian, intertidal/shoreline
and terrestrial environmentally
sensitive habitat areas (ESHAs) as
defined by the Coastal Act. The sea
level rise projection considered shall
be determined based on the type of
development and current State
guidance.

Clarification to require
compliance with State
guidance. - To be discussed
6 184 6.43 CR-I-55: Beach
Nourishment
In coordination with the California
Coastal Commission and other
permitting agencies (e.g., State Lands
In coordination with the California
Coastal Commission and other
permitting agencies (e.g., State Lands
Clarification that Coastal Act
compliance is required. - To
be discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary Commission, U.S. Army Corps of
Engineers), the City shall evaluate a
beach nourishment program in
conjunction with sand retention
structures to assist in maintaining
beach width and elevations, consistent
with sub-area policies. The beach
nourishment program will include
measures to protect water quality and
to avoid (and where unavoidable to
minimize and mitigate) potential
adverse coastal resource impacts,
including biological resource impacts,
from deposition of material, including
measures such as sand compatibility
specifications, restrictions on volume
of deposition, timing or seasonal
restrictions, and identification of
environmentally preferred locations
for deposits.

Commission, U.S. Army Corps of
Engineers), the City shall evaluate a
beach nourishment program in
conjunction with sand retention
structures to assist in maintaining
beach width and elevations, consistent
with sub-area policies and the Coastal
Act. The beach nourishment program
will need to be evaluated to be the
least environmentally damaging
feasible alternative and will include
measures to protect water quality and
to avoid (and where unavoidable to
minimize and mitigate) potential
adverse coastal resource impacts,
including biological resource impacts,
from deposition of material, including
measures such as sand compatibility
specifications, restrictions on volume
of deposition, timing or seasonal
restrictions, and identification of
environmentally preferred locations
for deposits.
6 185 6.44 CR-I-56:

Existing
Shoreline
Protection
Structures
Except as may be otherwise provided
in the LCP sub-area policies, legally
permitted shoreline protection
structures may be repaired and
maintained, as supported by Section
30235 of the Coastal Act, subject to all
coastal development permit
requirements (including those
associated with the construction of the
structure and/or prior repair and
maintenance episodes) until the
development they are protecting is
removed or no longer requires
Except as may be otherwise provided
in the LCP sub-area policies, legally
permitted shoreline protection
structures may be repaired and
maintained, as supported by Section
30235 of the Coastal Act, subject to all
coastal development permit
requirements (including those
associated with the construction of the
structure and/or prior repair and
maintenance episodes) until the
development they are protecting is
removed or redeveloped pursuant to
Policy as amended that could
impact Pacifica's dense
development pattern - To be
discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary shoreline protection structures, at
which time the shoreline protection
structure shall be reevaluated for
consistency with the LCP, and removed
if no longer necessary. Activities
considered “repair and maintenance”
shall not result in any enlargement or
extension of the shoreline protection
structure, or any seaward
encroachment or impairment of public
trust resources, and shall provide
mitigation for any new coastal
resource impacts not previously or
otherwise mitigated, including through
the City’s Shoreline Mitigation Program
(CR-I-5) and/or Policy CR-I-59.
the definition of a Substantial
Structural Modification (SSM) or no
longer requires shoreline protection
structures, at which time the shoreline
protection structure shall be
reevaluated for consistency with the
LCP removed if no longer necessary
and/or allowed, and the area restored.

Activities considered “repair and
maintenance” shall not result in any
enlargement or modification to the
shoreline protection structure, or any
replacement of materials in excess of
50%, or any seaward encroachment or
impairment of public trust resources,
and shall provide mitigation for any
new coastal resource impacts not
previously or otherwise mitigated,
including through the City’s Shoreline
Mitigation Program (CR-I-5) and/or
Policy CR-I-59.
6 185 6.44 CR-I-56:

Existing
Shoreline
Protection
Structures
Other modifications to existing
shoreline protection structures which
fall within the limitations of an
exclusion contained in the definition of
Substantial Exterior Structural
Modification shall be considered to be
an existing shoreline protection
structure. This policy shall not be
applied to justify the removal of a
shoreline protection structure which
protects any structure authorized to be
constructed pursuant to an exclusion
contained in the definition of
Substantial Exterior Structural
Modification.

Deleted Deletes portion of policy that
could impact Pacifica's dense
development pattern - To be
discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary 6 185 6.45 CR-I-57: New
Shoreline
Protection
Structures
Shoreline protection structures,
including revetments, breakwaters,
groins, seawalls, cliff retaining walls,
deep piers and caissons, and other
such construction that alters natural
shoreline processes shall only be
permitted consistent Section 30235 of
the Coastal Act and with the LCP’s subarea policies only when required to serve coastal-dependent uses or
protect existing structures or public
beaches in danger from erosion, when
designed to eliminate or mitigate
adverse impacts on local shoreline
sand supply.

Shoreline protection structures,
including revetments, breakwaters,
groins, seawalls, cliff retaining walls,
deep piers and caissons, and other
such construction that alters natural
shoreline processes shall only be
permitted if consistent Section 30235
of the Coastal Act and with the LCP’s
sub-area policies, and only when
required to serve coastal-dependent
uses or protect existing structures or
public beaches in danger from erosion,
when there is no less environmentally
damaging feasible alternative and
when designed to avoid, and where
unavoidable, minimize to the
maximum extent feasible adverse
impacts on local shoreline sand supply
and other coastal resources, where
unavoidable coastal resource impacts
are required to be commensurately
mitigated.

Amends policy to address
unavoidable feasible
alternative or coastal
impacts. - To be discussed
6 185 6.46 CR-I-58:

Authorization
Limits of
Shoreline
Protection
Structures
Shoreline protection structures shall
only be authorized until the time when
the existing structure protected by
such shoreline protection structure: 1)
is/are no longer present, or2) no
longer require(s) armoring. This policy
shall not be applied to justify the
removal of a shoreline protection
structure which protects any structure
authorized to be constructed pursuant
to an exclusion contained in the
definition of Substantial Exterior
Structural Modification.

Shoreline protection structures shall
only be authorized until the time when
the structure protected by such
shoreline protection structure: 1)
is/are no longer present, 2) no longer
require(s) armoring, or 3) is
redeveloped pursuant to the definition
of a Substantial Structural Modification
(SSM).

Amends policy that could
impact Pacifica's dense
development pattern - To be
discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary Glossar
y
215 7.1 Anticipated
Life
N/A The period over which a development
is expected to be usable, with normal
repairs and maintenance, for the
purpose for which it was designed,
typically a minimum of 75-100 years
for residential and commercial
development and a minimum of 100-
150 years for critical infrastructure.

New text from CCC's adopted
guidance for residential
development and critical
infrastructure. - To be
discussed
Glossar
y
215 7.2 Beach : The expanse of sand, gravel, cobble
or other loose material that extends
landward from the mean low water
line to the place where there is
distinguishable change in
physiographic form, or to the line of
permanent vegetation. The seaward
limit of a beach (unless specified
otherwise) is the mean low water line.
: The expanse of sand, gravel, cobble
or other loose material that extends
landward from the mean low water
line to the place where there is
distinguishable change in
physiographic form, or to the line of
permanent vegetation. The seaward
limit of a beach (unless specified
otherwise) is the mean low water line.

The inland extent of the beach shall be
determined as follows:
1) From a distinct linear feature (e.g., a
seawall, road, or bluff, etc.);
2) From the inland edge of the further
inland beach berm as determined from
historical surveys, aerial photographs,
and other records or geological
evidence; or
3) Where a beach berm does not exist,
from the further point separating the
dynamic portion of the beach from the
inland area as distinguished by
vegetation, debris or other geological
or historical evidence.

Amends text to be consistent
with Coastal Act
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary Glossar
y
216 7.3 Bluff A high bank or bold headland with a
broad, precipitous, sometimes
rounded cliff face overlooking a plain
or body of water.

Deleted Deletes text to eliminate
redundancy
Glossar
y
216 7.4 Coastal
Hazards
N/A Include but are not limited to episodic
and long-term shoreline retreat and
coastal erosion, high seas, ocean
waves, storms, tsunami, tidal scour,
wave overtopping, coastal flooding,
and their interaction, all of which may
be exacerbated by sea level rise.

Clarification
Glossar
y
217 7.5 Development On land, in or under water, the
placement or erection of any solid
material or structure; dis- charge or
disposal of any dredged material or of
any gaseous, liquid, solid, or thermal
waste; grading, removing, dredging,
mining, or extraction of any materials;
change in the density or intensity of
use of land, including, but not limited
to, subdivision pursuant to the
Subdivision Map Act (commencing
with Section 66410 of the Government
Code), and any other division of land,
including lot splits, except where the
land division is brought about in
connection with the purchase of such
land by a public agency for public
recreational use; change in the
intensity of use of water, or of access
thereto; construction, reconstruction,
demolition, or alteration of the size of
any structure, including any facility of
any private, public, or municipal utility;
and the removal or harvesting of major
vegetation other than for agricultural
On land, in or under water, the
placement or erection of any solid
material or structure; dis- charge or
disposal of any dredged material or of
any gaseous, liquid, solid, or thermal
waste; grading, removing, dredging,
mining, or extraction of any materials;
change in the density or intensity of
use of land, including, but not limited
to, subdivision pursuant to the
Subdivision Map Act (commencing
with Section 66410 of the Government
Code), and any other division of land,
including lot splits, except where the
land division is brought about in
connection with the purchase of such
land by a public agency for public
recreational use; change in the
intensity of use of water, or of access
thereto; construction, reconstruction,
demolition, or alteration of the size of
any structure, including any facility of
any private, public, or municipal utility;
and the removal or harvesting of major
vegetation other than for agricultural
New text to clarify terms
used in document
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary purposes, kelp harvesting, and timber
operations which are in accordance
with a timber harvesting plan
submitted pursuant to the provisions
of the Z'berg-Nejedly Forest Practice
Act of 1973 (commencing with Section
4511).

As used in this section, "structure"
includes, but is not limited to, any
building, road, pipe, flume, conduit,
siphon, aqueduct, telephone line, and
electrical power transmission and
distribution line.
purposes, kelp harvesting, and timber
operations which are in accordance
with a timber harvesting plan
submitted pursuant to the provisions
of the Z'berg-Nejedly Forest Practice
Act of 1973 (commencing with Section
4511).

As used in this section, "structure"
includes, but is not limited to, any
building, road, pipe, flume, conduit,
siphon, aqueduct, telephone line, and
electrical power transmission and
distribution line. In this LCP,
‘development’ is synonymous with
‘new development.’
Glossar
y
218 7.6 Environmental
Justice
The fair treatment of people of all
races, cultures, and incomes with
respect to the development, adoption,
implementation, and enforcement of
environmental laws, regulations, and
policies
The fair treatment and meaningful
involvement of people of all races,
cultures, and incomes with respect to
the development, adoption,
implementation, and enforcement of
environmental laws, regulations, and
policies
Clarification
Glossar
y
218 7.7 Existing
Structure
A structure that has any of the
following characteristics:
i) lawfully constructed prior to the
certification date of the LCLUP; or
ii) permitted for construction prior to
the certification date of the LCLUP, and
all permits remained in full force and
effect prior to the date of construction;
or
Deleted Deletes text to be consistent
with CCC guidance
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary iii) authorized to be constructed
pursuant to an exclusion contained in
the definition of Substantial Exterior
Structural Modification.”
Glossar
y
220 7.8 New
Development
Development, as defined in Section
30106 of the California Coastal Act,
where no existing development occurs.

New Development does not include
the remodeling or improvement of an
existing structure, as defined, and also
does not include any structure
authorized to be constructed pursuant
to an exclusion contained in the
definition of Substantial Exterior
Structural Modification.”.

Deleted Deletes text to clarify terms
used in document - To be
discussed
Glossar
y
222 7.9 Shoreline Intersection of the ocean or sea with land; the line delineating the shoreline
on National Ocean Service nautical
charts and surveys approximates the
mean low water line from the time the
chart was pre- pared.

Seaward of the base of coastal bluffs
and/or at or near the sandy
beach/ocean elevation, including as
depicted in Appendix B (“Coastal Zone
Vulnerability Maps”) and denoted as
“wave run-up,” “storm flood area,”
and “flood prone area.”
Clarification to be consistent
with CCC guidance
Glossar
y
222 7.10 Substantial
Exterior
Structural
Modification
(SESM)
Any physical improvement which
modifies an existing structure, as
defined, to achieve in any of the
following:
i) a seaward encroachment of the
structure; or
ii) removal or replacement of 50
Any physical improvement which
modifies an existing structure, as
defined, to achieve in any of the
following:
i) alteration, removal or replacement
of 50 percent or more of the linear
length of the exterior walls, or other
major structural components
Amends text to be consistent
with CCC SLR guidance.

Amendment may impact
Pacifica's dense urban
development - To be
discussed
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary percent or more of the linear length of
the exterior walls, whether or not the
floor area or building footprint is
expanded; or
iii) an addition that includes new floor
area at or below the first story equal to
50 percent or more of the structure’s
total existing floor area; or
ivii) an increase of the existing building
footprint equal to 50 percent or more;
but excluding any of the following:
i) removal, replacement, or
maintenance of nonstructural exterior
components of exterior walls such as
decorative siding, shingles, and roofing
materials and windows;
ii) development on any site which is
protected from coastal erosion by an
existing, permitted shore- line
protection structure;
iii) replacement of any structure
pursuant to the provisions of
subdivision (g) of Section 30610 of the
Public Resources Code;
iv) the demolition and reconstruction
of a single-family residence; provided,
that the reconstructed residence shall
not exceed either the floor area, height
or bulk of the former structure by
(including but not limited to floor, roof,
and foundation structures), whether or
not the floor area or building footprint
is expanded; or
ii) an addition that includes new floor
area at or below the first story equal to
50 percent or more of the structure’s
total existing floor area; or
iii) an increase of the existing building
footprint equal to 50 percent or more;
but excluding removal, replacement, or
maintenance of nonstructural exterior
components of exterior walls such as
decorative siding, shingles, and roofing
materials and windows;
Chapter Page # Modification
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Brief Summary more than 10 percent, and that the
reconstructed residence shall be sited
in the same location on the affected
property as the former structure; or
v) the reconstruction, repair, or
maintenance of any shoreline
protection structure; provided,
however, that the reconstructed,
repaired, or maintained shoreline
protection structure is not seaward of
the location of the former structure,
and that such modifications do not
increase the height or length of the
former shoreline protection structure
by more than 10 percent.

Changes to exterior walls, floor area,
height, length, or building footprint
shall be measured cumulatively from
those existing at the site on the date of
certification of the LCLUP. The cost of
improvements shall not be used as a
basis in application of this definition or
any policy relying thereupon unless
expressly stated in the policy.

Incremental changes that cumulatively
amount to replacement of 50 percent
or more over time shall also be
considered a SSM.

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