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agenda-report Study session to respond to community and City Council questions regarding the California Coastal Commission staff’s March 2023 suggested modifications to the City of Pacifica’s Certification Draft Local Coastal Land Use Plan (LCLUP) and the City’s potential alternative modifications, including the Special Resiliency Area policies. Consider and provide direction on the potential alternative modifications.

Pacifica City Council
March 2, 2024

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agenda-report Study session to respond to community and City Council questions regarding the California Coastal Commission staff’s March 2023 suggested modifications to the City of Pacifica’s Certification Draft Local Coastal Land Use Plan (LCLUP) and the City’s potential alternative modifications, including the Special Resiliency Area policies. Consider and provide direction on the potential alternative modifications.
Meeting
March 2, 2024
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Pacifica City Council
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CITY OF PACIFICA

COUNCIL AGENDA SUMMARY REPORT
3/2/2024
1 SUBJECT:

Study session to respond to community and City Council questions regarding the California Coastal Commission staff’s March 2023 suggested modifications to the City of Pacifica’s Certification Draft Local Coastal Land Use Plan (LCLUP) and the City’s potential alternative modifications, including the Special Resiliency Area policies. Consider and provide direction on the potential alternative modifications.

RECOMMENDED ACTION:

Receive a presentation from staff, hold a question and answer session for staff to respond to community questions, and provide direction on potential alternative modifications to the Local Coastal Land Use Plan.

STAFF CONTACT:

Christian Murdock, AICP, Planning Director
(650) 738-7341
[email protected]
Stefanie Cervantes, AICP, Senior Planner
(650) 738-7341
[email protected]
INTRODUCTION:

The California Coastal Act requires every city along the coast to prepare a Local Coastal Program (LCP), which consists of two parts: a Local Coastal Land Use Plan (LCLUP) and an Implementation Plan (IP). The LCLUP must be consistent with the Coastal Act. The LCLUP must specify the intended uses of land within the Coastal Zone, and serves as a policy framework for future actions, such as development review and City infrastructure projects. The LCLUP must balance statewide interests for the Coastal Zone as expressed in the Coastal Act with local land use priorities. The LCLUP also guides the contents of the IP, which consists of the zoning ordinance, zoning map, and other policies and programs to implement the LCLUP.

While the LCLUP is separate from the General Plan, much of the descriptive text and policies overlap between both documents due to their similar purposes of specifying land uses, establishing goals and policies, and providing a policy framework for future actions. There are many benefits to having an updated LCLUP, including updated maps, modernized policies to guide development, enhanced environmental protections, strengthened economic development and housing policies, and consistency with the City’s 2040 General Plan.

EXECUTIVE SUMMARY
This study session is intended to: (1) provide a clear understanding of the implications of the California Coastal Commission (CCC) staff’s March 2023 suggested modifications; (2) identify ways to potentially alter those modifications; and (3) receive feedback and submit a proposal of alternative modifications to the CCC. This report and attachments contain a considerable amount of information on the LCLUP Update process, CCC suggested modifications, draft alternative modifications prepared by City staff for consideration, and background information Pacifica City Council 2
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the Community Engagement Plan utilized throughout this process. In order to better explain the potential impacts of the CCC staff’s March 2023 suggested modification, staff has prepared case studies (Attachment B) that demonstrate how common scenarios would be implemented under the different policy documents (City’s existing 1980 LCLUP, the new LCLUP as modified by CCC Suggested Modifications, and new LCLUP as further modified by City alternative modifications). The report contains all the proposed City alternative modifications: Attachment C is a Summary Table, similar to the table attached in previous LCLUP reports, that contains the original 2020 LCLUP, CCC Suggested Modification, and the proposed City alternative modification, as well as a brief summary and/or explanation as to why the City is or is not proposing an alternative modification. The text changes can also be seen in a fuller context in Attachment F City’s Draft Certification LCLUP with CCC suggested modification and alternative modifications. Staff has also provided answers to the questions submitted by the public from the December 5th, 2024 study session and the more recent question submission opportunity.

The study session will allow staff to explain in greater detail many of the public and Council questions. Both the public and Council will have the opportunity to ask additional questions at this meeting. The study session will also give Council the opportunity to begin discussion on the City alternative modifications.

BACKGROUND/DISCUSSION:

In February 2020, City Council approved the Certification Draft Local Coastal Land Use Plan (“2020 LCLUP”), and directed the City Manager to transmit it to the California Coastal Commission (CCC) for certification. Additional background information, including the 2020 LCLUP document (also known as the “Certification Draft LCLUP”), are available on the Project Documents page of the Plan Pacifica website1.

Staff submitted the 2020 LCLUP to the CCC in June 2020. Between the years of 2020-2022, City and CCC staffs exchanged several rounds of information in response to CCC staff requests. The information requested by CCC staff was required to address that agency’s administrative filing requirements before the City’s application could advance to a point where CCC staff could provide formal substantive comments on policy provisions related to certification. In August 2022, the CCC finally accepted the 2020 LCLUP for filing. On December 16, 2022, the CCC took action to extend the deadline by one year, as authorized by Public Resources Code section 30517. The CCC’s action extended the deadline to December 22, 2023.

In late February 2023, the City received notice the CCC would consider the City’s Certification Draft LCLUP at the March 8, 2023, CCC meeting. The CCC staff report for the item included CCC staff’s final recommendation, which included many suggested modifications to the City’s submittal (“CCC Suggested Modifications”) 2. The City requested a continuance of the March 8th hearing date to allow an opportunity to review and consider the CCC staff’s recommendations.

Since March, City staff has met multiple times with CCC staff to gain a better understanding of the suggested modifications in order to develop a comprehensive analysis and explore potential revisions for future City Council consideration. On October 9, 2023, the Council approved the revision of the existing Certification Draft LCLUP to incorporate the 2040 General Plan and transmitting the Revised Certification Draft LCLUP to the CCC to, in part, allow more time to analyze and respond to the March 8, 2023 CCC staff suggested modifications and eliminating the December 22, 2023 deadline.

1. Community Engagement Plan
1 Available at https://www.planpacifica.org/project-docs. 2 Available at https://cityofpacifica.egnyte.com/dl/DpPxoDE8q3, with City-added numbering for identification.

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On October 9, 2023, the City Council also approved a three-meeting community engagement plan to update the public on where the LCLUP update process stood, and to discuss where it should go next. Additional information on the City’s work to update the LCLUP component of the City’s LCP, which started in 2009, is available in the City Council agenda reports for the City Council meetings on October 9, 2023 (Agenda Item No. 10), November 13, 2023 (Agenda Item No. 1), and December 5, 2023 (Agenda Item No. 1).

Following the December 5 community meeting that the Council had approved in the initial threemeeting community engagement plan (Meeting #2), on January 8, 2024, the Council directed a revision to the community engagement plan to include a revised Meeting #3 format and purpose, effectively creating a four-meeting community engagement plan (“Revised Community Engagement Plan”), with the possibility of a fifth meeting depending on the outcome of the third and fourth meetings. The Revised Community Engagement Plan is outlined below:
• Meeting #1: City Council Study Session
o Purpose: Study session to present and discuss the CCC staff suggested modifications from March 8, 2023.
o Timing: November 13, 2023
• Meeting #2: Community Roundtable Discussions
o Purpose: Provide a staff presentation followed by a community roundtable discussion of potential alternative modifications to those presented by CCC staff for the March 8, 2023 CCC meeting, based on discussions between City and CCC staffs that started in June 2023.
o Facilitation: Due to the complexity of the subject matter discussed at this community meeting, a professional facilitation service facilitated the roundtable conversations. City staff notetakers supplemented the facilitators to ensure comprehensive collection of community input.
o Timing: December 5, 2023
• Revised Meeting #3: Question and Answer Study Session o Purpose: Study session to respond to community and City Council questions.

Provide opportunity for public submission of questions to be answered in advance of the meeting, with an additional question-and-answer opportunity for the public at the meeting. City Council discussion and direction on all potential alternative modifications recommended by City staff.
o Timing: March 2, 2024
• Revised Meeting #4: City Council Consideration of a Comment Letter to CCC o Purpose: City Council consideration item to discuss a potential comment letter from the City requesting revisions to the CCC staff's March 2023 suggested modifications. Transmittal of this comment letter would need to be sufficiently in advance of a CCC certification hearing on the Revised Certification Draft LCLUP to allow time for CCC staff to analyze the City’s requests and publish a staff recommendation. Staff recommends transmitting the comment letter at least two months, but ideally three months, prior to a desired CCC certification hearing. o Timing: Currently anticipated in late-March/early-April 2024 (previously anticipated mid- to late-January 2024)
This community engagement process is intended to conclude the comprehensive LCLUP update process that started nearly 15 years ago. It involves concluding the LCLUP update Pacifica City Council 4
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process based on the structure and policy emphasis approved by the City Council in the 2020 LCLUP, with consideration of potential modifications to certain policies as an alternative to the CCC staff’s suggested modifications from March 2023. This process is not a reconsideration of the structure and policy emphasis that was approved in the 2020 LCLUP (and continued in the Revised LCLUP). The purpose of this process is to bring the Council and community to a point where a decision is made on whether to submit a comment letter to the CCC in response to CCC staff’s comments from March 2023. This is a necessary step to conclude the comprehensive LCLUP update process that was started in 2009 and most recently approved by City Council in February 2020 and revised to incorporate conforming General Plan amendments in October 2023. Consideration of a comment letter to propose alternative modifications to the CCC that may be acceptable to the CCC and the City Council is the best and most expedient way for the City to seek CCC certification of the Revised LCLUP in a form that the City Council may be likely to adopt following CCC action.

2. Prior Meeting Summaries
Meeting #1 Summary: Discussion of California Coastal Commission Staff’s Suggested Modifications (March 2023)
The November 13, 2023 study session staff report contains a summary of key suggested modifications, as well as attachments including a summary table with all CCC Suggested Modifications, the City’s 2020 LCLUP text (the meeting was conducted before City transmittal of the Revised LCLUP to the CCC), and a brief summary of each modification. Staff presented the key suggested modifications to provide additional information and context, responded to Council questions, and also provided information about other suggested modifications not included in the initial summary of key suggested modifications (meeting video).

The design of Meeting #1 was intended to provide information to aid understanding of the CCC Suggested Modifications and their relevance to Pacifica.

Meeting #2 Summary: Potential Alternative Modifications The December 5, 2023 study session staff report introduced key potential alternative modifications identified by staff as a way to resolve one of the major points of disagreement between the City and CCC: how to regulate development within existing densely developed neighborhoods near the shoreline, especially those located behind existing shoreline protection (e.g., seawalls). Staff had identified resolution of this issue as essential to addressing near- and mid-term adaptation challenges and progress towards LCLUP certification.

The alternative modifications identified by staff in relation to this issue were termed “Special Resiliency Areas,” or SRAs, which would consist of a subset of Pacifica wherein development would be authorized in reliance on existing shoreline protection subject to specific requirements.

Both City and CCC staff focused SRA discussions on the Rockaway Beach and West Sharp Park coastal neighborhoods which would be most significantly impacted if the CCC Suggested Modifications were to take effect citywide. Reasons for focusing on these two neighborhoods include, but are not limited to:
(1) the density and prevalence of existing development including high proportions of preCoastal Act development; (2) concentration of essential Coastal Act-supported land uses; (3) presence of critical public rights-of-way and infrastructure; and, (4) existence of broad shoreline protection benefitting multiple public and private Pacifica City Council 5
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landowners which complicates potential future removal.

Meeting #2 was structured to provide an initial informational presentation on the SRA concept and then to allow in-depth community member discussions in small groups to provide reactions to the concept. Main takeaways from Meeting #2 included an overall community expression of a lack of understanding of the key aspects of the SRA concept, potential concern about some of the requirements of the SRA concept, and a need to better understand how individual properties would be affected by the SRA concept if implemented. A summary of community feedback from Meeting #2 is included as Attachment A3.

3. Revised Meeting #3: Question and Answer Study Session Both the Council and community have indicated at Meeting #1 and Meeting #2 the need for more information and a better understanding about the status of the LCLUP Update overall, and more specifically about what potential alternative modifications staff is recommending and the reasons for and implications of these potential alternative modifications. The goal of Meeting #3 is to provide this information in a comprehensive fashion while answering specific Council and community questions. To achieve this goal, the remainder of the staff report will focus on the following elements:
• The context of the LCLUP Update
• Case studies demonstrating application of LCLUP policies under various scenarios • Answers to questions received from the community
A. Context of the LCLUP Update
The City’s LCLUP currently in effect was last comprehensively updated in 1980 (“1980 LCLUP”). The City’s effort to update the LCLUP started in 2009, concurrent with an update to the General Plan. The City Council adopted the 2020 LCLUP in February 2020 and has worked since then to achieve CCC certification. The City Council adopted the General Plan Update in July 2022. However, within the Coastal Zone, provisions of the General Plan that are in conflict with the 1980 LCLUP are not yet effective and will only take effect upon certification of those corresponding provisions within the 2020 LCLUP.

Certification of the 2020 LCLUP is necessary before it may take effect. In other words, both the City and CCC must agree on the contents of the LCLUP, which will require achieving a shared vision and compromising on areas of disagreement. Until certification is achieved, the City will continue to operate under the 1980 LCLUP.

Through staff’s recent work on the LCLUP Update including the recent community engagement process, a key question has emerged that staff believes captures community sentiment:

Is it in the City’s best interest to update the LCLUP at this time? Staff’s assessment is that the 1980 LCLUP is not adequate to continue guiding the City’s actions in the Coastal Zone on a long-term basis. Many objectives of the 1980 LCLUP have been accomplished, such as protection of key beach and open space areas and formalization of public coastal access, while its assessments of some coastal neighborhoods are no longer 3 At the December 5, 2023 study session, participants were asked by table facilitators to indicate if they agreed with statements made by other participants. Based on the notes gathered from each table it was unclear if a vote was taken on certain items, which has resulted in some summary notes showing “?”.

Staff has counted feedback from those items one vote in the total votes for each category.

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reflective of the challenges and needs of those areas. Moreover, the 1980 LCLUP does not do enough to help Pacifica plan for the future. The plan is over 40 years old, and as explained in this staff report and elsewhere, there are many benefits to having an updated LCLUP focused on the next 20+ years. These include updated maps reflecting conditions in Pacifica, modernized policies to guide development, enhanced environmental protections, strengthened economic development and housing policies, and consistency with the City’s 2040 General Plan. Importantly, the 1980 LCLUP does not effectively identify climate change and sea level rise (SLR) as major issues that need to be addressed.

There is a pressing need to update the LCLUP at this time. Indeed, the City Council has recognized since at least 2009 that an update was needed, and started the process at that time.

Yet, despite 15 years with various starts and stops in the process, the update is not yet completed. As more time passes, the need for an update continues to grow, and the problems the LCLUP seeks to address will only become more complex.

Recent community planning efforts have identified the need for action by the City on numerous fronts, including the following:
• The General Plan Update identified a community desire for in-fill, mixed-use development, preservation of open spaces, enhancement of parks and other community facilities, and improved planning to address hazard mitigation and evacuation from wildfires and other events, among other priorities. • The Housing Element Update demonstrated the need to plan for more than 2,000 housing units, while undertaking other supporting actions to accelerate housing approvals and provide services for the neediest members of our community. • The Economic Opportunities Study identified ways for the City to strengthen its fiscal position so it can continue to provide high-quality services, infrastructure, and facilities to meet community needs.

The priorities identified above cannot meaningfully move forward in the Coastal Zone while limited by the 1980 LCLUP. An updated LCLUP is needed to address these emerging community priorities while also addressing issues that are all the more pressing in the Coastal Zone such as climate change and SLR adaptation. While significant City staff resources continue to be absorbed by the LCLUP Update process, work on those other community priorities cannot proceed effectively. Housing Element implementation, pursuing economic development initiatives, planning for City infrastructure and facilities, etc., can all advance much more efficiently once an updated LCLUP is in place. Completion of the LCLUP Update is also needed before staff can focus on pursuing CCC certification of the Sharp Park Specific Plan, which combined with redevelopment of 2212 Beach Boulevard (a major economic opportunity site for the City) will provide a major boost to the Palmetto Avenue commercial corridor and enhance the City as a visitor destination.

There is an urgency to act and complete the LCLUP Update process. Over time, inconsistencies with the 2040 General Plan will become increasingly difficult to manage. This will be especially so in the realm of development review, which will affect not only private development but also City efforts to pursue economic development initiatives and major facilities improvements important to the community, including but not limited to a new library in Sharp Park.

There is understandably much community concern, especially among property owners, about the effect the LCLUP Update may have on their properties. Many property owners are concerned that the LCLUP Update will unduly restrict development of their properties.

However, for much of the Coastal Zone, the most restrictive versions of these policies are Pacifica City Council 7
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already in effect. Areas within 300 feet of the mean high tide line or the first public road parallel to the shoreline, whichever is greater, are in an area known as the “Appeal Jurisdiction,” meaning City-issued coastal development permits are subject to appeal to the CCC. This encompasses much of Pacifica’s Coastal Zone and the vast majority of the areas that would be subject to policies addressing SLR, coastal erosion, and other coastal hazards. These permits frequently are appealed to the CCC, meaning that agency takes final action on many projects in Pacifica. In the absence of a certified LCLUP regulating development with policies that take into account currently known hazards (SLR and coastal erosion among them), the CCC is free to impose its highly restrictive versions of policies regulating development in hazard areas. A certified LCLUP Update, potentially with policies such as those intended for the SRAs, would likely help ease the most restrictive policies the CCC would otherwise seek to impose on development.

Lastly, an update to Pacifica’s LCLUP to account for SLR is inevitable. State law, as enacted in late 2023 with Senate Bill (SB) 272, now requires LCLUPs throughout California to be updated to include a plan to address SLR. Plans to address SLR must (1) Use of the best available science;
(2) Include a vulnerability assessment that includes efforts to ensure equity for at-risk communities;
(3) Include SLR adaptation strategies and recommended projects; (4) Identify lead planning and implementation agencies; and (5) Identify a timeline for updates, as needed, based on conditions and projections and as determined by the local government in agreement with the CCC.

These updates are required no later than January 1, 2034. The 2020 LCLUP has largely addressed these requirements already. Further delay of the LCLUP Update will only constrain Pacifica’s timeline for adoption by the SB 272 deadline in the future, and would deprive Pacifica of as much as a decade of the various benefits to LCLUP adoption that have been previously discussed if adoption were to occur closer to the deadline.

Based on this context, staff’s assessment is that completion of the LCLUP Update as expeditiously as possible and consistent with the 2040 General Plan is in the City’s best interest.

B. Case Studies
The LCLUP Update process involves significant policy, technical, and legal complexity. As a result, the Council and community have both understandably expressed a desire for better explanations of the plan’s contents and descriptions of how those contents would affect individual properties and Pacifica more broadly. In order to help the Council and community better understand these issues, staff has prepared a series of case studies describing specific scenarios that could result from application of different potential policies in the Coastal Zone (Attachment B). Each case study includes an analysis of the scenario under the City’s 1980 LCLUP, the City’s 2020 LCLUP with CCC suggested modifications, and the City staff’s alternative modifications to be considered by City Council. Under the City’s 2020 LCLUP with CCC suggested modifications, the case studies discuss how the policies affect the Coastal Vulnerability Zone (CVZ) area and the area outside the CVZ. Under the staff-identified alternative modifications, the analysis includes how the policies would be implemented in the Special Resiliency Areas (SRAs) and outside the SRAs. The case studies include the following scenarios:
• Case Study #1: Basic residential maintenance, including a reroof, new windows, and/or new siding;
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• Case Study #2: Residential addition that does not meet the definition of Substantial Structural Modification (SSM);
• Case Study #3: Residential addition that meets the definition of SSM or new development;
• Case Study #4: Development on parcels with no sensitive environmental resources, such as habitat or animal species;
• Case Study #5: Development on parcels with or adjacent to sensitive environmental resources, such as habitat, animals, and/or creeks;
• Case Study #6: New and/or substantial replacement of shoreline protection structures; • Case Study #7: New and/or replacement of City infrastructure or services, such as a new pump station or bike lanes;
• Case Study #8: Residential rebuild after substantial structural damage caused by a noncoastal hazard, such as fire or earthquake; and
• Case Study #9: Residential rebuild after substantial structural damage caused by a repetitive coastal hazard, such as wave overtopping.

The analysis shows that the approval process and requirements for some of these scenarios differs by project type, scale, and location between the three comparison LCLUPs. Notably, however, Case Study #1 involving basic residential maintenance, including a reroof, new windows, and/or new siding, the analysis demonstrates that basic maintenance will continue to be allowed with a building permit.

Beyond Case Study #1, the case studies demonstrate potentially drastic differences between application of the policies in the various comparison LCLUPs. However, these differences may not be what they seem at first review, and do not necessarily reflect differences in policy preferences between the City and CCC that are subject to discussion and compromise. In key instances the differences stem in part from deviations between the policies outlined in the 1980 LCLUP and the current requirements of the Coastal Act, including the CCC’s interpretations of the Coastal Act. Thus, these differences result to some extent from the age of the 1980 LCLUP itself, and how the legal and policy context has changed over four decades, rather than active disagreements between the City and CCC over policies that are subject to negotiation. The reality is that much has changed in the more than 40 years since the 1980 LCLUP was certified, including our understanding of coastal hazards and reasonable actions to mitigate them, and many updates are needed to bring the City’s LCLUP into compliance with the Coastal Act and associated CCC interpretations.

Similarly, some changes are needed with certain provisions of the City’s 2020 LCLUP as it was submitted to the CCC. For instance, that document contained policies related to technical analysis of hazards, designed to determine areas that may be developed without reliance on shoreline protection (a Coastal Act requirement), that applied only to properties with direct shoreline frontage. The CCC suggested modifications expand these policies to be applied to the CVZ, which consists of areas mapped with known coastal hazards. While this will affect properties beyond the immediate shoreline, the CCC’s approach in the suggested modifications is more closely in line with Coastal Act requirements than the City’s initial approach.

Importantly, the potential alternative modifications to be considered would include the SRAs, which would allow the West Sharp Park and Rockway Beach neighborhoods flexibility to deviate from the most restrictive hazard analysis policies resulting from the LCLUP Update and generally would increase the development potential of properties in those neighborhoods.

These two neighborhoods have existing shoreline protection structures that provide coastal hazards protections for private and public development, and individual property owners cannot control the presence of the shoreline protection structures in those areas which are likely to remain present over the long-term given their primary purposes to protect public infrastructure.

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The case studies demonstrate that the City’s alternative modifications would allow development in the SRAs to use the existing shoreline protection structures in their analysis and design, potentially demonstrating less risk from certain coastal hazards and greater ability to site and design development to address coastal hazards.

Revisions to Special Resiliency Areas Policies
The SRA concept originated from the CCC’s work with local governments across the state. In order to achieve certification of the LCLUP, City staff and CCC staff have discussed the application of this key policy framework for Pacifica. The purpose of the SRA policies is to ensure ongoing economic use and vitality of property, provision of public services, operation of visitor-serving uses, and protection of broad coastal access. The SRAs would continue to rely on existing shoreline protection, while also requiring implementation of adaptation measures to be incorporated into development.

At the Community Roundtable Discussions during Meeting #2 on December 5, 2023, staff presented the SRA policies and associated maps to the community for the first time. While many community members expressed confusion on the concept, the City also received community feedback on the SRAs that was supportive, and other feedback that will allow for better description and implementation of the SRA policies. Additionally, City staff also met with CCC staff to further discuss adjustments to the SRA and exhibits that will allow the CCC to certify the LCLUP. During the discussion, CCC staff provide more insight that has been incorporated into the City’s alternative modifications in this report, as demonstrated in Attachments C, D (map), and E (map). The CCC staff suggestions included eliminating the proposed separate policies and instead incorporating the language to the existing policies, removing the waiver allowances from the SRA policies (and incorporating them into the Zoning Ordinance instead), renaming the “Visitor Amenity Improvements” policy to “Shoreline Management Plan,” and making the SRA linear along the length of shoreline protection devices.

Staff has identified in the case studies where the SRA policies would provide benefits to properties located there.

Overall, staff believes the revisions will make the SRA policies simpler to understand and easier to implement. One way staff has done this is to incorporate the SRA provisions into the existing policies, instead of creating new policies as previously proposed. This will help to demonstrate more directly where the SRA provisions would allow a deviation from a generally applicable policy. Additionally, the map figures have been updated to include just the existing shoreline protection structures in the West Sharp Park and Rockaway Beach neighborhoods. This will allow City staff to identify the areas protected by the SRA/existing shoreline protection structures more easily. Importantly, the underlying focus of the SRA policies would remain unchanged: to allow properties in the SRA areas to demonstrate reliance on existing shoreline protection structures when siting and designing development, a major difference between the generally applicable policies for other areas outside the SRAs. As demonstrated in the case studies, this is a major benefit for these properties as it will allow development to include the protections from coastal hazards that the existing shoreline protection structures provide. While development will still need to conduct technical reporting and analysis, the shoreline protection structures provide additional protections from coastal hazards and will thus allow more flexibility with siting and design, as the coastal hazards will be minimized compared to if the technical reporting was required to assume there was no existing shoreline protection structures. The SRAs also allow the City to continue to prioritize coastal access, visitor amenities, and City infrastructure in these areas.

The revised SRA language is incorporated into Chapter 6 of the LCP document and included in the Summary Table, as Modification Number 6.14, 6.15, 6.42, 6.44, and 6.46.

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Alternative Modifications
The SRA policies described above are among the most significant potential alternative modifications the City Council will consider. However, a number of other potential alternative modifications warrant discussion even though staff’s assessment is that a majority of the CCC suggested modifications are minor in nature and could be accepted as-is. The City staff’s alternative modifications range from minor to address typographical errors to clarifying text, to more significant modifications that affect application and implementation of policies that are more substantial in nature. All of the City staff’s proposed alternative modifications can be found in Attachments C and F.

Attachment F contains three rounds of revisions from the City’s 2020 LCLUP. The first is redline edits that were approved by City Council in October 2023 to incorporate changes that were made when the City adopted the 2040 General Plan. Then there is black text that is strikethrough or underlined, which indicates the CCC staff suggested modifications that were published for the March 8, 2023 CCC hearing. The third set of revisions are in green, these are the City staff proposed alternative modifications that coordinate with the Summary Table, Attachment C.

C. Frequently Asked Questions
During the December 5th Community Roundtable Discussion, staff received several questions related to the LCLUP and SRAs. Additionally, the City had an open period, from February 2nd to February 16th, where the public could submit questions online, by email, by phone, or in-person.

Responses to submitted questions can be found in Attachment G.

4. Future Meetings
This meeting is the third of four community engagement meetings planned to determine the City’s next steps in the LCLUP Update process. The next meeting, Revised Meeting #4, is planned as a City Council consideration item to discuss and approve submission of a comment letter from the City to the CCC requesting revisions to the CCC Suggested Modifications. The meeting is tentatively scheduled for late-March/early-April 2024. Revised Meeting #4 will consider whether to send a comment letter to the CCC addressing the full range of alternative modifications the City Council could consider requesting, as discussed above and provided in Attachment H. As stated above, on January 8, 2024, City Council approved a modification to the Community Engagement Plan to include a fourth meeting, with the possibility of a fifth meeting depending on the outcome of the third and fourth meetings. Any future changes to the Community Engagement Plan will be discussed at Meeting #4.

As staff noted during the November 13, 2023 study session, many of the other CCC suggested modifications not highlighted during the study session are minor in nature, either deleting or adding a word or phrase. However, staff values public input identifying any suggested modifications proposed by CCC staff with thoughts on how the City may propose alternative modifications. Any public comments received on alternative modifications will be considered by staff and presented to the City Council during Revised Meeting #3.

ALTERNATIVE ACTION:

No alternative action has been identified.

RELATION TO CITY COUNCIL GOALS AND WORK PLAN:

The Local Coastal Land Use Plan Update is consistent with the following item(s) in the Counciladopted Strategic Plan and Priority Work Plan for FY 2023-24:

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• Goal 4: Pursue climate change adaptation and mitigation. o Strategy C: Update Pacifica’s Local Coastal Plan and improve communications and collaboration with the California Coastal Commission.

FISCAL IMPACT:

There is no direct fiscal impact from this item.

ORIGINATED BY:

Planning Department
ATTACHMENT LIST:

Attachment A December 5th 2023 Report (PDF)
Attachment B Case Studies (PDF)
Attachment C Summary Table with CCC Suggested Modifications and Alternative Modifications (PDF)
Attachment D Rockaway Beach Map(PDF)
Attachment E West Sharp Park Map (PDF)
Attachment F LCP Redlined Doc (PDF)
Attachment G LCLUP FAQs (DOCX)
Attachment H DRAFT Letter - Revised Certification Alternative Mods Request (DOCX)

← All documents from this meeting