Attachment C Summary Table with CCC Suggested Modifications and Alternative Modifications

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 2 2.1 Parks and
Open Space
Sandy beach areas; including properties that are fully on beaches or coastal dunes or bluffs;
N/A CCC suggested modification adds new text
2 2.2 Coastal
Development
Review
These exemptions are generally set forth in
Section 30610 of the PRC and Sections 13252,
13252, and 13250 of the California Code of
Regulations (CCR)
These exemptions are generally set forth in Section
30610 of the PRC and Sections 13252, 13253, and
13250 of the California Code of Regulations (CCR).

N/A CCC suggested modification addresses a typo
with the code sections
2 2.3 LD-I-2 Designed to minimize impacts to public access, recreation, and coastal resources.

Designed to minimize impacts to public access,
recreation, and other coastal resources.

N/A CCC suggested modification adds the word
“other”
2 2.3 LD-I-2: Land
Divisions in
the Coastal
Zone
N/A Prohibited on properties that are within Coastal
Vulnerability Zones, unless the resulting parcels are
set aside for conservation, or unless the resulting
parcels can be developed consistent with the LCP.

N/A CCC suggested modification restates Coastal
Act prohibition on intensifying land
use/subdividing land in hazard areas.
2 2.4 LD-I-3:

Coastal
Development
Permit
Findings
N/A In advance of updating the Implementation Plan for
conformance with the policies of this 2023 Land
Use Plan, the policies of the Land Use Plan shall
provide the standard of review for any proposed
new development, including where these policies
are more protective of ESHA and other coastal
resources and maximizing public access as
consistent with the Coastal Act.

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

Any development of the Quarry site will require
detailed evaluation of biological resources to
ensure that sensitive habitat and wetlands are
protected; and should be sited and designed to
minimize coastal hazard risks in accordance with
policies in Chapter 5 and 6 of the LUP. The likely
footprint of development could be much smaller
than the area designated.

N/A CCC suggested modification restates coastal
development requirements related to hazards
and refers to the relevant Chapters 5 and 6 of
the LCLUP.
2 2.6 LD-I-14:

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

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

Non-permanent improvements shall not require
additional analysis.

CCC suggested modification clarifies the policy
related to the Beach Boulevard Promenade.

City staff is generally in support of the
suggested modification; however, City staff is
proposing an alternative modification to clarify
that non-permanent improvements, such as
bench and trash receptacles, do not require
additional analysis. This will help to streamline
any such improvements in the future.
2 2.6 LD-I-14:

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

Appropriate uses could include a hotel or
conventional commercial/residential mixed-use
project with cafes, restaurants, retail, and upperlevel housing, if such uses are deemed appropriate considering coastal hazards and the required
protections for coastal resources. The mix of uses
for any proposal shall emphasize uses that are of
N/A CCC suggested modification eliminates hotel as
preferred use, but continues to allow a hotel on
the site
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification interest to visitors and that generate revenues for
the City.
2 2.7 LD-I-16:

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

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

N/A CCC suggested modification restates coastal
development requirements related to hazards
and biological resources protections.
2 2.7 LD-I-16:

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

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

N/A CCC suggested modification revised City
revenues to community benefits.
2 2.8 LD-I-20:

Undeveloped
San Pedro
Avenue Site
Establish a Coastal Residential Mixed Use zoning
district to allow small-scale visitor-oriented
commercial uses as a stand-alone project without
any residential development, or small-scale visitororiented commercial uses with residential development at a density range of three to five
units per gross acre. Housing may be clustered,
and uses may be mixed vertically or horizontally.

Residential uses may be constructed attached to
or detached from commercial uses, provided the
overall site contains both commercial and
residential uses.

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

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

CCC suggested modification increases the
density allowances. After clarification from CCC
staff, that was not the intent of the revision.

City staff is proposing an alternative
modification that achieves the same previously
approved lower density range by using
different terms that are preferrable to the CCC
staff.

2.8 LD-I-20:

Undeveloped
San Pedro
Avenue Site
Development must include public coastal access
and must provide public open space.

Development must include public coastal access,
provide public open space, and consider all
biological constraints.

N/A CCC suggested modification clarifies
requirements for development of this site.
2 2.9 LD-I-26:

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

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

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

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

N/A CCC suggested modification fixes a typo.
2 2.11 LD-I-27:

Public
Service
Priorities
Ensure that needs generated by development or
uses permitted over the planning period are
adequately served by existing and planned public
works facilities.

Ensure that needs generated by development or
uses permitted over the planning period are
adequately served by existing and planned public
works facilities, and plan for the maintenance,
operation, expansion and improvement to public
facilities considering threats from coastal hazards.

Support studies that evaluate the condition of
critical facilities, especially public works
infrastructure that has been identified as
N/A CCC suggested modification requires analysis of
alternatives for potential retrofit or relocation
but does not mandate relocation.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification vulnerable to hazards. Studies shall include
alternatives analyses for potential retrofit,
improvements, relocation, or other considerations.
2 2.12 LD-I-37:

Public
Services for
New
Development
s
N/A Public Services for New Development.

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

Public Services for New Development. Avoid locating
new or expanded public service facilities in the
Coastal Vulnerability Zone. If no feasible alternative
exists and a new or expanded public service facility
must be located within the Coastal Vulnerability
Zone, development shall be consistent with this LCP
and the Coastal Act.

CCC suggested modification may impact
infrastructure within the Coastal Zone that
serves areas outside the Coastal Zone. City staff
alternative modification allows new or
expanded public services within the CVZ only if
no other location can be accommodated.

Additionally, new or expanded public services
within the CVZ must design in compliance with
other LCP policies, such as designing for
adaptation, and the Coastal Act.
3 3.1 Coastal
Access Points
Maintain public parking as part of redevelopment
of City-owned 2212 Beach Boulevard property.

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

N/A CCC suggested modification adds requirement
for lateral access, which is a requirement under
the Coastal Act
3 3.2 Coastal
Access Points
N/A Conduct a prescriptive rights study. N/A CCC suggested modification requires additional study
3 3.2 Coastal
Access Points
N/A Conduct a prescriptive rights study. N/A CCC suggested modification requires additional study
3 3.3 PR-I-8:

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

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

The Planning Director (or the Coastal Commission’s
Executive Director if the Planning Director’s
determination is challenged) may determine that a
CCC suggested modification allows for
streamlined approval of temporary events
under certain circumstances. Generally, City
staff supports the approach. However, City staff
is proposing an alternative modification to
address typos and punctuation and clarify the
duration of events allowed under this criteria.

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

Such circumstances may include, but shall not be
limited to, the following:
• The event, either individually or together with
other temporary events scheduled before or after
the particular event, precludes the general public
from use of a public recreational area for a
significant period of time; or
• The event and its associated activities or access
requirements will either directly or indirectly impact
environmentally sensitive habitat areas, rare or
endangered species, significant scenic resources
(including as mapped on the LCP Land Use Plan
maps or as determined during project review), or
other coastal resources; or
• The event is scheduled between Memorial Day
weekend and Labor Day and would restrict public
use of roadways or parking areas or otherwise
significantly impact public use or access to coastal
waters; or
• The event has historically required a coastal
development permit to address and monitor
associated impacts to coastal resources. Temporary
events located solely within the Coastal
Commission’s original coastal development permit
jurisdiction area require review and determination
of coastal development permit requirement or
temporary event exemption from the Coastal
Commission.
3 3.4 PR-I-12:

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

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

N/A CCC suggested modification adds language to
include vertical trail improvements.
3 3.5 PR-I-24:

Sharp Park
Support the continued operation of golf at Sharp
Park Golf Course consistent with redeveloping
source protection, natural hazard, and coastal
vulnerability policies, and support development of
additional recreational uses in upland portions of
Support the continued operation of golf at Sharp
Park Golf Course consistent with redeveloping
source protection, natural hazard, and coastal
vulnerability policies, existing CDP terms and
conditions, and support development of additional
Support the continued operation of golf at Sharp
Park Golf Course consistent with redeveloping
source protection, natural hazard, and coastal
vulnerability policies, existing CDP terms and
conditions, and support development of additional
City staff alternative modification would delete
the word “existing,” which clarifies that a CDP
must be obtained and can be modified through
the appropriate approval process over time.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification the Park located outside the Coastal Zone east of
Highway 1.
recreational uses in upland portions of the Park
located outside the Coastal Zone east of Highway 1.
recreational uses in upland portions of the Park
located outside the Coastal Zone east of Highway 1.
3 3.6 PR-G-11:

Trail System
Expansion
Expand the trail system in Pacifica to create a
connected trail network with communitywide links
to open space and recreation facilities, as shown
on Figure 3-3.

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

N/A CCC suggested modification adds the California
Coastal Trail to the policy.
3 3.7 PR-I-57:

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

PR-I-57: Bicycle Roadway Retrofits
Roadway retrofits to create complete streets will
require additional analysis., such as coastal hazard
concerns in areas within the Coastal Zone.
consistent with this LCP.

CCC suggested modification adds language that
roadway retrofits need to analyze coastal
hazards. The City alternative modification
clarifies that the policy only applies to roadway
retrofits that do not increase capacity and are
intended to create complete streets.
3 3.8 PR-I-60:

Roadway
Abandonmen
t/Vacation
and Public
Access
Do not abandon, vacate, or render unusable any
City-owned right-of-way, unless necessary for
reasons of public safety or environmental
conservation. Whenever public roadways are
proposed to be abandoned, assess the value of
maintaining public pedestrian and/or bicycle
access, especially where coastal access can be
maintained or improved. Abandonment/vacation
of any public right-of-way that may negatively
affect coastal resources or public access to the sea
will require a coastal development permit. Any
public right-of-way that cannot be maintained in a
condition suitable for public use shall be offered to
another public agency or private association that
agrees to maintain the right-of-way for public use.

Do not abandon, vacate, or render unusable any
City-owned roadways and/or rights-of-way, unless
necessary for reasons of public safety or
environmental conservation. Whenever public
roadways and/or rights-of-way are proposed to be
abandoned, assess the value of maintaining public
pedestrian and/or bicycle access, especially where
coastal access can be maintained or improved.

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

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

CCC suggested modification adds City-owned
roadways, in addition to public rights-of-way.

City staff’s alternative modification indicates a
CDP may be required (as opposed to requiring
it in all instances). It is possible certain
vacations may be exempt from CDP
requirements.
4 4.1 Surface
Water
Some of the watersheds drain directly into the
ocean, while other feed one of five.

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

The City’s General Plan consistency changes
eliminated this sentence and the suggested
modification is no longer applicable.
4 4.2 Wetlands N/A Importantly, wetlands in the coastal zone only need meet one parameter (i.e., hydrology, hydric soils, or
hydrophytic species) to be considered a wetland, as
differentiated from three parameter delineations
which require all three to be present (e.g., ACOE
delineations).

Importantly, wetlands in the coastal zone only need
to meet one parameter (i.e., hydrology, hydric soils,
or hydrophytic species) to be considered a wetland,
as differentiated from three parameter delineations
which require all three to be present (e.g., U.S. Army
Corps of Engineers delineations).

CCC suggested modification clarifies the
language; however, City staff is proposing an
alternative modification to address typos and
expand an acronym.
4 4.3 ER-I-1: Creek
Protection
and
Restoration.

Requiring a minimum of 100 feet setbacks from
the top of creek banks, or from the outer edge of
riparian vegetation, where it exists, for
development proposed adjacent to creeks, in
keeping with City regulations and Best
Management Practices. Exceptions to such buffer
requirements should be supported by a biological
report demonstrating that the adjusted buffer, in
combination with incorporated siting, design or
other mitigation measures, shall prevent impacts
that significantly degrade the creek. Buffer
adjustments should also be limited to where the
Requiring a minimum of 100 feet setbacks from the
top of creek banks, or from the outer edge of
riparian vegetation, where it exists, whichever is
further, for development proposed adjacent to
creeks, in keeping with City regulations and Best
Management Practices. The 100-foot buffer may be
reduced by the minimum necessary (1) to avoid a
taking (for private development), or (2) to provide
required public services (for public development),
provided that the buffer is as close to 100 feet as
possible, and no less than 50 feet in any case, and
provided that creek resource impacts are avoided
Requiring a minimum of 100 feet setbacks from the
top of creek banks, or from the outer edge of
riparian vegetation, where it exists, whichever is
further, for development proposed adjacent to
creeks, in keeping with City regulations and Best
Management Practices. The 100-foot buffer may be
reduced by the minimum necessary (1) to avoid a
taking (for private development), or (2) to provide
required public services (for public development),
provided that the buffer is as close to 100 feet as
possible, and no less than 50 feet in any case, and
provided that creek resource impacts are avoided as
CCC suggested modification amends the text to
clarify exceptions; however, the statement “no
less than 50 feet in any case” is too prescriptive
and does not consider the quality of habitat or
design alternatives. City staff proposes to
eliminate the statement and the buffer will be
decided on a case-by-case basis as informed by
a qualified biologist.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification entire subject legal lot is within the buffer or
where it is demonstrated that development
outside the buffer would have a greater impact on
the creek.
as much as possible, and unavoidable impacts
commensurately mitigated, all as conclusively
demonstrated by a qualified biologist to the
satisfaction of the City, USFWS, and CDFW.
much as possible, and unavoidable impacts
commensurately mitigated, all as conclusively
demonstrated by a qualified biologist to the
satisfaction of the City, USFWS, and CDFW.
4 4.3 ER-I-1: Creek
Protection
and
Restoration.

N/A Permitted uses within buffer zones are limited to
uses dependent on the resources within these
areas and their buffer zones (i.e. habitat
management and restoration, scientific research
and educational activities, and low-intensity public
access and recreation). Temporary disruption (e.g.
less than six months) for the construction,
alteration, repair, and maintenance of existing or
newly permitted facilities or structures is allowed if
there are no feasible alternatives, the disruption
area is restored to its pre- disruption state or better within one year from the initial point of impact and
there is no significant ground disturbance.

Permitted uses within buffer zones are limited to
uses dependent on the resources within these areas
and their buffer zones (i.e., habitat management
and restoration, scientific research and educational
activities, and low-intensity public access and
recreation), except where reduced buffer is required
to avoid a taking or essential for the provision of
public services. Temporary disruption, as
determined by a qualified biologist in consideration
of on-site specific biological resources, for the
construction, alteration, repair, and maintenance of
existing or newly permitted facilities or structures is allowed if there are no feasible alternatives, the
disruption area is restored to its pre- disruption
state or better within one year from the initial point
of impact and there is no significant ground
disturbance.

CCC suggested modification added language to
Policy ER-I-2 that specified allowed uses within
a designated buffer area. City staff is generally
in support of the suggested modification;
however, City staff is proposing an alternative
modification to clarify that takings avoidance is
a relevant factor for consideration, as is
provision of public services. City staff is also
clarifying that temporary disruptions may be
permissible if reviewed and recommended by a
qualified biologist.
4 4.4 Plant
Communities
and Wildlife
Habitats
The EIR for the General Plan and Local Coastal
Land Use Plan Update includes a more detailed
description of each of these communities and
habitats. The listed species and habitats here are
not intended to preclude the possibility that other
species or habitat occur within Pacifica. Species
identified with various plant communities or
habitats are not necessarily present in the
Planning Area. Some of these communities are
recognized as “special status communities,” or
provide critical habitat for special status species.

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

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

CCC suggested modification clarifies the
language; however, City staff is proposing an
alternative modification to address typos.

Additionally, some of the City’s General Plan
consistency changes eliminated portions of this
text.
4 4.5 Annual
Grasslands
Annual Grasslands Grasslands N/A The City’s General Plan consistency changes eliminated the term “annual” from the header
and the suggested modification is no longer
applicable.
4 4.6 Northern
Coastal Scrub
Northern coastal scrub habitat is found on
undeveloped slopes, often in a mosaic with annual
grasslands. Northern maritime chaparral, a
special-status community, is included in this
category. Northern coastal scrub is dominated by
either coyote brush or California sagebrush,
depending on slope aspect.

Northern coastal scrub habitat is found on
undeveloped slopes, often in a mosaic with
grasslands. Northern maritime chaparral, a specialstatus community, is included in this category.

Northern coastal scrub dominated by either coyote
brush or California sagebrush, primarily depending
on slope aspect.

N/A CCC suggested modification removes the term
“annual” and generalizes language.
4 4.7 Seasonal
Wetlands
and Ponds
Seasonal Wetlands and Ponds Wetlands and Ponds N/A CCC suggested modification generalizes language
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.7 Seasonal
Wetlands
and Ponds
Seasonal Wetlands occur in smaller drainages and
localized depressions, forming ponds or flowing
water, and are underlain by saturated soils during
the winter and spring. Seasonal wetlands also
occur along the banks and sediments that
accumulate in creeks. Wetlands in Pacifica are
found along riparian areas, drainages, along the
coast, and as fresh and brackish water marshes
(such as on the Sharp Park Golf Course).

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

Wetlands occur in smaller drainages and localized
depressions, forming ponds or flowing water.

Wetlands also occur along in creeks, riparian areas,
drainages, along the coast, and as fresh and
brackish water marshes (such as on the Sharp Park
Golf Course). Vegetation and wildlife found in
wetlands varies with water characteristics,
inundation patterns, surrounding habitat, and level
of disturbance.

Wetlands occur in smaller drainages and localized
depressions, forming ponds or flowing water.

Wetlands also occur along in creeks, riparian areas,
drainages, along the coast, and as fresh and brackish
water marshes (such as on the Sharp Park Golf
Course). Vegetation and wildlife found in wetlands
varies with water characteristics, inundation
patterns, surrounding habitat, and level of
disturbance.

CCC suggested modification clarifies the
language; however, City staff is proposing an
alternative modification to address typos.
4 4.7 SpecialStatus
Species

SPECIAL-STATUS SPECIES IN SEASONAL WETLANDS

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

SPECIAL-STATUS SPECIES IN WETLANDS AND
PONDS
The California red-legged frog, San Francisco garter
snake, Leech’s skyline diving beetle, San Francisco
forktail damselfly, Tomales isopod, western pond
turtle, and bristly sedge are special-status species
that may be found in wetlands in and around
Pacifica. The wetlands in Sharp Park are also known
to support saltmarsh common yellowthroat.

Seasonal wetlands and ponds at Mori Point and
Sharp Park Golf Course also known to support the
California red-legged frog as well as the San
Francisco garter snake.

N/A Generalizes language
4 4.8 N/A N/A Dunes
Dune habitat includes areas with sandy substrates
proximate to the marine environment and may
range from bare to vegetated with species typical
of foredune and dune scrub communities, including
non-natives such as ice plant and invasive grasses.

Dune form topography may or may not be evident,
depending on the condition of the dune and past
land use or invasions, but may be readily restored.

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

N/A CCC suggested modification adds a new habitat
category.
4 4.9 Potential
Environment
ally Sensitive
Habitat Areas
(ESHAs)
Figure 4-3 identifies potential ESHAs in the
Planning Area. Potential ESHAs include all
designated critical habitat for Endangered or
Threatened Species; special status communities10;
and areas designated as “other potential
Environmentally Sensitive Habitat Areas”.

Figure 4-3 identifies potential ESHAs in the Planning
Area in three general categories: wetland,
stream/riparian, and other terrestrial ESHAs. These
potential ESHAs include all current designated
critical habitat for Endangered or Threatened
Species; known special status communities; and
areas designated as “other potential
Environmentally Sensitive Habitat Areas”. Figure 4-
3 is meant to serve as a flag for further studies to
be undertaken when development is proposed.

Figure 4-3 identifies potential ESHAs in the Planning
Area in three general categories: wetland,
stream/riparian, and other terrestrial ESHAs. These
potential ESHAs include all current designated
critical habitat for Endangered or Threatened
Species; known special status communities; and
areas designated as “other potential
Environmentally Sensitive Habitat Areas”. Figure 4-3
is meant to serve as a flag for further studies to be
undertaken when development is proposed.

CCC suggested modification clarifies the
language; however, City staff is proposing an
alternative modification to address typos.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification However, the map is illustrative and for information
purposes only; site-specific biological studies are
required as part of proposed development review
to determine the presence and extent of ESHA and
its required buffer zone. And other information
than Figure 4-3 may dictate the need for such
studies as well (e.g., site evaluation, other studies
nearby, etc.), even if the area is not mapped as
potential ESHA on Figure 4-3.

However, the map is illustrative and for information
purposes only; site-specific biological studies are
required as part of proposed development review to
determine the presence and extent of ESHA and its
required buffer zone. And oOther information than
Figure 4-3 may dictate the need for such studies as
well (e.g., site evaluation, other studies nearby,
etc.), even if the area is not mapped as potential
ESHA on Figure 4-3.
4 4.10 ER-G-6:

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

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

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

Prevent overuse in dune areas by mechanisms such
as restricting parking and directing pedestrian
traffic through signage and sand fencing to areas
capable of sustaining such use. Prohibit motor
vehicles in dune areas except for emergency
purposes, and prohibit motor vehicles in non-dune
beach areas except for emergency and essential
maintenance purposes and where previously
coastal permitted.

N/A CCC suggested modification adds new and
clarifying language.
4 4.11 ER-G-7:

Creeks and
Riparian
Areas as
Habitat
Protect year-round creeks and
their riparian habitats.

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

N/A CCC suggested modification adds clarifying
language.
4 4.12 ER-I-21:

Protection of
Biological
Resources
with New
Development
2) Pre-construction plant and wildlife surveys:

Project applicants shall engage a qualified biologist
to conduct presence/absence biological surveys
for sensitive plant and wildlife species prior to
construction adjacent to or within identified
special status communities and other sensitive
areas identified in Figure 4-3. If special status
species are identified, the qualified biologist shall
consult with the California Department of Fish and
Wildlife (CDFW) and establish no-disturbance
buffers around the special status specie to avoid
disturbance and direct impacts to these resources
during construction. If no special status species are
detected during surveys, then construction-related
activities may proceed. Nesting birds, in particular,
are protected by two means; they receive
protection under the Migratory Bird Treaty Act,
and nesting raptors (in the order Falconiformes or
Strigiformes) are protected under the State Fish
and Game Code, §3503.5.
2) Pre-construction plant and wildlife surveys:

Project applicants shall engage a qualified biologist
to conduct presence/absence biological surveys for
sensitive plant and wildlife species prior to
construction adjacent to or within areas identified
as potential ESHAs on Figure 4-3, or as otherwise
indicated and needed. If special status species are
identified, the qualified biologist shall consult with
the California Department of Fish and Wildlife
(CDFW) and establish no-disturbance buffers
around the special status specie to avoid
disturbance and direct impacts to these resources
during construction. If no special status species are
detected during surveys, then construction-related
activities may proceed. Nesting birds, in particular,
are protected by two means; they receive
protection under the Migratory Bird Treaty Act, and
nesting raptors (in the order Falconiformes or
Strigiformes) are protected under the State Fish
and Game Code, §3503.5.

N/A CCC suggested modification adds clarifying
language.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 4 4.12 ER-I-21:

Protection of
Biological
Resources
with New
Development
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, or other
sensitive habitat areas shown on Figure 4-3 of the
General Plan.
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, or other
sensitive habitat areas. Such assessment shall
identify means to avoid impacts to any such
resources (including through siting, design, and LCP
required buffers), and means of enhancing
resources and providing offsetting and
commensurate mitigation for unavoidable impacts
that are LCP allowable.
3) Require biological resource assessments be
conducted prior to approval for any development
within 300 feet of creeks, wetlands, or other
sensitive habitat areas, such as but not limited to
areas in Figure 4-3. Such assessment shall identify
means to avoid impacts to any such resources
(including through siting, design, and LCP required
buffers), and means of enhancing resources and
providing offsetting and commensurate mitigation
for unavoidable impacts that are LCP allowable.

CCC suggested modification clarifies the
requirements; however, City staff is proposing
an alternative modification to include the
reference to Figure 4-3 of the LCLUP.
4 4.12 ER-I-21:

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

N/A CCC suggested modification adds clarifying
language.
4 4.13 ER-I-23:

Verification
of ESHA
N/A Historical evidence of ESHA N/A CCC suggested modification adds new subpolicy under Verification of ESHA. 4 4.14 ER-I-24:

Management
of ESHA
No new development shall be allowed within
primary habitat areas with the
exception of resource-dependent uses
that can be demonstrated to have no significant
adverse impact.

No new development shall be allowed within ESHA
with the exception of resource-dependent uses
(such as habitat management and restoration,
scientific research and educational activities, and
low-intensity public access and recreation) that can
be demonstrated to have no significant disruption
of habitat values.

N/A CCC suggested modification adds clarifying
language.
4 4.14 ER-I-24:

Management
of ESHA
• Buffer areas shall be established around all
sensitive resources, providing a minimum of 100
feet, and varying as needed to account for
feeding, breeding, nesting, and other habitat
requirements. Exceptions to such buffer
requirements should be supported by a biological
report demonstrating that the adjusted buffer, in
combination with incorporated siting, design or
other mitigation measures, will prevent impacts
that significantly degrade the ESHA and will be
compatible with the continuance of the ESHA.

Buffer adjustments should also be limited to
where the entire subject legal lot is within the
buffer or where it is demonstrated that
development outside the buffer would have a
greater impact on the ESHA.
• Buffer areas shall be established around all ESHA,
providing a minimum of 100 feet, and may be
expanded as needed to account for feeding,
breeding, nesting, and other habitat requirements.

The 100-foot buffer may be reduced by the
minimum necessary (1) to avoid a taking (for
private development), or (2) to provide required
public services (for public development), provided
that the buffer is as close to 100 feet as possible,
and no less than 50 feet in any case, and provided
that ESHA resource impacts are avoided as much as
possible, and unavoidable impacts commensurately
mitigated, all as conclusively demonstrated by a
qualified biologist to the satisfaction of the City,
USFWS, and CDFW.
• Buffer areas shall be established around all ESHA,
providing a minimum of 100 feet, and may be
expanded as needed to account for feeding,
breeding, nesting, and other habitat requirements.

The 100-foot buffer may be reduced by the
minimum necessary (1) to avoid a taking (for private
development), or (2) to provide required public
services (for public development), provided that the
buffer is as close to 100 feet as possible, and no less than 50 feet in any case, and provided that ESHA
resource impacts are avoided as much as possible,
and unavoidable impacts commensurately
mitigated, all as conclusively demonstrated by a
qualified biologist to the satisfaction of the City,
USFWS, and CDFW.

CCC suggested modification amends the text to
clarify exceptions; however, the statement “no
less than 50 feet in any case” is too prescriptive
and does not consider the quality of habitat or
design alternatives. City staff proposes to
eliminate the statement and the buffer will be
decided on a case-by-case basis as informed by
a qualified biologist.
4 4.14 ER-I-24:

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

N/A CCC suggested modification amends text to
clarify exceptions.
4 4.15 ER-I-28:

Construction
during
If site work or construction occurs during the
nesting season (February 1 through August 31),
then pre-construction breeding bird surveys shall
be performed by a qualified wildlife biologist prior
If site work or construction occurs during the
nesting season (February 1 through August 31),
then pre-construction breeding bird surveys shall
be performed by a qualified wildlife biologist prior
N/A CCC suggested modification deletes text related
to nesting during construction.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Nesting
Season
to any site disturbance to ensure that no nests will
be disturbed or destroyed during Project
implementation. If an active nest is found
sufficiently close to work areas to be disturbed by
construction activities, then the biologist shall
create a no-disturbance buffer of 250 feet around
passerine nests and a 500 foot buffer around
raptor nests. Work-free buffer zones shall be
maintained until after the breeding season or until
after the qualified biologist determines the young
have fledged (usually late June through mid-July).

Nests initiated during active construction would
be presumed to be unaffected by the activity, and
a buffer zone around such nests is not necessary.

However, nests shall be flagged and construction
activity shall avoid killing and/or injuring nesting
birds.
to any site disturbance to ensure that no nests will
be disturbed or destroyed during Project
implementation. If an active nest is found
sufficiently close to work areas to be disturbed by
construction activities, then the biologist shall
create a no-disturbance buffer of 250 feet around
passerine nests and a 500 foot buffer around raptor
nests. Work-free buffer zones shall be maintained
until after the breeding season or until after the
qualified biologist determines the young have
fledged (usually late June through mid-July).
4 4.16 ER-I-30:

Protection of
the California
Red-Legged
Frog and San
Francisco
Garter Snake
To minimize disturbance, require all grading
activity within 100 feet of aquatic habitat shall be
conducted during the dry season (May 1 through
October 15) to protect California red-legged frog
and San Francisco garter snake. A qualified
biologist shall conduct presence/absence surveys
for California red-legged frog and San Francisco
garter snake prior to construction in or adjacent to
riparian areas, grasslands near ponds/wetlands, or
other sensitive habitat. Any individuals identified
shall be treated in consultation with USFWS.

Construction shall follow accepted procedures for
exclusion and avoidance of California red-legged
frog and
San Francisco garter snake and their habitat.

Additionally, the biologist shall supervise the
installation of exclusion fencing along the
boundaries of the work area, shall conduct
environmental awareness training for construction
workers, and shall be present during initial
vegetation clearing and ground-disturbing
activities.

Allowed construction activity with the potential to
impact California red-legged frogs and San
Francisco garter snake shall be conducted during
the dry season (May 1 through October 15) to
protect California red-legged frog and San Francisco
garter snake. In such cases a qualified biologist shall conduct presence/absence surveys for California
red-legged frog and San Francisco garter snake
prior to construction in or adjacent to riparian
areas, grasslands near ponds/wetlands, or other
sensitive habitat. Any individuals identified shall be
treated in consultation with USFWS. Construction
shall follow accepted procedures for exclusion and
avoidance of California red-legged frog and
San Francisco garter snake and their habitat.

N/A CCC suggested modification adds clarifying
language.
4 4.17 ER-I-39: Bowl
Site
Establish appropriate zoning for the “Bowl” site
along the east side of Palmetto Avenue in
Fairmont West for Planned Development to
ensure site planning that clusters development,
avoiding potential flooding or geotechnical
hazards and protecting open space resources.

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

N/A CCC suggested modification adds clarifying
language.

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

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

N/A CCC suggested modification adds clarifying
language.
5 5.2 Coastal Bluffs A bluff is a high bank or bold headland with a broad, precipitous, sometimes rounded cliff face
overlooking a plain or body of water.

Deleted N/A CCC suggested modification deletes text in an introductory paragraph.
5 5.3 NH-G-1:

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

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

N/A CCC suggested modification adds clarifying
language.
5 5.4 NH-I-9:

Erosion
Prevention
Require erosion prevention of hillside areas by
revegetation or other acceptable methods.

Deleted NH-I-9: Hillside Erosion Prevention.

Require erosion prevention of hillside areas to
maintain slope stability by revegetation. Other slope
stability methods may be acceptable, consistent
with this LCP.

CCC suggested modification deleted the entire
policy related to hillside erosion prevention.

City staff alternative modification clarifies that
the policy is intended for hillside erosion, and
not bluff erosion.
5 5.5 NH-I-10:

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

N/A CCC suggested modification amends policy to
include Coastal Vulnerability Zones.
5 5.5 NH-I-10:

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

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

N/A CCC suggested modification amends the text to
be consistent with new definitions.
5 5.6 NH-I-17: New
Development
in Coastal
Zone
• Not accelerate the need for a shoreline structure
or increase the likelihood of a future seawall
beyond the existing development’s expected life;
N/A N/A CCC suggested modification deletes text related to new development.
5 5.6 NH-I-17: New
Development
in Coastal
Zone
Small improvement projects are exempt, including
improvements that would increase height, bulk or
floor area by less than ten percent.

N/A N/A CCC suggested modification deletes text related to small improvements to align with the
Substantial Structural Modification definition.
5 5.7 Flood Zones Flood hazards mapped by FEMA to support the development of Flood Insurance Rate Maps
(FIRMs) generally identify areas of greater flood
risk (100 and 500 year events) in the lower
reaches of the main stream channels, and the risk
of coastal flooding along the shoreline. Flood
zones based on the FIRMs are shown in Figure 5-3.

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

Flood zones based on the FIRMs are shown in
Figure 5-3.

N/A CCC suggested modification adds clarifying
language.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 5 5.8 NH-G-2:

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

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

N/A CCC suggested modification adds clarifying
language.
5 5.9 NH-I-24:

Flood Hazard
Reduction
Flood Hazard Reduction. Continue to comply with
the Flood Damage Prevention Ordinance in the
Municipal Code.

Deleted N/A City staff is not proposing an alternative
modification; however, once the City’s Flood
Prevention Ordinance is certified by CCC an LCP
amendment can be processed to include the
policy in the LCLUP.
5 5.10 NH-I- 26:

Flood Control
Maintenance
Regularly maintain flood control structures,
including, but not limited to drainage channels,
pipes, culverts, and stream beds.

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

Routine maintenance of streambeds shall conform
to the Coastal Act, including but not limited to
Section 30236.

CCC suggested modification removed
streambeds from the policy. Significant areas of
Pacifica are serviced by creeks as critical
stormwater infrastructure that require regular
maintenance. City staff alternative modification
clarifies that all routine maintenance in
streambeds will conform to the Coastal Act.
5 5.11 NH-I-27:

Flood Control
Structures
Require flood control devices that alter streams to
incorporate best mitigation measures whenever
feasible, and only permit them where no other
method for protecting existing structures in the
flood plain is feasible, where such
protection is necessary for public safety, or to
protect existing development.

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

N/A CCC suggested modification amends policy text
to include rivers, water supply, and mention of
fish and wildlife habitat.
5 5.12 NH-I-31:

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

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

N/A CCC suggested modification amends policy text
to include Coastal Vulnerability Zones.

5.13 NH-I-35:

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

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

N/A CCC suggested modification amends policy text
to expand considerations of ESHA buffers
5 5.14 NH-I-39:

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

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

CCC suggested modification amends policy to
require LCP consistency; however, City staff is
proposing an alternative modification to
address a grammatical error.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.1 Coastal
Resilience
The purpose of this chapter is to provide policies
which protect existing development from the
hazard of sea level rise and which guide the design
of new development to respond to sea level rise
during the economic life of the project. Topics
covered in this element include sea level rise
projections, transfer of development rights (TDR),
repair and replacement of existing shoreline
protection structures (e.g., sea walls), and
establishment of appropriate site design measures
for new development. Protection of property
rights is an important theme in this chapter.

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

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

CCC suggested modification deletes
introductory text. City staff is proposing an
alternative modification to add language
related to balancing City priorities.
6 6.2 Coastal Act
Policies
Therefore, the policies focus on protection and
armoring of the shoreline and reassessment of the
adaptation plan in the future. The policies do not
include managed retreat as an adaptation strategy
unless and until a future Local Coastal Land Use
Plan amendment and public input process
culminates in supporting the strategy.

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

N/A CCC suggested modification clarifies language
to be consistent with the Coastal Act.
6 6.3 Vulnerability
Assessment -
Pacific
Institute
Study
However, because the Coastal Vulnerability Zone
Maps show significant erosion for areas that are
protected by existing shoreline protection
structures, the Maps highlight the importance of
the existing structures and the vital need for them
to be maintained to protect those vulnerable
areas.

Deleted However, because the Coastal Vulnerability Zone Maps show significant erosion for areas that are
protected by existing shoreline protection
structures, the Maps highlight the protection
provided by the structures.

CCC suggested modification deletes
introductory text. City staff is proposing an
alternative modification to add language
related to the existing shoreline protections in
the City.
6 6.4 Adaptation
Plan
The cost-benefit analysis section of the Adaptation
Plan was not adopted or approved by the City of
Pacifica. The purpose of the cost benefit analysis
was to provide information regarding various sea
level rise scenarios and adaptation options and
was not intended to prescribe specific adaptation
policies. The cost-benefit analysis shall not be used
for any future purpose by the City of Pacifica or its
planning processes, including implementation of
the Local Coastal Program, public infrastructure
investment, permitting or other regulatory
purposes.

Deleted The cost-benefit analysis section of the Adaptation Plan was not adopted or approved by the City of
Pacifica. The purpose of the cost benefit analysis
was to provide information regarding various sea
level rise scenarios and adaptation options and was
not intended to prescribe specific adaptation
policies. The cost-benefit analysis was perceived to
require additional work to adequately analyze the
value of public recreational amenities.

CCC suggested modification deletes
introductory text. City staff is proposing an
alternative modification to add language
related to the cost-benefit analysis.
6 6.4 Adaptation
Plan
The findings of the Adaptation Plan are just one of
the considerations that were used to develop the
Coastal Resilience policies below and, as
discussed, the Coastal Resilience policies focus on
protection and armoring of the shoreline and
reassessment of the Adaptation Plan in the future.

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

N/A CCC suggested modification adds clarifying
language.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.4 Adaptation
Plan
Therefore, changes to the cost-benefit analysis in
a manner to discourage managed retreat as
suggested by some public commenters detailed
below would be unnecessary since the Coastal
Resilience policies do not include managed retreat
as an adaptation strategy. As noted earlier in this
section, the cost-benefit analysis prepared for the
Adaptation Plan shall not be used for any future
purpose by the City of Pacifica or its planning
processes.

Deleted Therefore, changes to the cost-benefit analysis are not necessary to inform the Coastal Resiliency
policies.

CCC suggested modification deletes
introductory text. City staff is proposing an
alternative modification to add language
related to the cost-benefit analysis.
6 6.4 Adaptation
Plan
The Adaptation Plan was prepared to inform City
decision making about a variety of sea level rise
adaptation policies, but does not include or dictate
the ultimate policies selected by the City. Although
managed retreat alternatives are analyzed in the
Adaptation Plan in accordance with the City’s
grant agreement with the CCC, these analyses do
not, in themselves, equate to a managed retreat
policy. To the contrary, the City has rejected
managed retreat as a sea level rise adaptation
policy in this LCP and managed retreat could only
become the policy of the City subsequent to a
future amendment to the LCP.

Deleted The Adaptation Plan was prepared to inform City decision making about a variety of sea level rise
adaptation policies, but does not include or dictate
the ultimate policies selected by the City. Although
managed retreat alternatives are analyzed in the
Adaptation Plan in accordance with the City’s grant
agreement with the CCC, these analyses do not, in
themselves, equate to a managed retreat policy. The
City uses other sea level rise adaptation policies in
this LCP and any future changes to these policies will
require an amendment to this LCP.

CCC suggested modification deletes
introductory text. City staff is proposing an
alternative modification to add language
related to the Adaptation Plan and potential
future changes.
6 6.5 CR-I-1:

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

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

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

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

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

CCC suggested modification is an addition of a
Coastal Act provision. City staff alternative
modification clarifies that the policy relates to
the anticipated life of the development
consistent with other policies in the LCP.
6 6.7 CR-I-3:

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

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

The City, in coordination with Coastal Commission
staff, shall create an alternating schedule to perform
half of the required surveys each year.

CCC suggested modification would require the
City to conduct additional monitoring. The new
requirement may be too burdensome on City
resources. City staff proposes an alternative
modification that would allow the City to
alternate the areas that are surveyed and
timing in order to realistically meet the
requirements of this policy. The schedule
would be created in coordination with CCC staff
in order to provide the most valuable and
efficient data.
6 6.8 CR-I-5:

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

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

N/A CCC suggested modification requires LCP
amendment to incorporate shoreline mitigation
program
6 6.8 CR-I-5:

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

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

N/A CCC suggested modification requires LCP
amendment to incorporate shoreline mitigation
program
6 6.9 CR-I-8:

Critical
Transportatio
n
Infrastructur
e
The City will pursue opportunities to preserve ,
protect, or relocate critical local transportation
infrastructure, or provide alternative access, to
mitigate against isolation and economic loss, and
to ensure public safety.

The City will pursue opportunities to preserve ,
protect, or relocate critical local transportation
infrastructure, or provide alternative access, to
mitigate against isolation and economic loss, and to
ensure public safety, while avoiding (and where
unavoidable minimizing and mitigating) impacts to
coastal resources, including public access and
recreation, to the maximum extent feasible, and
being consistent with prior permit conditions
and/or legal obligations pursuant to the California
Coastal Act.

The City will pursue opportunities to preserve,
protect, or relocate critical local transportation
infrastructure, or provide alternative access, to
mitigate against isolation and economic loss, and to
ensure public safety, while avoiding (and where
unavoidable minimizing and mitigating) impacts to
coastal resources, including public access and
recreation, to the maximum extent feasible, and
being consistent with prior permit conditions and/or
legal obligations pursuant to the California Coastal
Act.

City staff alternative modification would delete
the word “prior,” which clarifies that a permit
must be obtained and can be modified through
the appropriate approval process over time.
6 6.10 CR-I-9:

Hazard Prone
Infrastructur
e
The City will preserve, protect, or relocate hazard
prone infrastructure to maintain critical services.

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

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

City staff alternative modification would delete
the word “prior,” which clarifies that a permit
must be obtained and can be modified through
the appropriate approval process over time.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.11 CR-I-15:

Shoreline
Protection
Structures
N/A Shoreline Protection Structures. Shoreline
protection structures shall be avoided except that
existing shoreline protection structures may be
maintained or new shoreline protection structures
constructed to protect existing structures in danger
from erosion if found to be the least
environmentally-damaging alternative, impacts to
beach, public access and recreation, and other
coastal resources are fully mitigated consistent
with CR-I-5 and CR-I-59, and compliant with any
prior permit conditions and/or legal obligations
pursuant to the California Coastal Act . Allow
shoreline protection structures for the public road
and sewer line existing structures if necessary and
consistent with Policies CR-I-56 and CR-I-57, other
LCP policies, and the Coastal Act. New development
on blufftops shall comply will all LCP setback
policies, including CR-I-44.

N/A CCC suggested modification reorganizes the
document.
6 6.12 CR-I-16:

Beach
Nourishment
N/A Beach Nourishment. Evaluate the feasibility of
using beach nourishment, in conjunction with sand
retention structures (see artificial headlands
concept in the Adaptation Plan) as described in CRI-55, to reduce shoreline protection structure maintenance requirements and maintain beaches
of at least 100 feet in width on average. If feasible
and approved through a coastal development
permit, secure funding and implement as soon as
possible. Repeat as necessary. Mitigate all adverse
impacts and monitor effectiveness over time.

In coordination with the California Coastal
Commission and other permitting agencies (e.g.,
State Lands Commission, U.S. Army Corps of
Engineers), the City shall evaluate a beach
nourishment program in conjunction with sand
retention structures (see artificial headlands concept
in the Adaptation Plan) as described in CR-I-55, to
reduce shoreline protection structure requirements
and maintain beaches of at least 100 feet in width
on average, consistent with other LCP policies and
the Coastal Act. The beach nourishment program
will need to be evaluated to be the least
environmentally damaging feasible alternative and
will include measures to protect water quality and to
avoid (and where unavoidable to minimize and
mitigate) potential adverse coastal resource
impacts, including biological resource impacts, from
deposition of material, including measures such as
sand compatibility specifications, restrictions on
volume of deposition, timing or seasonal
restrictions, and identification of environmentally
preferred locations for deposits.

CCC suggested modification was an attempt to
organize the document by taking several
policies in the subarea sections related to
Beach Nourishment and putting them in
Section 6.5 Coastal Resiliency Policies to apply
to the entire Coastal Zone. However, City staff
proposes an alternative modification that is
more inclusive of all the language that is
included in the 2020 Revised Certification Draft
related to Beach Nourishment by deleting CR-I55 and incorporating the language into CR-1-

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

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.13 Sub-area
Policies and
Programs
Generally, for all lands within the 2050 Pacific
Institute erosion hazard zone11, utilities, roadways
and other public infrastructure should be
floodproofed unless other adaptation alternatives
are implemented and performing well.

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

N/A CCC suggested modification amends text to use
Coastal Vulnerability Zones.
6 6.13 Sub-area
Policies and
Programs
In addition, the City should, when appropriate,
evaluate and pursue floodproofing infrastructure
that may be currently exposed to coastal erosion
and flooding to reduce the consequences of
under-performance of protection measures (CR-I61).

In addition, the City should, when appropriate,
evaluate and pursue floodproofing infrastructure
that may be currently exposed to coastal erosion
and flooding to reduce the consequences of underperformance of protection measures, only if such floodproofing infrastructure is the least
environmentally damaging feasible alternative and
consistent with LCP and Coastal Act policies (CR-I61).

In addition, the City should, when appropriate,
evaluate and pursue floodproofing infrastructure
that may be currently exposed to coastal erosion
and flooding to reduce the consequences of underperformance of protection measures, only if such floodproofing infrastructure is designed to eliminate
or mitigate adverse impacts on local shoreline sand
supply, consistent with LCP and Coastal Act policies
(CR-I-61).

CCC suggested modification amends text to
related to floodproofing infrastructure. City
staff is proposing an alternative modification to
clarify requirements for sand supply.
6 6.13 Sub-area
Policies and
Programs
The City’s overall approach for new development
is to minimize or avoid current and projected
future coastal hazards through siting and design.

At the same time, managed retreat is not included
in any of the near-term policies. Managed retreat
would be reconsidered if feasibility and
monitoring warranted, as detailed in Coastal
Resilience Policies CR-I-3 and CR-I-4.

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

N/A CCC suggested modification deletes
introductory language specific to managed
retreat. Since the text is not policy language,
staff is not proposing an alternative
modification.
6 6.14 Special
Resiliency
Areas
N/A N/A The Special Resiliency Areas (SRA) include the
existing shoreline protection structures in the
Rockaway Beach and West Sharp Park sub-areas.

These areas have existing development patterns
with significant amounts of Pre-Coastal Act
development, a mix of public streets and
infrastructure, land use prioritized by the Coastal
Act, and significant unified public coastal access, all protected by broad existing shoreline protection,
that warrant a unique policy approach. The purpose
of modifying policies applicable to this area is to
allow ongoing economic use and vitality of property,
provision of public services, operation of visitorserving uses, and protection of robust coastal access In order to address many of the CCC suggested
modification’s impacts on Pacifica’s existing
developed neighborhoods, City staff is
proposing an alternative modification that
would create two Special Resiliency Areas
(SRAs), which would allow those areas greater
flexibility in permitting requirements and
design.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification for all persons including persons with disabilities
within a Special Resiliency Area (SRA). The two SRA
locations are identified in Figure 6-2 and 6-3.
6 6.15 CR-I-17
Shoreline
Management
Plan
N/A N/A The City will establish a funding source for visitor amenity improvements. Funding sources may
include, but not be limited to, grants, fees,
assessments, taxes, and any other lawful public or
private funding sources. The City will create a
funding and implementation plan with specific
projects to improve visitor amenities in the Special
Resiliency Areas or elsewhere in Pacifica. Creation of
this plan will include community outreach and input.

The plan will be updated every 5 years and will
identify specific short-, medium-, and long-term
projects to mitigate coastal resource impacts from
ongoing reliance on shoreline protection within
Special Resiliency Areas. In general, the
implementation plan will fund a variety of projects
identifying and carrying out shoreline protection
removal opportunities, implementing nature-based
solutions to adapt existing shoreline protection
devices, maintenance or alteration of existing
shoreline protection devices to expand public
coastal access including but not limited to trails and
beach access, acquiring and conserving undeveloped
coastal properties, and enhancing visitor amenities.

Specific amenity improvements and shoreline
protection device removal may occur anywhere
within the City of Pacifica.

In order to address many of the CCC suggested
modification’s impacts on Pacifica’s existing
developed neighborhoods, City staff is
proposing an alternative modification that
would create two SRAs, which would allow
those areas greater flexibility in permitting
requirements and design.
6 6.16 CR-I-15:

Shoreline
Protection
Structures (0-
1foot SLR or
260 foot
offset from
bluff toe to
infrastructur
e)
Shoreline Protection Structures (0-1 foot SLR or
260-foot offset from bluff toe to infrastructure).

Shoreline protection structures shall be avoided
except that the existing shoreline protection
structures may be maintained or new shoreline
protection structures constructed to protect
existing structures in danger from erosion if found
to be the least environmentally-damaging
alternative, impacts are fully mitigated consistent
with CR-I-5, and compliant with any prior permit
conditions and/or legal obligations pursuant to the
California Coastal Act . Allow shoreline protection
structures for the public road and sewer line
existing structures if necessary and consistent with
Policies CR-I-56 and CR-I-57, other LCP policies,
and the Coastal Act. New development on
blufftops shall comply will all LCP setback policies,
including CR-I-44.

Deleted N/A CCC suggested modification reorganizes the
document.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.17 CR-I-16:

Beach
Nourishment
(2 feet SLR or
260-foot
offset from
bluff toe to
infrastructur
e).

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

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.18 CR-I-18:

Shoreline
Protection
Structures (0-
1 foot SLR or
220-foot
offset from
bluff toe to
infrastructur
e or
development
)
Shoreline Protection Structures (0-1 foot SLR or
220-foot offset from bluff toe to infrastructure or
development). Maintain existing or construct new
shoreline protection structures to protect existing
public infrastructure structures, including between
Bill Drake Way and Manor Drive. Allow private
property owners to maintain existing or construct
new shoreline protection structures if allowed
pursuant to Policies CR-I-56 and CR-I-57, and if
consistent with prior permit conditions and/or
legal obligations pursuant to the California Coastal
Act, and require mitigation of beach, public access
and recreation and other coastal resource
impacts, consistent with CR-I-5 or CR-I-59, as
necessary.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.19 CR-I-19:

Beach
Nourishment
(0-1 foot SLR
or 220-foot
offset from
bluff toe to
infrastructur
e or
development
)
Beach Nourishment (0-1 foot SLR or 220-foot
offset from bluff toe to infrastructure or
development). Evaluate the feasibility of using
beach nourishment, in conjunction with sand
retention structures (artificial headlands concept)
as described in CR-I-55, to reduce shoreline
protection structure maintenance requirements
and maintain beaches of at least 100 feet in width
on average. If feasible and approved through a
coastal development permit, secure funding and
implement as soon as possible. Mitigate all
adverse impacts and monitor effectiveness over
time.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.20 CR-I-20:

Shoreline
Protection
Structures (0-
1 feet SLR or
70-foot
offset from
bluff toe to
development
or
Shoreline Protection Structures (0-1 feet SLR or
70-foot offset from bluff toe to development or
infrastructure). Private landowners may maintain,
expand, or construct new shoreline protection
structures to protect existing structures in danger
from erosion, consistent with CR-I-2 and any prior
permit conditions and/or legal obligations
pursuant to the California Coastal Act.

Deleted N/A CCC suggested modification reorganizes the
document.

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

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

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

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

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.22 CR-I-22:

Flood
Protection (1
feet SLR)
Flood Protection (1 feet SLR). Enable property
owners to modify development structures (e.g.,
elevate a residence) to manage impacts of wave
run-up and overtopping of bluff face.

Flood Protection. Enable property owners to
modify development structures to manage impacts
of wave run-up and overtopping of bluff face
provided such modifications are consistent with the
LCP and any prior permit conditions and/or legal
obligations pursuant to the California Coastal Act.

Flood Protection. Enable property owners to modify
development structures to manage impacts of wave
run-up and overtopping of bluff face provided such
modifications are consistent with the LCP and any
prior permit conditions and/or legal obligations
pursuant to the California Coastal Act.

Sharp Park
Golf Course
Sharp Park Golf Course. Strongly support the City
and County of San Francisco’s maintenance of the
Sharp Park Golf Course berm and armoring,
consistent with the Coastal Development Permit
issued by the California Coastal Commission,
including adaptation planning for the course, and
protecting public access.

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

Deleted Sharp Park Golf Course. Strongly support City and County of San Francisco’s ability to provide public
access along the coast, protect ESHA, and provide
flood protection.

CCC suggested modification deleted the entire
policy related to the Sharp Park Golf Course.

City staff is proposing an alternative
modification that would keep a policy related
to the Sharp Park Golf Course but would focus
on public access and resource enhancements.
6 6.24 CR-I-24:

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

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

Deleted N/A CCC suggested modification reorganizes the
document.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.25 CR-I-25:

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

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

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

Beach
Nourishment
(0-1 feet SLR)
Beach Nourishment (0-1 feet SLR). Pursue beach
nourishment and sand retention structures to
reduce shoreline protection structure
maintenance requirements and provide beach
resources. Encourage the City and County of San
Francisco to nourish the beach fronting the Sharp
Park Golf Course berm to maintain beach widths.

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.27 CR-I-27:

Flood
Protection (0
foot SLR)
(0 foot SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.28 CR-I-28:

Flood
Protection (3
feet SLR).
(3 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.29 CR-I-29:

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

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

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.30 CR-I-30:

Shoreline
Protection
(2-3 feet SLR,
or when
backshore
toe is 100
feet from
Highway 1).
(2-3 feet SLR, or when backshore toe is 100 feet
from Highway 1)
Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.31 CR-I-31:

Public Access
(0 feet SLR).
(0 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.32 CR-I-32:

Beach
Nourishment
/Public
Access (0
feet SLR).

Beach Nourishment/Public Access (0 feet SLR).

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

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.33 CR-I-35:

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

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

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.34 CR-I-37:

Beach
Nourishment
(2 ft SLR or
100 foot
offset from
shoreline to
infrastructur
e).

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

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.35 CR-I-38:

Flood
Protection (0
feet SLR).
(0 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.36 CR-I-39:

Flood
Protection (2
feet SLR or
100-foot
offset from
shoreline to
infrastructur
e).
(2 feet SLR or 100-foot offset from shoreline to
infrastructure)
Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.37 CR-I-40:

Groundwater
Management
(0-2 feet
SLR).
(0-2 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.38 CR-I-41:

Shoreline
Protection
Structure
Upgrades.

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

Deleted N/A CCC suggested modification reorganizes the
document.
6 6.38 CR-I-42:

Flood
Protection
(0-1 feet
SLR).
(0-1 feet SLR) Deleted N/A CCC suggested modification generalize policy and reorganized the document.
6 6.40 CR-I-43:

Technical
Reports.

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

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

N/A CCC suggested modification amends the text to
make the policy applicable to Coastal
Vulnerability Zones, instead of shoreline
properties.
6 6.41 CR-I-43:

Technical
Reports.
• consider the impacts from the med-high
projection (CalNRA & OPC 2018) of sea-level rise
for the anticipated duration of the proposed
development;
• consider the impacts from the med-high
projection (CalNRA & OPC 2018; or similar
precautionary projections as reflected in future
updated statewide guidance) of sea-level rise for
the anticipated life of the proposed development;
N/A CCC suggested modification amends the text to
reflect that best available science may change
over time.
6 6.42 CR-I-43:

Technical
Reports.
• demonstrate that the development will avoid (or
if unavoidable, minimize) impacts from coastal
hazards to the maximum extent feasible; and
• demonstrate that the development will avoid (or
if unavoidable, minimize) impacts from coastal
hazards for the anticipated life of the proposed
development without reliance on any existing or
future shoreline protection devices;
demonstrate that the development will avoid (or if
unavoidable, minimize) impacts from coastal
hazards for the anticipated life of the proposed
development without reliance on any existing or
future shoreline protection devices, except that in
Special Resiliency Areas development will be
allowed to consider protection provided by existing
shoreline protection structures when analyzing
hazards;
CCC suggested modification reflects language
from the Sea Level Rise adopted policy
guidance. City staff is generally in support of
the modification; however, staff is proposing an
alternative modification to address the Special
Resiliency Areas. The alternative modification
will give the SRA the ability to use the existing
shoreline protections structures when
analyzing coastal hazards impacts.
6 6.43 CR-I-43:

Technical
Reports.

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

1.1 for seismic conditions; and
N/A CCC suggested modification adds clarifying
language related to safety requirements.
6 6.44 CR-I-44:

Siting and
Design.

New development on vacant shoreline property
shall be sited and designed to be safe from
erosion, bluff failure, wave run-up, flooding and
other coastal hazards for at least 100 years
without shoreline protection, considering
projected sea level rise and other climate change
effects to be determined from best available
science and current guidance at the time of
approval of the proposed development. Permit
approvals shall prohibit shoreline protection
structures for the authorized development,
New development in Coastal Vulnerability Zones
shall be sited and designed to be safe from erosion,
bluff failure, wave run-up, flooding and other
coastal hazards for at least 100 years without
shoreline protection, considering projected sea
level rise and other climate change effects to be
determined from best available science and current
guidance at the time of approval of the proposed
development, as demonstrated by site-specific
analyses and/or technical reports. Permit approvals
shall prohibit shoreline protection structures for
New development in Coastal Vulnerability Zones
shall be sited and designed to be safe from erosion,
bluff failure, wave run-up, flooding and other coastal
hazards for at least 100 years the anticipated life of
the development without shoreline protection,
considering projected sea level rise and other
climate change effects to be determined from best
available science and current guidance at the time of
approval of the proposed development, as
demonstrated by site-specific analyses and/or
technical reports. Permit approvals shall prohibit
CCC suggested modification amends the policy
to be applicable to the Coastal Vulnerability
Zone and reflects current CCC conditions of
approval. City staff is generally in support of the
modification; however, staff is proposing an
alternative modification to address the Special
Resiliency Areas. The alternative modification
will give the SRA the ability to use the existing
shoreline protections structures when siting
and designing development.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification require the property owner to record an
acknowledgement that the development does not
qualify as an existing structure entitled to
construction of a shoreline protection structure
under Coastal Act Section 30235 and a waiver of
any rights to such protection structures and where
necessary require a removal and restoration plan,
including bonding for large projects, to avoid
future shoreline protection structures or project
failure.
the authorized development, require the property
owner to record an acknowledgement that the
development does not qualify as an existing
structure entitled to construction of a shoreline
protection structure under Coastal Act Section
30235, and any other laws, that waive any rights to
such protection structures that might exist, and
that, where necessary, requires a removal and
restoration plan, including bonding for large
projects, to avoid future shoreline protection
structures or project failure.
shoreline protection structures for the authorized
development, require the property owner to record
an acknowledgement that the development does
not qualify as an existing structure entitled to
construction of a shoreline protection structure
under Coastal Act Section 30235, and any other
laws, that waive any rights to such protection
structures that might exist, and that, where
necessary, requires a removal and restoration plan,
including bonding for large projects, to avoid future
shoreline protection structures or project failure.

However, in Special Resiliency Areas, new
development shall be allowed to be sited and
designed in reliance on and in consideration of
protection provided by existing shoreline protection
structures.

Additionally, staff is proposing an alternative
modification to change the year time period to
“anticipated life.” A CCC suggested
modification added a definition for anticipated
life, staff is proposing this alternative
modification to be consistent throughout the
document.
6 6.45 CR-I-45:

Assumption
of Risk by
Private
Landowners.

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

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

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

CCC suggested modification amends the policy
to be applicable to the Coastal Vulnerability
Zone and Tsunami Evacuation Zone and reflects
current CCC conditions of approval. City staff is
generally in support of the modification;
however, City staff proposes to change
“Evacuation” to “Inundation” zone. The use of
Tsunami Evacuation Zones for this purpose is
overly broad and not closely enough related to
actual tsunami hazard conditions. City staff’s
alternative modification will ensure a
requirement more closely aligned with actual
hazard conditions.
6 6.46 CR-I-49:

Substantial
Modification
s to Existing
Structures.

Substantial Modifications to Existing Structures.

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

Substantial Structural Modifications. When
proposed modifications to an existing structure
constitute a Substantial Structural Modification
(SSM), as defined, such proposed development shall
correct any existing legal nonconformities and shall
be undertaken consistent with the LCP and the
Coastal Act, including but not limited to Policies CR-I43 and CR-I-44. Except that in Special Resiliency Areas, development shall only be required to correct
existing nonconformities related to applicable
coastal hazards on the site.

CCC suggested modification requires projects
that meet the SSM definition to correct any
existing legal nonconformities, in order to the
entire site to be compliant with the LCP and
Coastal Act. Staff is generally in support;
however, staff is proposing an alternative
modification to address the Special Resiliency
Areas. The alternative modification will give the
SRA the ability to correct only existing
nonconformities associated with coastal
hazards present on the site, rather than a
broader range of potential LCLUP or zoning
nonconformities.
6 6.47 CR-I-51:

Habitat Sea
Level Rise
Migration
Buffers.

A sea level rise buffer area shall be added to
require new development habitat buffers if
necessary to allow for the migration of wetlands
and other coastal habitats caused by sea level rise
over the anticipated duration (i.e., economic life)
of the development. Habitats include all wetlands,
An additional sea level rise buffer area shall be
added to required habitat buffers if necessary to
allow for the migration of wetlands and other
coastal habitats caused by sea level rise over the
anticipated life of the development. Habitats
include all wetlands, riparian, intertidal/shoreline
A sea level rise buffer area shall be added to
required habitat buffers if necessary to allow for the
migration of wetlands and other coastal habitats
caused by sea level rise over the anticipated life of
the development. The overall buffer area shall
include both the sea level rise and habitat buffer.

CCC suggested modification would require an
additional seal level rise buffer. Staff is
generally in support of the modification;
however, staff is proposing an alternative
modification to clarify that a buffer area should
include all the buffer requirements.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification riparian, intertidal/shoreline and terrestrial
environmentally sensitive habitat areas (ESHAs) as
defined by the Coastal Act. The sea level rise
projection considered shall be determined for the
type of development from CalNRA and OPC (2018)
guidance or the latest update.
and terrestrial environmentally sensitive habitat
areas (ESHAs) as defined by the Coastal Act. The
sea level rise projection considered shall be
determined based on the type of development and
current State guidance.

Habitats include all wetlands, riparian,
intertidal/shoreline and terrestrial environmentally
sensitive habitat areas (ESHAs) as defined by the
Coastal Act. The sea level rise projection considered
shall be determined based on the type of
development and current State guidance.
6 6.48 CR-I-55:

Beach
Nourishment
In coordination with the California Coastal
Commission and other permitting agencies (e.g.,
State Lands Commission, U.S. Army Corps of
Engineers), the City shall evaluate a beach
nourishment program in conjunction with sand
retention structures to assist in maintaining beach
width and elevations, consistent with sub-area
policies. The beach nourishment program will
include measures to protect water quality and to
avoid (and where unavoidable to minimize and
mitigate) potential adverse coastal resource
impacts, including biological resource impacts,
from deposition of material, including measures
such as sand compatibility specifications,
restrictions on volume of deposition, timing or
seasonal restrictions, and identification of
environmentally preferred locations for deposits.

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

Delete and incorporated into CR-I-1 CCC suggested modification clarified that beach nourishment needs to be in compliance with
the Coastal Act. City staff proposes an
alternative modification that would delete CR-I55 and incorporate the language into CR-I-16. 6 6.49 CR-I-56:

Existing
Shoreline
Protection
Structures
Except as may be otherwise provided in the LCP
sub-area policies, legally permitted shoreline
protection structures may be repaired and
maintained, as supported by Section 30235 of the
Coastal Act, subject to all coastal development
permit requirements (including those associated
with the construction of the structure and/or prior
repair and maintenance episodes) until the
development they are protecting is removed or no
longer requires shoreline protection structures, at
which time the shoreline protection structure shall
be reevaluated for consistency with the LCP and
removed if no longer necessary. Activities
considered “repair and maintenance” shall not
result in any enlargement or extension of the
shoreline protection structure, or any seaward
encroachment or impairment of public trust
resources, and shall provide mitigation for any
new coastal resource impacts not previously or
otherwise mitigated, including through the City’s
Shoreline Mitigation Program (CR-I-5) and/or
Policy CR-I-59.

Except as may be otherwise provided in the LCP
sub-area policies, legally permitted shoreline
protection structures may be repaired and
maintained, as supported by Section 30235 of the
Coastal Act, subject to all coastal development
permit requirements (including those associated
with the construction of the structure and/or prior
repair and maintenance episodes) until the
development they are protecting is removed or
redeveloped pursuant to the definition of a
Substantial Structural Modification (SSM) or no
longer requires shoreline protection structures, at
which time the shoreline protection structure shall
be reevaluated for consistency with the LCP,
removed if no longer necessary and/or allowed,
and the area restored. Activities considered “repair
and maintenance” shall not result in any
enlargement or modification to the shoreline
protection structure, or any replacement of
materials in excess of 50%, or any seaward
encroachment or impairment of public trust
resources, and shall provide mitigation for any new
coastal resource impacts not previously or
otherwise mitigated, including through the City’s
Shoreline Mitigation Program (CR-I-5) and/or Policy
CR-I-59.

N/A CCC suggested modification revises the policy
to align with other provisions in the LCP,
Coastal Act, and CCC policy. Staff is not
proposing alternative modification.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification 6 6.50 CR-I-56:

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

Deleted Modifications to existing shoreline protection
structures which fall within the limitations of an
exclusion contained in the definition of Substantial
Structural Modification shall be considered to be
allowed without the above-mentioned
considerations.

CCC suggested modification deletes text related
to modifications to existing structures. City staff
is proposing an alternative modification to
clarify that maintenance and modification of
existing shoreline protection structures is
allowed.
6 6.51 CR-I-57: New
Shoreline
Protection
Structures
Shoreline protection structures, including
revetments, breakwaters, groins, seawalls, cliff
retaining walls, deep piers and caissons, and other
such construction that alters natural shoreline
processes shall be permitted consistent Section
30235 of the Coastal Act and with the LCP’s subarea policies only when required to serve coastaldependent uses or protect existing structures or public beaches in danger from erosion, when
designed to eliminate or mitigate adverse impacts
on local shoreline sand supply.

Shoreline protection structures, including
revetments, breakwaters, groins, seawalls, cliff
retaining walls, deep piers and caissons, and other
such construction that alters natural shoreline
processes shall only be permitted if consistent
Section 30235 of the Coastal Act and with the LCP’s
sub-area policies, and only when required to serve
coastal-dependent uses or protect existing
structures or public beaches in danger from coastal
hazards erosion, when there is no less
environmentally damaging feasible alternative and
when designed to avoid, and where unavoidable,
minimize to the maximum extent feasible adverse
impacts on local shoreline sand supply and other
coastal resources, where unavoidable coastal
resource impacts are required to be
commensurately mitigated
CCC suggested modification amends the policy
to address alternative evaluation and
minimizing coastal resource impacts. City staff
is generally in support; however, City staff is
proposing an alternative modification that
would replace the word “erosion” with “coastal
hazards” in order to be more inclusive of the
variety of coastal hazards affecting the
coastline and in recognition of the deleted subarea policies. 6 6.52 CR-I-58:

Authorization
Limits of
Shoreline
Protection
Structures
Shoreline protection structures shall only be
authorized until the time when the existing
structure protected by such shoreline protection
structure: 1) is/are no longer present, or 2) no
longer require(s) armoring. This policy shall not be
applied to justify the removal of a shoreline
protection structure which protects any structure
authorized to be constructed pursuant to an
exclusion contained in the definition of Substantial
Exterior Structural Modification.

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

N/A CCC suggested modification amends the policy
related to time limits on shoreline protection
structures. Staff is generally in support of the
modification, if alternative modifications to
other policies related to the Special Resiliency
Areas (SRAs) remain.

Gloss
ary

7.1 Anticipated
Life
N/A The period over which a development is expected
to be usable, with normal repairs and maintenance,
for the purpose for which it was designed, typically
a minimum of 75-100 years for residential and
commercial development and a minimum of 100-
150 years for critical infrastructure.

N/A CCC suggested modification adds new text from
CCC's adopted guidance for residential
development and critical infrastructure.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Gloss
ary

7.2 Beach The expanse of sand, gravel, cobble or other loose material that extends landward from the low
water line to the place where there is
distinguishable change in physiographic form, or
to the line of permanent vegetation. The seaward
limit of a beach (unless specified otherwise) is the
mean low water line.

The expanse of sand, gravel, cobble or other loose
material that extends landward from the mean low
water line to the place where there is
distinguishable change in physiographic form, or to
the line of permanent vegetation. The seaward
limit of a beach (unless specified otherwise) is the
mean low water line. The inland extent of the
beach shall be determined as follows:
1) From a distinct linear feature (e.g., a seawall,
road, or bluff, etc.);
2) From the inland edge of the further inland beach
berm as determined from historical surveys, aerial
photographs, and other records or geological
evidence; or
3) Where a beach berm does not exist, from the
further point separating the dynamic portion of the
beach from the inland area as distinguished by
vegetation, debris or other geological or historical
evidence.

N/A CCC suggested modification amends the text to
be consistent with Coastal Act.

Gloss
ary

7.3 Bluff A high bank or bold headland with a broad,
precipitous, sometimes rounded cliff face
overlooking a plain or body of water.

Deleted N/A CCC suggested modification deletes text to
eliminate redundancy.

Gloss
ary

7.4 Coastal
Hazards
N/A Include but are not limited to episodic and longterm shoreline retreat and coastal erosion, high seas, ocean waves, storms, tsunami, tidal scour,
wave overtopping, coastal flooding, and their
interaction, all of which may be exacerbated by sea
level rise.

N/A CCC suggested modification adds clarifying
language.

Gloss
ary

7.5 Development On land, in or under water, the placement or erection of any solid material or structure; discharge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste;
grading, removing, dredging, mining, or extraction
of any materials; change in the density or intensity
of use of land, including, but not limited to,
subdivision pursuant to the Subdivision Map Act
(commencing with Section 66410 of the
Government Code), and any other division of land,
including lot splits, except where the land division
is brought about in connection with the purchase
of such land by a public agency for public
recreational use; change in the intensity of use of
water, or of access thereto; construction,
reconstruction, demolition, or alteration of the
size of any structure, including any facility of any
private, public, or municipal utility; and the
removal or harvesting of major vegetation other
On land, in or under water, the placement or
erection of any solid material or structure; discharge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste;
grading, removing, dredging, mining, or extraction
of any materials; change in the density or intensity
of use of land, including, but not limited to,
subdivision pursuant to the Subdivision Map Act
(commencing with Section 66410 of the
Government Code), and any other division of land,
including lot splits, except where the land division is brought about in connection with the purchase of
such land by a public agency for public recreational
use; change in the intensity of use of water, or of
access thereto; construction, reconstruction,
demolition, or alteration of the size of any
structure, including any facility of any private,
public, or municipal utility; and the removal or
harvesting of major vegetation other than for
N/A CCC suggested modification adds new text to
clarify terms used in document and be
consistent with the Coastal Act.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification than for agricultural purposes, kelp harvesting,
and timber operations which are in accordance
with a timber harvesting plan submitted pursuant
to the provisions of the Z'berg-Nejedly Forest
Practice Act of 1973 (commencing with Section
4511).

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

In this LCP, ‘development’ is synonymous with ‘new
development.’
Gloss
ary

7.6 Environment
al Justice
The fair treatment of people of all races, cultures,
and incomes with respect to the development,
adoption, implementation, and enforcement of
environmental laws, regulations, and policies
The fair treatment and meaningful involvement of
people of all races, cultures, and incomes with
respect to the development, adoption,
implementation, and enforcement of
environmental laws, regulations, and policies
The fair treatment and meaningful involvement of
people of all races, cultures, and incomes with
respect to the development, adoption,
implementation, and enforcement of environmental
laws, regulations, and policies
The City’s General Plan consistency changes
eliminated this sentence and the suggested
modification is no longer applicable.

Gloss
ary

7.7 Existing
Structure
A structure that has any of the following
characteristics:
i) lawfully constructed prior to the certification
date of the LCLUP; or
ii) permitted for construction prior to the
certification date of the LCLUP, and all permits
remained in full force and effect prior to the date
of construction; or
iii) authorized to be constructed pursuant to an
exclusion contained in the definition of Substantial
Exterior Structural Modification.”
Deleted N/A CCC suggested modification deletes text to be consistent with CCC guidance.

Gloss
ary

7.8 New
Development
Development, as defined in Section 30106 of the
California Coastal Act, where no existing
development occurs. New Development does not
include the remodeling or improvement of an
existing structure, as defined, and also does not
include any structure authorized to be constructed
pursuant to an exclusion contained in the
definition of Substantial Exterior Structural
Modification.”
Deleted N/A CCC suggested modification deletes text to be consistent with CCC guidance.

Gloss
ary

7.9 Shoreline Intersection of the ocean or sea with land; the line delineating the shoreline on National Ocean
Service nautical charts and surveys approximates
the mean low water line from the time the chart
was pre- pared.

Seaward of the base of coastal bluffs and/or at or
near the sandy beach/ocean elevation, including as
depicted in Appendix B (“Coastal Zone Vulnerability
Maps”) and denoted as “wave run-up,” “storm
flood area,” and “flood prone area.”
N/A CCC suggested modification adds clarifying
language to be consistent with CCC guidance
Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Gloss
ary

7.10 Substantial
Exterior
Structural
Modification
(SESM)
Substantial Exterior Structural Modification
(SESM): Any physical improvement which modifies
an existing structure, as defined, to achieve any of
the following:
i) a seaward encroachment of the structure; or
ii) removal or replacement of 50 percent or more
of the linear length of the exterior walls, whether
or not the floor area or building footprint is
expanded; or
iii) an addition that includes new floor area at or
below the first story equal to 50 percent or more
of the structure’s total existing floor area; or
iv) an increase of the existing building footprint
equal to 50 percent or more;
but excluding any of the following:
i) removal, replacement, or maintenance of
nonstructural components of exterior walls such
as siding, shingles, and roofing materials and
windows;
ii) development on any site which is protected
from coastal erosion by an existing, permitted
shore- line protection structure;
iii) replacement of any structure pursuant to the
provisions of subdivision (g) of Section 30610 of
the Public Resources Code;
iv) the demolition and reconstruction of a singlefamily residence; provided, that the reconstructed residence shall not exceed either the floor area,
height or bulk of the former structure by more
than 10 percent, and that the reconstructed
residence shall be sited in the same location on
the affected property as the former structure; or
v) the reconstruction, repair, or maintenance of
any shoreline protection structure; provided,
however, that the reconstructed, repaired, or
maintained shoreline protection structure is not
seaward of the location of the former structure,
and that such modifications do not increase the
height or length of the former shoreline protection
structure by more than 10 percent.

Substantial Structural Modifications (SSM): Any
physical improvement which modifies an existing
structure in any of the following ways:
i) alteration, removal or replacement of 50 percent
or more of the linear length of the exterior walls, or
other major structural components (including but
not limited to floor, roof, and foundation
structures), whether or not the floor area or
building footprint is expanded; or
ii) an addition that includes new floor area equal to
50 percent or more of the structure’s total existing
floor area; or
iii) an increase of the existing building footprint
equal to 50 percent or more;
but excluding removal, replacement, or
maintenance of nonstructural exterior components
such as decorative siding, shingles, and windows.

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

Substantial Structural Modifications (SSM): Any
physical improvement which modifies an existing
structure in any of the following ways:
i) alteration, removal or replacement of 50 percent
or more of the linear length of the exterior walls, or
other major structural components (including but
not limited to floor, roof, and foundation
structures), whether or not the floor area or building
footprint is expanded; or
ii) an addition that includes new floor area equal to
50 percent or more of the structure’s total existing
floor area; or
iii) an increase of the existing building footprint
equal to 50 percent or more;
but excluding removal, replacement, or
maintenance of nonstructural exterior components,
such as decorative plywood roof sheathing,
underlayment, siding, shingles and other roof
materials, and windows, and other exterior
waterproofing/weatherproofing materials and
replacement of any structure pursuant to the
provisions of subdivision (g) of Section 30610 of the
Public Resources Code.

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

CCC suggested modification deletes text to be
consistent with CCC guidance. Staff is generally
in support of the modification; however, staff is
proposing an alternative modification to clarify
that nonstructural elements and waterproofing
materials are not part of the SSM definition.

Additionally, staff is proposing an alternative
modification that would introduce the language
related to subdivision (g) of Section 30610 of
the Public Resources Code.

Chapter Modific
ation
Number
Policy Number
and/or Subject
Addressed
City's Certification Draft CCC Suggested Modification Draft Alternative Modification Brief Summary/Justification Changes to exterior walls, floor area, height,
length, or building footprint shall be measured
cumulatively from those existing at the site on the
date of certification of the LCLUP. The cost of
improvements shall not be used as a basis in
application of this definition or any policy relying
thereupon unless expressly stated in the policy.

Pacifica City CouncilMarch 2, 2024

Pacifica City Council
March 2, 2024