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Agenda packet

Pacifica City Council
January 22, 2024

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Agenda packet
Meeting
January 22, 2024
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Pacifica City Council
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12
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Housing Element Update and to publicly accessible repositories including the Sharp Park and Sanchez branches of the Pacifica Library and invited comments on the Negative Declaration in compliance with CEQA Guidelines Sections 15082; and
WHEREAS, the 30-day minimum public review and comment period for the Negative Declaration commenced from November 16, 2023 through December 18, 2023; and WHEREAS, written comments on the Negative Declaration were collected and considered; and
WHEREAS, the Planning Commission of the City of Pacifica did hold a duly noticed public hearing to consider the Housing Element Update (HEU) at a regular meeting on January 4, 2024, at which time it considered all oral and documentary evidence presented, and incorporated all testimony and documents into the record by reference.

NOW, THEREFORE BE IT RESOLVED, that the Planning Commission of the City of Pacifica does hereby find as follows:

1. The above recitals are true and correct and material to this Resolution.

2. In making its findings and recommendation, the Planning Commission relied upon and hereby incorporates by reference all correspondence, oral and written comments, staff reports, and other related materials in connection with this agenda item.

BE IT FURTHER RESOLVED, that, with respect to the Negative Declaration, the Planning Commission of the City of Pacifica hereby:

1. Finds that (a) it has independently reviewed, analyzed, and considered the Negative Declaration and all written documentation and public comments prior to recommending City Council approval of the Housing Element Update, (b) the Negative Declaration has been completed in compliance with CEQA and consistent with state and local guidelines implementing CEQA, (c) the revisions to the Housing Element since the time of original circulation of the Negative Declaration do not require amendment or recirculation of the Negative Declaration pursuant to CEQA Guidelines Section 15073.5, since the revisions do not alter any of the findings or conclusions of the Negative Declaration, (d) the Negative Declaration represents the independent judgment and analysis of the City as lead agency for the Project, and (e) that on the basis of the whole record there is no substantial evidence in the record that the Housing Element will have a significant effect on the environment.

2. Recommends that the City Council make the findings set forth above and adopt the Negative Declaration, which is attached to the staff report, in accordance with the California Environmental Quality Act.

3. Declares that the custodian of the documents and other materials which constitute the record of proceedings upon which this decision is based is the Planning Department of the City of Pacifica, 540 Crespi Drive, Pacifica, CA 94044.

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January 4, 2024

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BE IT FURTHER RESOLVED, that the Planning Commission of the City of Pacifica does hereby:

1. Finds that the public health, safety, and general welfare are best served by adoption of the Housing Element.

2. Finds that the Housing Element substantially complies with Housing Element Law, as provided in Government Code 65580 et seq. and contains all provisions required by State Housing Element Law, as set forth in Exhibit “A” to this Resolution, which is incorporated herein by this reference and which identifies where each applicable requirement of the Government Code is addressed in the document.

3. Finds that the Housing Element substantially complies with all requirements of State Housing Element Law as interpreted by HCD. As required by Government Code Section 65585(e), the Planning Commission has considered the findings made by the Department of Housing and Community Development included in its letter dated August 8, 2023, as required by Government Code Section 65585(f).

The City has revised the Housing Element to address each of the findings in the HCD letter. The revisions, and the manner in which the Housing Element addresses HCD comments, have been listed in Exhibit “B” to this Resolution, which is incorporated herein by reference.

4. Recommends that the City Council adopt the Housing Element Update for the period of 2023-2031, in substantially similar form to that included as Exhibit “C” to this Resolution. The Planning Commission further recommends that staff be authorized to make revisions that are requested by HCD to achieve certification and that are consistent with Council action and direction. * * * * *

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EXHIBIT A

FINDINGS OF SUBSTANTIAL COMPLIANCE WITH STATE HOUSING
ELEMENT LAW, AS PROVIDED IN GOVERNMENT CODE 65580 ET SEQ.

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Conformance of Housing Element with State Law Requirements, Article

10.6 [65580 – 65589.11]
Note: All page number references are to the “clean” Adoption Draft version of the Housing Element published on December 8, 2023. Provisions labelled N/A are not applicable to the City of Pacifica

GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
Section 65583
The housing element shall consist of an identification and analysis of existing and projected housing needs and a
statement of goals, policies, quantified objectives, financial resources, and scheduled programs for the preservation, improvement, and development of housing.

Section 5 (Housing Needs)
Section 6 (Assessment of Fair
Housing)
Section 11 (Goals and Policies)
Section 14 (Quantified Objectives)
Appendix C (Housing Needs)
Appendix D (City of Pacifica
Assessment of Fair Housing)
The housing element shall identify adequate sites for
housing, including rental housing, factory-built housing, mobilehomes, and emergency shelters, and shall make
adequate provision for the existing and projected needs of all economic segments of the community.

Section 8 (Housing Sites Inventory)
Section 10 (Fair Housing Plan)
Appendix F (Housing Sites)
Appendix D (City of Pacifica Assessment
of Fair Housing)
The element shall contain all of the following: N/A
(a) An assessment of housing needs and an inventory of
resources and constraints relevant to the meeting of these needs. The assessment and inventory shall include all of the following:

Section 5 (Housing Needs)
Section 9 (Housing Constraints)
Appendix C (Housing Needs)
Appendix G (Housing Constraints)
(a)(1) An analysis of population and employment trends and documentation of projections
Appendix C (Housing Needs)
(a)(1) A quantification of the locality’s existing and projected housing needs for all income levels, including extremely low income households, as defined in subdivision (b) of Section 50105 and Section 50106 of the Health and Safety Code.

These existing and projected needs shall include the
locality’s share of the regional housing need in accordance with Section 65584. Local agencies shall calculate the subset of very low income households allotted under Section 65584 that qualify as extremely low income households. The local agency may either use available census data to calculate the percentage of very low income households that qualify as extremely low income households or presume that 50
percent of the very low income households qualify as
extremely low income households. The number of extremely low income households and very low income households
shall equal the jurisdiction’s allocation of very low income households pursuant to Section 65584.

Section 8 (Housing Sites Inventory)
Appendix F (Housing Sites Inventory)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(2) An analysis and documentation of household
characteristics, including level of payment compared to ability to pay,
Section 5 (Housing Needs)
Appendix C (Housing Needs)
(a)(2) housing characteristics, including overcrowding, and Section 5 (Housing Needs) Appendix C (Housing Needs)
(a)(2) housing stock condition. Section 5 (Housing Needs) Appendix C (Housing Needs)
(a)(3) An inventory of land suitable and available for
residential development, including vacant sites and sites having realistic and demonstrated potential for
redevelopment during the planning period to meet the
locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites, and an analysis of the relationship of the sites identified in the land inventory to the jurisdiction’s duty to affirmatively further fair housing.

Section 8 (Housing Sites Inventory)
Appendix F (Housing Sites Inventory)
Appendix D (City of Pacifica Assessment
of Fair Housing)
[Note that AB 2339 (Chapter 654, Statutes of 2022)
amended Section 65583(a)(4). It does not apply to ABAGarea housing elements unless the first draft of the housing element is submitted to ABAG after January 31, 2023 or a draft is submitted after April 1, 2023. Therefore the sections below include the statutory provisions of Section 65583(a)(4) effective in 2022. Jurisdictions
adopting their housing element after January 31, 2023
should describe why AB 2339 is not applicable to them.] Appendix G (Housing Constraints)
(a)(4)(A) The identification of a zone or zones where
emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit. The identified zone or zones shall include sufficient capacity to
accommodate the need for emergency shelter identified in paragraph (7), except that each local government shall
identify a zone or zones that can accommodate at least one year-round emergency shelter.

Appendix G (Housing Constraints);
Program HE-1-14
(a)(4)(A) If the local government cannot identify a zone or zones with sufficient capacity, the local government shall include a program to amend its zoning ordinance to meet the requirements of this paragraph within one year of the
adoption of the housing element. The local government may identify additional zones where emergency shelters are
permitted with a conditional use permit.

Appendix G (Housing Constraints);
Program HE-1-10

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(a)(4)(A) The local government shall also demonstrate that existing or proposed permit processing, development, and management standards are objective and encourage and
facilitate the development of, or conversion to, emergency shelters.

Appendix G (Housing Constraints)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(4)(A) Emergency shelters may only be subject to those development and management standards that apply to
residential or commercial development within the same zone except that a local government may apply written, objective standards that include all of the following:
(i) The maximum number of beds or persons permitted to be served nightly by the facility.
(ii) Sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not
require more parking for emergency shelters than other
residential or commercial uses within the same zone.
(iii) The size and location of exterior and interior onsite waiting and client intake areas.
(iv) The provision of onsite management.
(v) The proximity to other emergency shelters, provided that emergency shelters are not required to be more than 300 feet apart.
(vi) The length of stay.
(vii) Lighting.
(viii) Security during hours that the emergency shelter is in operation.

Appendix G (Housing Constraints);
Program HE-1-14
(a)(4)(B) The permit processing, development, and
management standards applied under this paragraph shall not be deemed to be discretionary acts within the meaning of the California Environmental Quality Act (Division 13
(commencing with Section 21000) of the Public Resources Code).

Appendix G (Housing Constraints);
Program HE-1-14
(a)(4)(C) A local government that can demonstrate to the satisfaction of the department the existence of one or more emergency shelters either within its jurisdiction or pursuant to a multijurisdictional agreement that can accommodate that jurisdiction’s need for emergency shelter identified in paragraph (7) may comply with the zoning requirements of subparagraph (A) by identifying a zone or zones where new emergency shelters are allowed with a conditional use
permit.

N/A
(a)(4)(D) A local government with an existing ordinance or ordinances that comply with this paragraph shall not be required to take additional action to identify zones for emergency shelters. The housing element must only
describe how existing ordinances, policies, and standards are consistent with the requirements of this paragraph.

N/A

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(5) An analysis of potential and actual governmental constraints upon the maintenance, improvement, or
development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and [Note: The types of housing identified in Section
65583(c)(1) include multifamily rental housing, factorybuilt housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy
units, emergency shelters, and transitional housing.]
Section 9 (Housing Constraints)
Appendix G (Housing Constraints)
(a)(5) for persons with disabilities as identified in the analysis pursuant to paragraph (7),
Appendix C (Housing Constraints)
(a)(5) including land use controls, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) building codes and their enforcement, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) site improvements, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) fees and other exactions required of developers, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) local processing and permit procedures, Appendix G (Housing Constraints), Section 2 (Governmental Constraints)
(a)(5) and any locally adopted ordinances that directly impact the cost and supply of residential development.

Appendix G (Housing Constraints),
Section 2 (Governmental Constraints)
(a)(5) The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Section 65584
Section 11 (Goals and Policies)
Section 12 (2023-2031 Programs),
programs HE-I-1, HE-1-2
(a)(5) and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7).

Section 11 (Goals and Policies)
Section 12 (2023-2031 Programs),
programs HE-1-9, HE-1-10, HE-1-11,
HE-1-12
(a)(6) An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or
development of housing for all income levels, including the availability of financing,
Appendix G (Housing Constraints)
Section 11 (Goals and Policies),
programs HE-1-1, HE-1-2
(a)(6) the price of land, Appendix G (Housing Constraints) (a)(6) the cost of construction, Appendix G (Housing Constraints) (a)(6) the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Section 65583.2,
Appendix F (Housing Sites)
(a)(6) and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Section 65584.

Appendix G (Housing Constraints)

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(a)(6) The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap
between the locality’s planning for the development of
housing for all income levels and the construction of that housing.

Section 11 (Goals and Policies)
Section 12 (2023-2031 Programs),
programs HE-1-1, HE-1-2

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(7) An analysis of any special housing needs, such as those of the
Section 5 (Housing Needs)
Appendix C (Housing Needs)
(a)(7) elderly; Appendix C (Housing Needs)
(a)(7) persons with disabilities, including a developmental disability, as defined in Section 4512 of the Welfare and Institutions Code;
Appendix C (Housing Needs)
(a)(7) large families; Appendix C (Housing Needs)
(a)(7) farmworkers; Appendix C (Housing Needs)
(a)(7) families with female heads of households; Appendix C (Housing Needs) (a)(7) and families and persons in need of emergency
shelter.

Appendix C (Housing Needs)
(a)(7) The need for emergency shelter shall be assessed based on the capacity necessary to accommodate the most recent homeless point-in-time count conducted before the start of the planning period, the need for emergency shelter based on number of beds available on a year-round and
seasonal basis, the number of shelter beds that go unused on an average monthly basis within a one-year period, and the percentage of those in emergency shelters that move to permanent housing solutions.

Appendix G (Housing Constraints)
(a)(7) The need for emergency shelter may be reduced by the number of supportive housing units that are identified in an adopted 10-year plan to end chronic homelessness and that are either vacant or for which funding has been identified to allow construction during the planning period.

N/A
(a)(7) An analysis of special housing needs by a city or county may include an analysis of the need for frequent user coordinated care housing services.

N/A
(a)(8) An analysis of opportunities for energy conservation with respect to residential development. Cities and counties are encouraged to include weatherization and energy
efficiency improvements as part of publicly subsidized
housing rehabilitation projects. This may include energy efficiency measures that encompass the building envelope, its heating and cooling systems, and its electrical system.

Section 11 (Goals and Policies),
Program HE-P-4
(a)(9) An analysis of existing assisted housing developments that are eligible to change from low-income housing uses during the next 10 years due to termination of subsidy
contracts, mortgage prepayment, or expiration of restrictions on use. “Assisted housing developments,” for the purpose of this section, shall mean multifamily rental housing that receives governmental assistance under federal programs listed in subdivision (a) of Section 65863.10, state and local multifamily revenue bond programs, local redevelopment
programs, the federal Community Development Block Grant Program, or local in-lieu fees. “Assisted housing
developments” shall also include multifamily rental units that Appendix C (Housing Needs)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
were developed pursuant to a local inclusionary housing program or used to qualify for a density bonus pursuant to Section 65915.
(a)(9)(A) The analysis shall include a listing of each
development by project name and address, the type of
governmental assistance received, the earliest possible date of change from low-income use, and the total number of
elderly and nonelderly units that could be lost from the locality’s low-income housing stock in each year during the 10-year period. For purposes of state and federally funded projects, the analysis required by this subparagraph need only contain information available on a statewide basis.

Appendix C (Housing Needs), Section 9
(a)(9)(B) The analysis shall estimate the total cost of producing new rental housing that is comparable in size and rent levels, to replace the units that could change from lowincome use, and an estimated cost of preserving the assisted housing developments. This cost analysis for replacement housing may be done aggregately for each five-year period and does not have to contain a project-by-project cost
estimate.

Appendix C (Housing Needs)
(a)(9)(C) The analysis shall identify public and private nonprofit corporations known to the local government that have legal and managerial capacity to acquire and manage these housing developments.

Appendix E (Housing Resources)
(a)(9)(D) The analysis shall identify and consider the use of all federal, state, and local financing and subsidy programs that can be used to preserve, for lower income households, the assisted housing developments, identified in this
paragraph, including, but not limited to, federal Community Development Block Grant Program funds, tax increment
funds received by a redevelopment agency of the
community, and administrative fees received by a housing authority operating within the community. In considering the use of these financing and subsidy programs, the analysis shall identify the amounts of funds under each available program that have not been legally obligated for other
purposes and that could be available for use in preserving assisted housing developments.

Appendix E (Housing Resources)
(b) (1) A statement of the community’s goals, quantified objectives, and policies relative to affirmatively furthering fair housing and to the maintenance, preservation, improvement, and development of housing.

Section 5 (Housing Needs)
Section 6 (Assessment of Fair
Housing)
Section 11 (Goals and Policies)
Section 14 (Quantified Objectives)
Appendix C (Housing Needs)
Appendix D (City of Pacifica
Assessment of Fair Housing)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(2) It is recognized that the total housing needs identified pursuant to subdivision (a) may exceed available resources and the community’s ability to satisfy this need within the content of the general plan requirements outlined in Article 5 (commencing with Section 65300). Under these
circumstances, the quantified objectives need not be
identical to the total housing needs. The quantified objectives shall establish the maximum number of housing units by
income category, including extremely low income, that can be constructed, rehabilitated, and conserved over a five-year time period.

Section 14 (Quantified Objectives)
(c) A program that sets forth a schedule of actions during the planning period, each with a timeline for implementation, that may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element
Section 12 (2023-2031 Programs)
(c) through the administration of land use and development controls,
Section 12 (2023-2031 Programs), HE1-1, HE-1-2, HE-1-3, HE-1-8, HE-I-14 (c) the provision of regulatory concessions and incentives, Section 12 (2023-2031 Programs), HEI-9 (c) the utilization of appropriate federal and state financing and subsidy programs when available,
Section 12 (2023-2031 Programs), HEI-7
(c) and the utilization of moneys in a low- and moderateincome housing fund of an agency if the locality has established a redevelopment project area pursuant to the Community Redevelopment Law (Division 24 (commencing
with Section 33000) of the Health and Safety Code).

Section 14 (Quantified Objectives)
In order to make adequate provision for the housing needs of all economic segments of the community, the program shall do all of the following:

N/A
(c)(1) Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a)
without rezoning, and to comply with the requirements of Section 65584.09.

Section 12 (2023-2031 Programs),
program HE-I-1, HE-1-2, HE-1-6, HE-1-
12 (c)(1) Sites shall be identified as needed to affirmatively further fair housing
Appendix D (City of Pacifica
Assessment of Fair Housing)
(c)(1) and to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing,
Appendix C (Housing Needs)
Appendix D (City of Pacifica
Assessment of Fair Housing)
(c)(1) factory-built housing, Appendix G (Housing Constraints)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(1) mobilehomes, Appendix B (Prior Housing Element
Review), Mobile Home Preservation
(c)(1) housing for agricultural employees, Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1) supportive housing, Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1) single-room occupancy units, Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1) emergency shelters, Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1) and transitional housing. Appendix G (Housing Constraints) Chapter 12 (2023-2031 Programs),
program HE-I-14
(c)(1)(A) Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, rezoning of those sites, including adoption of minimum density and development
standards, for jurisdictions with an eight-year housing element planning period pursuant to Section 65588, shall be completed no later than three years after either the date the housing element is adopted pursuant to subdivision (f) of Section 65585 or the date that is 90 days after receipt of comments from the department pursuant to subdivision (b) of Section 65585, whichever is earlier, unless the deadline is extended pursuant to subdivision (f). Notwithstanding the foregoing, for a local government that fails to adopt a housing element that the department has found to be in substantial compliance with this article within 120 days of the statutory deadline in Section 65588 for adoption of the housing
element, rezoning of those sites, including adoption of minimum density and development standards, shall be
completed no later than one year from the statutory deadline in Section 65588 for adoption of the housing element.

Section 12 (2023-2031 Programs),
program HE-I-1, HE-I-2
(c)(1)(B) Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, the program shall identify sites that can be developed for housing within the planning period pursuant to subdivision (h) of Section 65583.2. The identification of sites shall include all components specified in Section 65583.2. Note: Please see Section 65583.2
regarding the land inventory and conformance with
subdivision (h).

Section 12 (2023-2031 Programs),
program HE-I-1, HE-I-2
Appendix F (Housing Sites)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(1)(C) Where the inventory of sites pursuant to paragraph (3) of subdivision (a) does not identify adequate sites to accommodate the need for farmworker housing, the program shall provide for sufficient sites to meet the need with zoning that permits farmworker housing use by right, including density and development standards that could accommodate and facilitate the feasibility of the development of farmworker housing for low- and very low income households.

Section 12 (2023-2031 Programs),
program HE-1-12
(c)(2) Assist in the development of adequate housing to meet the needs of extremely low, very low, low-, and moderateincome households.

Section 12 (2023-2031 Programs), all
programs
(c)(3) Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to
the maintenance, improvement, and development of housing, including housing for all income levels
Appendix G (Housing Constraints)
(c)(3) and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable
accommodations for housing designed for, intended for
occupancy by, or with supportive services for, persons with disabilities.

Appendix G (Housing Constraints)
Section 12 (2023-2031 Programs),
programs HE-I-9, HE-I-12
(c)(3) Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone.

Appendix G (Housing Constraints)
Section 12 (2023-2031 Programs),
programs HE-I-14
(c)(3) Supportive housing, as defined in Section 65650, shall be a use by right in all zones where multifamily and mixed uses are permitted, as provided in Article 11 (commencing with Section 65650).

Appendix G (Housing Constraints)
Section 12 (2023-2031 Programs),
programs HE-I-14
(c)(4) Conserve and improve the condition of the existing affordable housing stock, which may include addressing
ways to mitigate the loss of dwelling units demolished by public or private action.

Appendix G (Housing Constraints)
Section 12 (2023-2031 Programs),
programs HE-I-8, HE-I-12
(c)(5) Promote and affirmatively further fair housing
opportunities and promote housing throughout the
community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law.

Section 6 (Assessment of Fair Housing)
Section 10 (Fair Housing Plan)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(6) Preserve for lower income households the assisted housing developments identified pursuant to paragraph (9) of subdivision (a).

Section 6 (Assessment of Fair Housing)
Section 10 (Fair Housing Plan)
Appendix D (City of Pacifica Assessment
of Fair Housing)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(6) The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available.

Appendix C (Housing Needs)
(c)(6) The program may include strategies that involve local regulation and technical assistance.

Section 12 (2023-2031 Programs),
programs HE-I-5, HE-I-7
(c)(7) Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory
dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2.

Section 12 (2023-2031 Programs),
programs HE-I-4
(c)(8) Include an identification of the agencies and officials responsible for the implementation of the various actions and the means by which consistency will be achieved with other general plan elements and community goals.

Section 15 (Consistency with General
Plan, Zoning Code, and Local Coastal
Land Use Plan)
(c)(9) Include a diligent effort by the local government to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort.

Appendix F (Housing Sites)
(c)(10)(A) Affirmatively further fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2. The program shall include an assessment of fair housing in the jurisdiction that shall include all of the following components:

Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(i) A summary of fair housing issues in the
jurisdiction
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(i) and an assessment of the jurisdiction’s fair housing enforcement and fair housing outreach capacity.

Appendix A (Community Consultation)
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii) An analysis of available federal, state, and local data and knowledge to identify integration and segregation patterns and trends,
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii)racially or ethnically concentrated areas of poverty and affluence,
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii) disparities in access to opportunity, Appendix C (Housing Needs) Appendix D (City of Pacifica Assessment

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of Fair Housing)
(c)(10)(A)(ii) and disproportionate housing needs, Appendix C (Housing Needs) Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii) including displacement risk. Appendix C (Housing Needs) Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(ii) The analysis shall identify and examine such patterns, trends, areas, disparities, and needs, both within the jurisdiction.

Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(10)(A)(ii) and comparing the jurisdiction to the region in which it is located, based on race and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2) and Section 65008.

Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(iii) An assessment of the contributing factors, including the local and regional historical origins
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(iii) and current policies and practices, for the fair housing issues identified under clauses (i) and (ii).

Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(iv) An identification of the jurisdiction’s fair housing priorities and goals, giving highest priority to those factors identified in clause (iii) that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance,
Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(iv) and identifying the metrics and milestones for determining what fair housing results will be achieved.

Appendix C (Housing Needs)
Appendix D (City of Pacifica Assessment
of Fair Housing)
(c)(10)(A)(v) Strategies and actions to implement those priorities and goals, which may include, but are not limited to, enhancing mobility strategies
Section 12 (2023-2031 Programs), HEI-11, HE-1-12
(c)(10)(A)(v) and encouraging development of new affordable housing in areas of opportunity,
Section 12 (2023-2031 Programs),
HE-I-8, HE-I-9
(c)(10)(A)(v) as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing,
Section 12 (2023-2031 Programs), all
programs
(c)(10)(A)(v) and protecting existing residents from
displacement.

Section 12 (2023-2031 Programs), HEI-7
(c)(10)(B) A jurisdiction that completes or revises an
assessment of fair housing pursuant to Subpart A
(commencing with Section 5.150) of Part 5 of Subtitle A of Title 24 of the Code of Federal Regulations, as published in Volume 80 of the Federal Register, Number 136, page
42272, dated July 16, 2015, or an analysis of impediments to fair housing choice in accordance with the requirements of Section 91.225 of Title 24 of the Code of Federal Regulations in effect before August 17, 2015, may incorporate relevant portions of that assessment or revised assessment of fair housing or analysis or revised analysis of impediments to fair housing into its housing element.

Section 6 (Assessment of Fair Housing)
(c)(10)(C) The requirements of this paragraph shall apply to housing elements due to be revised pursuant to Section
65588 on or after January 1, 2021.

Applicable; see compliance provisions
noted above

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(d)(1) A local government may satisfy all or part of its requirement to identify a zone or zones suitable for the development of emergency shelters pursuant to paragraph (4) of subdivision (a) by adopting and implementing a
multijurisdictional agreement, with a maximum of two other adjacent communities, that requires the participating
jurisdictions to develop at least one year-round emergency shelter within two years of the beginning of the planning period.

N/A. No multi-jurisdictional agreement
for emergency shelter
(d)(2) The agreement shall allocate a portion of the new shelter capacity to each jurisdiction as credit toward its emergency shelter need, and each jurisdiction shall describe how the capacity was allocated as part of its housing
element.

N/A. No multi-jurisdictional agreement
for emergency shelter
(d)(3) Each member jurisdiction of a multijurisdictional agreement shall describe in its housing element all of the following:

N/A. No multi-jurisdictional agreement
for emergency shelter
(d)(3)(A) How the joint facility will meet the jurisdiction’s emergency shelter need.
(d)(3)(B) The jurisdiction’s contribution to the facility for both the development and ongoing operation and management of the facility.
(d)(3)(C) The amount and source of the funding that the jurisdiction contributes to the facility.

N/A. No multi-jurisdictional agreement
for emergency shelter
(d)(4) The aggregate capacity claimed by the participating jurisdictions in their housing elements shall not exceed the actual capacity of the shelter.

N/A. No multi-jurisdictional agreement
for emergency shelter
(e) Except as otherwise provided in this article, amendments to this article that alter the required content of a housing element shall apply to both of the following: [Note that this provision is applicable to AB 2339 (Chapter 654, Statutes of 2022), which amended Section 65583(a)(4).

Jurisdictions adopting their housing element after
January 1, 2023 should describe why this amendment is
not applicable to them.]
The City Council has adopted an
emergency shelter ordinance that
complies with the applicable statutory
requirements.
(1) A housing element or housing element amendment
prepared pursuant to subdivision (e) of Section 65588 or Section 65584.02, when a city, county, or city and county submits a draft to the department for review pursuant to Section 65585 more than 90 days after the effective date of the amendment to this section.

The City Council has adopted an
emergency shelter ordinance that
complies with the applicable statutory
requirements.
(2) Any housing element or housing element amendment
prepared pursuant to subdivision (e) of Section 65588 or Section 65584.02, when the city, county, or city and county fails to submit the first draft to the department before the due date specified in Section 65588 or 65584.02.

The City Council has adopted an
emergency shelter ordinance that
complies with the applicable statutory
requirements.
(f) – (j): Not applicable N/A

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
Section 65583.1(a)
(a) The Department of Housing and Community
Development, in evaluating a proposed or adopted housing element for substantial compliance with this article, … may also allow a city or county to identify sites for accessory dwelling units based on the number of accessory dwelling units developed in the prior housing element planning period whether or not the units are permitted by right, the need for these units in the community, the resources or incentives available for their development, and any other relevant factors, as determined by the department.

Appendix F (Housing Sites)
(b) Sites that contain permanent housing units located on a military base undergoing closure or conversion as a result of action pursuant to the Defense Authorization Amendments and Base Closure and Realignment Act (Public Law 100-
526), the Defense Base Closure and Realignment Act of
1990 (Public Law 101-510), or any subsequent act requiring the closure or conversion of a military base may be identified as an adequate site if the housing element demonstrates that the housing units will be available for occupancy by
households within the planning period of the element. No sites containing housing units scheduled or planned for demolition or conversion to nonresidential uses shall qualify as an adequate site.

N/A (no military base in Pacifica)
Note: If communities are using the provisions of Section 65583.1(c), which allow RHNA credit for conversion of
non-affordable to affordable housing and for
preservation of existing affordable housing at risk of
loss, the applicable provisions need to be added to this table.

N/A. Provision is not being used for
RHNA credit.

Section 65583.2
(a) A city’s or county’s inventory of land suitable for residential development pursuant to paragraph (3) of
subdivision (a) of Section 65583 shall be used to identify sites throughout the community, consistent with paragraph (10) of subdivision (c) of Section 65583,
Appendix F (Housing Sites)
(a) that can be developed for housing within the planning period and that are sufficient to provide for the jurisdiction’s share of the regional housing need for all income levels pursuant to Section 65584. As used in this section, “land suitable for residential development” includes all of the following sites that meet the standards set forth in
subdivisions (c) and (g):

Appendix F (Housing Sites)
(a)(1) Vacant sites zoned for residential use. Appendix F (Housing Sites) (a)(2) Vacant sites zoned for nonresidential use that allows residential development.

Appendix F (Housing Sites)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(3) Residentially zoned sites that are capable of being developed at a higher density, including sites owned or leased by a city, county, or city and county
Appendix F (Housing Sites)
(a)(4) Sites zoned for nonresidential use that can be
redeveloped for residential use, and for which the housing element includes a program to rezone the site, as necessary, rezoned for, to permit residential use, including sites owned or leased by a city, county, or city and county.

Appendix F (Housing Sites)
(b) The inventory of land shall include all of the following: N/A (b)(1) A listing of properties by assessor parcel number. Appendix F (Housing Sites) (b)(2) The size of each property listed pursuant to paragraph (1), and the general plan designation and zoning of each property.

Appendix F (Housing Sites)
(b)(3) For nonvacant sites, a description of the existing use of each property.

Appendix F (Housing Sites)
(b)(3) If a site subject to this paragraph is owned by the city or county, the description shall also include whether there are any plans to dispose of the property during the planning period and how the city or county will comply with Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.

Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(b)(4) A general description of any environmental constraints to the development of housing within the jurisdiction, the documentation for which has been made available to the
jurisdiction. This information need not be identified on a sitespecific basis.

Appendix G (Housing Constraints)
(b)(5)(A) A description of existing or planned water, sewer, and other dry utilities supply, including the availability and access to distribution facilities.

Appendix F (Housing Sites)
Appendix G (Housing Constraints)
(b)(5)(B) Parcels included in the inventory must have
sufficient water, sewer, and dry utilities supply available and accessible to support housing development or be included in an existing general plan program or other mandatory
program or plan, including a program or plan of a public or private entity providing water or sewer service, to secure sufficient water, sewer, and dry utilities supply to support housing development. This paragraph does not impose any additional duty on the city or county to construct, finance, or otherwise provide water, sewer, or dry utilities to parcels included in the inventory.

Appendix F (Housing Sites)
(b)(6) Sites identified as available for housing for above moderate-income households in areas not served by public sewer systems. This information need not be identified on a site-specific basis.

N/A. All new development in the City of
Pacifica would be served by a public
sewer system.
(b)(7) A map that shows the location of the sites included in the inventory, such as the land use map from the
jurisdiction’s general plan, for reference purposes only.

Figures F-1 through F-10

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c) Based on the information provided in subdivision (b), a city or county shall determine whether each site in the inventory can accommodate the development of some
portion of its share of the regional housing need by income level during the planning period, as determined pursuant to Section 65584. The inventory shall specify for each site the number of units that can realistically be accommodated on that site and whether the site is adequate to accommodate lower income housing, moderate-income housing, or above moderate-income housing.

Appendix F (Housing Sites)
(c) A nonvacant site identified pursuant to paragraph (3) or (4) of subdivision (a) in a prior housing element and a vacant site that has been included in two or more consecutive
planning periods that was not approved to develop a portion of the locality’s housing need shall not be deemed adequate to accommodate a portion of the housing need for lower
income households that must be accommodated in the
current housing element planning period unless the site is zoned at residential densities consistent with paragraph (3) of this subdivision and the site is subject to a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower income households. An unincorporated area in a nonmetropolitan county pursuant to clause (ii) of subparagraph (B) of paragraph (3) shall not be subject to the requirements of this subdivision to allow residential use by right.

Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(c) Notwithstanding the foregoing, for a local government that fails to adopt a housing element that the department has found to be in substantial compliance with state law within 120 days of the statutory deadline in Section 65588 for adoption of the housing element, rezoning pursuant to this subdivision shall be completed no later than one year from the statutory deadline in Section 65588 for adoption of the housing element.

N/A – Statutory provision addresses
timing for rezoning, not Housing
Element compliance.
(c) The analysis shall determine whether the inventory can provide for a variety of types of housing, including multifamily rental housing,
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-1, HE-I-4, HE-I-5, HE-I7, HE-I-12
(c) factory-built housing, mobilehomes, Appendix F (Housing Sites) Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) housing for agricultural employees, supportive housing, Appendix F (Housing Sites) Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) single-room occupancy units, Appendix F (Housing Sites) Section 12 (2023-2031 Programs),

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programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) emergency shelters, and Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) transitional housing Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) and whether the inventory affirmatively furthers fair housing.

Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12
(c) The city or county shall determine the number of housing units that can be accommodated on each site as follows:

Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
programs HE-I-4, HE-I-5, HE-I-7, HE-I12

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(1) If local law or regulations require the development of a site at a minimum density, the department shall accept the planning agency’s calculation of the total housing unit capacity on that site based on the established minimum
density. If the city or county does not adopt a law or
regulation requiring the development of a site at a minimum density, then it shall demonstrate how the number of units determined for that site pursuant to this subdivision will be accommodated.

Appendix F (Housing Sites)
(c)(2) The number of units calculated pursuant to paragraph (1) shall be adjusted as necessary, based on the land use controls and site improvements requirement identified in paragraph (5) of subdivision (a) of Section 65583,
(c)(2) the realistic development capacity for the site, Appendix F (Housing Sites) (c)(2) typical densities of existing or approved residential developments at a similar affordability level in that
jurisdiction,
Appendix F (Housing Sites)
(c)(2) and on the current or planned availability and
accessibility of sufficient water, sewer, and dry utilities.

Appendix F (Housing Sites)
(c)(2)(A) A site smaller than half an acre shall not be deemed adequate to accommodate lower income housing need
unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site is adequate to accommodate lower income housing.

Appendix F (Housing Sites)
(c)(2)(B) A site larger than 10 acres shall not be deemed adequate to accommodate lower income housing need
unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site can be
developed as lower income housing.

Appendix F (Housing Sites)
(c)(2)(B) For purposes of this subparagraph, “site” means that portion of a parcel or parcels designated to
accommodate lower income housing needs pursuant to this subdivision.

Appendix F (Housing Sites)
(c)(2)(C) A site may be presumed to be realistic for
development to accommodate lower income housing need if, at the time of the adoption of the housing element, a
development affordable to lower income households has
been proposed and approved for development on the site.

Appendix F (Housing Sites)
(c)(3) For the number of units calculated to accommodate its share of the regional housing need for lower income
households pursuant to paragraph (2), a city or county shall do either of the following:

Appendix F (Housing Sites)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(3)(A) Provide an analysis demonstrating how the adopted densities accommodate this need. The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower income households.

Appendix F (Housing Sites)
(c)(3)(B) The following densities shall be deemed appropriate to accommodate housing for lower income households:
(i) For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre.
(ii) For an unincorporated area in a nonmetropolitan county not included in clause (i): sites allowing at least 10 units per acre.
(iii) For a suburban jurisdiction: sites allowing at least 20 units per acre.
(iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre.

Appendix F (Housing Sites)
(4)(A) For a metropolitan jurisdiction:
(4)(A)(i) At least 25 percent of the jurisdiction’s share of the regional housing need for moderate-income housing shall be allocated to sites with zoning that allows at least 4 units of housing, but not more than 100 units per acre of housing.

Appendix F (Housing Sites)
(4)(A)(ii) At least 25 percent of the jurisdiction’s share of the regional housing need for above moderate-income housing shall be allocated to sites with zoning that allows at least 4 units of housing.

Appendix F (Housing Sites)
(B) The allocation of moderate-income and above moderateincome housing to sites pursuant to this paragraph shall not be a basis for the jurisdiction to do either of the following:
(i) Deny a project that does not comply with the allocation. (ii) Impose a price minimum, price maximum, price control, or any other exaction or condition of approval in lieu thereof.

This clause does not prohibit a jurisdiction from imposing any price minimum, price maximum, price control, exaction, or condition in lieu thereof, pursuant to any other law.
(iii) The provisions of this subparagraph do not constitute a change in, but are declaratory of, existing law with regard to the allocation of sites pursuant to this section.

The City of Pacifica’s 2023-2031
Housing Element is not inconsistent with
this requirement.
(C) This paragraph does not apply to an unincorporated
area.

N/A
(D) For purposes of this paragraph: N/A
(i) “Housing development project” has the same meaning as defined in paragraph (2) of subdivision (h) of Section
65589.5.

N/A

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(ii) “Unit of housing” does not include an accessory dwelling unit or junior accessory dwelling unit that could be approved pursuant to Section 65852.2 or Section 65852.22 or through a local ordinance or other provision implementing either of those sections. This paragraph shall not limit the ability of a local government to count the actual production of accessory dwelling units or junior accessory dwelling units in an annual progress report submitted pursuant to Section 65400 or other progress report as determined by the department.

Appendix F (Housing Sites)
(E) Nothing in this subdivision shall preclude the subdivision of a parcel, provided that the subdivision is subject to the Subdivision Map Act (Division 2 (commencing with Section 66410)) or any other applicable law authorizing the
subdivision of land.

N/A
(d) For purposes of this section, a metropolitan county, nonmetropolitan county, and nonmetropolitan county with a micropolitan area shall be as determined by the United
States Census Bureau. A nonmetropolitan county with a
micropolitan area includes the following counties: Del Norte, Humboldt, Lake, Mendocino, Nevada, Tehama, and
Tuolumne and other counties as may be determined by the United States Census Bureau to be nonmetropolitan counties with micropolitan areas in the future.

N/A. San Mateo County is a
metropolitan county
(e) (1) Except as provided in paragraph (2), a jurisdiction shall be considered suburban if the jurisdiction does not meet the requirements of clauses (i) and (ii) of subparagraph (B) of paragraph (3) of subdivision (c) and is located in a
Metropolitan Statistical Area (MSA) of less than 2,000,000 in population, unless that jurisdiction’s population is greater than 100,000, in which case it shall be considered
metropolitan. A county, not including the City and County of San Francisco, shall be considered suburban unless the
county is in an MSA of 2,000,000 or greater in population in which case the county shall be considered metropolitan.

N/A
(2)(A)(i) Notwithstanding paragraph (1), if a county that is in the San Francisco-Oakland-Fremont California MSA has a
population of less than 400,000, that county shall be
considered suburban. If this county includes an incorporated city that has a population of less than 100,000, this city shall also be considered suburban. This paragraph shall apply to a housing element revision cycle, as described in
subparagraph (A) of paragraph (3) of subdivision (e) of Section 65588, that is in effect from July 1, 2014, to
December 31, 2028, inclusive.

N/A.
(2)(A)(ii) A county subject to this subparagraph shall utilize the sum existing in the county’s housing trust fund as of June 30, 2013, for the development and preservation of housing affordable to low- and very low income households.

N/A

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(2)(B) A jurisdiction that is classified as suburban pursuant to this paragraph shall report to the Assembly Committee on Housing and Community Development, the Senate
Committee on Housing, and the Department of Housing and Community Development regarding its progress in
developing low- and very low income housing consistent with the requirements of Section 65400. The report shall be
provided three times: once, on or before December 31, 2019, which report shall address the initial four years of the housing element cycle, a second time, on or before December 31, 2023, which report shall address the subsequent four years of the housing element cycle, and a third time, on or before December 31, 2027, which report shall address the
subsequent four years of the housing element cycle and the cycle as a whole. The reports shall be provided consistent with the requirements of Section 9795.

N/A
(f) A jurisdiction shall be considered metropolitan if the jurisdiction does not meet the requirements for “suburban area” above and is located in an MSA of 2,000,000 or greater in population, unless that jurisdiction’s population is less than 25,000 in which case it shall be considered suburban.

See notes below.
(g)(1) For sites described in paragraph (3) of subdivision (b) [non-vacant sites], the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential.

See Appendix F (Housing Sites) for
analysis of development potential and
explanation of the methodology.
(g)(1) The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development,
See Appendix F (Housing Sites) for
methodology.
(g)(1) the city’s or county’s past experience with converting existing uses to higher density residential development, See Appendix F (Housing Sites) for
methodology.
(g)(1) the current market demand for the existing use, See Appendix F (Housing Sites) for methodology.
(g)(1) an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent
redevelopment of the site for additional residential
development,
See Appendix F (Housing Sites) for
methodology.
(g)(1) development trends, See Appendix F (Housing Sites) for methodology.
(g)(1) market conditions, See Appendix F (Housing Sites) for methodology.
(g)(1) and regulatory or other incentives or standards to encourage additional residential development on these sites.

See Appendix F (Housing Sites) for
methodology.

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(g)(2) In addition to the analysis required in paragraph (1), when a city or county is relying on nonvacant sites described in paragraph (3) of subdivision (b) to accommodate 50
percent or more of its housing need for lower income
households, the methodology used to determine additional development potential shall demonstrate that the existing use identified pursuant to paragraph (3) of subdivision (b) does not constitute an impediment to additional residential
development during the period covered by the housing
element. An existing use shall be presumed to impede
additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.

N/A – the Housing Element does not
rely on nonvacant sites to
accommodate 50 percent or more of
Pacifica’s housing need for lower
income households.
(g)(3) Notwithstanding any other law, and in addition to the requirements in paragraphs (1) and (2), sites that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, that are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income, subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or occupied by low or very low income households, shall be subject to a policy requiring the
replacement of all those units affordable to the same or lower income level as a condition of any development on the site.

Replacement requirements shall be consistent with those set forth in paragraph (3) of subdivision (c) of Section 65915.

N/A – the Housing Element does not
include any sites that are covered by
the criteria in this statutory provision.
(h) The program required by subparagraph (A) of paragraph (1) of subdivision (c) of Section 65583 shall accommodate 100 percent of the need for housing for very low and lowincome households allocated pursuant to Section 65584 for which site capacity has not been identified in the inventory of sites pursuant to paragraph (3) of subdivision (a) on sites that shall be zoned to permit owner-occupied and rental multifamily residential use by right for developments in which at least 20 percent of the units are affordable to lower income households during the planning period.

Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1, HE-I-8
(h) These sites shall be zoned with minimum density and development standards that permit at least
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(h) 16 units per site at a density of at least 16 units per acre in jurisdictions described in clause (i) of subparagraph (B) of paragraph (3) of subdivision (c),
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(h) shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c)
Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1

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Packet Pg. 1288 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) 4879 Exhibit -7151-A2984 v1 Page A-25 January 4, 2024
(h) and shall meet the standards set forth in subparagraph (B) of paragraph (5) of subdivision (b).

Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1

GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(h) At least 50 percent of the very low and low-income
housing need shall be accommodated on sites designated
for residential use and for which nonresidential uses or mixed uses are not permitted, except that a city or county may accommodate all of the very low and low-income housing
need on sites designated for mixed uses if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.

Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1
(i) For purposes of this section and Section 65583, the phrase “use by right” shall mean that the local government’s review of the owner-occupied or multifamily residential use may not require a conditional use permit, planned unit
development permit, or other discretionary local government review or approval that would constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. Any subdivision of the sites shall be subject to all laws, including, but not limited to, the local government ordinance implementing the Subdivision Map
Act.

Appendix F (Housing Sites)
Section 12 (2023-2031 Programs),
program HE-I-1, HE-I-2, HE-I-4
(i) A local ordinance may provide that “use by right” does not exempt the use from design review. However, that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public
Resources Code. Use by right for all rental multifamily residential housing shall be provided in accordance with subdivision (f) of Section 65589.5.

Section 12 (2023-2031 Programs),
program HE-I-2.
(j) Notwithstanding any other provision of this section, within one-half mile of a Sonoma-Marin Area Rail Transit station, housing density requirements in place on June 30, 2014, shall apply.

N/A

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Packet Pg. 1289 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption)

EXHIBIT B

FINDINGS OF SUBSTANTIAL COMPLIANCE WITH STATE HOUSING

ELEMENT LAW BASED ON REVISIONS TO HOUSING ELEMENT TO

ADDRESS FINDINGS IN THE CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (HCD) LETTER FROM AUGUST 8, 2023

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Packet Pg. 1290 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-1 Exhibit B:

Demonstration of Substantial Compliance through Responses to California Department of Housing & Community Development (HCD) Findings on Draft Pacifica 2023-2031 Housing Element
On May 10, 2023, the City of Pacifica submitted its Draft Housing Element to the California Department of Housing & Community Development (HCD) for that agency’s review. Pursuant to Government Code section 65585, subdivision (b), HCD reviewed the Draft Housing Element and reported the results of its review 90 days after receiving the Draft. The City received HCD’s findings on August 8, 2023. HCD found that the Draft met many statutory requirements but required revisions to be compliant with Housing Element law (Article 10.6 of the Government Code). HCD’s letter included a 12-page Appendix describing the revisions needed. On July 27, 2023, City staff and consultants met with the HCD reviewer, who shared HCD’s intent and expectations on several of the required revisions.

The City of Pacifica has prepared this document to demonstrate that it has edited the Draft Housing Element to respond to all HCD comments, and produced a Draft that is substantially compliant with State Law. The City has also prepared a tracked change (redlined) version of the Draft Housing Element reviewed by HCD showing every change made. This document has organized the HCD findings in numeric sequence, from 1 to 41. Comments are numbered in bold red font. The HCD findings are copied verbatim from the August 8 letter in black font. The City’s responses appear below each finding in blue italic font. The responses direct the reader to the specific location in the “tracked change” document where the edits are located and summarize the edits made. Page number references are to the tracked change version of the Draft Housing Element. All of the tracked edits are incorporated in a “clean” version of the document.

A. Review and Revision
A.1
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
The element must provide a cumulative evaluation of the effectiveness of past goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, femaleheaded households, farmworkers, and persons experiencing homelessness).

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Packet Pg. 1291 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-2 City Response:

See Appendix B, Section 4. An additional section that provides a cumulative evaluation of the effectiveness of past goals, policies, and actions regarding the special needs populations has been added to Appendix B.

B. Housing Needs, Resources, and Constraints
B.1

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Enforcement: While the element included an evaluation of local and regional patterns, trends, and enforcement capacity, it must also identify and address past or current fair housing lawsuits, findings, settlements, judgements, or complaints. For additional information, please see pages 28-30 on HCD’s Affirmatively Furthering Fair Housing (AFFH) Guidance Memo at https://www.hcd.ca.gov/communitydevelopment/affh/docs/AFFH_Document_Final_4-27- 2021.pdf.

City Response:

See Appendix D. pp. 7, 16. An analysis of past or current fair housing lawsuits, findings, settlements, judgements, or complaints has been added to Appendix D. As noted in the added text, the City of Pacifica has not been a party to fair housing complaints or legal action in the past nor has the City been required to operate under a state or federal consent decree related to fair housing.

B.2

2. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
The element includes data and a general discussion of housing challenges faced by special needs households. However, the element must be revised to include an analysis of the existing needs and resources for each special need group including seniors, farmworkers, large households, and persons with disabilities including developmental disabilities and extremely low-income (ELI) households. For example, the element should discuss the existing resources to

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Packet Pg. 1292 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-3 meet housing needs (availability of shelter beds, number of large units, number of deed restricted units, etc.,), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps.

City Response:

See Appendix C Housing Needs (throughout), Housing Element Implementation Actions within HE-I-5. An analysis of the existing needs and resources for each special need group has been added to multiple sections within Appendix C. Implementation Actions to address needs have been added and expanded. See Housing Element Section 12. 2023-2031 Programs.

B.3

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).) This is an introductory statement citing state law and does not require a response.

B.3.1
Progress in Meeting the Regional Housing Need Allocation (RHNA): As you know, the City’s RHNA may be reduced by the number of new units built since July 1, 2022. However, the element must demonstrate the availability of these units in the planning period. First, it is unclear how many units the City is counting as credit towards the RHNA. For example, the element analyzes several potential projects equating 232 units (Table F-5); however, Table F-7 only reflects credit for 139 units. The element should reconcile these numbers and accurately reflect the number of units as credit towards the RHNA. Second, while the element provided some general information regarding each project’s status, it should still demonstrate the likelihood that these units will be built during the planning period. To demonstrate the availability of these units, the element could analyze infrastructure schedules, City’s past completion rates on pipeline projects, outreach with project developers, describe any expiration dates on entitlements, anticipated timelines for final approvals, and any remaining steps for projects to receive final entitlements. Based on a complete analysis, the element may need to add or modify programs committing to facilitating and encouraging the development of these projects.

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Packet Pg. 1293 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-4 City Response:

See Revised Tables F-2 and F-9 (formerly F-7) and related narrative in Section F-4. Planned and Approved Projects. The number of units has been reconciled and language on each project’s status has been added. Based on HCD guidance, planning applications that have a high likelihood of approval have been included as an offset to RHNA. (In the prior version, they were included as opportunity sites.)
B.3.2.A
Realistic Capacity:
• General – The element is generally assuming 80 percent of maximum allowable densities to calculate residential capacity on identified sites.

Further, the element includes examples of recent projects that have developed between 25-100 percent of the maximum allowable density with an average density of 81 percent (Table F-4). The element should analyze projects including information on typical densities on all recent and pipeline projects, the zone, acreage, built density, allowable density, level of affordability, outliers from the assumed densities and presence of exceptions such as a density bonus. Further, the element should analyze and evaluate this data to support its realistic capacity calculations.

City Response:

See Appendix F. The element has been revised to include additional analysis regarding typical densities on recent and pipeline projects, the zone, acreage, built density, allowable density, etc. These criteria have been analyzed and the conclusions applied to the revised sites list. See Appendix F for discussion of realistic capacity, development trends, and redevelopment potential of sites on the revised inventory.

B.3.2.B
• AB 2011 Capacity Assumptions – The element is assuming additional capacity on sites that will be rezoned during the planning period beyond the projected densities that will be allowed once the rezoning is completed.

Specifically, the element assumes additional capacity pursuant to AB 2011 (Statues of 2022) which allows sites and projects that meet specific criteria to qualify for additional densities and ministerial approvals. However, for the element to utilize AB 2011 capacity assumptions, the City must demonstrate the likelihood that the sites and potential projects will qualify to utilize the provisions of AB 2011. The element should include local examples of sites redeveloping with qualifications similar to those required under AB 2011. Alternatively, the element could commit to rezoning to similar densities allowed under AB 2011 (60 units per acre) as a method to

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Packet Pg. 1294 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-5 utilizing these capacity assumptions. Based on a complete analysis, the element may need to adjust capacity assumptions and include or modify programs committing to rezoning to appropriate densities.

City Response:

See Program HE-I-1.10. The Housing Element has been revised to incorporate the alternative suggested by HCD. Specifically, the Housing Element has been revised with commitments to rezone to 60 units per acre for any sites that remain on the inventory that had previously assumed AB 2011 densities. Therefore, capacity assumptions regarding AB 2011 are no longer applicable to sites identified within the Housing Element.

B.3.2.C
• Sites in Zones that Allow 100 Percent Nonresidential Uses – The element identifies sites in zones that allow nonresidential uses. The element must analyze the likelihood that the identified units will be developed as noted in the inventory in zones that allow 100 percent nonresidential uses. This analysis should consider the likelihood of nonresidential development, performance standards, and development trends supporting residential development. For additional information, see the Building Blocks at https://www.hcd.ca.gov/planning-and- community-development/housingelements/building-blocks/analysis-sites-and- zoning.

City Response
See revisions to Appendix F, Section 9. The Housing Element has been revised to ensure that commercial uses will not be allowed on the entirety of these sites once rezonings are complete. The sites will be required to include residential uses (see Program HE-I-2). As such, additional analysis for any such sites is no longer required. See also Appendix G, Section 2. subsection "Processing and Permitting Procedures" sub-subsection "findings"
B.3.3
Site Size: The element identifies several sites at less than a half-acre to accommodate the lower-income RHNA. These sites are not eligible absent a demonstration that sites of equivalent size and affordability were successfully developed during the prior planning period or unless other evidence is provided.

The inventory indicates that some of the sites would be consolidated; however, the element should provide an analysis demonstrating the potential for lot consolidation. For example, the analysis could describe the City’s role or track record in facilitating small-lot consolidation; policies or incentives offered or

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Packet Pg. 1295 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-6 proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for lot consolidation; or information from the owners of each aggregated site.

City Response:

See Housing Element Section 8. The sites inventory has been revised to include no low income designated sites on sites of less than one half-acre. The implementation action previously numbered as HE.I-1.5 has been removed accordingly.

B.3.4
Suitability of Nonvacant Sites: The element is utilizing nonvacant sites to accommodate a portion of the RHNA. However, the element must demonstrate the potential for additional development. The methodology for demonstrating additional development on nonvacant sites must discuss existing uses, development trends, and policies and programs to encourage additional residential development. For example, the element indicates several factors that may have been utilized when demonstrating the likelihood for redevelopment including the degree of underutilization based on the current build out of the site, age of existing uses, vacancies, and other trends (p. F-15).

However, the element must provide support for these assumptions including analyzing and discussing how these factors are indicative of redevelopment potential. Second, the element should relate these factors to the actual sites and quantify where possible (e.g., age of building, current vs. allowed floor area ration (FAR), etc.,). Based on a complete analysis the element may need to add or revise programs to facilitate redevelopment.

Additionally, to provide sufficient capacity for the RHNA during the planning period and as part of identifying sites with potential for development, the element should consider public comments received regarding the inclusion of sites from property owners written interest in residential development in the planning period.

Finally, if the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households, the City must make findings based on substantial evidence, the existing uses will be presumed to impede additional residential development. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution), the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.

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Packet Pg. 1296 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-7 City Response:

See Appendix F, Section: Other Commercial Opportunity Sites (pp. F-21-F-26).

The Housing Sites Inventory analysis included in Appendix F has been significantly revised to include new redevelopment factor analysis and precedent trend analysis to supplement prior analysis. Non-vacant parcels are included on the Sites List as potential residential development opportunities based on five redevelopment characteristics and rezoning to densities in the range of 30-60 DU/A. Nonvacant sites must meet four out of five criteria to be included on the sites list as discussed in the section: “Other Commercial Opportunity Sites.” The factors were gathered from approved projects in Pacifica and some of its surrounding neighboring cities. The site characteristics are summarized in Table F-7. How the factors were considered in relation to specific sites is provided in site list tables F-10 and F-11.

B.3.5
Publicly-Identified Sites: The element identifies several publicly-identified sites to accommodate a portion of the RHNA including school district and CityOwned sites. The element must include an analysis addressing general plan designations, allowable densities, support for residential capacity assumptions, existing uses, and any known conditions that preclude development in the planning period and the potential schedule for development. For example, the element should evaluate public comments and other information to evaluate the likelihood of redevelopment of these sites during the planning period. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act (Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5).

City Response:

See Housing Element Program HE-I-1 and HE-I-3. An analysis of public comments and other factors has been expanded in relation to publicly owned sites as described in Appendix F. Specifically, Implementation Action HE-I-1.6 commits to completion of the Surplus Land Act (SLA) and other required processes for City-owned sites. Implementation Action HE-I-3 commits to coordination with the Pacifica School District and Jefferson Union High School District to complete the SLA process for school district-owned sites.

Implementation Actions HE-I-1.5, 1.6, and 1.11 commit to completion of the decertification process for Caltrans-owned sites within three years from the

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Packet Pg. 1297 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-8 start of the planning period.

B.3.6
CalTrans Sites: The element identifies multiple CalTrans sites to accommodate a portion of the RHNA. The element should include additional information to determine that these sites will be available for residential development with the appropriate zoning and densities during the planning period. Additionally, the element should include a commitment to the decertification of any applicable Caltrans sites within three years from the start of the planning period and alternative actions if this does not occur (e.g., identify additional adequate sites) by January 31, 2026.

City Response:

See Housing Element Program HE-I-1 and HE-I-3. The analysis of Caltransowned sites has been expanded as described in Appendix F. Implementation Actions HE-I-1.5, 1.6, and 1.11 commit to completion of the decertification process for Caltrans-owned sites within three years from the start of the planning period. The program now includes timelines and backup actions.

B.3.7
Availability of Zoning: The element indicates that several sites that do not have appropriate zoning or densities to accommodate the RHNA (p. 12). As such, the element shows a shortfall of 1,039 units including 510 units for lowerincome households. While the element includes programs committing to rezoning sites (Program 1-1 General Plan and Zoning Amendments), because zoning was not in place at the start of the planning period (January 31, 2023), the element must include a program committing to housing element rezone requirements pursuant to Government Code section 65583.2 (h) and (i). As part of these rezoning requirements, the element must commit to establishing a minimum density of 20 units per acre (Gov. Code 65583.2 (h)). Please see the programs section of this review for additional information.

City Response:

See Housing Element Section 8, Programs HE-I-1 and HE-I-4, and Appendix F Section 9. Pacifica Sites List The Element has been revised to ensure consistency with Government Code section 65583.2 and commits to establishing a minimum of 20 units per acre. Please see the revised organization and composition of the sites inventory, specifically tables 4, F-5, F7, and F-9 to F-12. See also the analysis included within Appendix F sections 6

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Packet Pg. 1298 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-9 and 7.

B.3.8
AB 725: For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above-moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)).

City Response:

See Appendix F, Section 8. Income Assumptions on RHNA Sites List. All sites included in the housing element are consistent with the criteria set forth in the Government Code. See revised sites list and analysis in Appendix F, Section 8.

B.3.9
Availability of Infrastructure: The element states that “nearly” all housing sites have the most efficient infrastructure except two areas that will need additional analysis and that may impact the design and timing of the development (p. G30). Additionally, the element indicates that potential infrastructure constraints related to water pump stations, among other things, may impact a projects ability to reach maximum capacity. First, the element must specifically indicate if total infrastructure capacity (existing and planned) is available to accommodate the RHNA. Second, the element must include a program committing to actions and a timeline to make sufficient infrastructure available to accommodate the RHNA.

City Response:

See revised housing site inventory in Section 9. and Appendix F. See also Appendix G. The revised Housing Site Inventory significantly reduces the number of units in the Rockaway Pump Station catchment area from approximately 700 to approximately 180 units. Analysis, described in Appendix G, demonstrates that when combined with already planned capital improvements to replace all sewer main lines in the catchment area, there is no water pump infrastructure constraint to the development of the 180 units included in the inventory.

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Packet Pg. 1299 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-10 Zoning for a Variety of Housing Types:

B.3.10.A
• Emergency Shelters: Zoning to permit emergency shelters without discretionary action was required as part of the 4th cycle housing element and prior to the 5th cycle housing element. The element states that the City’s zoning regulations does not address emergency shelters (p. G-16) and the City will include a program committing to comply with Government Code section 65583, subdivision (a)(4).). Further, the City provided additional documentation indicating that the City’s definition of special care facilities includes people experiencing homelessness and is permitted byright for six or fewer persons. However, the City does not explicitly address emergency shelters and only allows by-right approvals for similar uses in limited circumstances (e.g., six of fewer persons). Additionally, because zoning for emergency shelters was supposed to be completed two planning periods ago and the time to identify appropriate zoning has lapsed, HCD cannot find the element in compliance until the appropriate zoning to permit emergency shelters without discretionary action is demonstrated or completed. For additional information, please see https://www.hcd.ca.gov/planning-and-community-development/housingelements/building-blocks/zoning-variety-of-housing-types.

As part of implementing zoning changes to permit emergency shelters without discretion, the City should address compliance with parking standards pursuant to Government Code section 65583, subdivision (a)(4)(A) and additional requirements regarding zoning, capacity and habitability pursuant to Chapter 654, Statutes of 2022 (AB 2339). For additional information and timing requirements, please see HCD’s memo at https://www.hcd.ca.gov/sites/default/files/docs/planning-andcommunity/ab2339- notice.pdf.

City Response:

See Appendix G, Ordinance 849-C.S., and Housing Element Program HE-I-14. See also Appendix B.

After the publication of the Housing Element in May, 2023, the City of Pacifica adopted Ordinance 849-C.S. Emergency Shelters. This Ordinance expands the areas where an emergency shelter can be located and updates and clarifies procedures to ensure compliance with state law. Analysis of constraints to emergency shelters has been expanded and is included in Appendix G. See also Program HE-I-14 and table B-2 in Appendix B.

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Packet Pg. 1300 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-11 B.3.10.B
• Transitional and Supportive Housing: Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).). The element notes that the City does not currently address supportive and transitional housing and includes Program HE 1- 14 (State and Federal Law Conformance) committing to address this housing type. However, the Program should be revised to amend zoning that specifically commits to permitting these housing types as a residential use and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone pursuant to Government Code Section 65583 (a)(5).

City Response:

See Program HE-I-14. The program commits to update the zoning code with respect to Transitional and Supportive Housing to conform to the Government Code requirements by 2025. See Housing Element Program HE-I-14 and HE-I-1 (13.b), See also additional explanation added at the beginning of Housing Element Programs HE-I-1, HE-I-3, HE-I-11, HE-12, and HE-I-14.

B.3.10.C
• Accessory Dwelling Units (ADUs): After a cursory review of the City’s ordinance, HCD discovered several areas which were not consistent with State ADU Law. This includes, but is not limited to, definition of site, minimum landscaping requirements, parking, and subjective standards, among others. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with state law. For more information, please consult HCD’s ADU Guidebook, published in December 2022, which provides detailed information on new state requirements surrounding ADU development:
https://www.hcd.ca.gov/sites/default/files/2022-
07/ADUHandbookUpdate.pdf.

City Response:

See Housing Element Programs HE-I-4, HE-I-14. Housing Element Programs HE-I-4, HE-I-14 have been revised to include commitments for conformance with enacted legislation, additional metrics, timeline

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Packet Pg. 1301 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-12 specifics, and backup actions.

B.3.10.D
• Single-Room Occupancy (SRO) Units: The element indicates that SROs are defined as a boardinghouse that includes lodging and meals. SROs provide a valuable source of affordable housing especially for persons experiencing homelessness and extremely low-income households. The element should analyze any occupancy standards, length of stay, and whether SROs are permitted as a residential use under the current definition. Based on complete analysis, the element may need to add or modify programs with a commitment to removing any potential constraints on the development of SROs. For additional information, please see:
https://www.hcd.ca.gov/planning-and-community- development/housingelements/building-blocks/zoning-variety-of-housing-types.

City Response:

See Housing Element Programs HE-I-9 and HE-I-14 and appendices C and G. The programs have been revised to include specific commitments related to SROs, and terminology definitions within the zoning code, including updating the definition of “boardinghouse” to explicitly indicate that it includes the SRO use, See also expanded analysis included in Appendices C (Section 18) and G (Section 2).

B.4

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).) City Response:

Additional analysis has been provided in Appendix G, Section 2, regarding the types of uses described in the code sections referenced by HCD. Additional discussion on how the Element incorporates public comments on this topic has been added to Appendix A, Section 3. The programs below have also revised :

1. Persons with disabilities, including developmental disabilities: See Policy HE-P-11, Programs HE-I-1, HE-I-5, HE-I-6, HE-I-9, and HE-I-12.

2. Multifamily rental housing: See revised Programs HE-I-2, HE-I-3 and additional analysis in Appendix C, Section 2.

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Packet Pg. 1302 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-13

3. Factory-built housing: See Program HE-I-14.

4. Mobile homes: See Policy HE-P-12, Programs HE-I-7 and HE-I-13).

5. Housing for agricultural employees: See Programs HE-I-1, HE-I-9, HE-I-12, and HE-I-14.

6. Supportive housing: See Programs HE-I-5, HE-I-10, HE-I-11, and HE-I-14.

7. Single-room occupancy units, See Programs HE-I-9 and HE-I-14 and response to comment B.3.10.D above.

8. Emergency shelters: See Ordinance 849-C.S., and Housing Element Program HE-I-14. See also Appendix B. and response to comment B.2 above.

9. Transitional housing: See Programs HE-I-11 and HE-I-14.

B.4.1
Land Use Controls (Parking): The element notes that one-bedroom multifamily units are required to provide 1.5 spaces per unit, including one garage or carport space (p. G-11). Requiring smaller bedroom types (e.g., one-bedroom units) to provide 1.5 parking spaces is considered a constraint. Additionally, the element must analyze covered parking requirements for impacts on cost, supply, housing choices, affordability and achieving maximum densities. The element must include a program committing to reducing parking requirements for smaller bedroom types (e.g., one space per one- bedroom unit).

City Response:

See Housing Element Program HE-I-1. See also HE-I-12, HE-I-14. Program commitments were revised to conform with the comment and make specific commitments to reduce parking as described in the program text.

B.4.2
Fees and Exaction: The element some general information regarding fees including total amount of fees and their proportion to the development costs for both single family and multifamily housing. However, a complete analysis must include a listing of all required fees for single family and multifamily housing development, including impact fees, and analyze their impact as potential constraints on housing supply and affordability. For additional information and a sample analysis and tables, see the Building Blocks at
https://www.hcd.ca.gov/planning-and-community-development/housingelements/building- blocks/fees-and-exactions.

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Packet Pg. 1303 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-14 City Response:

See Appendix G, Section 2. Additional analysis has been added to Appendix G and demonstrates the fees and exactions are not constraints on the development of housing units.

Local Processing and Permit Procedures:

B.4.3.A
• Multifamily Housing – The element indicates that multifamily housing is required to obtain a Site Development Permit and listed the required approval findings (p. G-23) illustrating constraints for multifamily development. For example, the approval findings require multifamily housing to meet several subjective criteria related to impacts on surrounding uses and character of the neighborhood. The approval findings also indicates that the applicant must meet both the City’s subjective findings in addition to the City’s design guidelines. Secondly, the element notes that 1) clustered housing including zero lot line projects and condominiums and 2) multifamily and mixed-use development in commercial zones are required to obtain both a Site Development and Conditional Use permits (CUP). However, several of the required CUP findings are similar to the site development permit findings. Lastly, the analysis noted that a typical multifamily project has a 9–24 month approval timeline (pg. G-22). The analysis demonstrated that 1) multifamily housing is subjected to a highly discretionary process with subjective findings and minimal guidance to promote certainty and objectivity 2) the City subjects some multifamily housing and other housing types to two types of processes that are subjective and potentially redundant of each other and 3) multifamily housing is subjected to a lengthy approval process. The element must include or modify a program addressing and removing or modifying the Site Development Plan and CUP (beyond objective standards) for multifamily housing in zones that are intended to permit multifamily housing (e.g., residential).

City Response:

See revised Programs HE-I-2, HE-I-3, and Appendix G for analysis. The Programs noted above have been revised to include: removal of subjective findings from the Site Development Permit (PSD) required for residential projects or mixed-use projects that include residential use; and removal of the requirement for approval of a Conditional Use Permit (UP) to authorize residential uses consistent with the General Plan, including but not limited to land use and density.

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Packet Pg. 1304 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-15 B.4.3.B
• Planned Development (PD) – The element described the general process for projects in the PD zoning, indicating that this process is highly discretionary (p. G-22). However, the analysis should clearly explain whether PDs are optional or required for areas intended for residential uses and whether there are established development standards prior to the approval of the PD. If the PD is mandatory in areas intended for residential uses without fixed development standards, the element should specifically evaluate these requirements for impacts on cost, supply, feasibility, and approval certainty of housing. Based on a complete analysis, the element may need to add or modify programs to address any potential constraints.

City Response:

See revised Programs HE-I-2, HE-I-3, and Appendix G for analysis. The programs have been revised to require the following: rezone properties that are undeveloped, designated in the General Plan for residential use, and zoned as P-D (Planned Development) to a non-P-D zoning classification aligned with their allowable use(s) and permissible densities in the General Plan to establish an approval process for these sites that does not require legislative approval by City Council (the Development Plan); and revise the criteria and findings associated with project approvals in the P-D zoning district to focus on objective standards compliance to streamline project review and approval for sites located in the HPD (Hillside Preservation District) overlay district that must be rezoned to P-D.

B.4.3.C
• Permit Streamlining Act (PSA) and CEQA – The element should address public comments on this draft submittal and discuss compliance with the Permit Streamlining Act and intersections with CEQA and timing requirements, including streamlining determinations and add or modify programs as appropriate.

City Response:

See Program HE-I-2. Program text was revised to include an implementation action to initiate a standard operating procedure regarding the PSA and CEQA.

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Packet Pg. 1305 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-16 B.4.4
Inclusionary Housing: The element generally mentions the City’s inclusionary zoning ordinance, but it must also analyze the City’s inclusionary housing requirements, including its impacts as potential constraints on the development of housing for all income levels. The analysis should evaluate the inclusionary broader policy’s implementation framework, including the percentage of new residential construction that is dedicated to affordable housing, the types of options and incentives offered, relationships with State Density Bonus Law (SDBL) and any other factors that may impact housing costs.

City Response:

See Appendix G, Section 2. Appendix G has been revised to include expanded analysis on the inclusionary zoning ordinance and requirements. The analysis concludes that these are not a constraint to the development of housing units for all income levels.

B.4.5
On/Off-Site Improvements: The element must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width), and analyze their impact as potential constraints on housing supply and affordability. For additional information and a sample analysis, see the Building Blocks at https://www.hcd.ca.gov/planning-andcommunity-development/housing- elements/building-blocks/codes-andenforcement-and-onsite-offsite-improvement- standards.

City Response:

See Appendix G, Section 2. Appendix G has been revised to include expanded analysis of subdivision level improvement requirements. The analysis concludes that these are not a constraint to the development of housing units or affordability.

Constraints on Housing for Persons with Disabilities:

B.4.6.A
• Reasonable Accommodation –The element briefly describes its reasonable accommodation procedures (p. G-16). However, the element should also describe the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities. Additionally, HCD understands that the City must make findings that the request would not cause impacts on surrounding uses and coastal

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Packet Pg. 1306 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-17 zone resources. In addition to describing the reasonable accommodation process and listing the required approval findings, the element must analyze these findings for potential constraints on persons with disabilities.

Based on a complete analysis, the element may need to add or modify programs to remove any potential constraints.

City Response:

See Policy HE-P-4, Program HE-I-12, and Appendix G, Section 2.

Analysis on Reasonable Accommodation procedures has been expanded in Appendix G. Program text has been revised to include specific commitments and additional timelines related to reasonable accommodations.

B.4.6.B
• Group Homes of Seven or More Persons – The element notes that the City defines group homes for seven or more persons as a “special care facility” and that this use is subject to a discretionary use permit and must comply with a 500- foot spacing requirements. For your information, zoning should simply implement a barrier-free definition of family instead of subjecting, potentially persons with disabilities, to special regulations such as the number of persons, population types and licenses. These housing types should not be excluded from residential zones, most notably low-density zones, which can constrain the availability of housing choices for persons with disabilities. Requiring these housing types to obtain a special use or CUP could potentially subject housing for persons with disabilities to higher discretionary standards where an applicant must demonstrate compatibility with the neighborhood, unlike other residential uses.

As such, the element must include a program removing the spacing requirements and commit to allowing these uses in any zone that permits residential uses and only subject to those restrictions that apply to similar residential uses. Please see HCD’s for more info
https://www.hcd.ca.gov/sites/default/files/docs/planning-andcommunity/group-home-technical-advisory-2022.pdf.

City Response:

See Program HE-I-4 and Appendix G, Section 2. Analysis on potential constraints regarding Group Homes has been expanded in Appendix G.

Program text has been revised to remove the 500-foot spacing requirement and apply the same types of zoning standards to group homes with seven or more persons as would apply to other similar housing types in the same zoning district. The amended zoning code will expand beyond recent updates to the zoning code to clarify that seven or more individuals as described above living in a home would be a

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Packet Pg. 1307 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-18 permitted use and not by itself be cause for application to the City for a use permit or license. The definition of family will be revised to conform with contemporary best practice, including clarification that family be defined as, “family or single housekeeping unit.”
B.5

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).)
The element must analyze the length of time between receiving approval for a housing development and submittal of an application for building permits, and any local efforts to address or mitigate nongovernmental constraints such as reduced fees, financing for affordable housing or expedited processes. The analysis should address any hinderances on the construction of a locality’s share of the regional housing need and programs should be added or modified as appropriate.

City Response:

See Program HE-I-2. Program HE-I-2 has been revised to provide additional clarity and level of commitment to streamlining and expediting of processes for housing at all income levels.

B.6

6. Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).).

The element indicates the City has 101 affordable units with expiring affordability restrictions within the next eight years (e.g., 2025). The element must include an assessment of conversion risk and estimate and analyze the cost for replacing versus preserving the units. For more information on the analysis, please visit: https://www.hcd.ca.gov/planning-and-communitydevelopment/housing- elements/building-blocks/assisted-housing-developmentsrisk-conversion.

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Packet Pg. 1308 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-19 City Response:

See Appendix C., Section 9, Program HE-I-8. An assessment of conversion risk of the property has been expanded in Section 9 of Appendix C.

Additionally, Program HE-I-8 has been revised to clarify the City's response.

There is a low likelihood of conversion risk for the 101 units indicated in the comment above. The long track record of renewal in the Section 8 program, and limits to density and senior housing use requirements as described above, indicate it is highly unlikely the owner will opt to pursue such a path. As described above and in program HE-I-8 the city is committed to proactive outreach to minimize the risk of this occurring.

C.1
C. Housing Programs

1. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, singleroom occupancy units, emergency shelters, and transitional housing. (Gov.

Code, § 65583, subd. (c)(1).)
This is an introductory statement citing state law and does not require a response.

C.1.1
As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established.

Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

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Packet Pg. 1309 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-20 City Response:

See Housing Element Section 8. Housing Sites Inventory, Appendix F, and Program HE-I-1. The sites list organization and structuring of the sites list has been substantially revised. Analysis of the sites on the reorganized list has also been significantly expanded as discussed in Section 8 and in Appendix F. Additional program language has been added to program HE-I1 to demonstrate that each site included on the inventory in this draft is adequate for at least the number of units allocated.

C.1.2
Shortfall of Sites: As noted above, because zoning was not in place at the start of the planning period, the City is showing a shortfall of 1,039 units including 510 units for lower-income households. While the element included Program 1-1 (General Plan and Zoning Amendments) committing to rezoning to allow residential uses at appropriate densities to accommodate the RHNA, programs to address the lower-income RHNA must specifically commit to rezoning pursuant to Government Code sections 65583, subdivision (c)(1) and 65583.2, subdivisions (h) and (i). Examples of requirements include permitting, without discretionary action, multifamily developments in which 20 percent or more of the units are affordable to lower-income households, requiring minimum densities and residential performance standards. For more information, please see HCD’s site inventory guidance memo: https://www.hcd.ca.gov/communitydevelopment/housingelement/docs/sites_inventory_memo_final06102020.pdf.

Additionally, since the City failed to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), all rezones to accommodate the RHNA must be completed no later than one year from the statutory deadline. As such, Program 1-1 (General Plan and Zoning Amendments) to accommodate a shortfall and rezones to address prior identified sites must be completed no later than one year from the statutory deadline.

City Response:

See Program HE-I-1. The program has been revised to commit to all required rezonings and specific timelines have been added or revised.

C.1.3
Program HE-1-4 (Accessory Dwelling Units (ADUs)): This Program commits to various actions to facilitate the development of ADUs.

However, given the City’s reliance on ADUs, the element must include a

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Packet Pg. 1310 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-21 commitment to adjusting projected assumptions if the number of units and affordability do not actualize during the planning period.

Specifically, the degree of additional actions should be in stride with the degree of the gap in production and affordability. For example, if actual production and affordability of ADUs is far from anticipated trends, then the element must commit to amending the housing element, identifying additional sites, and rezoning within a timely manner (e.g., within six months).

City Response:

See Program HE-I-4. The program has been revised and a backup action has been added. It now includes commitments for a mid-cycle review and if a gap is identified also commits to identification and rezoning of additional sites if that gap cannot already be accommodated within in the buffer sites.

C.1.4
Publicly Identified Sites: While the element included Program 1-1 (General Plan and Zoning Amendments) and 1-3 (Public Land Planning), these programs may need to be revised based on a complete sites analysis (see above finding). Additionally, while these programs commit to outreach and issuing requests for proposals (RFP), actions need to be revised with additional actions, firm commitments, discrete timelines, and quantifiable metrics. The element should also include specific actions, as needed, to making the Caltrans sites available during the planning period. Additional actions to facilitate development should include commitments to compliance with the Surplus Land Act, annual outreach with developers, rezoning and financial assistance, issuing requests for proposals, facilitating any subsequent entitlements, and numerical objectives by affordability.

City Response:

See Programs HE-I-1 and HE-I-3 and Appendix F. Program text has been revised to include additional commitments, timelines, metrics, and backup actions for publicly owned sites, including Caltrans sites remining on the inventory. Appendix F, Section 7 discusses each individual site in greater detail.

C.2

2. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate- income households. (Gov. Code, § 65583, subd. (c)(2).)

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Packet Pg. 1311 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-22 The element includes general commitments to addressing various special needs populations. However, given the importance of farmworkers and the local and regional needs, the element must include specific actions to addressing this population.

Examples of actions could include proactive outreach with developers and the community, identifying potential sites, provide incentives (e.g., expediated permitting, flexible development standards, gap funding, fee waivers), and applying for state and federal funding.

See Programs HE-I-5, HE-I-9, HE-I-12, and HE-I-14 and Appendices B, C, F, and E. Program text has been revised to include additional actions related to farmworker and agricultural employee housing. Specifically, several provisions of HE-I-9 that had been proposed for further consideration are now made as commitments. A new section (18) has been added to Appendix C analyzing housing need for this important population.

Appendix F, Section 7 has been expanded to include greater detail on each relevant site in greater detail and Appendix E includes additional relevant housing resources information and analysis.

C.3

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov.

Code, § 65583, subd. (c)(3).)
As noted in Findings B4 and B5, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

In addition, Program HE 1-2 (Zoning and Streamlining) identifies various changes to development standards and other process to the facilitate development of housing. However, several of the actions state that the City “will consider” addressing and implementing including increasing heights, reducing parking, modifying densities standards, changes to the City’s definition of family, etc., Given the importance and need of several of these actions, the element should be revised to affirmatively commit to these changes.

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Packet Pg. 1312 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-23 City Response:

See Housing Element Section 10. Fair Housing Plan and Programs HE-I-1, HE-I-4, HE-I-6, HE-I-9, and HE-I-12. The document has been revised to include additional analysis and program commitments regarding governmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. Programs have also been revised to remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. The actions in this plan directly respond to the updated analyses in Appendix C – Special Housing Needs and Appendix D – Assessment of Fair Housing. In addition, constraints listed above are analyzed in the Housing Element Section 9. Housing Constraints and Appendix D – Assessment of Fair Housing. Programs were also modified throughout to address potential fair housing issues for contributing factors that are described in the fair housing analysis. Program HE-I-2 (Zoning and Streamlining) affirmatively commits to changing standards and other process to the facilitate development of housing, including increasing heights, reduced parking, modifying densities standards, and changes to the City’s definition of family.

C.4

4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
Goals, Priorities, Metrics, and Milestones: Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. Additionally, quantified metrics that target beneficial impacts for people, households, and neighborhoods (e.g., number of people or households assisted, number of housing units built, number of parks or infrastructure projects completed).

Lastly, the City is considered a majority racially and concentrated area of affluence (RCAA). Therefore, the element must include significant and meaningful programs (beyond the RHNA) that target RCAA and relatively higher income neighborhoods to enhance housing mobility and provide housing choices and affordability throughout the City.

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Packet Pg. 1313 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-24 City Response:

See Housing Element Section 10. Fair Housing Plan and Programs HE-I-1, HE-I-4, HE-I-6, HE-I-9, and HE-I-12. Program language has been strengthened regarding affirmative marketing strategies for affordable housing units located within RCAAs to market units to lower income households by developing standard City-required marketing activities by housing developers for new or available BMR or low-income units to increase the chances of people, including families with children, outside the RCAA to learn about affordable housing opportunities within the RCAA. The actions in this plan directly respond to the updated analyses in Appendix C - Special Housing Needs and Appendix D – Assessment of Fair Housing.

D. Quantified Objectives
D.1
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov.

Code, § 65583, subd. (b)(1 & 2).)
While the element includes quantified objectives for new construction, it currently targets no objectives for housing rehabilitation and should be revised accordingly. In addition, the element could increase its housing conservation and preservation objectives accordingly.

For your information, conservation objectives may include the variety of strategies employed by the City to promote tenant stability, code enforcement, naturally affordable housing, and the preservation of units at-risk of conversion to market rate use.

City Response:

See Housing Element Program HE-I-8. The program was modified to include an expanded rehabilitation program. The quantified objectives summary and analysis were revised to include rehabilitation as described in Section 14.

Quantified Objectives.

E. Consistency with General Plan
E.1
Coastal localities shall document the number of low- and moderate-income units converted or demolished, and the number of replacement units provided. (Gov. Code, § 65588, subd. (d).)

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Packet Pg. 1314 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption) Exhibit B: Responses to HCD Findings – January 4, 2024 B-25 The element analyzes the housing stock in the coastal zone. Specifically, the element stated that 57 housing units were demolished within the coastal zone between 2015-2022 due to an emergency natural disaster. In conversations with the City, it was noted that the City was not able to identify the number of lower-income renters in these units due to the emergency and that the owner generally did not maintain the property including complying with building codes.

Furthermore, the City noted that while these units were not deed-restricted, anecdotal information indicates that there were a number of lower- and moderate -income households living in these units. The element should include a program committing to actions that preserve coastal housing units for lowerand moderate-income households. This Program could commit to annual monitoring, commitment to complying with replacement requirements and proactive noticing and outreach to non-profits and service providers in the event that future coastal housing is at-risk.

City Response:

See Housing Element Program HE-I-8. The element was revised to include a proactive property identification program whereby the City’s code enforcement staff would identify properties in need of significant maintenance to assist with property rehabilitation. The program also commits to updating its operating procedures to require income levels of occupant income levels prior to the issuance of any permit for demolition of residential units or conversion to nonresidential uses within the Coastal Zone.

End

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Packet Pg. 1315 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption)

EXHIBIT C
DRAFT 2023-2031 HOUSING ELEMENT OF THE GENERAL PLAN AS

RECOMMENDED FOR APPROVAL BY THE PLANNING COMMISSION
INTENTIONALLY OMITTED FROM PLANNING COMMISSION RESOLUTION NO. 2024-001.

THE DRAFT HOUSING ELEMENT AS RECOMMENDED BY THE PLANNING COMMISSION IS INCLUDED AS ATACHMENT B TO THE CITY COUNCIL AGENDA REPORT.

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Packet Pg. 1316 Attachment: Attachment D - Planning Commission Resolution No. 2024-001 (5559 : 2023-2031 Housing Element Update Adoption)

PLANNING COMMISSION
Staff Report
Scenic Pacifica
Incorporated Nov. 22, 1957
DATE: January 4, 2024 FILE: GPA-106-24
ITEM: 1
SUBJECT: Consideration of Planning Commission recommendation to City Council on adoption of an Initial Study/Negative Declaration pursuant to the California Environmental Quality Act (CEQA) and on Adoption of the 2023-2031 Housing Element of the General Plan.

PROJECT
LOCATION: Citywide
PUBLIC NOTICE: A one-eighth page Notice of Public Hearing was published in the Pacifica Tribune on December 20, 2023.

CEQA STATUS: Recommend adoption of an Initial Study/Negative Declaration (IS/ND).

REQUIRED
APPROVALS: City Council approval of the 2023-2031 Housing Element of the General Plan.

RECOMMENDED
ACTION: Adopt the attached Resolution to recommend City Council adoption of an Initial Study/Negative Declaration, and approval of the 2023-2031 Housing Element of the General Plan (Attachment A).

DISCUSSION

1. Background
State law1requires every city and county to adopt a housing element as one of the mandated elements of the general plan. The housing element of the general plan must be substantially compliant with state housing element law2 and updated periodically to maintain consistency with the Regional Housing Needs Allocation (RHNA) process. The RHNA and housing element update processes occur every eight years. Currently, local agencies are adopting housing element updates to address the 6th Cycle RHNA, 1 Government Code § 65302.
2 Government Code § 65580 et seq.
1 Packet Pg. 3

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Packet Pg. 1317 Attachment: Attachment E - Planning Commission staff report (no attachments) - January 4, 2024 (5559 : 2023-2031 Housing Element Update PC Staff Report
2023-2031 Housing Element Adoption Recommendation to City Council January 4, 2024

Page 2 ends

which in the Association of Bay Area Governments (ABAG) region covers the period from 2023-2031.

Work on the Housing Element Update (HEU) commenced in August 2022, immediately following City Council’s adoption of the comprehensive 2040 General Plan Update in July 2022. Staff’s efforts over that period have resulted in preparation of a Draft Housing Element that includes all components necessary to comply with state law, as described in detail in Exhibit A to Attachment A. The Planning Commission must consider the Draft Housing Element and recommend to City Council whether to adopt it. Following City Council adoption, staff will then transmit the Adopted Housing Element to the California Department of Housing and Community Development (HCD) for review and certification.

2. Community Engagement and Input
Public input has been an essential part of the process to prepare the Draft Housing Element. The City has provided numerous public input opportunities that have included online and in-person engagements. The community engagement strategy was developed with public and City Council input, including a FlashVote poll asking the community how it would prefer to be engaged during the HEU process, and also including a citywide mailer to all residential and business recipients in Pacifica announcing the HEU process and how to be involved. The City Council approved the community engagement strategy on August 8, 2022.

The City held three community meetings in late-2022 (one online and two in-person) to seek community input for the HEU to address RHNA 6 and guide its work to prepare the Draft Housing Element. These community meetings informed the public about the requirements for the HEU and the City’s obligation to plan for the RHNA. Public feedback received at these meetings confirmed the overall sites strategies and priorities to accommodate Pacifica’s RHNA, which was essential to the preparation of an initial Draft Housing Element.

The City also conducted a City Council-Planning Commission joint study session on March 21, 2023, provided a written public review and comment period from February 24 through March 27, 2023, and held three Planning Commission meetings to discuss objective development standards (ODS) on June 19, August 21, and September 5, 2023.

The City held two additional City Council-Planning Commission joint study sessions on September 25 and October 16, 2023, to discuss specific revisions to the Draft Housing Element in response to comments from HCD. Following revisions to the Draft Housing Element and release of an updated draft on December 8, 2023, an additional written public comment period on the Draft Housing Element was provided between publication of the latest Draft Housing Element and this public hearing.

A full discussion of the extensive community engagement process undertaken during development of the Draft Housing Element is included in Appendix A: Community Consultation of the Draft Housing Element (Attachment B).
1 Packet Pg. 4

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Packet Pg. 1318 Attachment: Attachment E - Planning Commission staff report (no attachments) - January 4, 2024 (5559 : 2023-2031 Housing Element Update PC Staff Report
2023-2031 Housing Element Adoption Recommendation to City Council January 4, 2024

Page 3 ends

3. Review by California Department of Housing and Community Development (HCD)
Staff transmitted a Draft Housing Element to the California Department of Housing and Community Development (HCD) for a 90-day review period on May 10, 20233. City staff met with HCD staff assigned to review Pacifica’s Draft Housing Element on July 7 and July 27, with the first meeting including a site visit to Pacifica. The meetings provided City staff an opportunity explain the approaches to sites and programs contained in Pacifica’s Draft Housing Element, as well as the challenges and constraints that informed the approaches. City staff was able to answer numerous HCD staff questions and also heard HCD’s perspectives on key themes that must be addressed in a housing element in order to be certified by HCD.

HCD issued a comment letter to the City on August 8, 2023 (Attachment C). The letter included more than 30 unique comments requiring further analysis by staff and revisions to the Draft Housing Element.

The HCD comment letter attached to the staff report includes red numbering assigned by staff to aid reference to individual comments. Overall, staff assessed that HCD’s comments were generally as expected, and Pacifica did relatively well as compared to HCD comments made to other San Mateo County jurisdictions on their first submittals. Staff has revised the Draft Housing Element to address all HCD comments as further detailed in Exhibit B to Attachment A.

4. Prior Consideration of Draft Housing Element
The Planning Commission has been involved throughout development of the Draft Housing Element. As summarized above, the Planning Commission has already participated in six meetings to consider various aspects of the Draft Housing Element. Input from the Planning Commission has formed an important contribution to the process and ensured that public input has been thoroughly considered and incorporated where possible. The following list summarizes the Planning Commission’s prior involvement:
• March 21, 2023 | Joint study session of City Council and Planning Commission o Agenda report | Meeting video | Minutes
• June 19, 2023 | Planning Commission Discussion of ODS o Agenda report | Meeting video | Minutes
• August 21, 2023 | Planning Commission Discussion of ODS o Agenda report | Meeting video | Minutes
• September 5, 2023 | Planning Commission Discussion of ODS o Agenda report | Meeting video | Minutes not yet available • September 25, 2023 | Joint study session of City Council and Planning Commission o Agenda report | Meeting video | Minutes
3 The cover letter and first draft transmitted to HCD are available on the Project Documents page of PlanPacifica.org.
1 Packet Pg. 5

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• October 16, 2023 | Joint study session of City Council and Planning Commission o Agenda report | Meeting video | Minutes
The ODS discussed by the Planning Commission included height, setbacks, lot coverage, floor area ratio (FAR), open space per dwelling unit, and off-street parking standards that should apply to the various sites in the Housing Sites Inventory. These six ODS will provide the basic framework to guide development of the sites in the Housing Sites Inventory and will be brought forward for adoption concurrently with the “Phase 1” rezoning action later in 2024, as described in Program HE-I-1, which is necessary to accommodate the City’s RHNA. Additional ODS will be considered as part of the Phase 2 rezoning action described in Program HE-I-2.

Key Policy Items Discussed by City Council and Planning Commission at Joint Study Sessions on September 25 and October 16, 2023
At the two City Council-Planning Commission joint study sessions on September 25 and October 16, 2023, more than a dozen specific comments in HCD’s letter from August 8, 2023, were discussed. The discussion and guidance provided allowed staff to incorporate changes into the Draft Housing Element related to the following, which comprised the most significant policy items requiring revisions in response to HCD’s comment letter:
• Reorganization of Housing Sites Inventory (HCD Comment B.3.1) • Assembly Bill (AB) 2011 Sites (HCD Comment B.3.2.B)
• Infrastructure Constraints (Rockaway Beach Pump Station) (HCD Comment B.3.9) • Farmworker Housing (HCD Comments B.2 & C.2)
• Affirmatively Furthering Fair Housing (AFFH): Mobility Support and Transit Advocacy (HCD Comment B.2)
• 100% Nonresidential Sites (HCD Comment B.3.2.C)
• Site Consolidation Program (HCD Comment B.3.3)
• Surplus Lands Act for City/School District/Caltrans Sites (HCD Comments B.3.5 & B.3.6) • Emergency Shelter Zoning (HCD Comment B.3.10.A)
• Zoning for Transitional and Supportive Housing (HCD Comment B.3.10.B) • Accessory Dwelling Unit (ADU) Zoning (HCD Comment B.3.10.C) • Single-Room Occupancy (SRO) Zoning (HCD Comment B.3.10.D) • Off-street Parking Minimum Requirements (HCD Comment B.4.1) • Permits & Findings for Housing Approvals (HCD Comment B.4.3.A) • Planned Development (P-D) Zoning (HCD Comment B.4.3.B) • Group Homes for 7+ Persons (HCD Comment B.4.6.B)
• Affirmatively Furthering Fair Housing (AFFH): Affirmative Marketing Strategy in Racial Concentrated Areas of Affluence (RCAA) (HCD Comment C.4) • Housing Rehabilitation (HCD Comment D.1)
Staff also made other revisions to the Draft Housing Element based on its assessment of applicable legal requirements and professional judgment. These revisions are, in staff’s judgment, relatively minor compared to the significant policy items for which the Planning Commission and City Council already provided direction and/or confirmed staff’s recommended policy approaches. 1 Packet Pg. 6

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A full depiction of revisions made to the prior Draft Housing Element from May 2023 in response to HCD’s comments is provided in the redline version of the latest Draft Housing Element on the Project Documents page of PlanPacifica.org.

5. Key Housing Element Components
The Draft Housing Element consists of a main chapter and seven appendices covering specific subject matter:
• Appendix A: Community Consultation
• Appendix B: Prior Housing Element Review
• Appendix C: Housing Needs
• Appendix D: Assessment of Fair Housing
• Appendix E: Housing Resources
• Appendix F: Housing Sites
• Appendix G: Housing Constraints
Due to the length and complexity of the Draft Housing Element, this staff report focuses on summarizing two key components of the document: the Housing Sites Inventory and the proposed Policies and Programs.

A. Housing Sites Inventory
The Draft Housing Element describes the City’s RHNA and identifies specific sites that can accommodate development of housing consistent with the RHNA. This information is summarized primarily in the main chapter and in Appendix F: Housing Sites.

The City of Pacifica’s 6th Cycle RHNA allocation is 1,892 housing units. These housing units are further segmented by income4to ensure that sufficient housing can be approved and constructed for all income levels, as demonstrated in Table 1, below:

Table 1: Pacifica’s 6th Cycle RHNA
Very Low
Income5
<50% of AMI
Low Income
50-80% of AMI
Moderate Income
80-120% of AMI
Above Moderate
Income
>120% AMI TOTAL
Units 538 310 291 753 1,892
4 The income levels in the RHNA refer to Area Median Income, or AMI, for the county in which a local jurisdiction is located. The 2023 AMI thresholds for San Mateo County are published by the San Mateo County Department of Housing and vary by family size. The Department of Housing’s published data also indicate the maximum rents considered to be affordable for each income level.
5 The RHNA only provides a Very Low Income (VLI) assignment for the lowest income level. However, other provisions of state law require the City to address Extremely Low Income (ELI) housing needs (0-30% of AMI). The Draft Housing Element apportions half of the VLI RHNA to the ELI category as permitted by law. 1 Packet Pg. 7

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Pacifica’s 6th Cycle RHNA is an increase of 1,479 units, or 358 percent, compared to its 5th Cycle RHNA allocation of 413 units. The increased RHNA required extensive evaluation of potential housing sites during preparation of the Draft Housing Element. Appendix F of the Draft Housing Element includes a detailed discussion of the City’s plan to satisfy its RHNA, including identification of specific sites and their suitability for housing affordable at various income levels. The Housing Site Inventory identifies five sites with suitable existing General Plan land use designations and 21 sites that will require General Plan amendments and/or rezoning to make them suitable for RHNA purposes. Table 2 includes a summary of the methods used to satisfy the RHNA:

Table 2: Methods Used to Satisfy 6th Cycle RHNA
Method Units
Existing General Plan Capacity 122
Amended General Plan Capacity (i.e., “Rezoning”) 2,042
Accessory Dwelling Units (ADUs) 187
Approved Housing Units 223
TOTAL 2,574
The combined effect of the four methods used to satisfy Pacifica’s 6th Cycle RHNA is a buffer of 36 percent above the 1,892-unit requirement, for a total of demonstrated capacity for the approval and construction of 2,574 housing units. HCD’s Housing Element Site Inventory Guidebook6suggests that housing elements include a buffer of “at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower income RHNA,” and goes on to indicate that jurisdictions can also create a buffer by “projecting site capacity at less than the maximum density.” The site inventory in the Draft Housing Element places an emphasis on the lower income RHNA by providing a 50 percent buffer for that income category. The buffers for each income level are demonstrated in Table 3, below. Additional buffer is provided across all income levels by assuming only 81 percent of the maximum density on each site based on an average of densities for projects actually approved in Pacifica in recent years.

Table 3: Buffers by RHNA Income Level
Lower Income
Capacity
Moderate
Income
Capacity
Above Moderate
Income Capacity TOTAL
RHNA Requirement 848 291 753 1,892
Draft Housing Element 1,271 437 866 2,574
Buffer 50% 38% 15% 36%
6 Available at: https://www.hcd.ca.gov/community-development/housingelement/docs/sites_inventory_memo_final06102020.pdf. 1 Packet Pg. 8

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Beyond simply meeting the numerical requirement to accommodate the RHNA, the site inventory also balances the distribution of new housing throughout the city as shown in Figure 1, below. Please note that Figure 1 differentiates between sites that count toward the City’s RHNA requirement, referred to as “Core RHNA,” and sites that are intended as “buffer” sites that exceed the RHNA requirement. Please also note that, as explained in a note at the bottom of Figure 1, in some cases, housing development will only occur on a portion of the housing site and, in those cases, a separate figure included in the Housing Element specifies the exact location on the site on which housing is intended to be developed. 1 Packet Pg. 9

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Figure 1: Housing Site Inventory Map
This figure shows the parcels on which housing is intended to be developed on all or a portion of the parcel. Where the entire parcel is not intended to be developed with housing, the specific areas of the parcel intended for housing development are 1 Packet Pg. 10

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depicted in Appendix F, Figures F-2 through F-10 “Areas assumed for housing (in blue shading).” The areas of the parcels that are not shown as “Areas assumed for housing (in blue shading)” are not included in the Housing Element site inventory.

The site inventory considered factors such as access to transportation and other infrastructure, proximity to public transit and other services, high-opportunity areas near schools and parks, and prior public input including avoidance of hillsides to the maximum extent practicable and prioritizing redevelopment of single-use commercial centers into mixed-use residential/commercial. Importantly, and as further analyzed in Appendix D: Assessment of Fair Housing, the site inventory must support Affirmatively Furthering Fair Housing (AFFH). This includes actions to counter historic patterns of racial segregation in housing, avoiding concentration of lower income housing in the lowest income/lowest resource areas of the city, and identifying opportunities for affordable housing construction in the highest opportunity/highest resource areas of the city. The site inventory achieves these AFFH objectives by distributing housing sites in a balanced manner throughout Pacifica.

B. Policies and Programs
The policies and programs contained in the Draft Housing Element are an important companion to the Housing Site Inventory used to accommodate the RHNA. One important purpose of the policies and programs is to facilitate implementation of the RHNA by reducing or removing barriers to housing approval and construction. These are considered Housing Constraints and are analyzed in Appendix G.

The policies and programs are also intended to address other non-production aspects of housing, such as protection and preservation of housing units to prevent their loss or conversion to non-housing uses.

In total, the Draft Housing Element contains 14 programs (with numerous implementation actions associated with the programs). Some notable programs in the Draft Housing Element include the following:
• HE-I-1: General Plan and Zoning Amendments to Achieve RHNA o Includes future General Plan amendments and rezoning needed to accommodate the RHNA, along with six core ODS to guide development until Program HE-I-2 is completed
• HE-I-2: Zoning Modernization and Streamlining
o Includes a comprehensive update to the City’s zoning regulations to implement a broad range of objective development and design standards to guide development
• HE-I-5: Fund a Housing Action Fund
o Includes establishing and funding7 a special purpose City fund to pursue affordable housing-related activities
• HE-I-8: Rehabilitation of Homes in Lower Resource and Coastal Areas 7 The City has already taken steps to implement this program by establishing the Housing Action Fund and allocating approximately half of the $3.4 million of Excess Educational Revenue Augmentation Funding (ERAF) revenues projected to be collected in FY2023-24 (approximately $1.67 million) during the annual budget process.

While the city is not guaranteed to receive Excess ERAF long-term, the allocation of these funds in the FY 2023-24 budget demonstrates the City’s commitment to support housing activities. 1 Packet Pg. 11

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o Includes assignment of Code Enforcement staff to proactively identify properties in need of significant maintenance, prior to receipt of a complaint and initiation of enforcement activity, to ascertain underlying reasons for the degraded property condition, and connection with available local, state, and federal resources that can assist with property rehabilitation for lower income or disabled property owners
• HE-I-12: Fair Housing Affirmative Marketing Strategy
o Includes improving the marketing activities for affordable housing units when they become available, such as adding schools outside the RCAA to the required recipient list for application solicitations to increase the chances of families with children outside the RCAA to learn about affordable housing opportunities within the RCAA
• HE-I-14: State and Federal Law Conformance
o Includes significant modernization of the Pacifica Municipal Code to align with state law addressing various housing-related topics
The timeline for implementation of each program is set forth in the main chapter of the Draft Housing Element. In total, work to implement Housing Element programs will comprise a major work program for Planning Department and other City staff during the eight-year planning period.

6. California Environmental Quality Act
Adoption of the Draft Housing Element is an action subject to environmental review pursuant to the California Environmental Quality Act (CEQA). To comply with CEQA, staff has prepared an Initial Study/Negative Declaration (IS/ND), entitled “Housing Element Update – 2023-2031,” State Clearinghouse No. 2023110438 (Attachment D). Due to the Planning Commission’s purely advisory role on this item, it will also provide a recommendation to City Council on whether to adopt the IS/ND as prepared by staff.

The IS/ND found that adoption of the Draft Housing Element could not have a significant effect on the environment. The primary reason for this conclusion is that the Draft Housing Element is a policy document. It does not propose or approve specific projects, change General Plan land use designations or rezone properties, or implement ordinance amendments of any kind. Rather, it sets forth a plan for how the City may best facilitate housing development in a manner consistent with and required by state law, which will be implemented over the eight-year Housing Element cycle.

The IS/ND was available for public review and comment from November 16 through December 18, 2023. The City received eight comment letters from private individuals but did not receive any comments from public agencies during the public comment period (Attachment E). While CEQA does not require preparation of a formal response to comments for adoption of an IS/ND, staff has nevertheless prepared the responses below to address key themes in the public comment letters submitted.

Comment Theme 1: The Housing Element will add approximately 2,000 new housing units to the City of Pacifica, which will result in potentially significant environmental impacts including potential cumulative 1 Packet Pg. 12

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impacts. Environmental review should not be deferred to a project-by-project basis, and an environmental impact report (EIR) should be prepared.

Response to Comment: The Draft Housing Element, if adopted, would not amend the Land Use Element of the General Plan, or rezone the Zoning Map. Rather, these actions would require further Planning Commission and City Council actions in the future. General Plan amendments to the Land Use Element of the General Plan and rezoning to the Zoning Map are actions that would be subject to environmental review pursuant to CEQA. The City will prepare an environmental impact report (EIR) to assess potentially significant environmental impacts that would result from implementation of Housing Element Program HE-I-1 which includes the General Plan amendment and rezoning actions necessary to create new housing capacity and to accommodate the RHNA. Because adoption of the Housing Element would not amend the Land Use Element of the General Plan or rezone sites to create new housing capacity, this action would not result in any direct or indirect physical impacts to the environment.

Comment Theme 2: Development of housing on Site 21 (Oceana High School) would have potentially significant effects on the environment and should have been evaluated in the IS/ND.

Response to Comment: As described in the response to Comment Theme 1, the Draft Housing Element, if adopted, would not amend the Land Use Element of the General Plan, or rezone the Zoning Map. Therefore, adoption of the Housing Element would not result in any direct or indirect physical impacts to the environment. Furthermore, the specific setbacks, lot coverage, height, and other development standards associated with the future General Plan amendment and rezoning necessary to establish new housing capacity on Site 21 are not known at this time.

As a result, potential aesthetic impacts are not reasonably foreseeable at this time and cannot be adequately analyzed. As noted in the response to Comment Theme 1, the City will prepare an EIR to assess the impacts of Housing Element Program HE-I-1.

Comment Theme 3: State Planning and Zoning Law requires housing elements to provide an “inventory of land suitable and available for residential development” that have “realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need.” (Gov. Code sec. 65583(a)(3)). As a result, the Draft Housing Element should include the former Sea Bowl bowling alley site in the Housing Site Inventory based on a specific development proposal contemplated for the site.

Response to Comment: This comment does not relate to the sufficiency or adequate of the IS/ND. Rather, the comment relates to the content of the Housing Site Inventory in the Draft Housing Element. The comment has been made available to the Planning Commission for consideration.

Based on the foregoing public comments, no revisions to the IS/ND prepared by staff and attached to this staff report are required at this time.
1 Packet Pg. 13

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7. Public Comments
The City received extensive written public comments during the course of development of the Draft Housing Element. These are consolidated in Appendix A: Community Consultation of the Draft Housing Element (Attachment B).

The public remains welcome to submit written public comments at [email protected].

8. Staff Recommendation
Staff recommends adoption of the attached Resolution which would recommend City Council approval of the Negative Declaration and the 2021-2031 Housing Element of the General Plan.

Adoption of the Housing Element after revisions in response to HCD’s comment letter is consistent with the actions taken by other Bay Area jurisdictions following receipt of their HCD comment letters.

Following adoption, staff will then transmit the Adopted Housing Element to HCD for a 60-day review period. The potential exists for HCD to have additional comments on the Adopted Housing Element which may require further revisions. Staff will request that the Council, when adopting the Housing Element, authorize staff to make revisions that are requested by HCD to achieve certification and that are consistent with Council direction. More substantive revisions could require readoption before the City achieves certification.

9. Commission Action
MOTION FOR APPROVAL:

Move to adopt the attached Resolution to:

A. Recommend that the City Council adopt an Initial Study/Negative Declaration for the project title “Housing Element Update – 2023-2031,” State Clearinghouse No. 2023110438 in accordance with the California Environmental Quality Act (CEQA); and B. Recommend that the City Council approve the 2023-2031 Housing Element of the General Plan in the form included as Attachment B to the staff report; and C. Incorporate all documents and testimony into the record by reference.

ATTACHMENT LIST:

Attachment A - Draft Resolution Recommending Approval to City Council (PDF) Attachment B - Draft Housing Element 2023-2031 - December 8, 2023 (PDF) Attachment C - HCD Comment Letter on First Draft Housing Element (with numbering) (PDF) Attachment D - Pacifica Housing Element Draft Initial Study/Negative Declaration (IS/ND) (PDF)
Attachment E - Public Comments on IS/ND (PDF)
1 Packet Pg. 14

ATTACHMENTS TO PLANNING COMMISSION STAFF REPORT INTENTIONALLY OMITTED

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MINUTES

CITY OF PACIFICA
PLANNING COMMISSION January 4, 2024

COUNCIL CHAMBERS
2212 BEACH BOULEVARD 7:00 p.m.

Chair Hauser called the meeting to order at 7:09 p.m.

ROLL CALL: Present: Commissioners Devine, Berman, Leal, Godwin, Wright and Chair Hauser

Absent: Commissioner Ferguson
Chair Hauser stated that Commissioner Devine was participating remotely due to just cause and she asked her to explain for the record her reason for remote participation due to just cause.

Planning Director Murdock stated he was trying to get her video on the screen, stating that she was having a problem connecting visually.

Chair Hauser asked if she needed to be on video.

Planning Director Murdock stated that she did and they will try to figure out the problem. He stated that she will try to disconnect and rejoin and hopefully will be able to connect by video.

Commissioner Devine was finally connected.

Chair Hauser then asked Planning Director Murdock if he thought they should officially start the meeting now, and with his approval, she called the meeting to order at 7:15 p.m. and readdressed the state code allowing remote participation for just cause.

Commissioner Devine stated that she was participating remotely due to just cause of need for child care.

Chair Hauser then asked her, according to the code, to identify if any individuals over 18 are present in the room from which she is present remotely.

Commissioner Devine confirmed that there were no individuals present in the room with her.

Planning Director Murdock then took a verbal roll call.

SALUTE TO FLAG: Led by Vice Chair Leal
STAFF PRESENT: Planning Director Murdock
Asst. City Attorney Murphy
Sr. Planner Harkousha
Sr. Planner Cervantes
Chair Hauser opened public comments for anyone wanting to speak on administrative business.

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APPROVAL OF ORDER Commissioner Berman moved approval of the Order OF AGENDA of Agenda; Commissioner Godwin seconded the motion.

Planning Director Murdock took a verbal roll call.

The motion carried 6-0.

Ayes: Commissioners Devine, Berman, Leal, Godwin,
Wright and Chair Hauser
Noes: None
APPROVAL OF None
MINUTES:

DESIGNATION OF LIAISON TO CITY COUNCIL MEETING OF JANUARY 22, 2024:

Chair Hauser explained the need for a liaison if the present item moves forward to Council.

Commissioner Wright stated, if no other volunteers, he would volunteer as the liaison.

Chair Hauser appreciated his consistency in volunteering.

ORAL COMMUNICATIONS:

Sr. Planner Cervantes introduced the call-in speaker.

Clif Lawrence, Pacifica, explained that on Channel 26, they are not seeing the visual meeting and that is technically not an open forum.

Chair Hauser explained that they can participate by Zoom, and mentioned the process.

CONSENT ITEMS:

None

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PUBLIC HEARINGS:

1. GPA-106-24 File No. 2023-025 – General Plan Amendment GPA-106-24 for consideration of Planning Commission recommendation to City Council on adoption of an Initial Study/Negative Declaration pursuant to the California Environmental Quality Act (CEQA) and on Adoption of the 2023-2031 Housing Element of the General Plan.

Recommended CEQA Action: Adoption of an Initial Study/Negative Declaration (IS/ND).

Planning Director Murdock presented the staff report.

Chair Hauser asked if they could check with Mr. Lawrence that they are able to follow the meeting remotely and when he confirmed that, she passed it back to Planning Director Murdock to continue the report.

Planning Director Murdock completed the staff report.

Chair Hauser thanked him for the thorough report and asked if he would like to introduce his team.

Planning Director Murdock agreed, and stated he had Asst. City Attorney Karen Murphy, Sandi Counsel, sites expert, Carol Johnson, constraints analyst, Sabrina Mora, fair housing analyst, Sr.

Planner Brianne Harkousha, assisting staff member and Nick Hamilton of Good City Company via Zoom who is available to answer questions.

Chair Hauser asked if Councilmembers had any questions before public comment. She had a couple but she would save them for after public comment and then opened the Public Hearing.

Sr. Planner Cervantes introduced the call-in speakers.

Clif Lawrence, Pacifica, expressed his thoughts and concerns on this declaration instead of CEQA report.

Sam Casillas, Pacifica, stated that he agreed with Mr. Lawrence’s comments, and then expressed his thoughts and concerns on this declaration.

Chair Hauser closed the Public Hearing and asked staff if they wanted to add anything else before moving on to Councilmember questions or comments.

Planning Director Murdock clarified staff’s position on concerns expressed by commenters on the EIR process. He explained that they will not be deferring to individual companies but will be doing an initial EIR.

Commissioner Berman asked clarification regarding their review and potential recommendation for approval of the housing element EIR before the processing of the zoning changes.

Planning Director Murdock explained that this is a policy level document setting forth a number of policy and programs, etc., but not effectuating the rezoning in the General Plan amendments

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that would allow the housing elements to occur, thus, no resulting effect on the environment from this housing element adoption. He added that the rezoning and General Plan amendments to the land use element would be part of program No. 1 and would have the potential for physical impacts to the environment and warrant preparation of the EIR, thus staff is taking preparation of one.

Commissioner Berman asked if staff foresees any issues with effectively committing to this housing element prior to adopting the zoning changes and reviewing the EIR.

Planning Director Murdock did not think so at this time as they have gone through a robust public process to identify sites that make sense for that housing element process. They have yet to get final confirmation from HCD and believe it is a solid site list, but it is not the final list, pending certification. However, they are confident the list will not need to be changed.

Commissioner Berman appreciated that they have a 36% buffer for RHNA which gives them some confidence.

Chair Hauser stated she was going to go down the line, person by person, and asked if she has any further to add.

Commissioner Berman stated that was her last question and she will wait for deliberation.

Chair Hauser then started with Commissioner Leal.

Commissioner Leal stated he didn’t have any additional questions.

Commissioner Godwin stated that Planning Director Murdock answered all his questions via text.

Commissioner Wright stated he had a few process related questions. He understood this started when the state put a mandate down and acknowledged how much time it took to put this together.

He has appreciated the public input and how staff has incorporated that as well as Commission suggestions, etc., and he thanked them for all their hard work and doing it in a timely manner. He asked if he could share how they did it all with the constraints put on them from above.

Planning Director Murdock thanked him for his thoughts, agreeing that it has been a team effort by everyone, and he thought it started on the basis of public input stemming from the General Plan Update process. They heard the concerns about maintaining open space, and they did their best to find locations on infill sites, not hillsides, and resulted in proposed higher densities, in addition to transit concerns causing them to try to find sites near transit routes. Thus staff did their best to incorporate all aspects from input for the ultimate product.

Commissioner Wright acknowledged staff’s effort to provide a progressive buffer system to get what our priorities are. He mentioned how impressed he was at the last meeting at the amount of community input there was and he loved being a Pacifican where we all care about our community and appreciated how staff wrapped their arms around that and tried to get the best produce for the city. He asked staff’s thought on the best time to get community input in the process to help get the best product that they want.

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Planning Director Murdock stated that staff welcomed the community input and provided a website for that purpose and they got a lot of input from them on the housing element website, adding that they can go to Pacifica.gov to get updated information, give input and get onto lists to receive updated info on meetings, etc.

Commissioner Devine stated that she wanted to understand a little bit more about the process with the EIR and what will be brought up, such as the rezoning sites.

Planning Director Murdock stated that the city is obligated, during the CEQA process, to consider potential alternatives and one of the processes that could possibly be brought up is modifying a housing element site if there are significant and unavoidable environmental impacts. They hope that is not the case, as it complicates things in revising the housing element and sending it back to the state for review, but it is one of the many options when addressing environmental impacts that could be identified in the EIR process.

Commissioner Devine realized how much time and effort went into this and she really appreciated staff’s work.

Chair Hauser has a few questions and clarifications. The first is referring to items in Appendix F that were added to the first draft, and she asked if it was possible to add the graphics on those for clarification.

Planning Director Murdock thought she was referring to the Oddstad Boulevard site and Skyline water tank site.

Chair Hauser responded affirmatively.

Planning Director Murdock asked if her concern was related to the highlighting of the parcel line versus the polygon outline.

Chair Hauser responded affirmatively, adding that she thought, on the other polygons, the graphics are clear, and when you add that second cyan polygon without any explanation, it is confusing as to why. She thought the polygons look great and the appendix is well worded.

Planning Director Murdock thought they could make the changes to have them align with the other sites. And, in referring to a motion, it is Figure F9 and Figure F10.

Chair Hauser referred to page 182, Appendix D, stating all the figures are very clear but she wasn’t sure they have been updated to reflect the lower income versus market rate income changes made in the body of the document, and she asked if staff could check that before it goes to Council.

Planning Director Murdock asked confirmation that it was on the red line on page 182.

Chair Hauser responded affirmatively, stating that it trickles through all the Appendix D figures and asked if they were updated. She stated that there were some that didn’t match page 14. She referred to the last RHNA cycle where there was a category for extreme low income and it is talked about but there isn’t a separate category for it and she asked for an explanation.

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Planning Director Murdock agreed to do that, adding that Sandie Counsel could then possibly add on or clarify. He stated that the category is for very low income and there is methodology to split 50-50 for very low and extremely low income and that is where the breakdown comes from, but it is not specifically a RHNA allocation for ELI but other provision s require that you assess the need and accepted methodology that many if not most communities use.

Chair Hauser understood. She then referred to the six objective development standards (ODS) they studied were part of the rezoning effort, and she appreciated that all that work was going into that effort instead of a bigger document. She then thanked staff for all the amazing work they did incorporating everything they received into the document. She then asked if any Commissioners had anything to deliberate.

Commissioner Wright stated that he had one more question. He stated that, as they are ready to put this work forward, he knows they did their best, and asked if they had any suggestions as to how that is going to be received.

Planning Director Murdock stated they hope very well, assuming he was referring to being received by California Housing and Community Development. He stated that staff believes the housing element they have prepared through the process complies with state law and their hope is that, when the state reviews the document, they find they agree with the city that the document is compliant with state law. Staff won’t know until they resubmit after City Council hopefully adopts it later this month, but they wouldn’t be the first city to have to go through another round of work with HCD in order to achieve substantial compliance. They are cautiously optimistic, as they put their best foot forward as mentioned and they hope to be found in substantial compliance.

Commissioner Wright stated that they all appreciate staff’s continued support of the community’s priorities in this process even if they take a chance that it will be sent back and have to revisit it.

Chair Hauser stated that she didn’t see any strong feelings about deliberating so they can either entertain a motion or deliberate.

Commissioner Berman stated she wasn’t deliberating, but wanted to echo the appreciations expressed for city’s staff because of all the hard work that has gone into this and she also appreciated the Commission’s hard work. She acknowledged that she had to miss several meetings because of being on maternity leave, but they put in a lot of work and she feels that, as a city, they have done really well.

Commissioner Devine stated that she was pouring over the redline documents and felt confident and pleased with how much time went into this. She felt they did their best to process it and she was pleased at the community members who showed up they did their best to read their comments and she was pleased to see where this goes. She appreciated the process for her since she joined the Commission, mentioning her initial concerns at the possibility of significant changes in the city she, her husband, and his family grew up in, but she has learned a lot and appreciated the process.

Chair Hauser stated that she was willing to make a motion. She didn’t think she had to make any comments about the graphics they talked about.

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Chair Hauser moved to adopt the attached resolution that the Planning Commission recommend that the City Council adopt an Initial Study/Negative Declaration for the project title “Housing Element Update – 2023-2031”, State Clearinghouse No. 2023110438 in accordance with CEQA and Recommend that the City Council approve the 2023-2031 Housing Element of the General Plan in the form included as Attachment B to the staff report; and incorporate all documents and testimony into the record by reference; Commissioner Godwin seconded the motion.

Planning Director Murdock took a verbal roll call.

The motion carried 6-0.

Ayes: Commissioners Devine, Berman, Leal, Godwin,
Wright and Chair Hauser
Noes: None
Chair Hauser declared that anyone aggrieved by the action of the Planning Commission has ten (10) calendar days to appeal the decision in writing to the City Council.

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CONSIDERATION:

None
COMMISSION COMMUNICATIONS:

Commissioner Godwin reminded everyone that these aren’t approved projects and can be approved with substantial lower density when they come before the Commission and this is just the housing element and what actually happens is yet to be determined.

STAFF COMMUNICATIONS:

Planning Director Murdock thanked the Commission for their significant work, attention to detail, leadership in preparing the draft housing element and regarding the continuation of the process, Council is currently scheduled to consider the draft housing element and Planning Commission’s recommendation to adopt on Monday, January 22, and staff invites any community members who continue to participate in the process to give further public comment at that hearing.

ADJOURNMENT:

There being no further business for discussion, Commissioner Berman moved to adjourn the meeting at 8:13 p.m.; Commissioner Wright seconded the motion.

Planning Director Murdock took a verbal roll call.

The motion carried 6-0.

Ayes: Commissioners Devine, Berman, Leal, Godwin,
Wright and Chair Hauser
Noes: None
Respectfully submitted,
Barbara Medina
Public Meeting Stenographer
APPROVED:
____________________________
Planning Director Murdock

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Packet Pg. 1336 Attachment: Attachment F - Planning Commission Draft Minutes - January 4, 2024 (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Housing Element Update
Guide to revisions made between December 8, 2023 Public Review Draft, and January 22, 2024 Adoption Draft
The following revisions were made to the draft between the December 8, 2023 Public Review Draft and the January 22, 2024 Adoption Draft. The changes below are reflected in the January 22 Draft, and are also described below to highlight any revisions.

1. Table 1: Table 1 included the correct numerical counts for Extremely Low-Income and Very Low Income, however the corresponding percentages were incorrect and have been updated.

2. Tables 2, 4, F-2, F-9, and F-10: The Approved Projects entry in Table 2 contained a typo and has been increased by four units from 163 to 167 Above Moderate-Income Units.

This change required a corresponding change of an additional four units throughout Tables 2, 4, F-2, and F-9.

3. Figures F-9 and Figure F-10: The two figures have been revised to conform with the graphic conventions used elsewhere in the appendix.

4. Table F-10: The parcel designated as APN 016-251-010 was erroneously included with Site 6 and has been removed.

5. An additional three columns of data were added to Table F-4 as follows: Site Size in Acres; Affordable Units; and, Notes. The data now included previously was shown elsewhere within the document or was the backup data for other tables in the element and is now included together as part of an expanded Table F-4 and the corresponding narrative was updated.

6. The last sentence of Program HE-I-14 (8) was revised to reflect adoption of the Emergency Shelter Ordinance and now reads: “To implement this, Ordinance No. 894- C.S. was adopted on December 11, 2023, and is effective for areas outside the coastal zone on January 10, 2024”

7. Additional minor typographical corrections and formatting changes were also made.

These include:

A. A typo to the penultimate sentence prior to Table 5 within Section 12. 2023-2031 Programs.

B. A typo on P. F-9, first bullet point.

C. Section titles in the margin of Appendix C were corrected.

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Planning Department

INITIAL STUDY AND NEGATIVE

DECLARATION
Date: November 16, 2023
Project Title: Housing Element Update – 2023-2031
Lead Agency: City of Pacifica
Planning Department
540 Crespi Drive
Pacifica, CA 94044
Contact Person: Christian Murdock, Planning Director
(650) 738-7341
[email protected]
Project Location: Citywide
Project Proponent: City of Pacifica
Project Description: The project is an update of the Housing Element of the City of Pacifica General Plan covering the 2023 to 2031 planning period as required by the California Government Code. The Housing Element update contains an analysis of the community’s housing needs, resources, constraints, and opportunities. It also contains goals, policies, and programs for housing and action programs which detail the actions to be taken by the City to respond to the community’s evolving housing needs.

Pacifica is located along the Pacific coast of the San Francisco Peninsula, in San Mateo County.

It is part of the San Francisco-Oakland-San Jose metropolitan area, and is approximately 13 miles south of downtown San Francisco, 40 miles northwest of San Jose, and six miles west of San Francisco International Airport.

The cities of Daly City, South San Francisco, and San Bruno border Pacifica to the north and east, and contain urban development that reaches Pacifica City limits. To the east and the south are unincorporated portions of San Mateo County and the ridges of the Coast Range.

Much of the land to the southeast and south is preserved as units of the Golden Gate National Recreational Area, the State and County Park systems, and protected watershed. Rural and agricultural land is also prevalent south of the city.

Access to Pacifica is primarily via State Route (SR) 1, also known as Highway 1 or Coast Highway, and SR 35, also known as Skyline Boulevard. SR 1 and SR 35 connect to Interstate 280 which in turn connects to the larger regional roadway system. Buses connect Pacifica to high-capacity transit service at the Daly City and Colma Bay Area Rapid Transit (BART) stations and the San Bruno Caltrain station.

The Pacific Ocean borders Pacifica to the west. Lands west of SR 1, along with Shelldance Nursery and some lands to the south, are part of the State-designated Coastal Zone. The regional setting is depicted in Figure 1.

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Figure1: Regional Location
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Figure2: Housing Element Update Plan Area

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As shown in Table 1, Residential land use designations make up a quarter of existing land use within Pacifica. Approximately 1,984 acres, or 26 percent, of the city is designated as singlefamily, multi-family, or mobile homes (City of Pacifica, 2022).

Table 1 Distribution of Existing Land Uses
Table 3.1-1: Existing Land Uses in Pacifica
Land Use Acres in Pacifica Percent of Pacifica
Open Space
Parks and Accessible Open Space 2865 37.4%
Other Open Space 737 9.6%
Beach 48 1%
Subtotal 3,650 48%
Public, Community, and Institutional Uses
Schools 238 3%
Other Public or Community Uses 105 1%
Utilities 55 1%
Subtotal 393 5%
Residential Uses
Single-Family 1,789 23%
Multi-Family 186 2%
Mobile Homes 9 0.1%
Subtotal 1,984 26%
Commercial and Mixed Use
General Commercial 83 1%
Hotels 7 0.1%
Office 4 0.1%
Mixed Use 12 0.2%
Subtotal 106 1%
Industrial Uses
Industrial 78 0.2%
Agriculture, Undeveloped and Vacant
Agriculture 363 5%
Vacant and Undeveloped 1,142 15%
Subtotal 1,504 20%
Total 7,665 100%
Single-family housing makes up 1,789 acres, about 91 percent of residential land use area, while multi-family housing makes up about 186 acres or 9 percent of residential land use area, and mobile homes make up less than one percent of residential land use area. Single-family houses are typical in all neighborhoods, while multi-family housing is distributed in clusters throughout the City.

Pacifica has a small amount of mixed-use development, primarily along Palmetto Avenue in West Sharp Park and in Rockaway Beach. Several buildings along Palmetto Avenue have restaurants or retail on the ground floor and housing units or office space on the second floor. Overall, West Sharp Park has the greatest mix of uses throughout the neighborhood, both vertically and

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horizontally.

Public, community, and institutional uses occupy 393 acres of Pacifica’s land. Of this, about 60 percent is school land and buildings, including the campuses of Oceana and Terra Nova high schools which are part of the Jefferson Union High School District. Other significant public land holdings include two library sites, the Calera Creek Water Recycling Plant, police and fire stations, and water tanks throughout the city.

Public/Institutional land uses are interspersed throughout the city.

Commercial and office uses occupy approximately 97 acres in Pacifica, making up only one percent of the City’s land. Pacifica has no central downtown area. Most retail, restaurants and services are located in neighborhood shopping centers and commercial areas distributed around the City.

Most of the 17 acres of industrial land in Pacifica is located between Palmetto Avenue and the ocean, in the northern end of the West Sharp Park neighborhood.

Large parcels of undeveloped land are present along the northern bluffs, the north slope of Milagra Ridge, Gypsy Hill, the Rockaway Quarry site, the face of Cattle Hill, Fassler Ridge, and the slope of Montara Mountain. Smaller vacant “infill” lots are found primarily in the West Sharp Park, East Sharp Park, Westview-Pacific Highlands, Rockaway Beach, and Pedro Point neighborhoods. Given environmental factors such as slope and sensitive species, there are some constraints on the development potential of these sites.

There are about 360 acres of land used for agriculture in the City of Pacifica. About 260 acres of this are within City limits, at Millwood Ranch and Park Pacifica Stables, on properties directly north of Sharp Park, and along Linda Mar Boulevard west of the Pacifica Center for the Arts.

About 104 acres are outside City limits, at Shamrock Ranch between San Pedro Creek and Highway 1.

Background and History
The Housing Element is a policy-level document providing direction for the implementation of various programs to accommodate ongoing housing needs, and to encourage the production of housing units for all income levels and is one of the State-mandated elements of the General Plan. The Housing Element identifies the City’s housing conditions and needs, and establishes the goals, objectives, and policies that comprise the City’s housing strategy to accommodate projected housing needs, including the provision of adequate housing for low-income households and for special-needs populations (e.g., unhoused people, seniors, single-parent households, large families, and persons with disabilities).

As part of the 6th Cycle Housing Element update, cities are required to identify housing sites that provide the development capacity to accommodate build out of the City’s Regional Housing Needs Assessment (RHNA) allocation at all income levels. To accommodate the City’s RHNA need for all income levels, future housing development would occur through a variety of methods and as detailed in the Housing Sites section of the proposed 2023-2031 Housing Element.

Opportunities for future housing development include accessory dwelling units (ADUs) and opportunity sites. Opportunity sites do not represent proposals for new housing development.

Rather, they are sites where new housing development may occur in the future as the Housing Element is implemented.

Regional Housing Needs Allocation
The RHNA is a California State Housing Law requirement that is part of the periodic process of updating local general plan housing elements. It is a process that determines existing and projected housing need (i.e., RHNA allocation) for all jurisdictions in the state (including cities

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and unincorporated county areas) with the intent to provide opportunities for a mix of unit types, tenure, and affordability. The RHNA allocates housing need based on future estimates of housing unit growth need over the RHNA planning period (2023-2031). The proposed 2023-2031 Housing Element update would bring the element into compliance with State legislation passed since adoption of the 2015-2023 Housing Element and with the current Association of Bay Area Governments (ABAG) RHNA. ABAG has allocated the region’s 441,176 housing unit needs between each city and county in its region.

Pacifica’s RHNA allocation for the 2023-2031 planning period (6th RHNA cycle) is 1,892 units, as shown in Table 2, which is distributed among four income categories (ABAG 2021). The 1,892 units (or 2,599 total housing units including a 36% buffer) allocated to Pacifica as part of the RHNA process include approved projects in the pipeline, accessory dwelling units (ADU), and opportunity sites. For the last RHNA cycle, the City was allocated a total of 413 units to be accommodated in its Housing Element inventory of adequate sites.

Table 2 RHNA Allocation and Percentage of Income Distribution for Pacifica Income Level Percent of Area Median Income (AMI) Units Percent Very Low 0-50% 538 28.4%
Low 51-80% 310 16.4%
Moderate 81-120% 291 15.4%
Above
Moderate
>120% 753 39.8%
Total – 1,892 100%
Source: ABAG
2021
Pacifica is meeting its RHNA through the following means:
▪ Approved projects
▪ Opportunity sites that allow residential
▪ Opportunity sites that need rezoning
▪ Projected ADU development
The City has identified enough units through projected ADU development, approved projects, and opportunity sites to meet its 6th Cycle RHNA. After considering these sites, the City is projected to develop 2,599 units, sufficient units to address its entire RHNA allocation, as set forth in more detail below. The rezoning of certain opportunities sites will be done at a later phase and is considered an implementation action under the Housing Element update. Table 3, below, shows the City’s strategy for addressing their RHNA. (Continued on next page)

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Table 3 Strategy to Address Regional Housing Needs
Lower Income
Moderate
Income
Above Moderate
Income Total
RHNA 848 291 753 1,892
RHNA
Credits
Approved Projects 52 8 188 248
Projected ADUs/JADUs 112 56 19 187
Opportunity Sites That
Allow Residential
24 76 22 122
Opportunity Sites that
Need Rezoning
660 151 524 1,335
Total 848 291 753 1,892
RHNA Surplus/Buffer Sites +426 +107 +138 +707
The City has already approved 248 pipeline units, which consist of approved projects that have not received a certificate of occupancy before June 30, 2022. Based on the average annual ADU permits approved between 2018-2022, the City estimates the production of 187 ADUs over the eight-year planning cycle. The City also identified 122 units that can be accommodated on sites currently designated with sufficient allowable density. The remainder of units needed to satisfy the City’s RHNA obligations (“Core RHNA” sites) and those to provide surplus/buffer units would require future rezoning.

Table 4, below, includes a full list of Housing Element Update goals and associated policies.

Table 4 Pacifica Housing Element Goals and Policies
ID Number Goals and Supportive Policies
Goal HE-G-1 Maintain, Improve, and Develop Housing: Encourage the development and retention of housing in a variety of types for all income levels with priority given to low-income households and projects that foster sustainable urban development.

Goal HE-G-2 Affirmatively Further Fair Housing: Ensure community members have equitable access to safe, sanitary, and affordable housing, foster inclusive neighborhoods, remove barriers to housing for vulnerable communities, and protect residents from displacement.

Policy HE-P-1 Amend the general plan, map, and zoning ordinance to implement the land use designations, goals, policies, and programs identified in the 2023-2031 Housing Element.

Policy HE-P-2 Focus redevelopment in underutilized commercial shopping centers to create vibrant, mixed-use, and walkable neighborhood centers.

Policy HE-P-3 Remove constraints to housing development by streamlining the city’s development review and permitting processes and conducting a significant code modernization initiative.

Policy HE-P-4 Promote energy savings in housing and urban development patterns.

Policy HE-P-5 Strengthen transportation networks that connect residents with services and economic opportunities, including through partnerships with transportation agencies, with an emphasis on seniors and lower-income residents.

Policy HE-P-6 Facilitate production of affordable housing with an emphasis on affordable rental housing and workforce housing to decrease the impact of housing prices on cost burdened households.

Policy HE-P-7 Expand affordable rental and homeownership housing choices in areas of opportunity and higher resources.

Policy HE-P-8 Encourage upgrades to and maintenance of housing units.

Policy HE-P-9 Support the safety and wellbeing of people of all ages and abilities by encouraging agefriendly and universal design in new and rehabilitated housing and neighborhood improvements.

Policy HE-P-10 Support lower income families with children and multiple generations living together by ensuring a proportion of lower cost units include three or more bedrooms.

Policy HE-P-11 Deeply affordable housing is needed by people with developmental disabilities. Extremely low-income (ELI) units are particularly important to people with developmental disabilities,

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and some of the City’s planned production of ELI units should be subject to a preference for people with developmental disabilities.

Policy HE-P-12 Protect residents from displacement and preserve the affordability of existing housing by preventing the conversion of existing affordable housing units to less affordable housing types. For example, by supporting the preservation and habitability of mobile home communities.

Policy HE-P-13 Housing opportunities shall be provided for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, family status, disability, or any other legally protected class.

Policy HE-P-14 Maintain effective reasonable accommodation policies and programs.

Policy HE-P-15 Promote fair housing enforcement and outreach by regularly communicating about fair housing issues and laws to residents and property owners.

Policy HE-P-16 Improve services and amenities in existing neighborhoods, especially in areas of lower opportunity, with an emphasis on the needs of families, children, and seniors.

Policy HE-P-17 Support housing security for households with low incomes or special needs by strengthening services for residents facing eviction, housing instability, and risk of homelessness.

Policy HE-O-1 Maintain safe and sanitary housing: implement the safe and sanitary criteria of the housing code and engage with property owners of deteriorated or deteriorating housing.

Policy HE-O-2 Conserve energy through implementation of the California Green Building Standards Code and California Energy Code.

Policy HE-O-3 Require smoke detectors: property owners are required to maintain smoke detectors and verification of smoke detectors by building division whenever there is an inspection related to other city permits.

Policy HE-O-4 Impose a condition of approval on all permits benefitting from a Density Bonus Ordinance or other deviations from development standards to develop affordable or senior housing to restrict future uses to affordable, senior, or both.

Policy HE-O-5 Regulate condominium conversions to minimize housing impacts to renters as codified in Pacifica Municipal Code Title 9, Chapter 4, Article 24.5.

Policy HE-O-6 Supports and encourage property owner-designation of historic structures as set forth in Pacifica’s Historic Preservation Ordinance.

Policy HE-O-7 Prioritize infill residential development.

Policy HE-O-8 Provide an encouraging environment for construction of accessory dwelling units (ADUs).

Policy HE-O-9 Identify opportunities to include housing incentives in development applications.

Policy HE-O-10 Assist affordable housing developers with preparation of funding and development applications.

Policy HE-O-11 Require a geotechnical site investigation prior to permitting site development.

Policy HE-O-12 Reference the Open Space Task Force Report when evaluating development proposals for sites identified in the report.

Policy HE-O-13 Prevent the deterioration of housing units resulting from deferred maintenance.

Source: Pacifica, City of. 2023 Pacifica Draft 2023-2031 Housing Element.

Other Public Agencies Whose Approval is Required
With recommendations from the City’s Planning Commission, the Pacifica City Council will need to take the following discretionary actions in conjunction with the Housing Element Update:
▪ Adoption of the Final Negative Declaration
▪ Approval of the proposed 2023-2031 Housing Element
The City will seek certification of the Housing Element from the HCD subsequent to the City’s adoption.

Consultation with California Native American Tribes Traditionally and Culturally Affiliated with the Project Area Pursuant to Public Resources Code Section 21080.3.1 There are no tribes that have requested consultation under AB 52. In accordance with SB 18, the City contacted the NAHC in August 2023, to request a consultation list of tribes traditionally

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and culturally affiliated with Pacifica. The NAHC provided a list of five tribes—Amah Mutsun Tribal Band of Mission San Juan Bautista, the Costanoan Rumsen Carmel Tribe, the Indian Canyon Mutsun Band of Coastanoan, the Muwekma Ohlone Indian Tribe of the SF Bay Area, and the Ohlone Indian Tribe. The City contacted the five listed tribes regarding the City’s General Plan updates and received no response.

Cumulative Scenario
In addition to the specific impacts of individual plans or projects, CEQA requires environmental documents to consider potential cumulative impacts of the proposed plan. CEQA defines “cumulative impacts” as two or more individual impacts that, when considered together, are substantial or will compound other environmental impacts. Cumulative impacts are the combined changes in the environment that result from the incremental impact of development of the proposed plan or project and other nearby plans and projects. For example, air quality impacts of two nearby projects on either side of the same roadway may be less than significant when analyzed separately but could have significant impact when analyzed together. Cumulative impact analysis allows the environmental document to provide a reasonable forecast of future environmental conditions and can more accurately gauge the effects of a series of plans or projects.

CEQA requires cumulative impact analysis to consider either a list of planned and pending plans and projects that may contribute to cumulative effects, or a forecast of future development potential.

Because the proposed plan is a general plan housing element update, cumulative impacts are treated differently than they would be for a specific development. For general plan amendments, CEQA Guidelines Section 15130 provides the following direction relative to cumulative impact analysis:

Impacts should be based on a summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or areawide conditions contributing to the cumulative impact.

Because the proposed 2023-2031 Housing Element is essentially a set of goals and policies to enable future projects that could occur within the timeframe of the General Plan and the implementation of those goals and policies will be analyzed separately, the analysis focuses on whether there are any impacts of the Housing Element that could be cumulative if combined with other projects.
(Continued on next page)

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Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry
Resources
□ Air Quality
□ Biological Resources □ Cultural Resources □ Energy
□ Geology/Soils □ Greenhouse
Gas Emissions
□ Hazards & Hazardous
Materials
□ Hydrology/Water Quality □ Land Use/Planning □ Mineral Resources □ Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation □ Tribal Cultural
Resources
□ Utilities/Service Systems □ Wildfire □ Mandatory
Findings of
Significance
Determination
Based on this initial evaluation:
■ I find that the proposed plan COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. □ I find that although the proposed plan could have a significant effect on the environment, there will not be a significant effect in this case because revisions to the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
□ I find that the proposed plan MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
□ I find that the proposed plan MAY have a “potentially significant impact” or “less than significant with mitigation incorporated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is
required, but it must analyze only the effects that remain to be addressed.

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□ I find that although the proposed plan could have a significant effect on the environment, because all potential significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed plan, nothing further is required.

Signature: ___________________________ Date: 11/16/2023 Christian Murdock
Planning Director
City of Pacifica

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Environmental Checklist
1 Aesthetics
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Except as provided in Public Resources Code Section
21099, would the project:
a) Have a substantial adverse effect on a scenic
vista?

b) Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?

c) In non-urbanized areas, substantially degrade
the existing visual character or quality of public
views of the site and its surroundings? (Public
views are those that are experienced from a
publicly accessible vantage point). If the
project is in an urbanized area, would the
project conflict with applicable zoning and
other regulations governing scenic quality?

d) Create a new source of substantial light or
glare that would adversely affect daytime or
nighttime views in the area?

PHYSICAL SETTING
Scenic views generally refer to visual access to, or the visibility of, a particular natural or manmade visual resource from a given vantage point or corridor. Focal views focus on a particular object, scene, setting, or feature of visual interest. For purposes of CEQA, scenic views are limited to views from publicly-accessible places and do not include private views from locations that exclude general public access.

Views to the ocean and along the panoramic coastline are an integral part of Pacifica’s character.

Highway 1 provides a unique visual experience with coastal and hillside views. Sharp Park Road also represents an important visual summary of Pacifica. Other defining views include the view over the West Sharp Park district and Pacifica Pier from Highway 1; views towards Cattle Hill and Fassler Ridge from Highway 1; and the view to the ocean from Grace McCarthy Vista Point on Sharp Park Road.

IMPACT ANALYSIS
Scenic corridors consist of land visible from the public right-of-way and are comprised primarily of natural features and landforms. While the State and County have identified Highway 1 and Sharp Park Road in Pacifica as eligible for scenic highway designation, no formal designation has been granted. As such, there are no state scenic highways in Pacifica.

The proposed Housing Element Update would facilitate housing development in the City; however, it does not propose specific projects but rather puts forth goals and policies that regulate housing and various aspects of new housing development in Pacifica. Because it is a policy document, the Housing Element Update would not result in environmental impacts.

Further, all future development accommodated under the Housing Element Update would be subject to the City’s zoning and design review requirements intended to protect the visual character and quality of areas in part by establishing height limits, and to limit light sources on any property to avoid any new sources of substantial light or glare.

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Packet Pg. 1349 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 13
November 2023
Therefore, there would be no impacts related to aesthetics.

NO IMPACTS
2 Agricultural and Forestry Resources
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use?

b) Conflict with existing zoning for agricultural
use or a Williamson Act contract?

c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))?

d) Result in the loss of forest land or conversion
of forest land to non-forest use?

e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of Farmland
to non-agricultural use or conversion of forest
land to non-forest use?

PHYSICAL SETTING
There are about 260 acres of land used for agriculture or private recreation within City limits, at Millwood Ranch, the former Pack Pacifica Stables on Cape Berton Drive, properties directly north of Sharp Park Road, and along Linda Mar Boulevard. Most land in this category involves horse boarding and trail riding and has a rural character. A significant portion of Pacifica is forested, including Eucalyptus, Coastal Mixed Hardwood/Oak Woodland, Riparian Mixed Hardwood, and Monterey Cypress.

IMPACT ANALYSIS
There are no lands within the City of Pacifica that are shown as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency. “Forest land” is defined in PRC Section 12220(g) pursuant to the California Forest Legacy Program Act of 2007 as land that can support 10 percent or more native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits. There is no land in the City of Pacifica designated as forest land, or timberland zoned as Timberland Production (CDFW 2020).

Therefore, the Housing Element Update would not convert Prime Farmland, Unique Farmland,

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Packet Pg. 1350 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 14
November 2023
or Farmland of Statewide Importance (Farmland), or conflict with existing zoning and existing Williamson Act contracts, and no impact would occur. The Housing Element Update would not conflict with existing zoning for, or cause rezoning of, forest land, or timberland zoned Timberland Production, and no impact would occur. Further, the proposed Housing Element Update does not propose specific projects but rather puts forth goals and policies that regulate housing and various aspects of new housing development in Pacifica and no impact would occur.

NO IMPACT
3 Air Quality
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?

b) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non- attainment under an
applicable federal or state ambient air quality
standard?

c) Expose sensitive receptors to substantial
pollutant concentrations?

d) Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people?

PHYSICAL SETTING
Air quality is affected by the rate, amount, and location of pollutant emissions, and the associated meteorological conditions that influence pollutant movement and dispersal. Atmospheric conditions, including wind speed, wind direction, and air temperature, in combination with local surface topography (i.e., geographic features such as mountains and valleys), determine the effect of air pollutant emissions on local air quality.

The City of Pacifica is located within the San Francisco Bay Area Air Basin (SFBAAB). The Bay Area Air Quality Management District (BAAQMD) is the regional agency with regulatory authority over emission sources in the Bay Area, which includes all of San Francisco, San Mateo, Santa Clara, Alameda, Contra Costa, Marin, and Napa counties and the southern half of Sonoma and southwestern half of Solano counties.

Due to its position relative to wind flow patterns and topography, air quality in Pacifica is better than it is in the Bay Area overall. At Pacifica’s location, winds bring air from the ocean and are generally strong enough to carry away local emissions.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts related to odors or other potential emissions. The Housing Element Update would not conflict with or obstruct implementation of the Bay Area Clean Air Plan from 2017. Within San Mateo County, the area’s air quality standards for ozone and suspended particulate matter (PM10) are generally

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Packet Pg. 1351 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 15
November 2023
met, and the updated Housing Element will not violate any air quality standards, nor will it substantially contribute to air quality violations.

Development facilitated under the Housing Element Update would be residential development, which would not be considered a major generating source of odor and would not create objectionable odors to surrounding sensitive land uses. In addition, individual developments would be reviewed during the project review process for compliance with the BAAQMD’s CEQA Air Quality Guidelines (2022), which identifies land uses associated with odor complaints as wastewater treatment plants, landfills, confined animal facilities, composting stations, food manufacturing plants, refineries, and chemical plants. Therefore, the adoption of the Housing Element Update would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard or expose sensitive receptors to substantial pollutant concentrations.

There are no impacts associated with the Housing Element Update.

NO IMPACT
4 Biological Resources
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Have a substantial adverse effect, either
directly or through habitat modifications, on any
species identified as a candidate, sensitive, or
special status species in local or regional plans,
policies, or regulations, or by the California
Department of Fish and Wildlife or U.S. Fish
and Wildlife Service?

b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional plans,
policies, or regulations, or by the California
Department of Fish and Wildlife or U.S. Fish
and Wildlife Service?

c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological
interruption, or other means?

d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use
of native wildlife nursery sites?

e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?

f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?

PHYSICAL SETTING
Pacifica’s varied topography creates a wide range of habitats in the City, including intertidal

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Packet Pg. 1352 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 16
November 2023
areas, beaches, ridges, coastal headlands, woodlands, grasslands, scrub, creeks, and wetlands.

Most natural vegetation in the valley and canyon bottoms has been converted to development.

However, intact native habitats persist along the riparian corridors of San Pedro, Calera, Rockaway, and Milagra Creeks, and on steep slopes.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that regulate various aspects of new housing development in Pacifica. Because it is a policy document, the Housing Element Update would not result in impacts to biological resources.

Potential environmental impacts related to General Plan amendments and/or rezoning, as identified for opportunity sites to accommodate the RHNA, will be considered as part of the associated program in the Housing Element. In addition, all future development accommodated under the Housing Element Update would be consistent with the General Plan, zoning and design review requirements, and other regulations such as the tree preservation ordinance, designed to protect biological resources.

As a policy document the Housing Element would result in no impacts to biological resources.

NO IMPACT
5 Cultural Resources
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant
to §15064.5?

b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5?

c) Disturb any human remains, including those
interred outside of formal cemeteries?

PHYSICAL SETTING
Native Americans once had an extensive presence in Pacifica. When Europeans arrived, the area was home to people speaking the Costanoan/Ohlone language and living in and around two villages. In 1769, an expedition led by Gaspar de Portola, governor of the Spanish territory covering California, discovered San Francisco Bay from a point on Pacifica’s Sweeney Ridge, and camped in San Pedro Valley. Not long after, Mission San Francisco de Asis (Mission Dolores in present-day San Francisco) was established, and in 1786 the Mission developed an outpost in San Pedro Valley, alongside Pruristac. The Costanoan village was wiped out by disease in 17911.

The City of Pacifica has nine local historical landmarks, which are designated in the City’s Municipal Code. In addition to Sanchez Adobe and the Little Brown Church, these include the former San Pedro Schoolhouse (now City Hall); the 1907 Anderson’s Store building on Paloma Avenue; the Sharp Park Golf Course club house, from 1932; Vallemar Station; the former Dollaradio Station; and two private residences. The City of Pacifica also contains three statedesignated historic landmarks: the Portola Expedition Camp; Site of the Discovery of San 1 California Historical Resources Information System (CHRIS), 2009

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Packet Pg. 1353 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 17
November 2023
Francisco Bay; and, Sanchez Adobe (also a locally-designated historic landmark, as noted above).

IMPACT ANALYSIS
The Housing Element Update will not result in substantial adverse changes in the significance of historical resources or archaeological resources. Nor will the Housing Element Update directly or indirectly destroy a unique paleontological resource or site or other unique geologic feature.

The Housing Element Update does not propose the development of any specific sites, and any future development would be subject to developmental review and required to adhere to existing requirements in state law designed to reduce impacts to historic and cultural resources. The General Plan contains policies for the protection of cultural resources, and all new development must be consistent with these policies. The Housing Element update contains a further policy to support and encourage property owners to designate additional historic structures per Pacifica’s Historic Preservation Ordinance (see Policy HE-O-6). State law, the City’s General Plan and CEQA assure that, once any new development occurs, a thorough archaeological survey will take place and any identified impacts will be mitigated. Because it is a policy document, the Housing Element Update would not disturb any human remains, including those interred outside of formal cemeteries.

Therefore, the adoption of the Housing Element Update would have no impact.

NO IMPACT
6 Energy
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project construction
or operation?

b) Conflict with or obstruct a state or local plan
for renewable energy or energy efficiency?

PHYSICAL SETTING
In the Bay Area, as in most other places in the United States, automobiles and commercial vehicles (composed of small, medium, and large trucks) are the largest energy consumers in the transportation sector. Automobiles and commercial vehicles are generally fueled by diesel or gasoline. Other transit modes in the Bay Area include ferries, buses, light rail, BART, and commuter rail. These transit modes also consume gasoline, diesel, and electricity.

In 2015, the County totaled approximately 35 trillion British thermal units (Btu) in energy use from electricity and natural gas. Natural gas accounted for 56 percent of that energy usage (California Energy Commission. 2015. http://www.ecdms.energy.ca.gov/. Accessed May 2021) In 2018, Senate Bill 100 accelerated the State’s Renewable Portfolio Standards Program, codified in the Public Utilities Act, by requiring electricity providers to increase procurement from eligible renewable energy and zero-carbon resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.

Energy consumption is directly related to environmental quality in that the consumption of

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Packet Pg. 1354 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 18
November 2023
nonrenewable energy resources releases criteria air pollutant and greenhouse gas (GHG) emissions into the atmosphere.

IMPACT ANALYSIS
Pacific Gas and Electric Company (PG&E) serves the City of Pacifica with power transmission/distribution infrastructure. PG&E is responsible for all electric delivery and maintaining the electric grid from point of connection at power plants, natural gas fields, and renewable energy sources in northern California. Peninsula Clean Energy is an alternative renewable energy electricity provider. Both providers offer clean energy options including significant shares of GHG emissions free power generation.

The Housing Element Update in and of itself is a policy document and would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation. In addition, future development would be consistent with the General Plan and would be consistent with other local policies and regulations. These regulations include Pacifica Municipal Code, Title 8, Chapter 6 Energy Code and Chapter 7 Green Building Standards Code. Further, the Housing Element Update contains policies that encourage the conservation of energy though the implementation of the California Green Building Standards Code and California Energy Code.

The Housing Element Update does not generate impacts associated with wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation, or conflict with any plan for renewable energy efficiency. Therefore, there would be no impact.

NO IMPACT
7 Geology and Soil
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Directly or indirectly cause potential
substantial adverse effects, including the risk
of loss, injury, or death involving:

i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on
other substantial evidence of a known fault?

ii) Strong seismic ground shaking? 
iii) Seismic-related ground failure, including
liquefaction?

iv) Landslides? 
b) Result in substantial soil erosion or the loss of
topsoil?

c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in
on- or off-site landslide, lateral spreading,
subsidence, liquefaction, or collapse?

d) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or indirect
risks to life or property?

e) Have soils incapable of adequately supporting
the use of septic tanks or alternative

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Packet Pg. 1355 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 19
November 2023
wastewater disposal systems where sewers
are not available for the disposal of
wastewater?
f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?

PHYSICAL SETTING
The City of Pacifica lies within the geologically complex region of California referred to as the Coast Ranges geomorphic province2. The Coast Ranges province lies between the Pacific Ocean and the Great Valley (Sacramento and San Joaquin valleys) provinces and stretches from the Oregon border to the Santa Ynez Mountains near Santa Barbara. Much of the Coast Range province is composed of marine sedimentary deposits and volcanic rocks that form northwest trending mountain ridges and valleys, running subparallel to the San Andreas Fault Zone. The Coast Ranges can be further divided into the northern and southern ranges, separated by the San Francisco Bay. West of the San Andreas Fault lies the Salinian Block, a granitic core that extends from the southern end of the province to north of the Farallon Islands.

Modern seismic activity within the Coast Range continues to be associated with movement along the San Andreas system of faults. Regionally, this fault system is the boundary between large sections, or plates, of the earth’s crust known as the North American Plate and Pacific Plate.

This boundary is a complex system of generally parallel, northwest trending faults that extend across the greater San Francisco Bay Area. The San Andreas is also the closest active fault to Pacifica as it transects across the northeastern tip of the city3. Other nearby active faults are the San Gregorio and Hayward faults.

Pacifica includes coastal areas as well as part of the Santa Cruz Mountains, one of the northwest trending ridges typical of the Coast Ranges. The Santa Cruz Mountains form the mountainous spine of the San Francisco Peninsula. Much of the upland areas are underlain by granitic bedrock associated with the Salinian Block creating rugged steep terrain in areas. The Salinian Block consists of highly fractured and weathered granite, granodiorite and quartz diorite much of which has been subject to a lot of tectonic forces. More competent granitic rocks can be found in areas such as Montara and San Pedro Mountains located to the south. Other geologic units in the area include sandstones associated with the Franciscan Formation, greenstones, and alluvial materials from drainages that head towards the Pacific Ocean.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts related to the following: substantial soil erosion of the loss of topsoil; development on a geologic unit or soil that is unstable, or that would become unstable as result of future development, and potentially result in the on or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse; development located on expansive soils, as defined by the California Building Code, creating a substantial risks to life or property; or, development on soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water.

The Housing Element Update will not permit development in areas where development is 2 A geomorphic province is an area that possesses similar bedrock, structure, history, and age. California has 11 geomorphic provinces (CGS, 2002).
3 An “active” fault is defined by the State of California as a fault that has had surface displacement within Holocene time (approximately the last 11,000 years)

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Packet Pg. 1356 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 20
November 2023
currently prohibited in the General Plan, Local Coastal Land Use Plan or any City approved Specific Plan area. Potential impacts associated with General Plan amendment and/or zoning changes will be considered during the associated amendment process.

In addition, future development facilitated by the Housing Element Update would be consistent with the General Plan, and would be consistent with other local policies and regulations designed to address geotechnical hazards. Therefore, the adoption of the Housing Element Update would result in no impacts on geology and soils.

NO IMPACT
8 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?

b) Conflict with an applicable plan, policy, or
regulation adopted for the purpose of reducing
the emissions of greenhouse gases?

ENVIRONMENTAL SETTING
According to the California Air Resources Board emissions inventory reports for 2000 through 2019, California’s GHG emissions continue to decrease. In 2019, emissions from GHG emitting activities statewide were 418 million metric tons carbon dioxide equivalent (CO2e). Per capita rates of emissions in the Bay Area and San Mateo County are lower than the California average.

In 2019, the Climate Center completed a report showing that the Bay Area’s transportation sector is the primary source of the Bay Area greenhouse gas emissions, contributing about 50 percent of the region’s CO2e, followed by natural gas usage (33 percent) and electricity usage (14 percent). Between 2014 and 2019, the Bay Area reduced its emissions by about 3.6 percent.

In 2014, the City of Pacifica released a Climate Action Plan, which provided a baseline inventory of GHG emission in 2005. For a similar year, San Mateo County countywide CO2 emissions were 5.91 million metric tons in 2006, averaging 8.1 metric tons per capita. By contrast, emissions in Pacifica were estimated at 4.5 metric tons per capita4.

IMPACT ANALYSIS
In April 2017, BAAQMD adopted the 2017 Clean Air Plan. The goals of the plan are to protect public health and the climate. Consistent with the GHG reduction targets adopted by the state of California, the plan lays the groundwork for a long-term effort to reduce Bay Area GHG emissions 40 percent below 1990 levels by 2030 and 80 percent below 1990 levels by 2050 (BAAQMD 2017). As of 2022, BAAQMD has updated their approach on evaluating communitywide planning documents, such as a General Plan or Housing Element Update. It is recommended that each plan is evaluated based on whether they would be consistent with California’s long-term goal of achieving carbon neutrality by 2045 (BAAQMD 2022). In order for impacts to be considered less than significant, the communitywide planning document must demonstrate that GHG emissions from the jurisdiction will decline consistent with California’s GHG reduction targets of 40 percent below 1990 levels by 2030 and carbon neutrality by 2045 (BAAQMD 2022). 4 Sustainable San Mateo, U.S. Census Bureau, 2011-2015 American Community Survey

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Packet Pg. 1357 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 21
November 2023
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts related to greenhouse gas emissions. Additionally, the City would require individual projects to comply with the latest Title 24 Green Building Code and Building Efficiency Energy Standards which would reduce energy use from lighting, water-efficient faucets and toilets, and water efficient landscaping and irrigation.

Development within the city would obtain electrical power from Peninsula Clean Energy (PCE) or PG&E. PG&E expects to source 60 percent renewable energy by 2030, up from 33 percent in 2022, in order to comply with Senate Bill 100 (PG&E 2018). PCE exceeds the PG&E’s proportion of renewable power generation.

The Housing Element Update would not generate GHG emissions that may have a significant impact on the environment and would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. Thus, there would be no impact related to GHGs.

NO IMPACTS
9 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use,
or disposal of hazardous materials?

b) Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?

c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within 0.25 mile of an existing or proposed school?

d) Be located on a site that is included on a list of
hazardous material sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?

e) For a project located in an airport land use plan or, where such a plan has not been adopted, within
two miles of a public airport or public use airport,
would the project result in a safety hazard or
excessive noise for people residing or working in
the project area?

f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?

g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury, or
death involving wildland fires?

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Packet Pg. 1358 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 22
November 2023

ENVIRONMENTAL SETTING
The California Department of Toxic Substances Control (DTSC) and State of California Water Resources Control Board (SWRCB) track and identify sites with known or potential contamination and sites that may impact groundwater in accordance with Section 65962.5 of the California Public Resources Code. SWRCB records identify 34 hazardous materials release sites in Pacifica, of which 32 are completed/closed, one was recently reopened for site assessment, and one is open but eligible for closure.

Fire hazards in Pacifica include both urban and wildland fires. Urban fires involve the uncontrolled burning of built structures due to human-made causes; wildland fires affect grassland, forest, and brush (and the structures on them), and can result from either human or natural causes. Pacifica has a substantial risk of wildland fires, with many areas of high and very high threat within the city.

The Safety Element of the General Plan details the known and potential hazards from wildland fires. The Element identifies the hazards of wildland fires combined with steep terrain, narrow streets, and unavailability of water infrastructure to support firefighting response in undeveloped areas of the city. The Element identifies fire prevention, including public education and code enforcement, as the most effective means of suppressing fire.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts related to hazardous material transport, use, or disposal.

In addition, the transport, use, and storage of potentially hazardous materials during construction of future development facilitated by the Housing Element Update would be required to comply with all local, State, and federal regulations, such as the Hazardous Materials Transportation Act, Resource Conservation and Recovery Act, the California Hazardous Material Management Act, and California Code of Regulations Title 22. Development facilitated by the Housing Element Update would also be guided by Multi-jurisdictional Local Hazard Mitigation Plan (MJ-LHMP) for San Mateo County, which includes the City of Pacifica.

Operation of any new housing would likely involve an incremental increase in the use of common household hazardous materials, such as cleaning and degreasing solvents, fertilizers, pesticides, and other materials used in regular property and landscaping maintenance. Use of these materials would be subject to compliance with existing regulations, standards, and guidelines established by the federal, State, and local agencies related to storage, use, and disposal of hazardous materials.

The Housing Element in and of itself does not propose any development and therefore would have no impact on existing or proposed schools. The City contains two hazardous substance sites that are not closed following remediation as well as large amount of open space land prone to fire hazard. San Francisco International Airport (SFO) is located approximately four miles east of Pacifica. Small areas within the northeast of Pacifica are located within Airport Influence Area B (AIA B), the Project Referral Area for San Francisco International Airport, as well as the 2020 Forecast Community Noise Equivalent Level (CNEL) area. The Housing Element update would not result in safety hazards in relation to the Comprehensive Airport Land Use Compatibility Plan. The Safety Element of the 2040 General Plan provides policies that address conformance with local emergency response programs and continued cooperation with emergency response service providers. Wildfire hazard is minimal in most of Pacifica within city limits because it is mostly urbanized. However, areas along the southwestern perimeter within Pacifica’s Sphere of Influence (SOI) and in San Pedro Valley County Park are designated as Very High FHSZs. Most of this land in the Very High FHSZ zone is an urban reserve or park. These portions within the SOI are

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Packet Pg. 1359 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 23
November 2023
designated State Responsibility Areas (SRA), where the state of California is financially responsible for the prevention and suppression of wildfires.

In addition, future development facilitated by the Housing Element Update is subject to individual CEQA review processes. Based on the above, the Housing Element update would result in no impact on hazards or hazardous materials.

NO IMPACT
10 Hydrology and Water Quality
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground water
quality?

b) Substantially decrease groundwater supplies
or interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of the
basin?

c) Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or river
or through the addition of impervious surfaces,
in a manner which would:

i) Result in substantial erosion or siltation
on- or off-site;

ii) Substantially increase the rate or amount
of surface runoff in a manner which would
result in flooding on- or off-site;

iii) Create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or

iv) Impede or redirect flood flows? 
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project
inundation?

e) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?

PHYSICAL SETTING
The City of Pacifica is located within all or part of nine watersheds. The majority of the City drains west towards the Pacific Ocean. From north to south, the major watersheds that drain to the ocean are Milagra Creek, Sanchez Creek (also known as Sharp Park Creek), Calera Creek, and San Pedro Creek. A small portion of Pacifica drains to the east, contributing to the upper basin of San Mateo Creek watershed, which flows east toward San Francisco Bay.

The San Pedro Valley Groundwater Basin lies within the City of Pacifica and has a surface area of approximately 700 acres. Alluvial deposits, or clays, sands, and silts with interspersed gravel deposited by rivers, are found throughout the majority of the basin and are the primary water5.h Packet Pg. 1360 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 24
November 2023
bearing formations in the City of Pacifica. Existing data indicates that the alluvial deposits in San Pedro Valley are approximately 150 feet thick or more5.

The alluvium contains semi-confined and unconfined groundwater that is transmitted and stored through intergranular porosity. Previous studies indicate that the aquifer is recharged by local precipitation and runoff. The outflow of water from the aquifer occurs by evapotranspiration and seepage to streams, springs, and the ocean. The water table fluctuates seasonally in response to outflow and recharge volumes. The fluctuations vary based on characteristics such as soil permeability, rainfall, and slopes. Water quality, groundwater level, and groundwater storage data for the San Pedro Valley Groundwater Basin is minimal.

As part of a Sewer System Evaluation Survey, groundwater wells in the City of Pacifica were monitored to determine the location of seasonally shallow groundwater. The groundwater was mapped for three depths below the ground surface: less than 1.5 feet, less than 3.0 feet, and less than 6.0 feet. Communities with seasonally shallow groundwater include Pedro Point, Park Pacifica, Vallemar, Fairway Park, Linda Mar, and Sharp Park.

Flood hazards exist along most of the creeks in Pacifica. Broad flood inundation is relatively common in several low-lying areas, including the Sharp Park area along Sanchez Creek and in the Linda Mar neighborhood along San Pedro Creek. In much of the City, however, the creeks are confined within deeply incised channels, limiting potential flooding in these areas.

Flood hazards have been mapped by the Federal Emergency Management Agency (FEMA) to support the development of Flood Insurance Rate Maps (FIRMs). These maps generally identify areas of greater flood risk (e.g., 1 and 0.2 percent annual chance flood areas, also referred to as 100 and 500 year events) in the lower reaches of the main stream channels, as well as the risk of coastal flooding along the shoreline.

Pacifica can experience flooding from coastal sources. Coastal flooding in Pacifica typically occurs as some combination of high tides, large wind-driven waves, storm surge, swells, or tsunami waves. Areas with the potential for coastal flooding have been mapped and shown on the FEMA FIRMs based on a coastal flooding analysis updated in 20176.

Sea level rise resulting from global climate change has the potential to alter the frequency and magnitude of coastal flood events in Pacifica. Current estimates of sea level rise are based on Ocean Protection Council analysis adopted in 2018.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts that violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality; substantially decrease groundwater supplies or interfere substantially with groundwater recharge that would impede sustainable groundwater management of the basin; result in impacts regarding flood hazard; or result in impacts related to a water quality control plan or sustainable groundwater management plan.

Future development facilitated by the Housing Element Update would be subject to compliance with existing regulations, standards, and guidelines established by the federal, state, and local agencies in addition to the goals and policies in the General Plan, Local Coastal Program, and PMC related to hydrology and water quality. For example, the Safety Element prohibits development in hazardous areas, including flood zones, unless detailed site investigation ensure that 5 City of Pacifica, Draft Wastewater Facilities Plan, Revision 2, 1992. 6 FEMA. National Flood Hazard Layer for San Mateo County, Item: 06081C-NFHL2019, April 4, 2019. Available at:
https://mtc.maps.arcgis.com/home/item.html?id=929195bc63d74955bb54cf26c94b7659, accessed June 2021.

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risks can be reduced to acceptable levels and the structures will be protected for its design life.

Additionally, future development would be compliant with Chapter 12 of Title 6 of the PMC which requires appropriate construction best management practices (BMPs). BMPs may include measures such as the installation of silt fences to trap sediments, slope stabilization, and regular sweeping of construction sites to control dust.

Therefore, the Housing Element Update would not result in impacts that violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality; substantially decrease groundwater supplies or interfere substantially with groundwater recharge that would impede sustainable groundwater management of the basin; result in impacts regarding flood hazard; or result in impacts related to a water quality control plan or sustainable groundwater management plan.

NO IMPACT
11 Land Use and Planning
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Physically divide an established community? 
b) Cause a significant environmental impact due
to a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding
or mitigating an environmental effect?

PHYSICAL SETTING
The City of Pacifica is located in San Mateo County and is bordered to the west by the Pacific Ocean. It is part of the San Francisco-Oakland-San Jose metropolitan area, and is approximately 13 miles south of downtown San Francisco, 40 miles northwest of San Jose, and six miles west of San Francisco International Airport.

It shares a northern border with Daly City, and eastern borders with South San Francisco and San Bruno. To the east, and to the south, are unincorporated portions of San Mateo County and the ridges of the Coast Range. Much of the land to the southeast and south is preserved as units of the Golden Gate National Recreational Area, the State and County Park systems, and protected watersheds. Rural and agricultural land is also prevalent south of the city. Land west of SR 1, along with Shelldance Nursery and some lands to the south, is part of the Statedesignated Coastal Zone.

The most common land use in the City is open space, covering nearly half (3,614 acres) of the total land area. Another 361 acres are used for agriculture, and 1,204 acres remain vacant or undeveloped. Together these areas make up nearly 67 percent of the city. (Land used for rightof-way is not counted.) Developed land is concentrated in the north and south of the Pacifica, separated by tracts of park land and open space. Of the developed land area, residential land uses are the most common, covering 1,957 acres and accounting for 26 percent of Pacifica. This is accompanied by 395 acres of public or community uses, 108 acres of commercial uses, 18 acres of industrial uses, and 3.5 acres of mixed-use development.

IMPACT ANALYSIS
The Housing Element is a policy document and does not propose any specific sites for development and therefore has no impact on dividing an established community. Further, the

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Housing Element Update does not physically divide any established community. Rather, by allowing for compact and concentrated development in already-urbanized neighborhoods, increasing opportunities for housing and economic development, and improving linkages, the Housing Element update provides improved connections to and continuity with surrounding neighborhoods.

The Housing Element Update examines the City’s housing needs, as they exist today, and projects future housing needs. This Housing Element Update focuses on addressing the City’s housing needs by providing objectives and policies associated with fair housing, the prevention of displacement, and promoting housing stability. The Housing Element Update includes proposed actions the City would be undertaking to achieve its housing RHNA targets and also would implement ABAG’s land use goals and policies by encouraging new development in areas with access to transit and services, thus minimizing vehicle trips and GHG emissions. Potential impacts associated with zone changes will be analyzed during the zone change process.

The Housing Element update is consistent with the 2040 General Plan and will not cause a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

NO IMPACT
12 Mineral Resources
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Result in the loss of availability of known
mineral resources that would be of value to
the region and the residents of the state?

b) Result in the loss of availability of a locallyimportant mineral resources recovery site delineated on a local general plan, specific
plan or other land use?

PHYSICAL SETTING
According to the California Department of Conservation (DOC) mineral land classification map the city contains extensive aggregate mineral resources (DOC 2015). Sand and gravel resources are primarily concentrated along waterways.

IMPACT ANALYSIS
The Housing Element is a policy document and does not propose any specific development. In addition, development facilitated by the Housing Element Update would be subject to CEQA review for environmental impacts prior to adoption of the rezoning program. The Housing Element Update, in and of itself, would not result in the loss of availability of a known valuable mineral resource to the region, nor to a mineral resource recovery site. Therefore, there would be no impact on mineral resources.

NO IMPACT
13 Noise

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Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Generation of a substantial temporary or
permanent increase in ambient noise levels in
the vicinity of the project in excess of
standards established in the local general plan
or noise ordinance, or applicable standards of
other agencies?

b) Generation of excessive ground borne
vibration or ground borne noise levels?

c) For project located within the vicinity of a
private airstrip or an airport land use plan, or
where such a plan has not been adopted,
within two miles of a public airport or public
use airport, would the project expose people
residing or working in the project area to
excessive noise levels?

PHYSICAL SETTING
Sound waves, traveling outward from a source, exert a sound pressure level (commonly called “sound level”), measured in decibels (dB). In general, people can perceive a two- to three-dB difference in noise level; a difference of 10 dB is perceived as a doubling of loudness. “Noise” is often defined as unwanted sound. Environmental noise is usually measured in A-weighted decibels, a metric corrected for the variation in frequency response of the human ear.

Environmental noise levels typically fluctuate over time; different types of noise descriptors are used to account for this variability. Some descriptors characterize cumulative noise over a given period, while others describe single noise events. Cumulative noise descriptors include the energy-equivalent noise level (Leq), Day-Night Average Noise Level (DNL), and Community Noise Equivalent Level (CNEL).

Vibration is energy radiated through the ground. The rumbling sound caused by the vibration of room surfaces is called groundborne noise. Sources of groundborne vibration include natural phenomena (e.g., earthquakes, volcanic eruptions, sea waves, landslides) or human-made causes (e.g., explosions, machinery, traffic, trains, construction equipment). Vibration sources may be continuous, such as factory machinery, or transient, such as the passing of a train.

The effects of groundborne vibration include perceptible floor movement, rattling of windows, shaking of items on shelves or hanging on walls, and rumbling sounds. In contrast to noise, vibration is not a common environmental problem. In extreme cases, vibration can cause damage to buildings. Building damage is usually not a factor for normal transportation projects, with the exception of blasting and pile driving during construction.

The greatest potential for noise intrusion from airports occurs when aircraft land, take off, or run their engines while on the ground. San Francisco International Airport (SFO) is located approximately four miles east of Pacifica. Based on SFO’s 2019 noise contours, no part of Pacifica is currently within the 65 dB CNEL noise contour, SFO’s Aircraft Noise Abatement Office maintains a noise abatement program that integrates parts of the approved Noise Compatibility Plan; City and County of San Francisco resolutions; stated goals of the San Francisco International Airport/Community Roundtable; and air traffic control requirements. The program includes a mix of regulatory and voluntary actions that together minimize the impacts of noise on communities while ensuring safety.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies

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that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Impacts regarding
In addition, development proposals for individual projects would be subject to adopted noise guidelines including General Plan noise limitations. For example, Title 5, Chapter 10 of the Pacifica Municipal Code makes it unlawful to cause any “loud, disturbing, unnecessary, or unnatural noise” that disturbs persons in Pacifica, and identifies specific types of noises including vehicle horns and amplifiers. It prohibits the use of pile drivers or similar equipment between 8 p.m. and 7 a.m., and restricts the hours of solid waste collection. In addition, Title 5, Chapter 28 defines the terms for regulating loud parties. Chapter 29 requires general disclosure of the existence of the airport and the potential for noise from overflight, for all property in the City.

Special disclosure is required for property within the airport’s CNEL noise footprint as of 1983.

No part of the City is currently within the 65 dB CNEL noise contour, according to SFO’s 2019 land use contour maps.

Furthermore, because it is a policy document, the Housing Element Update would not, in and of itself, result in generation of a substantial temporary or permanent increase in ambient noise or vibration levels in the city. No impact would occur.

NO IMPACT
14 Population and Housing
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Induce substantial unplanned population
growth in an area, either directly (for example,
by proposing new homes and businesses) or
indirectly (for example, through extension of
road or other infrastructure)?

b) Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?

PHYSICAL SETTING
According to the California Department of Finance, the city had a population of 38,330 in 20207.

City records show that 14,520 housing units can be found in the city, out of which 75 percent are single-family detached units, 24 percent are multifamily units, and less than one percent are mobile homes. The average household size is 2.86 persons per household, which includes persons living alone, family households, and unrelated persons sharing living quarters. Pacifica’s proportion of the overall San Mateo County population is 5 percent, but the city has 15 percent of the unsheltered homeless population in the county8.

IMPACT ANALYSIS
The Housing Element Update is a policy document that would not induce substantial unplanned population growth in an area or displace existing residence or housing. The Housing Element Update is consistent with the other elements in the General Plan and is not expected to induce 7 Source: C/CAG 2040 Model, CA DoF, 2020.
8 2022 San Mateo County One Day Homeless County and Survey (2022).

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substantial unplanned population growth in the area, either directly (e.g., proposing new home and businesses) or indirectly (e.g., through extension of roads or other infrastructure). Zoning to implement the Housing Element Update and individual development projects will be subject to environmental review.

The City of Pacifica had an estimated population of 38,330 residents as of 2020 (DOF 2020).

The California Department of Housing & Community Development (HCD), ABAG and Metropolitan Transportation Commission (MTC) are responsible for identifying the projected RHNA for each jurisdiction in the Bay Area, including Pacifica. These documents include population, employment, and housing projections for the region.

As discussed in the Project Description, the Housing Element Update would provide the capacity to meet the City’s RHNA, therefore, the Housing Element Update would be consistent with State requirements for the RHNA. The Housing Element Update identifies policies and implementation actions that will accommodate potential future residential development to meets the City’s RHNA, including housing for lower-income households.

Implementation of the Housing Element Update would increase access to housing to meet housing needs in the city. The Housing Element Update aims to increase the number of housing units in Pacifica, so that anyone displaced will be able to find replacement accommodation in the same area. The 2040 General Plan also contains policies that reduce impacts of displacement or necessity of replacement housing.

Thus, the Housing Element Update would not induce substantial unplanned population growth in an area and would not displace substantial numbers of existing people or housing. Therefore, no impact would occur.

NO IMPACT
15 Public Services
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project result in substantial adverse
physical impacts associated with the provision
of a new of physically altered governmental
facilities, need for new or physically altered
governmental facilities, the construction of
which could cause significant environmental
impacts, in order to maintain acceptable
service ratios, response times or other
performance objectives for any of the public
services:

Fire protection? 
Police protection? 
Schools? 
Parks? 
Other public facilities? 

PHYSICAL SETTING
The cities of Brisbane, Daly City, and Pacifica are contributing members of the North County Fire Authority (NCFA), a Joint Powers Authority established in 2003. The NCFA provides both emergency response and non-emergency public safety services to the three cities and their

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185,000 people in its service area. Two of the NCFA’s 10 stations are in Pacifica. Fire Station 71, at 616 Edgemar Avenue, serves the north end of Pacifica, while Fire Station 72, at 1100 Linda Mar Boulevard, serves the south end.

The Pacifica Police Department responds to public safety calls, provides traffic safety and security for public events, and handles calls for assistance (some 20,000 annually). The Police Department serves the City from its station at 2075 Coast Highway. The 18,000 square foot station, opened in 2004, has been deemed adequate to support a sufficient level of service for future population growth in Pacifica.

Pacifica School District serves students in kindergarten through 8th grade, while Jefferson Union High School District serves students in 9th through 12th grades. There are also three private schools within the city. Pacifica School District (PSD) currently operates two TK-5 elementary schools, Sunset Ridge and Ortega, three K-8 schools, Ocean Shore, Vallemar, and Cabrillo, and one comprehensive middle school, Ingrid B. Lacy. The Linda Mar Education Center provides two support space for home-schooled children. Jefferson Union High School District (JUHSD) enrolls just under 5,000 high school and high-school-equivalent students in Brisbane, Colma, Daly City, and Pacifica. The district has two high schools in Pacifica. According to the California Department of Finance, school enrollment in San Mateo County is projected to decrease in the future. PSD projects a small enrollment growth of approximately 125 students over the next five years.

Pacifica is served by the San Mateo County Library (SMCL), a system with 12 branch libraries and a service area population of 285,149 as of 2017. San Mateo County Libraries is governed by the San Mateo County Library Joint Powers Authority (Library JPA). Pacifica is the only member of the Library JPA where the branch is divided into two facilities. The Pacifica-Sharp Park library is located in West Sharp Park in the northern part of the City, while the PacificaSanchez library is adjacent to the Park Mall shopping center in the south.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts related to public facilities and services. Since all housing sites are on sites already intended for development in the General Plan, the Housing Element update will not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services listed above (fire, police, schools, parks and others).

In addition, future development would pay generally applicable development impact fees and school fees to mitigate their proportional impacts on public infrastructure. Therefore, Housing Element Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities and there would be no impact.

NO IMPACT
16 Recreation
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project increase the use of existing
neighborhood and regional parks or other

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recreational facilities such that substantial
physical deterioration of the facility would
occur or be accelerated?
b) Does the project include recreational facilities
or require the construction or expansion of
recreational facilities which might have an
adverse physical effect on the environment?

PHYSICAL SETTING
City parks and school playfields provide active use areas and areas for passive enjoyment for Pacifica residents. Five categories are identified: district parks, neighborhood parks, pocket parks, special facilities, and school grounds. Pacifica's City parks and school grounds total approximately 242 acres, providing 6.3 acres per 1,000 Pacifica residents in 2020. City parks include five baseball fields and two soccer fields. School sites provide another 15 tennis courts, 10 baseball or softball fields, eight soccer fields, four football fields, three gyms, two full tracks, and two swimming pools. The Jean E. Brink Pool, located at Oceana High School, is home to the City of Pacifica’s aquatics program. Pacifica currently has 13 playgrounds within its district, neighborhood and pocket parks.

Regional parks and beaches in Pacifica total approximately 2,930 acres. Land is owned and managed by various agencies, including the National Park Service, the State of California, San Mateo County, the City and County of San Francisco, and the City of Pacifica. The City does not have permitting authority over park land owned by other public agencies.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts related to recreational facilities. Additionally, development proposals for individual projects would be subject to adopted parkland dedication requirements, or payment of fees in-lieu of parkland dedication, to ensure sufficient parkland remains available in Pacifica. Therefore, the Housing Element Update would not increase the use of existing recreational facilities or require the construction or expansion of recreational facilities. Thus, there would be no impact.

NO IMPACT
17 Transportation
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Conflict with a program plan, ordinance or
policy addressing the circulation system,
including transit, roadways, bicycle and
pedestrian facilities?

b) Would the project conflict or be inconsistent
with CEQA Guidelines Section 15064.3,
subdivision (b)?

c) Substantially increase hazards due to a
geometric design feature (E.g., sharp curves or
dangerous intersections) or incompatible uses
(e.g., farm equipment)?

d) Result in inadequate emergency access? 

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PHYSICAL SETTING
The City’s 2040 General Plan Circulation Element identifies future street and traffic improvements, and addresses walking, biking, transit, and parking, to enable a multi-modal circulation system.

The city is served by San Mateo Transit District (SamTrans). SamTrans provides local bus service in Pacifica, as well as service to and from BART and Caltrain stations. As of 2023, 11 SamTrans bus routes serve Pacifica.

In 2018, CEQA Guidelines Section 15064.3 was finalized to help determine the significance of transportation impacts. Beginning on July 1, 2020, level of service (roadway congestion) is no longer considered an acceptable metric for analyzing transportation impacts under CEQA.

Instead, jurisdictions must adopt vehicle miles traveled (VMT) thresholds to analyze impacts related to the number of automobile trips and miles traveled.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts related to consistency with adopted transportation and emergency evacuation plans, transportation facilities, safety, and VMT.

Individual projects would be required to adhere to Federal, State, and local policies and regulations including those in the General Plan, California Fire Code (to ensure sufficient emergency vehicle access), and the San Mateo County Congestion Management Program (CMP). The 2040 General Plan has specific policies that require new development comply with complete street concepts and emergency access on new roadways during the project development review process. In it anticipated that most of the development projected in the Housing Element update will be infill, and thus the 2040 General Plan contains policies to develop a plan to widen critical rights-of-way that do not currently provide adequate clearance for emergency vehicles. Future development proposals would be required to be reviewed for consistency with the City’s existing and planned circulation network; and ensure that the construction of new features would not impede emergency access.

Therefore, the Housing Element Update would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities; would not substantially increase hazards due to a geometric design feature or incompatible use; and result in inadequate emergency access.

NO IMPACT
18 Tribal Cultural Resources
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project cause a substantial adverse
change in the significance of a tribal cultural
resources, defined in Public Resource Code
Section 21074 as either a site, feature, place,
cultural landscape that is geographically
defined in terms of the size and scope of the
landscape, scared place, or object with cultural

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value to a California Native American tribe, and
that is:
i) Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in
Public Resource Code section
5020.1(k), or

ii) A resource determined by the lead
agency, in its discretion and supported
by substantial evidence, to be
significant pursuant to criteria set forth
in subdivision (c) of Public Resource
Code Section 5024.1. In applying the
criteria set forth in subdivision (c) of
Public Resource Code Section 5024.1,
the lead agency shall consider the
significance of the resource to a
California Native American tribe.

PHYSICAL SETTING
According to the California Historical Resources Information System, one formally recorded and one informally recorded Native American archaeological resource has been found in Pacifica.

The Sanchez Adobe’s State Historical Landmark and Point of Historical Interest is listed on the National Register of Historic Places and operated by the San Mateo County Parks Department as an historical site. The Sanchez Adobe Park, site of the Pruristac village and the San Pedro mission outpost, also is listed in the National Register of Historic Places and the California Register of Historical Resources.

Historic resources are standing structures of historic or aesthetic significance. Architectural sites dating from the Spanish Period (1529-1822) through the early years of the Depression (1929- 1930) are generally considered for protection if they are determined to be historically or architecturally significant. These may include missions, historic ranch lands, and structures from the Gold Rush and the region’s early industrial era. Post-Depression sites may also be considered for protection if they could gain historic significance in the future. Historic resources are often associated with archaeological deposits of the same age.

IMPACT ANALYSIS
The Housing Element Update does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle.

Because it is a policy document, the Housing Element Update would not result in impacts related tribal cultural resources. In addition, the Housing Element Update would not result in any impacts to the Sanchez Adobe site.

Therefore, the Housing Element Update would not have any impacts on tribal cultural resources.

NO IMPACT
19 Utilities and Services Systems
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Require or result in the relocation or
construction of new or expanded water,

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wastewater treatment or storm water drainage,
electric power, natural gas, or
telecommunications facilities, the construction
or relocation of which could cause significant
environmental effects?
b) Have sufficient water supplies available to
serve the project and reasonably foreseeable
future development during normal, dry and
multiple dry years?

c) Result in a determination by the waste water
treatment provider, which serves or may serve
the project that it has adequate capacity to
serve the project’s projected demand in addition
to the provider’s existing commitments?

d) Generate solid waste in excess of state or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the
attainment of solid waste reduction goals?

e) Comply with federal, state, and local
management and reduction statues and
regulations to solid waste?

PHYSICAL SETTING
This section evaluates potential effects on utilities that may occur during implementation of the Housing Element Update. Utilities and service systems consist of water supply and delivery, wastewater, storm drain facilities, and solid waste systems.

The North Coast County Water District (NCCWD), an independent water purveyor, supplies water to Pacifica and part of San Bruno. The district gets its water from the San Francisco Public Utilities Commission (SFPUC) through the Hetch Hetchy system. Pacifica’s water is pumped from San Andreas Lake and the Harry Tracy water Treatment Plant in Millbrae via a main distribution line.

The City operates a wastewater treatment plant, sewage lift stations, and stormwater pump stations, as well as the citywide system of sewer mains and lateral pipes that connect to homes and businesses. Wastewater flows through some 106 miles of main pipes to five sewer pump stations, and on to the Calera Creek Water Recycling Plant. The City’s topography prevents gravity flow to the plant, and requires pump stations at Rockaway Beach, Linda Mar and Sharp Park (two), and Skyridge.

Pacifica Gas and Electric (PG&E) provides gas and electric service to Pacifica homes and businesses. With energy obtained from power plants, natural gas fields, and renewable energy sources in northern California. Peninsula Clean Energy is an alternative renewable-energy electricity provider. Both providers offer clean energy options including significant shares greenhouse gas (GHG) emissions-free power generation.

Solid waste collection and recycling services in Pacifica are provided by Recology of the Coast, a division of Recology. Recology, based in San Francisco, operates a number of landfills, waste transfer and materials recovery facilities, including the recycling yard at 1046 Palmetto Avenue in Pacifica. Recology emphasizes waste reduction and diversion, and is the largest compost facility operator by volume in the United States. In Pacifica, Recology of the Coast currently provides curbside pick-up of garbage, recyclables, and green waste for both residential and commercial customers.

IMPACT ANALYSIS
The Housing Element Update is a policy document and as such does not propose specific development projects. Because it is a policy document, the Housing Element Update would not result in impacts related to utilities and services systems.

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Packet Pg. 1371 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 35
November 2023
Development facilitated by the Housing Element Update would be subject to all utility service standards set in the PMC and General Plan. Individual projects would also be individually reviewed to ensure adequate utility services would be provided to each site. A lack of existing utility facilities or low levels of service would result in potentially significant impacts through the expansion of those utilities. Future development facilitated under the Housing Element Update would be concentrated in urban areas that are served by existing utilities infrastructure, including potable water, wastewater, stormwater drainage, electrical power, natural gas, and telecommunications facilities. Impacts identified for an individual project would be addressed through the project approval process.

Development facilitated by the Housing Element Update would be subject to the provisions of Chapter 12 of Title 6 of the PMC “Storm Water Management and Discharge Control” and evaluated to determine adequacy of utility infrastructure as part of the standard city development review process and there would be no impact.

The City’s wastewater collection system is designed to serve the entire population of Pacifica. In 2021, the City prepared a Collection System Master Plan Update that evaluates the capacity of the existing sewer system and identifies sewer improvements that are necessary to achieve the required capacity. The report is also intended to create a long-range Capital Improvement Program (CIP) for the wastewater collection system. The collection and conveyance of wastewater generated by the Housing Element Update will use the existing sanitary and sewer system.

The Integrated Waste Management Act of 1989 requires that all jurisdictions meet a 50 percent waste reduction requirement. Since 2007, CalRecycle has been using a new system to measure diversion rates. This new system uses a per capita disposal threshold as one of several "factors" in determining a jurisdiction's compliance with diversion requirements.

Therefore, as a policy document, the Housing Element Update will not have any impacts on utilities and service systems and there is no impact.

NO IMPACTS
20 Wildfire
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?

b) Due to slope, prevailing winds, and other
factors, exacerbated wildlife risks, and thereby
expose project occupants to pollutant
concentrations from a wildfire or the
uncontrolled spread of wildfire?

c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines
or other utilities) that may exacerbate fire risk or
that may result in temporary or ongoing impacts
to the environment?

d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope

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Packet Pg. 1372 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 36
November 2023
instability, or drainage changes?

PHYSICAL SETTING
The California Department of Forestry and Fire Protection (CAL FIRE) has designated Fire Hazard Severity Zones (FHSZs) throughout the state based on factors such as fuel, terrain, and weather. FHSZ maps evaluate physical conditions that create a likelihood that an area will burn over a 30- to 50-year period. Areas are classified by varying degrees of fire hazard severity (i.e., moderate, high, and very high), referring to the ability of a fire in any given area to cause damage.

There are 470 acres along the southwestern perimeter within the Sphere of Influence are designated as Very High FHSZs (VHFHSZs). Most of the land within the VHFHSZs is an urban reserve or park, and land adjacent to these areas that is within city limits is low- and very-low density residential development. Per the 2021 MJ-LHMP, Pacifica had no population or structures within very high, high, or moderate wildland fire severity zones.

CAL FIRE also maps wildfire risk, or the probability of a fire occurring in a given area, throughout California. Areas of high fire risk can be found in Milagra Ridge, Sharp Park, the Quarry Area, Cattle Hill, the Pedro Point Headlands, and a large portion of Sweeney Ridge. Additionally, CAL FIRE designates land as either a Federal, State, or Local Responsibility Area (FRA, SRA, and LRA, respectively), based on population density, land use, and land ownership. All of the VHFHSZs within the Sphere of Influence are designated SRA, where the State of California is financially responsible for the prevention and suppression of wildfires, while the NCFA has primary responsibility for LRA within the City limits. Lands in Pacifica owned by the federal government and the County—GGNRA lands—are designated as a Federal Responsibility Area (FRA).

About two-thirds of Pacifica is undeveloped, and nearly half is protected open space. This undeveloped land is mainly on the rugged ridges that form the City’s eastern edge and descend down to the ocean between Pacifica’s valley communities. Coastal scrub is the predominant vegetation type, interspersed with annual grassland. Significant areas of eucalyptus forest and mixed woodland are present in eastern Sharp Park and on Cattle Hill and San Pedro Mountain.

IMPACT ANALYSIS
The Housing Element Update is a policy document and as such does not propose specific development projects, but facilitates housing needed to accommodate the current RHNA cycle.

The Housing Element Update anticipates that most of the new housing needed to accommodate the current RHNA cycle will be ADUs or new development on opportunity sites, all of which are infill sites immediately proximate to existing development.

There are no LRA FHSZs within the City of Pacifica. However, there are wildfire risk areas (SRA very high FHSZs) directly adjacent to the southern boundary of the city. Land adjacent to these areas that is within city limits is designated as Transitional Open Space Residential (TOSR) or other designations to ensure very low densities of residential development commensurate with the degree of fire hazard. Future development would be required to adhere to all policies, goals, and standards in the MJ-LHMP, Pacifica Municipal Code, and CBC, CFC, including vehicular access and emergency access. Implementation of General Plan policies will ensure that adequate emergency access is provided.

The Wildland-Urban Interface (WUI) of Pacifica allows residents to enjoy close contact with open ridges and woodlands, and in addition brings residents in close proximity to the risk of Wildland fires. As noted above, a portion of Pacifica’s Sphere of Influence is designated as VHFHSZ.

While the City does not have permitting authority in this area, the Housing Element Update has not identified opportunity sites in these areas. To address Wildland fire risk, the City cooperates with California Department Forestry and Fire Protection and the North County Fire Authority (NCFA) through cooperative fire protection agreements. The NCFA practices fire prevention activities, including its Vegetation Management Program. State and federal regulations, and City

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Packet Pg. 1373 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 37
November 2023
of Pacifica development standards play an important role in limiting potential fire hazards. Any new development in WUI areas would be required to conform to modern fire and building codes which significantly reduce the risk of a structural fire expanding into a wildland fire.

Smoke and air pollution, specifically particulate matter, from air pollution can be a health hazard, especially for sensitive populations such as children, the elderly, and people with respiratory illnesses. Pacifica lies within the jurisdiction of the Bay Area Air Quality Management District (BAAQMD), and policies in the Proposed Project promote continued compliance with BAAQMD air quality standards and guidelines. BAAQMD has developed a comprehensive Wildfire Response Program, which contains public resources designed to help the public prepare for and protect their health during wildfire events. Additionally, BAAQMD maintains regulations on wood burning in order to prevent wildfires and reduce air pollution from particulate matter.

While some areas of the City could be subject to risks associated with downstream flooding or landslides due to post-fire instability, future development would be required to adhere to all applicable regulations focused on both flooding and seismic safety, in addition to the fire safety regulations. Implementation of General Plan policies combined with the California Building Code standards and the building permit review of all new structures in the City, would ensure that there are no risks from downslope or downstream flooding or landslides.

Further, the Housing Element Update does not propose specific projects but puts forth goals and policies that regulate various aspects of new housing development in Pacifica. Because it is a policy document, the Housing Element Update would not have a significant impact on wildfire safety. Additionally, any potential impacts associated with rezoning will be analyzed during the zone change process. Therefore, there would be no impact.

NO IMPACT
21 Mandatory Findings of Significance
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the habitat of
a fish or wildlife species, cause a fish or wildlife
population to drop below self-sustaining levels,
threaten to eliminate a plant or animal
community, substantially reduce the number or
restrict the range of a rate or endangered plant
or animal or eliminate important example of the
major periods of California history or
prehistory?

b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effect of a project
are considerable when viewed in connection
with the effects of past projects, the effects of
other current projects, and the effects of
probably future projects.)

c) Does the project have environmental effects
which will cause substantial adverse effects on
human beings, either directly or indirectly?

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Packet Pg. 1374 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 38
November 2023

IMPACT ANALYSIS
The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that facilitate new housing development in Pacifica consistent with the current RHNA cycle. Because it is a policy document, the Housing Element Update would not have the potential to substantially degrade the quality of the environment. Adoption of the Housing Element Update would not have a substantial adverse effect, either directly or indirectly, on any species identified as a candidate, sensitive, or special status species. In addition, the Housing Element Update would not have a substantial adverse effect on any riparian habitat or sensitive natural community.

Therefore, the Housing Element Update would not substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory and no impacts would occur.

The Housing Element Update is a policy document, does not approve any development, and therefore would not have impacts that are individually limited but cumulatively considerable.

Based on the above, the Housing Element Update will result in no impacts on items identified in the Mandatory Findings of Significance.

NO IMPACT

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Packet Pg. 1375 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 39
November 2023
References
Association of Bay Area Governments (ABAG)
Bay Area Air Quality Management District (BAAQMD) 2017 Clean Air Plan Bay Area Air Quality Management District (BAAQMD) CEQA Air Quality Guidelines California Air Resources Board
California Department of Conservation (DOC), 2015
California Department of Finance, 2020
California Department of Toxic Substances Control (DTSC) California Division of Land Resource Protection, Farmland Mapping and Monitoring Program
California Energy Commission. 2015. http://www.ecdms.energy.ca.gov/. Accessed May 2021
California Geological Survey, 2002
California Historical Resources Information System (CHRIS), 2009 City of Pacifica, 2040 General Plan
City of Pacifica, Climate Action Plan, 2014
City of Pacifica, Draft Housing Element (2023-2031)
City of Pacifica, Draft Wastewater Facilities Plan, Revision 2, 1992.

City of Pacifica, Local Coastal Program
City of Pacifica, Municipal Code
Federal Emergency Management Agency. National Flood Hazard Layer for San Mateo County
Intergovernmental Panel on Climate Change (IPCC): Summary for Policymakers, 2018.

Accessed at
https://www.ipcc.ch/site/assets/uploads/sites/2/2019/05/SR15_SPM_version_report_L R.pdf, 2019.

North Coast County Water District (NCCWD). 20-year Master Plan. February 2016.

Accessed at http://www.nccwd.com, June 2021.

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Packet Pg. 1376 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) City of Pacifica Initial Study
Housing Element Update Page 40
November 2023
Pacific Gas & Electric (PG&E), 2018
Pacifica Municipal Code
Regional Housing Needs Allocation (RHNA) Projections
San Francisco International Airport Aircraft Noise and Flight Tracking. Accessed https://www.flysfo.com/community/noise/live-flighttracking in June 2021.

State of California Water Resources Control Board (SWRCB)

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Packet Pg. 1377 Attachment: Attachment H - Initial Study/Negative Declaration (IS/ND) (5559 : 2023-2031 Housing Element Update Adoption) From:

To: Harkousha, Brianne
Subject: Fwd: Notice of Intent to Adopt a Negative Declaration Date: Tuesday, November 21, 2023 12:09:27 PM
[CAUTION: External Email]
Hello Ms Brianne Harkousha,
How are you? Hope all is well.

I’m reaching out to you today regarding the email I received below. Based on this email, it appears the Housing Element Project Initial Study (IS) was approved to have no significant impact to the environment. If that is the case, pls see my questions below. 1). What was the criteria in getting approval on the Housing Element Project Initial Study (IS)? 2). Who ensured that the approver/s of the IS was unbiased? 3). Many of the East Sharp Neighbors have attended in person/virtual meetings as well as sent written statements over our concerns to proceed with building low income housing at Oceana High School. It appears our concerns have not been taken into consideration. At what point will our voices be heard?
Thx in advance for your response!
Happy Thanksgiving!
Best,
Angela Wilson
Begin forwarded message:

From: Pacifica Housing Element Updates <[email protected]> Date: November 17, 2023 at 9:05:21 AM PST
To: [email protected]
Subject: Notice of Intent to Adopt a Negative Declaration Reply-To: [email protected]

5.i
Packet Pg. 1378 Attachment: Attachment I - Public Comments on IS/ND (5559 : 2023-2031 Housing Element Update Adoption) From: Housing
To: Murdock, Christian; Harkousha, Brianne
Subject: FW: Housing at Oceana...

Date: Thursday, November 30, 2023 9:50:47 AM
Attachments: image001.png
image002.png
FYI – Public comment received re: Housing Element.

Thank you,
ELIZABETH BROOKS, MPA (she/her) | MANAGEMENT ANALYST II PLANNING DEPARTMENT | CITY MANAGER'S OFFICE
540 Crespi Drive, Pacifica, CA 94044
Phone: (650) 501-6025 | [email protected]
From:

Sent: Tuesday, November 28, 2023 9:28 PM
To: Housing <[email protected]>
Subject: Housing at Oceana...
[CAUTION: External Email]
To the Pacifica planning department and Mr. Christian Murdock. The community surrounding the Oceana High School has Scenic views of the Pacific Ocean. Nearly three quarters of the residences surrounding Oceana High school sometimes travel down Paloma Ave and when the community travels down Paloma Ave they have an unobstructed View of the Pacific Ocean. People of the community also walk down Paloma Ave and have a fantastic view of the Pacific Ocean. Many times people park and have their lunch (while in their vehicles)on Paloma Ave and gaze out onto the Pacific Ocean. Thus, I disagree that "no" scenic views will be compromised with building new housing on the Oceana High school site. Taking away this scenic view would have a significant negative effect on the environment of this neighborhood. Not only will the residences that have homes on Paloma Ave lose their views of the Pacific Ocean but also, the community as a whole who travel westward on Paloma Ave, daytime gazers who briefly park and have lunch, and lastly daytime walkers who frequently walk on Paloma Ave. These are facts.

Al Romero
Pacifica Ca.94044
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open attachments or reply.

5.i
Packet Pg. 1379 Attachment: Attachment I - Public Comments on IS/ND (5559 : 2023-2031 Housing Element Update Adoption) Pacifica City Council
1800 Francisco Boulevard
Pacifica, CA 94044
[email protected]
Date: December 13, 2023
From: Samuel Casillas, Pacifica,
Subject: Housing Element Update Project's Initial Study intent to prepare a Negative Declaration Dear City Council:

The City of Pacific’s Housing Element Update Project's Initial Study to prepare a Negative Declaration instead of conducting a full environmental Impact Report (EIR) is in violation of multiple CEQA regulations that the city must comply with in order to satisfy the multiple issues that will be generated by the addition of approximately 1800 new housing units. The proposed lack of an EIR and the negative declaration determination that no EIR is necessary is non-compliant. It does not properly address hazards, traffic mitigation and water delivery and water sanitation issues therefore violating CEQA. Since the city is adding approximately 1800 units, in its entirety at once, for the housing element it cannot defer CEQA reviews to a project-by-project basis.

Without addressing the impact of traffic mitigation (and the air pollution it will cause), the impact of wastewater treatment plant expansion, not utilizing the best available data to determine hazard zones including fire, landslides, flooding and drinking water availability along with biological resources for protected species makes this housing element dismissal of an EIR non-conforming and in violation of multiple CEQA regulations. The city also neglected to address any development water runoff that would occur from this amount of additional housing that would potentially be detrimental to adjacent protected waterways where protected species are present.

Thank you,
Samuel Casillas
Board member, PPCA
Past Vice-Chair, Pacifica Economic Development Committee Past Member, Pacifica Sea Level Rise Adaptation Planning Committee Past Co-Chair GGNRA Board Liaison Committee
Past Member, Pacifica GPU Community Outreach Committee

5.i
Packet Pg. 1380 Attachment: Attachment I - Public Comments on IS/ND (5559 : 2023-2031 Housing Element Update Adoption) 1 Murdock, Christian
From: Clif Lawrence
Sent: Saturday, December 16, 2023 10:18 AM
To: Public Comment
Cc: Clif Lawrence
Subject: Housing Element - Proposed Negative Declaration [CAUTION: External Email]

If you are looking for what could have a significant impact on our environment... I suggest you don't have to look further than that 2,000 new housing units would be nearly a 14% increase in the total housing of Pacifica.

Tell me that's not significant.

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

5.i
Packet Pg. 1381 Attachment: Attachment I - Public Comments on IS/ND (5559 : 2023-2031 Housing Element Update Adoption)

5.i
Packet Pg. 1382 Attachment: Attachment I - Public Comments on IS/ND (5559 : 2023-2031 Housing Element Update Adoption) 425 Market Street
Suite 2900
San Francisco, CA 94105
415.227.0900 Phone
415.227.0770 Fax
BN 80062504v1
December 18, 2023
VIA E-MAIL ([email protected])
Christian Murdock,
Planning Director
City of Pacifica
Planning Department
540 Crespi Drive
Pacifica, CA 94044
Re: Comments on the Draft Initial Study/Mitigated Negative Declaration for the Pacifica Housing Element Update – 2023-2031
Dear Christian:

Thank you for the opportunity to comment on the City of Pacifica Draft Initial Study/ Mitigated Negative Declaration for the Draft Housing Element Update – 2023-2031 released for public review and comment on November 16, 2023 (“Housing Element Update IS/MND”).

As you know, Buchalter, a Professional Corporation, represents Toll Brothers with its proposal to develop a residential townhome project on property located at 4625 Coast Highway in the City of Pacifica (the “City”) (APN: 022-150-440) (the “Sea Bowl Property”). Toll Brothers is proposing to demolish the existing Sea Bowl bowling alley and to develop the property with 79 townhome style units, 24 accessory dwelling units (“ADUs”), and 14 duet-style units, along with 186 resident parking spaces and 22 guest parking spaces (the “Project”). The 24 ADUs will be deed-restricted as rentals for lower income households. Toll Brothers filed with the City an SB 330 Preliminary Application for the Project on September 11, 2023 which the City is currently processing.

In prior drafts of the Housing Element Update, the City included the Sea Bowl Property in the sites inventory and then deleted it. As we have explained in our prior correspondence (see attached letters which are incorporated by this reference), State Planning and Zoning Law requires housing elements to provide an “inventory of land suitable and available for residential development” that have “realistic and demonstrated potential for redevelopment during the

5.i
Packet Pg. 1383 Attachment: Attachment I - Public Comments on IS/ND (5559 : 2023-2031 Housing Element Update Adoption) Christian Murdock,
December 18, 2023

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