City of Pacifica LCLUP Update FAQs, Page 1
This assortment of Frequently Asked Questions (FAQs) is provided to assist the public in understanding information about the LCLUP. This FAQ is provided as a courtesy to the public and is not intended to provide legal advice nor is it intended to be relied upon as the process for any specific project. The FAQ may be updated periodically with new information from time to time.
Basic Facts
What percentage of residents, homes, and
businesses would be affected by the LCLUP
Update?
Generally speaking, the LCLUP affects all of Pacifica’s residents and anyone that comes into Pacifica to work or visit. The Coastal Zone makes up about 15% of the land within the City of Pacifica. Nearly half of the land in the Coastal Zone is preserved as open space. Within the Coastal Zone, residential use makes up 21% of land. In addition, six out of the City’s seven hotels are located in the Coastal Zone. Much of the City’s public facilities and critical infrastructure, including the Sharp Park Library, Council Chambers, Civic Center, Calera Creek Water Recycling Plant and several sewer and stormwater pump stations and transmission pipelines, are located within the Coastal Zone.
Why does the 1980 LCLUP not meet the
City’s current needs? Why not just amend it
on an as needed basis? Why do we need a
brand new LCLUP?
The 1980 LCLUP is no longer adequate to meet the City’s various needs for a modern, comprehensive land use plan for the Coastal Zone (roughly 15 percent of Pacifica’s land area and a significant proportion of key facilities, infrastructure, and tax base). The 1980 LCLUP fails to prioritize the City’s housing needs, economic development objectives, environmental protection priorities, and other key community needs and also does not effectively address coastal erosion, sea level rise, and natural hazards that are becoming more severe due to climate change. The 1980 LCLUP also does not contain the required elements in Senate Bill (SB) 272 that requires LCLUPs throughout California to be updated to include a plan to address sea level rise no later than January 1, 2034.
In the over 40 years since the 1980 LCLUP was adopted, many of its goals have been carried out, including a zoning code with regulations to protect slopes and preserve open space, and the revitalization of the Rockaway Beach area. Many issues facing Pacifica are enduring but the legal environment governing land use, environmental preservation, housing, climate change adaptation and resiliency, and other planning issues have changed. New priorities have emerged with a new generation of Pacifica residents and stakeholders.
Can staff identify the undeveloped properties? Undeveloped properties can be found in Figure 4-1 of the 2040 General Plan.
How do the policies protect Pacifica? The policies in the 2020 LCLUP provide for greater environmental protection and clearer regulations for development. The 2020 LCLUP also includes the City’s first policies related to sea level rise adaptation that begin the City’s long-term efforts to confront the City of Pacifica LCLUP Update FAQs, Page 2
Basic Facts
challenges of sea level rise. These will provide clarity to property owners and other stakeholders as to how their properties may develop in light of sea level rise.
What is the 'modification' of the LCLUP in
response to exactly?
The City’s ongoing efforts on the LCLUP Update related primarily to responding to the California Coastal Commission as the City continues its efforts to obtain Coastal Commission certification of the 2020 LCLUP. The City is currently considering whether to request alternative modifications to those Suggested Modifications proposed by California Coastal Commission staff in March 2023, which can be found here:
https://www.coastal.ca.gov/meetings/agenda/#/2023/3
Involvement of other public agencies
How involved is State & Federal government
in this issue?
The California Coastal Commission is a state agency and the City has been engaging extensively with them. Other state agencies have been indirectly involved in the LCLUP Update process, which includes the Ocean Protection Council, the agency that publishes the official sea level rise projections for the State of California.
Is San Francisco involved? The City and County of San Francisco owns land within the City of Pacifica’s Coastal Zone; however, they do not have any decision-making authority related to the City’s LCLUP Update.
Role and Authority of CCC
Is there a better way (e.g., City wide
referendum) to protect the freedom and
choice of Pacificans, rather than giving power
to a small unelected group (CCC) to create
rules that impact an entire town?
Under state law, California Coastal Commission certification is required for an LCLUP to take effect. A referendum of Pacifica voters cannot replace California Coastal Commission certification. The City is continuing its efforts to explore policy approaches in the LCLUP that are acceptable to the Pacifica Council that may also be acceptable to the California Coastal Commission.
Who are the Coastal Commission? And
where do you get minutes and their policy.
And why are non-elected people making
rules in our community? (No accountability).
Information about the Coastal Commission, the Commissioners, and their meetings can be found here: https://www.coastal.ca.gov/. The Coastal Commission is comprised of 12 voting members, appointed equally (four each) by the Governor, the Senate Rules Committee, and the Speaker of the Assembly. A number of Coastal Commissioners are elected representatives of jurisdictions throughout the state, such as city councilmembers or county supervisors, although no process exists in state law to directly elect Coastal Commissioners.
How can an unelected Coastal Commission
make rules that infringe on our private
City of Pacifica LCLUP Update FAQs, Page 3
Role and Authority of CCC
property rights? We have a right to protect
our properties. Managed retreat is stealing
the peoples’ land isn't it? What right do
strangers have to think they can take
property owned and maintained by families
for years? Is there more concern for the
Coastal Commission ideology than for
families and people who live in and visit our
city?
The California Coastal Act grants authority to the Coastal Commission to carry out the purpose and intent of the Act, including adopting regulations for its administration.
Does the CCC recognize coastal protections? Yes, the Coastal Act allows shoreline protection structures such as seawalls and rock revetment. Public Resources Code section 30235 provides that shoreline protection structures “shall be permitted when required to serve coastal-dependent uses or to protect existing structures or public beaches in danger from erosion and when designed to eliminate or mitigate adverse impacts on local shoreline sand supply.” The interpretation of “existing structures” by the California Coastal Commission has changed over time, and the agency currently interprets the term to mean those structures in existence on the effective date of the Coastal Act (January 1, 1977).
How can the City and Planning Department
help us to prevent CCC from overreaching
their powers and changing the law the way
they see fit because this problem will not
only affect those near the sea but the
neighboring homes once the seawalls fall.
Planning Director Christian Murdock said at the
last meeting that the City does not have to follow
CEQA guidelines, and it is the responsibility of the
CCC – is that true?
Yes, for purposes of adoption of Local Coastal Program amendments by the City of Pacifica (this includes the LCLUP). See California Environmental Quality Act (CEQA) Guidelines Section 15265 (“Adoption of Coastal Plans and Programs”) which provides that “CEQA does not apply to activities and approvals pursuant to the California Coastal Act … by: (1) Any local government, as defined in Section 30109 of the Public Resources Code, necessary for the preparation and adoption of a local coastal program …” Section 15265 further provides that “CEQA shall apply to the certification of a local coastal program … by the California Coastal Commission.” The California Coastal Commission will perform environmental review pursuant to its certified CEQA-equivalent regulatory program.
Will the LCLUP Update be acceptable to the
Coastal Commission?
Staff has worked with the Coastal Commission staff and both staffs have discussed policies that are likely to be supported by the Coastal Commission. While the Coastal Commission Will this be accurate with the Coastal is made up of individuals, similar to Pacifica’s City Council, and they have discretion on how Commission?
City of Pacifica LCLUP Update FAQs, Page 4
Role and Authority of CCC
How likely is the Coastal Commission to
accept City Policies? Is it flexible and what
exactly does it want?
they vote, staff is confident and is working towards a document that is consistent with the Coastal Act and should be acceptable to the Commission.
How did the Coastal Commission’s position
change from 2020 to now?
The Coastal Commission staff submitted several comment letters during the course of the City’s LCLUP Update process leading up to City Council approval in February 2020.
However, it was not until 2023 that the Coastal Commission staff released its official set of suggested modifications, which can be found here:
https://www.coastal.ca.gov/meetings/agenda/#/2023/3, on the City’s LCLUP Update that it believed would be required to find the plan in compliance with the Coastal Act.
Coastal Commission should recognize
existing armoring and how can the City bring
CCC to that view?
The California Coastal Commission does recognize existing shoreline protection structures that have valid permits. However, the key issue for Pacifica is how to gain Coastal Commission recognition of existing armoring (i.e., shoreline protection structures) that serve an area wide function, that protect public streets and infrastructure, and that will be required over the long-term to protect public health and safety in Pacifica. City and Coastal Commission staffs have been working closely on potential policies to be included in the LCLUP Update, known as Special Resiliency Areas (SRAs), that would address this issue in the West Sharp Park and Rockaway Beach neighborhoods.
What is CCC's timeline? The Coastal Commission is bound by statutory timelines to act on the City’s LCLUP Update once accepted for filing. These timelines are generally 90 days for action, unless the Coastal Commission grants itself a 12-month extension.
Why are the bullets on page 6 of the staff
report ranked, and why are they ranked in
that manner?
In the December 5, 2023 staff report, under the Coastal Resources Enhancements section, the list of bullet points is ordered from highest to lowest priority under the Coastal Act and the policy direction of the California Coastal Commission staff.
Why does the Coastal Commission deny the
existence of coastal armoring on its map of
Pacifica?
The armoring reflected in CCC maps of Pacifica include only permitted armoring. It is the case that some of existing armoring along the coast was never permitted by the CCC or was authorized with permits previously which have expired and owners have not yet removed it or obtained new permits.
Role of the City
The city as a whole will have to bear the
burden for few coastal properties; why?
The Coastal Zone is an important component of the City of Pacifica. Approximately 15% of the City’s land area is in the Coastal Zone, as well as # out of # hotels, and numerous key City facilities and infrastructure including the Calera Creek Water Recycling Plant (CCWRP), City of Pacifica LCLUP Update FAQs, Page 5
Role of the City
Civic Center, Council Chambers, Sharp Park Library, and numerous sewer and stormwater pump stations and transmission pipes. The entire City relies on these facilities and infrastructure. Therefore, it is important for the entire community to be involved in creating the long-term policy approach for the Coastal Zone that is described in the LCLUP Update.
Why is the City giving in to the CCC? The City is not giving in to the CCC. Adoption of an updated LCLUP is in the City’s best interests for a number of reasons. The 1980 LCLUP is not adequate to continue guiding the City’s actions in the Coastal Zone on a long-term basis. Many objectives of the 1980 LCLUP have been accomplished, such as protection of key beach and open space areas and formalization of public coastal access, while its assessments of some coastal neighborhoods are no longer reflective of the challenges and needs of those areas. The City Council has recognized since at least 2009 that an update was needed to accomplish changing prioritizes ad effectively address climate change and sea level rise (SLR). State law, as enacted in late 2023 with Senate Bill (SB) 272, now requires LCLUPs throughout California to be updated to include a plan to address SLR. The 2020 LCLUP has largely addressed these requirements already. Further delay of the LCLUP Update will only constrain Pacifica’s timeline for adoption by the SB 272 deadline in the future, and would deprive Pacifica of as much as a decade of the various benefits to LCLUP adoption that have been previously discussed if adoption were to occur closer to the deadline.
While it is important for the City to vigorously pursue policies in its LCLUP that best serve the City’s interests, it is also important to recognize that the Coastal Act affords the CCC significant substantive and procedural authorities with power equivalent to the City in the LCLUP process. Therefore, it is important for both agencies to reach agreement on the content of the LCLUP in order for certification to be achieved, and insisting on policies in the City’s LCLUP that the CCC will reject will not advance the City closer to CCC certification of an LCLUP update. City staff is working closely with CCC staff to seek areas of compromise to move the plan forward.
Why would City Council sacrifice almost the
entire coast of Pacifica for two carved out areas?
Please see response above. Additionally, the West Sharp Park and Rockaway Beach areas contain higher densities and prevalence of existing development, including high proportions of pre-Coastal Act development, concentrations of essential Coastal Actsupported land uses, presence of critical public rights-of-way and infrastructure, and existence of broad shoreline protection benefiting multiple public and private landowners, City of Pacifica LCLUP Update FAQs, Page 6
Implementation of 2020 LCLUP
What will the implementation process look
like?
Similar to how the 1980 LCLUP was implemented, the 2020 LCLUP will be implemented in stages through a variety of public and private actions. An immediate step following LCLUP certification will be City work to update the Implementation Plan (IP) of the City’s Local Coastal Program, which includes the zoning regulations, zoning map, and other City policies and programs to implement the LCLUP. City Council approval of the IP followed by Coastal Commission certification will be required. Private party implementation generally will occur as private development projects are proposed.
Additionally, if the 2020 LCLUP contains Special Resiliency Area (SRA) policies, some implementation programs will require a proactive approach, such as the Visitor Amenity Improvements and potentially Beach Nourishment programs.
How will city apply new obligations in admin
of the LCLUP?
How will the city keep up?
Will it be forever? The 2020 LCLUP is intended to provide the policy approach for the City’s coastal zone until the year 2040. The City should begin work on the next iteration of the LCLUP prior to 2040.
The City Council also retains discretion to amend the LCLUP at any time, subject to followWhat is the timeline? on certification by the Coastal Commission.
Role of the City
which complicated potential future removal. Further, as described in the case studies document prepared for the March 2, 2024, community meeting, the CCC’s most restrictive policies are de facto in effect in much of Pacifica’s Coastal Zone already due to the CCC Appeal Jurisdiction. Therefore, one sensible approach is to update the LCLUP to derive other benefits for the City, such as the Special Resiliency Area (SRA) policies that would significantly benefit development potential in the West Sharp park and Rockaway Beach neighborhoods.
The Coastal Commission hasn’t even voted to
accept the CCC staff’s revisions. Why is City Staff
rushing to accept this raw deal?
The LCLUP Update process has been ongoing for nearly 15 years. The process has not been rushed, and key policies are being thoroughly considered as part of a robust public process that involves the community and decision makers. The City Council will have the ultimate discretion whether to accept Coastal Commission’s final modification to achieve a certified LCLUP..
City of Pacifica LCLUP Update FAQs, Page 7
2020 LCLUP Not Certified
What happens if we don’t get approval from the
CCC?
If the CCC were not to approve the City’s 2020 LCLUP, the 1980 LCLUP would remain in place as the certified document. However, the 1980 LCLUP no longer serves the City well to guide public and private activities in the Coastal Zone.
The City will have six months from any future Coastal Commission certification to locally adopt any changes implemented by the Coastal Commission. If the City did not approve the LCLUP as certified by the Coastal Commission, the certification would become null and void after six months and the 1980 LCLUP would remain in the place as the certified document.
What happens if the city does not make the
changes the CCC requested? It is understood
they would default to the 1980 plan, but don’t
really understand the implications of that.
What is Plan B if the CCC does not approve the
SRAs? Will the City then accept the CCC proposed
modifications?
Currently, staff is confident that the coordination between the City and CCC will result in the SRAs being certified by the CCC if City Council decides to include them in the LCLUP.
While confident, the City staff cannot be certain unless and until a CCC certification hearing to consider the SRA policies occurs. There may be additional modifications that are proposed to the SRAs and the City Council will have the ultimate discretion whether to accept Coastal Commission’s final modification to achieve a certified LCLUP As noted in an answer above, the City Council retains ultimate discretion whether to accept the CCC’s suggested modifications. However, only through mutual agreement between the City and CCC can new policies take effect in an updated LCLUP. Failure to reach agreement will result in the 1980 LCLUP remaining in effect which City staff believes is not in the City’s best interests.
Effects on Property
Commerce centers are prioritized [but]
residential is not so much. Would the RV
park/mobile home park also be protected? Is
space between these also visitor serving?
Does the 100 year plan affect temporary
structures?
The Coastal Act supports protection of existing structures. The Coastal Commission currently interprets “existing structures” to mean those in existence on the effective date of the Coastal Act (January 1, 1977). Structures constructed after January 1, 1977, are likely to encounter significant difficulty obtaining Coastal Commission approval of shoreline protection structures. The same is true for structures that may have expanded or redeveloped in excess of the 50% threshold currently used by the Coastal Commission to determine when an “existing structure” shall be considered new development for purposes of shoreline protection structures. Permitting of existing structures is within the City of Pacifica LCLUP Update FAQs, Page 8
Effects on Property
Coastal Commission’s jurisdiction and not an issue the City can address within its own jurisdiction.
What the City can strive to do is include policies in the LCLUP that are as supportive as possible of shoreline protection structures under circumstances that are also agreeable to the Coastal Commission. Similarly, the City can also pursue policies in the LCLUP that address circumstances not accounted for in the Coastal Act, such as publicly-owned shoreline protection structures that are providing protection to public infrastructure, behind which private property with post-Coastal Act development would also receive benefit from that protection. The City is exploring ways to accomplish this, which is the purpose of the Special Resiliency Area, or SRA, policies.
Who can I talk with about my property and
how these policies affect me and my future
and property? If this, then this type of
discussion.
You can contact City of Pacifica Planning Department staff to discuss. Business hours and contact information are available on the Planning Department webpage. An appointment is recommended.
Homes in coastal areas will be flooded.
Certain beloved landmarks exist in these
areas, like old restaurants. How will we
protect these landmarks?
The 2020 LCLUP identifies different types of flooding hazards, including storm-induced flooding and coastal flooding. Many historical landmarks will be considered “existing structures” for purposes of shoreline protection structures, which can be one way of minimizing risks from coastal flooding hazards. Whether a permit for shoreline protection can be approved is a property- and fact-specific inquiry and in general, individual property owners are responsible to pursue construction of shoreline protection structures when eligible and desired. In the SRAs, these landmarks will have the protection of existing shoreline protections structures and will be allowed to adapt, if necessary.
How will this impact our home or business?
Looks like the SRAs are good for the two
vulnerable areas included, but what about all
the other neighborhoods?
The case studies that will be presented in the staff report for the March 2, 2024, community meeting explain a number of common scenarios. The ability to construct shoreline protection structures depends on the specific facts applicable to a given property. The Special Resiliency Areas, or SRAs, are one example of how a compromise approach with the Coastal Commission could result in additional protections for parts of Pacifica.
Why is the rest of Pacifica’s coastal
development still subject to managed retreat
regulations?
There are no managed retreat policies proposed in the LCLUP Update. Rather, the update would modernize the City’s 40+ year old 1980 LCLUP to reflect the applicable legal and regulatory environment applicable today. This includes but is not limited to development regulations and policies that recognize the significant hazards present in Pacifica’s Coastal City of Pacifica LCLUP Update FAQs, Page 9
Effects on Property
Zone. In some cases, the presence of significant hazards will affect the development potential of property. But it is the case that the Coastal Act limits the authorization for shoreline protection structures to “existing development,” as that term is interpreted and applied by the Coastal Commission, which is a matter beyond the City’s jurisdiction or control.
Will I lose my investment (my home/property
or ability to sell) if so, when, because I live in
West Fairway Park but outside the SRA?
There are no provisions in the 2020 LCLUP that propose to take property from private property owners or to force any individual property owner to sell a property. However, it is important to note that a variety of hazards affect property in the Coastal Zone, including but not limited to flooding and coastal erosion hazards. The 2020 LCLUP makes a major advancement over the 1980 LCLUP to identify and map those hazards so that appropriate policies to minimize the risks to development can be implemented. Within the Special Resiliency Areas, or SRAs, reliance on existing shoreline protection structures is one important way that hazard mitigation can be accomplished when considering development on sites within the SRAs.
How will homeowners be compensated for
their losses? How does the city plan to pay
for all the law suits that will result if the CCC
plan is accepted by City Council?
The potential impact of the LCLUP is dependent on the specific circumstances of each property, including the location, size, and specific site conditions, all of which determine the specific policies that would apply. Generally, policies within the LCLUP encourage existing homes to look at other adaptative measures to protect the homes aside from shoreline protection structures. Thus, any potential allegations of losses would need to be Who will compensate us for the lost value of analyzed on a site-specific basis. our properties and businesses? If the City
decides to move forward with the CCC
changes to the LCLUP, this is a taking, unless
we are going to be compensation. I pay
current market rate property taxes, is the
City going to pay me the current market rate
value of my property to leave Sharp Park? Is
the City and County expecting us to pay
current market rate property taxes when our
properties are losing value due to redlined
maps found on the internet? How will you
address the concerns of lenders and insurers
City of Pacifica LCLUP Update FAQs, Page 10
Effects on Property
who are already looking to pull out of Sharp
Park?
What conditions can you add to the LCLUP to
provide a more equitable treatment of
private citizens that have an investment in
coastal property? These are our homes, and
we should be allowed to protect them, as
there is no infringement on the public good.
If protection is denied, is that considered a
“taking” of private property and should we
be compensated?
What do you expect to happen to properties
and property value in Pacifica if CCC staff’s
recommendation are accepted? Won’t this
cause blight throughout the Pacifica?
The City alternative modifications and SRA policies are an attempt to increase investment and development potential in two densely developed neighborhoods in Pacifica – Rockaway Beach and West Sharp Park. Implementation of CCC suggested modifications related to existing structures may require property owners to take on additional, unanticipated costs triggered by otherwise typical projects such as additions on properties throughout the City. The potential increase in cost could lead to disinvestment in these properties due to property owners choosing not to significantly improve property in order to avoid triggering the SSM definition. Reduced investment in turn could lead to deteriorated housing and blighted conditions. The SRA policies would reduce this potential for disinvestment and blight in the areas where the SRA policies would apply, and provide a clear framework for ongoing investment and development in the SRA areas which will enhance these highly-visible and frequently visited neighborhoods.
If we live on the ocean, what are the
alternatives? What if we can’t afford these
alternatives?
There are proactive and reactive ways that policies in the 2020 LCLUP could affect an individual property owner such as one living directly along the shoreline. A proactive way is proposal of new development or an alteration to existing development. The case studies prepared for the March 2, 2024, community meeting explain a variety of scenarios that may be applicable to such a property.
A reactive way that the 2020 LCLUP policies could affect a shoreline property is coastal hazard damage. The Coastal Zone is a highly dynamic area subject to various hazards. The 2020 LCLUP makes a major advancement beyond the 1980 LCLUP to identify these hazards City of Pacifica LCLUP Update FAQs, Page 11
Effects on Property
and put in place policies to minimize the risks from these hazards. The case studies also assess scenarios where a property is damaged by hazards and how that property may repair or rebuild depending on the nature of the damage.
In general, properties will only be required to implement adaptation measures when development is proposed triggering the Substantial Structural Modification (SSM) criteria or when a property is damaged and the repairs meet the threshold for an SSM. The City is not proposing exact stringent adaptation measures and instead would allow for each property to adapt depending on the specifically applicable coastal hazards. If the private development project triggers the SSM criteria, the adaptation measures required would be part of the cost of development. In certain cases, if Special Resiliency Area or SRA policies are put in place, some properties that are repeatedly and significantly damaged by coastal hazards may not be allowed to repair to the pre-damage condition.
How has the City of Pacifica considered and
addressed the inconsistency in how parts of
the coast will be able to develop and the
inequality that it will create between
neighborhoods?
As explained elsewhere, the City’s 1980 LCLUP is more than 40 years old and does not reflect the current state of the law and the Coastal Commission’s interpretation and application of the law as it pertains to coastal planning issues. It is not possible at this time to obtain the Special Resiliency Area (SRA) policies for the entirety of Pacifica. However, successfully enacting these policies will enhance development potential in two critical neighborhoods in Pacifica that are home to significant public access and recreation resources, public infrastructure and facilities, and commercial and economic tax base for Pacifica. Applying the SRA policies to these areas would be beneficial to Pacifica overall.
Effects on Property – Commercial
How do the Special Resiliency Areas (SRAs)
affect commerce?
In general, the SRAs would provide greater development potential for properties in the SRA than would otherwise be available outside the SRAs. This would facilitate greater commerce in the SRAs. See the case studies prepared for the March 2, 2024, community meeting for more information the SRAs.
How do we protect business important to the
economy and homeowner rights?
In an attempt to provide maximum development potential and economic use of properties in existing neighborhoods, City staff is proposing an alternative modification to incorporate the Special Resiliency Area (SRA) policies.
What financial resources do we have if we
remove commercial zoning?
The LCLUP does not propose to remove commercial zoning. However, in some cases, the LCLUP proposes to expand mixed use commercial and residential land uses.
City of Pacifica LCLUP Update FAQs, Page 12
Erosion
Are there cost effective plans to hold back
erosion now rather than fighting it down the
line when it may be too late?
The City is currently working on several shoreline protection projects, including the Beach Boulevard Infrastructure Resiliency Project (BBIRP), 310-330 Esplanade Infrastructure Preservation Project, and the 400 Esplanade Esplanade Infrastructure Preservation Project.
Additionally, individual property owners may qualify to construct shoreline protection structures to protect their property. There are also non-structural shoreline protection techniques identified in the 2020 LCLUP that the City intends to explore, contingent on funding and technical feasibility.
What tools do we have to protect the bluff?
Who is exploring the technologies, what have
other cities done to successfully protect bluff
top erosion?
The City’s Vulnerability Assessment and Adaptation Planning Process, which informed the LCLUP Update process, relied on technical advice from expert coastal engineers. The City’s experts explored a range of technical solutions that could provide shoreline protection other than traditional seawall techniques, and the 2020 LCLUP encourages incorporation of these methods contingent on funding and technical feasibility.
Sand Retention
Sand Retention – Are natural resources being
replenished? Public communications on how to
know who and what are making resource
decisions.
The City currently does not have a sand retention or replenishment program. There are policies in the 2020 LCLUP that support sand replenishment efforts contingent upon funding and technical feasibility. Any such efforts will require a public process for permitting, in which the community can provide additional input. Undertaking any such replenishment activities will require close coordination between the City of Pacifica and the Coastal Commission.
Coastline
Moving coastline back = what does that do to
current zoning?
Long-term adaptation planning is a complex task. It may involve changes in allowable density and intensity of certain land uses over time. In general, the 2020 LCLUP does not propose major land use or zoning changes along the shoreline and overall supports continuing land use consistent with the development pattern in Pacifica for the near-and medium-terms.
City of Pacifica LCLUP Update FAQs, Page 13
Substantial Structural Modifications
Are roof replacements considered an SSM? No, the SSM definition does not include nonstructural elements such as shingle replacements. See the case studies in the staff report prepared for the March 2, 2024, community meeting for more information. The Plan Pacifica webpage also includes a detailed explanation of LCLUP policies that would govern roof replacements.
Does 50% replacement policy include floors
and roofs?
Clarify the 50% rule, is it cumulative? What type
of repairs qualify. Deferred maintenance count, if
you do a repair and find lots of damage
additionally to the repair will this be triggered? If
a tree falls on my house, can I rebuild? Is it
discretionary and if so who makes that
determination. Selling a house, does an
inspection show major issues, affect a potential
sale and if needed can you go over the 50%?
The Substantial Structural Modification (SSM) definition states that incremental changes are cumulative, which means that the definition could be triggered with one project or a number of smaller projects that add up to 50%. SSM does not prohibit projects that surpass the 50% threshold, instead it means that once the threshold is met there are a number of other policies that are triggered, such as CR-I-43 Technical Reports and CR-I-44 Siting and Design. These policies may require modifications to an existing structure to mitigate hazards and such work may be beyond the scope of the initial project intended to be undertaken. In the Special Resiliency Areas, a project triggering the SSM definition will be required to correct nonconformities related to hazards and coastal resources only.
See the case studies in the staff report prepared for the March 2, 2024, community meeting for more information on application of the SSM to various development and hazard damage scenarios.
The application of cumulative SSM modifications will be based on available permit records, the availability of which will vary by property. In the event a property already exceeds the SSM threshold, further action by the property owner will not be automatically triggered.
However, any further structural modifications to the property could trigger the requirements of the SSM definition and associated policies.
How is the 50% threshold met? The
definition is unclear.
What is the definition of 'incremental' in the
SRA's? Most of the 50% could already be
filled for properties depending on definition.
Is it cumulative since 1977? Cumulative per
owner? Per property?
Who is making decision on percentage of
project fixes and how is that determined?
City of Pacifica Planning Department staff will be implementing the Substantial Structural Modification regulations and making determinations based on available permit records, which will vary by property.
Why must property owners waive their rights
to protection from coastal armoring in the
SRA’s if they are granted a permit for an
SSM?
The Coastal Act only authorizes shoreline protection structures for existing development.
The Coastal Commission has interpreted that significant modifications to property, such as that in the Substantial Structural Modification (SSM) definition, effectively makes existing development into new development and thus, ineligible for shoreline protection structures. The deed restriction to waive rights to future shoreline protection is the CCC’s preferred method to effectuate the referenced Coastal Act provision. In any case, authorization to construct shoreline protection structures is outside the City’s permit City of Pacifica LCLUP Update FAQs, Page 14
Substantial Structural Modifications
jurisdiction and the City must follow the CCC’s approach on this subject. However, no property owner is obligated to undertake an SSM and can choose to retain “existing structure” status if desired (unless improvements are required to ensure minimum habitability under the California Building Code or to eliminate nuisance conditions under the Pacifica Municipal Code).
Why does the CCC’s version of SSM modify
Pacifica’s definition to line out almost all of
the Exclusions taken directly from Sec. 30212
of the Coastal Act?
The CCC’s suggested modifications to the SSM definition are consistent with their recent practice and planning guidance on this subject.
Deed Restrictions
Deed Restrictions/Disclosures – do these come
into play?
The LCLUP would require approvals for development in the Coastal Vulnerability Zones and Tsunami Evacuation Zones to require a deed restriction stating that the owner assumes liability and indemnifies and holds the City, its officers, agents, and employees harmless, including any injury and/or damage from coastal hazards in connection with the permitted development; unconditionally waives any claim of damage from coastal hazards against the City; waives rights to future shoreline armoring; acknowledges the development may need to be removed and the site restored in response to future hazard conditions; and assumes all responsibility for any adverse effects to property caused by the permitted project and/or need for removal or relocation.
City staff is proposing an alternative modification that would change the disclosures requirements from the Tsunami Evacuation Zone to the Tsunami Inundation Zone, which generally will be a lesser area of Pacifica where tsunami inundation is more likely to occur, thus making the deed restriction requirements more closely related to the presence of an actual hazard.
CCC staff wants development restrictions to
apply to tsunami evacuation areas. These areas
extend far beyond just the coastal area, such as
the Linda Mar Shopping Center and surrounding
neighborhoods. What are these restrictions and
for what purpose?
City of Pacifica LCLUP Update FAQs, Page 15
Definitions
Further definitions of LCLUP terms compared
to CCC.
The CCC suggested modifications make changes to many of the definitions in the City’s LCLUP to ensure they are consistent with the Coastal Act. Please refer to Attachment C Summary Table with CCC Suggested Modification and Alternative Modifications. “Non conformity” definition. The City’s LCLUP has a definition for Non-Conforming Use and Non-conforming Structures.
There are no suggested modifications to these definitions. City of Pacifica Planning Department staff would be responsible for making determinations on the presence of any nonconformities on a property. Nonconformities are assessed based on the condition of a specific property relative to existing regulations that are in effect at time of the determination.
Non-conforming Use: “A use of a structure or land that was lawfully established and maintained, but which does not conform with the use regulations or required conditions for the district in which it is located by reason of adoption or amendment of this code or by reason of annexation of territory to the City.”
Non-conforming Structure: “An existing structure that is legally nonconforming with an LCP standard.”
What does a nonconformity mean?
What constitutes nonconforming and who
deems this as nonconforming?
What is the baseline date for any structures
in the context of nonconforming?
What is clear for what is existing vs a new
development?
While there is no definition of “existing” in the Coastal Act, California Coastal Commission has interpreted “existing structures” to mean those structures in existence on the effective date of the Coastal Act (January 1, 1977). It is also possible that alterations to a structure in excess of the thresholds in the Substantial Structural Modification (SSM) definition could result in a structure being treated substantially similar to a new development, including for purposes of qualifying for shoreline protection structures. The alternative modifications proposed by City staff to implement Special Resiliency Area or SRA policies would minimize the effect of the SSM definition on many properties in the SSM and expand development potential beyond that which would otherwise apply outside the SRA.
How is the City redefining the meaning of
“existing development”?
The City and Coastal Commission disagree on a reasonable interpretation of the term “existing structure.” To address this issue, the City staff proposes an alternative modification that would not include a local definition of “existing development” or “existing structure” in the LCLUP and which instead would rely on how those terms are more broadly interpreted under the law. At present that would mean an interpretation consistent with the Coastal Commission’s preferred position, which is structures in What is the definition of “existing”? existence on the effective date of the Coastal Act (January 1, 1977) and which have not City of Pacifica LCLUP Update FAQs, Page 16
General SRAs
What are the SRAs and how were they
chosen?
The SRAs are “Special Resiliency Areas” which are areas that have existing development with significant amounts of pre-Coastal Act development, a mix of public streets and infrastructure, land uses prioritized by the Coastal Act, and significant unified public coastal access. Planning staff created the criteria and identified the areas that meet that criteria in close coordination with Coastal Commission staff.
What is the process to determine SRAs?
SRA? How will it affect those not in the SRA
zone?
Areas outside of the SRA will be subject to generally applicable policies in the LCLUP.
Is the Sharp Park Specific Plan motivating the
SRA?
No, the Sharp Park Specific Plan was approved in 2022 as part of the General Plan Update process, before the concept of Special Resiliency Areas or SRAs had been developed. The SRAs would benefit implementation of the Sharp Park Specific Plan, however, by allowing development to occur in reliance on the existing Beach Boulevard shoreline protection structures.
Why is the quarry not included in the SRA to
be used as mitigation?
The SRAs do not identify any specific mitigation measures or areas for mitigation. The Visitor Amenity Improvement policy outlines the overall approach and states that the implementation plan will be created with public input and updated every 5 years. It is possible that Visitor Amenity Improvements could occur in the Rockaway Quarry area either on City property or in cooperation with the private property owner.
If there is an existing seawall in an area, is it
considered an SRA?
Not automatically, as there are several criteria for an area to be considered a SRA.
What precedents are there from SRAs? The SRA policies would be a novel approach to implement LCLUP policies that balance statewide priorities in the Coastal Act with unique local conditions in this way. The City is not aware of any precedential value and expansion of SRAs to other locations in Pacifica would require further coordination with the Coastal Commission and a subsequent LCLUP amendment.
Definitions
undergone a Substantial Structural Modification (SSM). However, by choosing not to define the term in the LCLUP, the City enables an evolving definition of “existing structures” that may emerge from ongoing litigation against the Coastal Commission on this subject, as well as any subsequent clarifications made by the California Legislature in state law.
City of Pacifica LCLUP Update FAQs, Page 17
General SRAs
Will the SRA line continue to move or is it
static?
If certified by the California Coastal Commission, the SRA boundaries will be part of the LCLUP. If the boundary were to be changed, it would require an LCLUP amendment certified by the CCC. While staff has not identified a justification for a SRA boundary change at this time, a boundary change is possible if conditions change and agreement can be reached with the CCC.
How often are these areas re-evaluated
(zones/SRAs)?
Have any communities implemented SRAs? Currently, there are no other jurisdictions that have received certification of an LCLUP with this concept. However, ‘carve-outs’ to reflect unique local conditions is a concept that has also been called ‘neighborhood planning’ by the California Coastal Commission and is being explored in various jurisdictions throughout California.
Have any other cities developed in SRA, like
Santa Cruz, Capitola or Monterey?
Does SRA have CCC’s blessing? The SRA concept originated from the CCC’s work with local governments across the state.
While there is growing support for the concept, the policy specifics have not yet been certified by the CCC for any jurisdiction and California and the City of Pacifica has the potential to be the first. Acceptance of the specific approach being contemplated in Pacifica will not be known until the certification hearing at the CCC – however, City staff has been working in close coordination with CCC staff to craft policies they believe will be acceptable to the CCC.
What does it mean to live in an SRA vs a nonSRA, who is getting more protection? The case studies prepared in the staff report for the March 2, 2024, community meeting include additional information on the differences between SRA and non-SRA areas.
If the Pacifica City Council were to approve the
new SRA areas (a compromise with City Staff and
CCC) - when would this take effect? We are not
experiencing Sea Level rise at this time. Does this
happen immediately upon approval of the
revised LCLUP or at a later date? Months, 1 year,
5 years, 20 years, 50 years? What would be the
triggering event? And how much notice will
property owners have of this effective date and
how will they be notified? (ie: replacing a roof
means putting a deed restriction on my property
giving up my shoreline protections)
If the City Council approved the Special Resiliency Areas (SRA), they would become effective once the LCLUP document is certified by the California Coastal Commission and subsequent adoption by City Council.
The triggering event for LCLUP policies that affect private property will generally be an event that requires a coastal development permit (CDP), such as an addition or new development. These policies do not have effect for properties automatically upon adoption. As explained in the case studies prepared for the March 2, 2024, community meeting, re-roof projects and other routine property maintenance will not trigger a requirement for a deed restriction to waive rights to future shoreline protection structures.
Why is staff proposing Special Resiliency Areas
(SRAs) to protect two small areas of Pacifica
when Section 30235 of the Coastal Act already
The purpose of the SRA policies is to allow ongoing economic use and vitality of property, provision of public services, operation of visitor-serving uses, and protection of broad coastal access. The SRAs would continue to rely on existing shoreline protection, while also City of Pacifica LCLUP Update FAQs, Page 18
General SRAs
provides these protections to existing
development?
requiring implementation of adaptation measures to be incorporated into development.
The main focus of the SRA policies is future development and protection of existing development.
How does the “Alternative Adaption
Strategies/SRA” concept actually further “longterm adaptation planning and coastal resource protection” and/or a balanced approach, when it
essentially is presented by the City of Pacifica
staff as a plan to continue armoring into
perpetuity?
The SRAs focus on already developed area of the City. By providing additional protection and flexibility to these areas, it allows other areas of the City to be protected and/or conserved.
SRA Policy #1 – Development Protected with Existing Shoreline Protection Will policy #1 allow development? Yes, the intent of SRA Policy #1 is to streamline development and allow development in the SRA to rely on the existing shoreline protection when designing the project. Note, however, that specific language is still under development between City and CCC staffs, and the language referenced in this question is one example of the way the SRA policies may be implemented.
Coastal Hazards Induced Damages
What will homeowners do if they have to
abandon property due to hazard/access?
Decisions to abandon property will remain up to individual property owners and will not be dictated by any policies in the LCLUP. A property subject to the coastal hazards induced damages policy may be allowed to redevelop subject to meeting all generally applicable LCLUP policies, which would not include reliance on existing shoreline protection structures, except for properties covered by the SRAs.
Property owners would remain individually financially responsible for their properties.
Where will funding come from, how, and
what's the plan to get it?
2 events within 1 year. Is that a red tag? A repetitive coastal hazard damage policy is no longer part of the SRA policies. CCC staff indicated during recent staff-to-staff discussions an interest in potentially applying a repetitive coastal hazard damage policy to certain high-risk areas of Pacifica, to be determined at a later date (separate from ongoing discussions of SRA policies), if deemed necessary by the CCC during the certification hearing process as a further offset for the City of Pacifica LCLUP Update FAQs, Page 19
SRA Policy #4 – Shoreline Management Plan
What are the specifics on the coastal
resource enhancements?
At this time there are no specifics. As stated in the policy language, the City implementation plan associated with this policy will include a community outreach process that will allow the community to provide input on what the specific visitor amenity improvements will be. The creation of the implementation plan will occur postcertification.
The policy states that the implementation plan will be updated every 5 years. Every 5 years the City will have to go through a process of inventorying the projects achieved and create the plan for the next 5 years. Frequently updating the plan will ensure that the City’s vision and need for coastal resource mitigation is up-to-date. Frequent updates to the implementation plan will also allow the City to identify possible funding gaps for future projects.
What are plausible examples of “substantial”
trade-offs/offsetting benefits that might
garner approval by the CCC to approve the
proposed Special Resiliency Areas (SRAs).
Trails, picnic areas and bathroom
enhancements are standard improvements
and should not be construed as “substantial”.
How would these “substantial”
enhancements be funded?
How does a 5 year implementation work?
Where is the money best spent in relation to
improvements for the particular areas that have
potential impacts? Which area is chosen over
others?
What's the relationship between maintaining
seawall and amenities?
Currently, there is no relationship. The Shoreline Management Plan policy states that an Implementation Plan will be created post-certification of the LCLUP and that the Implementation Plan must contain a variety of projects to offset the allowance for development that relies on existing shoreline protection structures. Factors affecting Coastal Hazards Induced Damages
SRA policies. The repetitive coastal hazard damage policy would essentially require development to be modified or removed after a third coastal hazard damage event that has resulted in a cumulative total of 25% of the pre-damage appraised value or repairs that trigger the SSM definition (essentially the same as presented in Meeting #2 on this topic).
City staff needs to further explore the specific locations CCC staff has in mind for application of such a policy, but in the interest of full disclosure to the public and Council and the timing of LCLUP Meeting #3, City staff has included discussion of this policy concept for City Council consideration.
City of Pacifica LCLUP Update FAQs, Page 20
SRA Policy #4 – Shoreline Management Plan
maintenance of shoreline protection structures such as seawalls are separate from and independent of the visitor amenities improvements. However, failure to fulfill the requirements of the Visitor Amenity Improvement Policy could result in suspension of the development allowance within the SRA until compliance is achieved.
Coastal Vulnerability Zone
What is the Coastal Vulnerability Zone and
what does it mean for each neighborhood?
In 2018, the City prepared a Sea Level Rise Vulnerability Assessment to identify areas that would be affected by projected sea level rise, erosion, flooding and other coastal hazards.
These maps are based on technical analysis of the presence of applicable hazards. Some of the 2020 LCLUP policies affect properties in these area because the City has identified a hazard and thus addressing the hazard will be necessary in the course of development reviews.
What triggers are there when a property sells
in a hazardous coastal zone?
The City does not currently have and has no plan to establish any sort of notification or requirement for selling properties within the Coastal Vulnerability Zone. The 2020 LCLUP policies will only be implemented if and when development is proposed, or if a property incurs significant hazard damage.
Pacifica’s 2020 LCLUP draft protected the
SHORELINE from NEW development. CCC
staff's changes make those same restrictions
apply to EXISTING development in coastal
vulnerability areas and tsunami evacuation
areas (basically, everything west of Highway
1, according to city maps). What is the legal
and legislative authorization to make these
demands on Pacifica homeowners?
While the CCC suggested modifications expand the areas that many of policies apply to, none of the policies are implemented until development is proposed and would be applied to new development or substantial structural modifications (SSMs).
Residential Development
How are residential spaces going to be
affordable?
Housing affordability is a major regional and statewide issue that is not directly at issue in the LCLUP. However, the LCLUP does affect the conditions under which development can occur, including residential development. The LCLUP contains policies that could increase the cost of development on certain sites such as through required hazard mitigations and City of Pacifica LCLUP Update FAQs, Page 21
public infrastructure and access requirements. However, the LCLUP also includes policies to support higher-density mixed use housing which may increase the potential for more affordable housing options to be constructed.
If more housing is added, how will it be
protected from sea rise?
In most cases, new development will need to be designed to be located outside of projected sea level rise for the life of the development. Within the Special Resiliency Areas (SRAs), new development may be allowed to rely on existing shoreline protection structures that mitigate hazards such as sea level rise.
How does RHNA numbers affect SRA policies? There is no relationship between the City’s Regional Housing Needs Allocation (RHNA) and the Special Resiliency Area (SRA) policies. However, the SRA policies may increase the potential for housing of various types to be developed which would count toward the City’s RHNA progress.
Can I rebuild my home in the coastal area in the
event of fire, earthquake, or other natural
disaster? What are the restrictions and why do
they apply?
In general, rebuilding in the event of a property destroyed by a disaster is authorized under the Coastal Act. Please refer to Case Study #8 and #9 prepared for the March 2, 2024, community meeting for more detail.
Shoreline Protection Structures
What is/are negative impact(s) of existing
sea level / coastal protections?
Shoreline protection structures can result in reduced size or elimination of sandy beaches depending on design of the structure and coastal conditions in the area.
Construction of new shoreline protection projects can result in construction-phase impacts such as reduced water quality, underwater noise, risk of spills, and placement of fill in waters.
These factors are evaluated during the environmental review process associated with any potential shoreline protection structure project that may be proposed.
Are there negative impacts of expanding or
improving coastal protections? / What are
the impacts of beach protection?
What is the full cost of the seawall?
The costs of a shoreline protection structure depends on a number of factors, including the linear length and design. The City conducted a cost analysis of different shoreline protection types associated with the Beach Boulevard Infrastructure Resiliency Project (BBIRP). Costs for the public and Council selected hybrid option (~$80M not including operation and maintenance costs) developed at that time are available on the City website under Appendix A of the May 2021 Updated Alternative Analysis Report located under the Phase 1 Document Library at https://www.cityofpacifica.org/departments/public-works/engineering/capitalimprovement-projects/beach-boulevard-infrastructure-resiliency-project. GHD (the City’s City of Pacifica LCLUP Update FAQs, Page 22
Shoreline Protection Structures
engineering consultant) is currently working on an updated cost for the hybrid option that will be forthcoming.
Will new revetment happen? A number of factors will determine whether any particular shoreline protection structure will be constructed, including the ability to obtain required permits and the availability of Is there a future for the seawall or not? sufficient funding for construction.
If the community is more interested in
more seawall infrastructure, are we better
off with the new plan or the old plan?
The SRAs policies do not contain any requirements for hard armoring or seawalls and thus there is no cost. The SRA boundaries are determined by a number of criteria, including whether an area contains an existing shoreline protection structure; however, the SRAs do not contain any policies related to existing or new shoreline protection structures. The main source of support for shoreline protection structures is the Coastal Act itself, which neither the 1980 LCLUP nor 2020 LCLUP can modify. As stated above, the City is working on the BBIRP and the City will move forward with BBIRP project in either case.
Seawall – No real mention of future sea
protection. Maintain current infrastructure
only. Pier is the only mandate with N/S
section of seawall. Does the new SRA
protect the entire seawall or just the pier?
How does this affect the Quarry, and does
this affect revetment plans? How would
this affect the future of the Quarry?
The 2040 LCLUP, if certified by the Coastal Commission, would add the Rockaway Quarry site into the City’s certified Local Coastal Program (LCP), enabling the City of Pacifica to grant coastal development permits for development in the Rockaway Quarry. Currently, the Rockaway Quarry site is in an Area of Deferred Certification and is not a part of Pacifica’s certified LCP. Certification of the LCLUP would not directly affect any plans for shoreline protection structures at any location in the City of Pacifica as those determinations are made at a project level through the coastal development permit process.
Why are we only repairing one section?
The City is currently designing or in the permit review process for several shoreline protection structures, including the Beach Blvd. Infrastructure Resiliency Project (BBIRP), the 310-330 Esplanade Infrastructure Preservation Project, and the 400 block of Esplanade Project. There are several factors that determine which sections and locations of the coastline the City prioritizes for new or replacement shoreline protection structures, including risk to public infrastructure and other public structures.
1984 seawall constructed: how long will it
last before next solution comes?
The City is currently working on the Beach Boulevard Infrastructure Resiliency Project (BBIRP). The LCLUP and BBIRIP project are not dependent on one another. Additional information on the BBIRP can be found here:
https://www.cityofpacifica.org/departments/public-works/engineering/capitalimprovement-projects/beach-boulevard-infrastructure-resiliency-project City of Pacifica LCLUP Update FAQs, Page 23
Shoreline Protection Structures
How does the plan propose to protect
private property that in the past has had
permission to maintain its revetment and
was tasked to maintain it?
Shoreline protection structure permitting decisions are ultimately within the jurisdiction fo the Coastal Commission and the City cannot control these decisions. It can, however, seek policies in the LCLUP that may be helpful to shoreline protection where appropriate, which can inform the CCC’s decision making. Policy CR-I-56 in the LCLUP applies to existing shoreline protection structures. The Coastal Act Section 30235 allows repair and maintenance of legally permitted shoreline protection structures.
The LCLUP policies require that when development is proposed on private property that the new buildings are designed to avoid coastal hazards. Development usually refers to adding or replacing structures, but it doesn't cover routine maintenance like fixing a roof.
Our beach homes have existed for about
100 years coming to be with the Ocean
Shore Railroad. We have maintained our
sea wall protection for all this time. How
can the CCC tell us to stop and endanger
ourselves and houses for an indeterminate
year for sea rise?
Can the BBIRP sea wall be built without a
Coastal Commission-certified LCLUP? Does the
Coastal Commission have to approve the BBIRP
sea wall in order for it to be built? Can the sea
wall be built if we still have the 1980 LCP?
Yes, the Beach Boulevard Infrastructure Resiliency Project can be built without the LCLUP certification because the project requires that the City obtain a permit from the California Coastal Commission (CCC). The project will be reviewed under the CCC regulations (i.e.
Coastal Act) and policies.
Has the city considered using Mello Roos
bond assessments to the properties along
the coastline that benefit the most from
coastline protection?
The City has performed initial research on various funding mechanisms for infrastructure projects along the shoreline. As with all potential funding sources, there are pro’s and con’s of a Mello Roos funding approach. The City would undertake a public process to discuss new funding mechanisms that could include direct costs for property owners.
What will happen to an existing, previously
approve shoreline protection after an SSM
is triggered, and it is no longer authorized?
Outside of the SRAs, if project meets the definitions of an SSM, the development is required to be designed to withstand coastal hazards and would no longer require armoring. The policies in the LCLUP call for removal of the existing shoreline protection structure.
Future Funding
The sea level rise will lead to property values
going down, the assessments should account
for that, how does the town plan for less
future tax revenue?
A variety of factors, including impacts on the City’s tax base, must be evaluated as part of the long-term sea level rise adaptation planning process.
City of Pacifica LCLUP Update FAQs, Page 24
Future Funding
Is the city protecting future tax revenue using
SRAs?
The Rockaway Beach and West Sharp Park neighborhoods both contain visitor-serving retail and lodging that are important to the City’s tax revenues. The SRAs will enable ongoing operation, improvement, and redevelopment of properties within the SRAs which should have a positive effect on City tax revenues over the long-term.
What are the estimated costs to move critical
infrastructure in coastal areas? Who pays for
that? Where will this infrastructure go?
Relocation of infrastructure is technical and legally complex, and can include significant costs. Any project proposing relocation of infrastructure would need thorough review and approval of funding by the City Council.
Who pays the cost of removing coastal armoring? The cost of removing armoring would be the responsibility of the property owner. If the property is privately owned, then private property owners would be financially responsible for removal. If the property is publicly owned, then the City or other public agency that owns the property would be responsible.
If the City adopts the SRA approach, how likely is
it that Pacifica will qualify for grant funding for
armoring, given the widespread emphasis on
nature-based solutions for coastal resiliency
projects?
It is not possible to generalize a response to this question. Every grant has its own requirements to qualify and must be evaluated individually.
Infrastructure
When coastal flooding may happen, what is
the plan for the huge amount of
infrastructure like sewers that will need
moving? Who/how will the town pay?
Addressing long-term City infrastructure needs is part of the iterative sea level rise adaptation planning process the City will undertake following certification of the LCLUP.
The City’s approach in the near- and medium-terms are to protect existing infrastructure until sufficient study can occur and long-term options be considered by the City Council.
Where does the underground infrastructure
of Beach Blvd fit into the LCLUP?
What happens to Manor infrastructure?
Critical infrastructure in the SRAs impacts all
of Pacifica: what are we doing to make our
infrastructure resilient and insulated from
coastal hazards?
Has the City undertaken any long-range
planning to move infrastructure?
As explained elsewhere, relocation of infrastructure is technically and legally complex, and involves significant costs. The LCLUP Update would enable ongoing protection of City of Pacifica LCLUP Update FAQs, Page 25
Infrastructure
infrastructure to enable the City to undertake study of long-term infrastructure relocation where appropriate and feasible.
Other
By changing the definition of wetlands in the
coastal zones to only meet one parameter,
dozens of homes adjacent to these areas
would be affected by the new buffer zone
definitions. What does this mean to
homeowner?
The definition change is needed to be consistent with the state law including the Coastal Act. The one-parameter wetland test has been in state law for many years. The new requirements will only affect homes if/when development is proposed. Please see Case Study #5 for additional details.
Protection of infrastructure is the fundamental purpose of the Beach Boulevard Infrastructure Resiliency Project (BBIRP). The LCLUP Update would support the BBIRP project. Protection of infrastructure in other parts of Pacifica would require separate projects, and two projects are currently underway along Esplanade Avenue in the vicinity of Manor Drive.
Where does the underground infrastructure
of Beach Blvd fit into the LCLUP?
What happens to Manor infrastructure?
Critical infrastructure in the SRAs impacts all
of Pacifica: what are we doing to make our
infrastructure resilient and insulated from
coastal hazards?
Why did the CCC recommend removing
'Protection of property rights is an important
theme in this chapter.' from Ch.6 pg.156 of
our LCLUP Draft? Is it to implement the
apparent lack of prioritization of property
rights in the State of California Sea Level Rise
Guidance: 2024 Science and Policy Update?
Discussion with CCC staff revealed they felt the statement as drafted placed too much emphasis on protection of property rights without sufficient mention of other important considerations. Further discussions with CCC staff have resulted in mentioning property rights as one of several important considerations as an acceptable alternative modification that the City could propose.
Why was ‘Evaluating the feasibility of beach
nourishment with sand retention structures,
as described in CR-I-55, to reduce shoreline
protection maintenance and maintain 100’
wide beaches’ deleted from Ch. 6 pg. 173? Is
the possibility of considering Beach
The specific CCC suggested modification was done to reorganize the document to be more straightforward. Policy CR-I-16 contains the Beach Nourishment policy language.
City of Pacifica LCLUP Update FAQs, Page 26
Other
Nourishment and Sand Retention Structures
retained anywhere else in the Draft?
How would Pacifica benefit by locking into
potentially economically destructive
‘precautionary’ policies now, when future
engineering and scientific advancements
could provide much better solutions than are
currently available?
Many policies in the LCP address short- and medium-term effects. If/when advances in engineering and solutions are economically feasible for the City to incorporate into City work plans or City regulations for private development, amendments to the LCP can be processed. A key principle in the LCLUP Update is to periodically update the document with the best availability science, potentially as often as every 5-10 years.
How will the City of Pacifica comply with SB
272 (Allen) that requires local governments
to develop plans for sea level rise, if the draft
LCLUP isn’t approved?
The 2020 LCLUP has largely address the requirements of SB 272 already. Further delay of the LCLUP Update will only constrain Pacifica’s timeline for adoption by the SB 272 deadline in the future, and would deprive Pacifica of as much as a decade of the various benefits to LCLUP adoption that have been previously discussed if adoption were to occur closer to the deadline.
Is there a comprehensive and holistic view of
the entire Pacifica coastline / coastal zone
that is being proposed by City staff that
would justify the proposed SRAs?
The 2020 LCLUP is intended to be the long-term plan for the entire coast in Pacifica. The SRA would allow critical areas of Pacifica to continue to develop with the protection of existing shoreline structures, while other areas of the coast can be conserved for open space and, perhaps not be armored in the future. The SRAs, along with the City Alternative Modification, provide a balanced approached to the entire coastline.
What policies in the draft LCLUP protect and
preserve coastal resources against hazards of
falling debris and toxic materials littering the
shoreline, that also impact public safety?
How are structures that are already
uninhabitable (such as 1112 Palmetto Ave
and 189 Kent Road) and/or at the
bluff/hillside edges (i.e., Recology of the
Coast Recycle Yard and adjacent properties)
going to be addressed within the LCLUP
without a policy for planned removal?
Generally applicable Pacifica Municipal Code provisions addressing property maintenance and public nuisances govern these sorts of issues.
These properties will need to handled on a case-by-case basis, and the City has important authorities to address building habitability and safety through the California Building Code.
A) Will council write the CCC to demand the
rock revetment removal order be canceled?
The 2020 LCLUP is a policy document and does not contain any specific details on future plans for infrastructure improvement or changes. These questions are too technical and City of Pacifica LCLUP Update FAQs, Page 27
Other
B) What is Council’s plan to defend Palmetto,
Hwy 1, the southern storm drain outfall and
W Avalon homes? Who pays?
C) When will city alert 8 homes on W Avalon
their homes and backyards will front an
erosion hole and erode themselves if
unprotected?.
D) What is the property tax loss if the Resort
and W Avalon homes are destroyed?
E) Has NCCWD been notified to plan
relocation of their lines? What is relocation
cost?
F) Where will the sewer line be relocated?
Far enough east to avoid another move?
G) What other infrastructure is in the area
subject to resort erosion? Cost to move?
H) If Palmetto and Hwy 1 have to be moved,
where would either go? Onto Oceana? What
is cost for relocation, condemnation of
existing businesses, city office and homes?
project specific and would require further project specific level analysis to properly address. General response can be found in other responses related to infrastructure and property values above.
Facilities of concern are but not limited to:
Linda Mar beach pump stations, Lighthouse
pump station, quarry sewer plant, storm
pump station south end golf course, pump
station south sharp park, council chambers
pump, potential library, IBL school.
A) How will these facilities be defended?
B) If moved, where? East of Hwy 1 to avoid
frequent moves? What streets and
homes/businesses will be impacted or
City of Pacifica LCLUP Update FAQs, Page 28
Other
condemned with the relocation? Cost?
Timetable?
Request for discussion on specific CCC
Suggested Modifications
Please refer to Attachment C of the March 2, 2024 report, which contains a brief discussion and/or justification on all CCC Suggested Modification and City Alternative Modifications.
Next steps & Information
How will I get information and get answers? Materials about the LCLUP can be found on the Plan Pacifica page.
You can also contact Planning staff at [email protected] to ask questions about the LCLUP Update process.
What are the timelines/next steps? Revised Meeting #4 is anticipated for late-March/early-April 2024.
The meeting is anticipated to entail City Council discussion and potential approval of a comment letter to be submitted to California Coastal Commission.
When is the next meeting?
What is the best thing to do? The Community Engagement process is intended to allow the City Council decide what is the best course of action for the City of Pacifica as a whole, based on public input from the community and technical support from City staff.