CITY OF PACIFICA
COUNCIL AGENDA SUMMARY REPORT
4/15/2024
1 SUBJECT:
Modifications to the City of Pacifica’s Revised Certification Draft Local Coastal Land Use Plan (LCLUP), including the Special Resiliency Area policies, and direction to staff regarding transmittal of alternative modifications to the California Coastal Commission.
RECOMMENDED ACTION:
Receive a presentation from staff and confirm alternative modifications to the Revised Certification Draft LCLUP to be transmitted to the California Coastal Commission.
STAFF CONTACT:
Christian Murdock, AICP, Planning Director
(650) 738-7341
[email protected]
Stefanie Cervantes, AICP, Senior Planner
(650) 738-7341
[email protected]
EXECUTIVE SUMMARY:
The City has worked on an update to its Local Coastal Land Use Plan (LCLUP) since 2009.
Most recently in 2023 and 2024, the City has undertaken a community engagement strategy to inform the community and City Council about the LCLUP Update process and steps that could be considered to respond to California Coastal Commission staff suggested modifications from March 2023 that would modify the City’s Certification Draft LCLUP approved by City Council in February 2020. The key action City staff has identified for City Council consideration is whether to submit a collection of alternative modifications in response to California Coastal Commission (CCC) staff’s March 2023 suggested modifications.
City staff has worked extensively with CCC staff since March 2023 to identify compromise approaches in the alternative modifications that would resolve disagreements between the agencies in a mutually agreeable way. Of note, these alternative modifications would establish Special Resiliency Areas, or SRAs, that would enable greater development potential in certain neighborhoods where existing shoreline protection structures are present and that meet other specific criteria. City staff is uncertain whether a viable path forward on LCLUP certification exists in the absence of these alternative modifications.
Following detailed consideration of the alternative modifications proposed by staff, the City Council should confirm which alternative modifications to transmit to the CCC. The finalized list of alternative modifications would then be prepared for transmittal to the CCC by adoption of a resolution at a subsequent City Council meeting. Should the City Council take these remaining actions, staff anticipates the CCC would consider final action on the City’s LCLUP Update in late-summer 2024.
INTRODUCTION:
The California Coastal Act requires every city along the coast to prepare a Local Coastal Program (LCP), which consists of two parts: a Local Coastal Land Use Plan (LCLUP) and an Pacifica City Council 2
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Implementation Plan (IP). The LCLUP must be consistent with the Coastal Act. The LCLUP must specify the intended uses of land within the Coastal Zone, and serves as a policy framework for future actions, such as development review and City infrastructure projects. The LCLUP must balance statewide interests for the Coastal Zone as expressed in the Coastal Act with local land use priorities. The LCLUP also guides the contents of the IP, which consists of the zoning ordinance, zoning map, and other policies and programs to implement the LCLUP.
While the LCLUP is separate from the General Plan, much of the descriptive text and policies overlap between both documents due to their similar purposes of specifying land uses, establishing goals and policies, and providing a policy framework for future actions. There are many benefits to having an updated LCLUP, including accurate maps, modernized policies to guide development, enhanced environmental protections, strengthened economic development and housing policies, and consistency with the City’s 2040 General Plan.
The City’s LCLUP currently in effect was last comprehensively updated in 1980 (“1980 LCLUP”). The City’s effort to update the LCLUP started in 2009, concurrent with an update to the General Plan. The City Council adopted the 2020 LCLUP in February 2020 and has worked since then to achieve CCC certification. The City Council adopted the General Plan Update in July 2022. However, within the Coastal Zone, provisions of the General Plan that are in conflict with the 1980 LCLUP are not yet effective and will only take effect upon certification of those corresponding provisions within the 2020 LCLUP.
Staff’s assessment is that the 1980 LCLUP is not adequate to continue guiding the City’s actions in the Coastal Zone on a long-term basis. Many objectives of the 1980 LCLUP have been accomplished, such as protection of key beach and open space areas and formalization of public coastal access, while its assessments of some coastal neighborhoods are no longer reflective of the challenges and needs of those areas. Moreover, the 1980 LCLUP does not effectively identify climate change and sea level rise (SLR) as major issues that need to be addressed.
Lastly, an update to Pacifica’s LCLUP to account for SLR is inevitable. State law, as enacted in late 2023 with Senate Bill (SB) 272, now requires LCLUPs throughout California to be updated to include a plan to address SLR.
BACKGROUND/DISCUSSION:
In February 2020, City Council approved the Certification Draft Local Coastal Land Use Plan (“2020 LCLUP”), and directed the City Manager to transmit it to the California Coastal Commission (CCC) for certification. Additional background information, including the 2020 LCLUP document (also known as the “Certification Draft LCLUP”), are available on the Project Documents page of the Plan Pacifica website1.
Staff submitted the 2020 LCLUP to the CCC in June 2020. Between the years of 2020-2022, City and CCC staffs exchanged several rounds of information in response to CCC staff requests. The information requested by CCC staff was required to address that agency’s administrative filing requirements before the City’s application could advance to a point where CCC staff could provide formal substantive comments on policy provisions related to certification. In August 2022, the CCC finally accepted the 2020 LCLUP for filing. On December 16, 2022, the CCC took action to extend the deadline by one year, as authorized by Public Resources Code section 30517. The CCC’s action extended the deadline to December 22, 2023.
In late February 2023, the City received notice the CCC would consider the City’s Certification 1 Available at https://www.planpacifica.org/project-docs.
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Draft LCLUP at the March 8, 2023, CCC meeting. The CCC staff report for the item included CCC staff’s final recommendation, which included many suggested modifications to the City’s submittal (“CCC Suggested Modifications”) 2. The City requested a continuance of the March 8th hearing date to allow an opportunity to review and consider the CCC staff’s recommendations.
Since March 2023, City staff has met multiple times with CCC staff to gain a better understanding of the suggested modifications in order to develop a comprehensive analysis and explore potential revisions for City Council consideration. On October 9, 2023, the Council approved the revision of the existing Certification Draft LCLUP to incorporate 2040 General Plan provisions and directed transmittal of the Revised Certification Draft LCLUP to the CCC.
Submission of the Revised Certification Draft LCLUP, in addition to aligning the document with the 2040 General Plan, also had the benefit of allowing more time to analyze and respond to the March 8, 2023 CCC staff suggested modifications and eliminated the December 22, 2023 deadline for CCC action.
1. Community Engagement Plan
On October 9, 2023, the City Council approved a three-meeting community engagement plan to update the public on where the LCLUP update process stood, and to discuss where it should go next. Additional information on the City’s work to update the LCLUP component of the City’s LCP, which started in 2009, is available in the City Council agenda reports for the City Council meetings on October 9, 2023 (Agenda Item No. 10), November 13, 2023 (Agenda Item No. 1), and December 5, 2023 (Agenda Item No. 1).
Following the December 5 community meeting that the Council had approved in the initial threemeeting community engagement plan (Meeting #2), on January 8, 2024, the Council directed a revision to the community engagement plan to include a revised Meeting #3 format and purpose, effectively creating a four-meeting community engagement plan (“Revised Community Engagement Plan”), with the possibility of a fifth meeting depending on the outcome of the third and fourth meetings. The Revised Community Engagement Plan is outlined below:
• Meeting #1: City Council Study Session
o Purpose: Study session to present and discuss the CCC staff suggested modifications from March 8, 2023.
o Timing: November 13, 2023
• Meeting #2: Community Roundtable Discussions
o Purpose: Provide a staff presentation followed by a community roundtable discussion of potential alternative modifications to those presented by CCC staff for the March 8, 2023 CCC meeting, based on discussions between City and CCC staffs that started in June 2023.
o Facilitation: Due to the complexity of the subject matter discussed at this community meeting, a professional facilitation service facilitated the roundtable conversations. City staff notetakers supplemented the facilitators to ensure comprehensive collection of community input.
o Timing: December 5, 2023
• Revised Meeting #3: Question and Answer Study Session o Purpose: Study session to respond to community and City Council questions.
Provide opportunity for public submission of questions to be answered in advance of the meeting, with an additional question-and-answer opportunity for 2 Available at https://cityofpacifica.egnyte.com/dl/DpPxoDE8q3, with City-added numbering for identification.
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the public at the meeting. City Council discussion and direction on all potential alternative modifications recommended by City staff.
o Timing: March 2, 2024
• Revised Meeting #4: City Council Consideration of a Comment Letter to CCC o Purpose: City Council consideration item to discuss the alternative modifications to the CCC staff's March 2023 suggested modifications. Since initial conception of transmitting a comment letter, CCC staff has clarified that this transmittal must take the form of an adopted City Council resolution. Thus, discussion of Meeting #4 will henceforth relate to transmittal of a resolution instead of a comment letter.
Transmittal of a resolution including alternative modifications would need to be sufficiently in advance of a potential CCC certification hearing to allow time for CCC staff to analyze the City’s requests and publish a staff recommendation.
Staff recommends transmitting the resolution at least two months, but ideally three months, prior to a desired CCC certification hearing. o Timing: April 15, 2024
This community engagement process is intended to conclude the comprehensive LCLUP update process that started nearly 15 years ago. It involves concluding the LCLUP update process based on the structure and policy emphasis approved by the City Council in the 2020 LCLUP, with consideration of potential modifications to certain policies as an alternative to the CCC staff’s suggested modifications from March 2023 (i.e., the “alternative modifications”). This process is not a reconsideration of the structure and policy emphasis that was approved in the 2020 LCLUP (and continued in the Revised LCLUP).
The purpose of this process is to bring the Council and community to a point where a decision is made on whether to submit a resolution to the CCC in response to CCC staff’s suggested modifications from March 2023. This is a necessary step to conclude the comprehensive LCLUP update process that was started in 2009 and most recently included incorporation of conforming General Plan amendments in October 2023. Consideration of a resolution to propose alternative modifications that may be acceptable to the CCC is the best and most expedient way for the City to seek CCC certification of the LCLUP in a form that is acceptable to the City Council.
The need for transmittal of alternative modifications by resolution arose during a City-CCC staff coordination after LCLUP Meeting #3 on March 2, 2024. At the coordination meeting, CCC staff relayed that further internal discussions at the CCC concluded that transmittal by resolution was required pursuant to Public Resources Code section 30510 which states, in part, that “a proposed local coastal program may be submitted to the [CCC]” only if it is submitted “pursuant to a resolution adopted by the local government...” Staff has prepared the draft resolution included as Attachment A which will serve as the mechanism for transmittal of the alternative modifications to the CCC once they are finalized by the City Council. Adoption of the resolution would be considered at a subsequent City Council meeting.
2. Prior Meeting Summaries
Meeting #1 Summary: Discussion of California Coastal Commission Staff’s Suggested Modifications (March 2023)
The November 13, 2023 study session staff report contains a summary of key suggested modifications, as well as attachments including a summary table with all CCC Suggested Modifications, the City’s 2020 LCLUP text (the meeting was conducted before City transmittal of the Revised Certification Draft LCLUP to the CCC), and a brief summary of each modification.
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Staff presented the key suggested modifications to provide additional information and context, responded to Council questions, and also provided information about other suggested modifications not included in the initial summary of key suggested modifications (meeting video).
The design of Meeting #1 was intended to provide information to aid understanding of the CCC Suggested Modifications and their relevance to Pacifica.
Meeting #2 Summary: Potential Alternative Modifications The December 5, 2023 study session staff report introduced key potential alternative modifications identified by staff as a way to resolve one of the major points of disagreement between the City and CCC: how to regulate development within existing densely developed neighborhoods near the shoreline, especially those located behind existing shoreline protection (e.g., seawalls). The alternative modifications identified by staff in relation to this issue were termed “Special Resiliency Areas,” or SRAs, which would consist of a subset of Pacifica wherein development would be authorized in reliance on existing shoreline protection subject to specific requirements. Both City and CCC staff focused SRA discussions on the Rockaway Beach and West Sharp Park coastal neighborhoods which would be most significantly impacted if the CCC Suggested Modifications were to take effect citywide Meeting #2 was designed as a community roundtable to allow in-depth community member discussions in small groups to provide reactions to the concept. Main takeaways from Meeting #2 included an overall community expression of a lack of understanding of the key aspects of the SRA concept, potential concern about some of the requirements of the SRA concept, and a need to better understand how individual properties would be affected by the SRA concept if implemented.
Meeting #3 Summary: Question and Answer Study Session
The March 2, 2024 study session staff report provided information on the overall status of the LCLUP Update, specific responses to community and Council questions asked in advance of and during the meeting, and case studies demonstrating application of LCLUP policies under various scenarios. Meeting #3 allowed members of the public to submit questions during an open submission period, from February 2nd to February 16th, where the public could submit questions online, by email, by phone, or in-person. The case studies described specific scenarios that could result from application of different potential policies in the Coastal Zone.
Additionally, the staff report contained all the potential alternative modifications to be considered, including the SRA. Between the December and March meetings (Meetings #2 and #3), staff made additional revisions to the SRA policies that were included in the March 2nd staff report. The changes included eliminating the proposed separate policies and incorporating the language into existing policies for improved clarity, removing the waiver allowances from the SRA policies (and incorporating them into the Zoning Ordinance instead), renaming the “Visitor Amenity Improvements” policy to “Shoreline Management Plan,” and making the SRA linear along the length of shoreline protection devices rather than a polygon where a property would either be “in” or “out” of an SRA.
The City Council provided feedback on certain key points at the end of Meeting #3. This feedback allowed staff to follow-up with CCC staff following Meeting #3. The outcome of these follow-up efforts is discussed further in the following section of this staff report.
3. Meeting #3 Follow-up Items
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Staff noted several points in City Council’s discussion at the end of Meeting #3 that warranted follow-up with CCC staff as part of the ongoing, focused collaboration efforts between the new staffs toward the mutual interest of achieving certification of the LCLUP Update. These followup items are described below with a summary of initial CCC staff feedback provided during a staff-to-staff coordination meeting held on March 26, 2024.
A. Substantial Structural Modification (SSM) Definition The SSM definition, provided in the Glossary of the LCLUP, includes descriptions of certain structural modifications to existing structures that must be aggregated to determine whether policies applicable to new development should apply to sites with existing development. The City Council expressed concern at Meeting #3 that certain improvements that are common in Pacifica could inappropriately trigger the SSM definition and associated requirements contained in other LCLUP policies. These fell into two categories:
• Property repairs necessary to address pest infestation City Council expressed concern that commonplace replacement of structural building components to address termite infestation and dry rot (a type of fungus infestation) could lead to triggering of the SSM definition and create a hardship for property owners. CCC staff’s initial reaction to exempting structural building component replacements to address termite and dry rot infestations was positive, and staff has included these exemptions in the proposed alternative modifications to the SSM definition in Attachment B. Note that CCC staff has not provided official comment on these revisions and reserves the right to further comment on these (and all other) potential alternative modifications.
• Property alterations required to comply with other state laws City Council expressed concern that undertaking structural modifications to comply with other state laws, such as seismic retrofits/upgrades and disabled accessibility improvements, could lead to triggering of the SSM definition and create a hardship for property owners. CCC staff’s initial reaction to exempting structural modifications required by state laws other than the Coastal Act was positive, and staff has included these exemptions in the proposed alternative modifications to the SSM definition in Attachment B. Note that CCC staff has not provided official comment on these revisions and reserves the right to further comment on these (and all other) potential alternative modifications.
B. Southward Extension of West Sharp Park SRA Boundary
The City Council expressed interest in potentially extending the West Sharp Park SRA boundary southward beyond its currently proposed terminus in the vicinity of Beach Boulevard and Clarendon Road. The extension would result in the SRA boundary continuing generally along the existing berm on the western boundary of the Sharp Park Golf Course.
CCC staff’s initial reaction to a potential southward extension of the West Sharp Park SRA boundary was not positive. They expressed concern that the underlying justification for the SRAs – which is to align them with areas where existing, broad shoreline protection structures protect public roads, sidewalks, parking areas, access ways, and sewer/water infrastructure, and where inland relocation or adaptation of these features is not readily possible in the shortterm – would not be likely to apply to the area south of Clarendon Road. CCC staff indicated that if the City were to include a southward boundary extension, then they would likely need to prepare a suggested modification to remove it from the LCLUP prior to certification. They were Pacifica City Council 7
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concerned that this would undermine the overall approach of coordination and compromise between the two agencies and would suggest ongoing disagreements heading into the CCC certification hearing.
In any event, CCC staff also clarified that the CCC retains permit jurisdiction over a significant portion of the Sharp Park Golf Course area, roughly the western half of the property inclusive of the existing berm, as demonstrated in a CCC jurisdictional boundary determination from 2011 (Attachment C). The effect of CCC permit jurisdiction in this area is that the City’s LCLUP would provide “non-binding guidance” and the standard of review for permitting decisions in this area would be the Chapter 3 policies of the Coastal Act (Attachment D3). In other words, the SRA boundary and associated policies would have no direct effect in this area.
The current limits of the SRAs reflective of City-CCC coordination are included in Attachments E and F.
4. Additional Information for Meeting #4 Consideration
A. Data/Brief Summary of Previous Approvals
Members of the public expressed concern at Meeting #3 about the potential impacts of new LCLUP policies on their properties and projects they may be likely to undertake in the future. In recognition of these concerns, staff performed a high-level review of over 40 coastal development permits (CDPs) that have been heard by the Planning Commission in the last seven years in order to see how impactful the potential new LCLUP policies would be to projects actually undertaken in Pacifica.
Many of the projects included City-initiated projects and projects outside of the CCC appeal jurisdiction. The majority of the projects were in the San Pedro and West Sharp Park neighborhoods. Staff found that many of the projects were outside of the Coastal Vulnerability Zones (CVZs) and thus would not have been required to conduct technical reports to analyze coastal hazards or record a deed restriction waiving rights to future shoreline protection and assuming risk. Additionally, because many of the project sites are in West Sharp Park, the allowances of the proposed SRAs would allow projects that were located in the CVZ to use the existing shoreline protection structure when conducting technical analysis of coastal hazards. It is likely that analysis conducted for these projects would demonstrate less or no coastal hazard risk and would allow similar project designs to those originally proposed.
Of all the private development CDPs that were more closely analyzed, only one site was outside of an SRA, within a CVZ, and would meet the threshold of the SSM definition. That project site was partially within a coastal erosion CVZ and not protected by an SRA and thus would likely have a different development footprint under the new policies versus the approved CDP.
Additionally, staff found that a few projects that would not be affected by the CVZ or SSM policies were within the CCC appeal jurisdiction and thus could have been appealed to the CCC where that agency could have imposed requirements similar to those in the new LCLUP.
To the extent the past seven years of types of projects is a predictor of types of future projects, staff’s analysis of CDPs considered by the Planning Commission in the past seven years indicates that the vast majority of projects most likely to be undertaken in Pacifica are not likely to be adversely impacted by the policies in the new LCLUP. 3 Attachment D is an excerpt of a 2017 CCC staff report for a coastal development permit (CDP) application related to the Sharp Park Golf Course berm. The full CCC staff report is available at https://documents.coastal.ca.gov/reports/2017/11/w9a/w9a-11-2017-report.pdf.
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B. Other Changes to Alternative Modifications
Staff has made a limited number of changes to the alternative modifications presented at Meeting #3 in response to further public input provided to staff and feedback from CCC staff during a subsequent coordination meeting. All changes made to alternative modifications since Meeting #3 are shown in red “track changes” format in Attachment B. The changes related primarily to Modification No. 6.14 (Special Resiliency Areas) and Modification No. 7.10 (SSM Definition). Several additional changes were also necessary to address Public Resources Code section 30610(g), discussed in the Meeting #3 staff report and staff presentation, related to restoration of development destroyed by a disaster. CCC staff suggested incorporating this provision in relevant policies rather than in the SSM definition.
5. Meeting #4: Review of all Alternative Modifications
This meeting is intended to allow City Council to receive a presentation from staff on all of the proposed alternative modifications, including the SRA policies, and to allow City Council to ask questions on any of the alternative modifications. Each row in Attachment B contains the original text approved by the City, the CCC suggested modification per the March 8th, 2023 report, and the proposed City alternative modification. The table also contains a brief summary and/or explanation as to why staff is or is not proposing an alternative modification.
As mentioned in several other LCLUP reports, many of the suggested modifications by CCC staff do not alter the City’s policy position and are minor in nature. For these types of suggested modifications, the City Manager recommends that they could be accepted by the City as proposed or with minor revisions. These types of suggested modifications include typo corrections, clarifications, language generalization, Coastal Act provisions, minor deletions or additions of text, and reorganization of the document. A small number of the suggested modifications do alter the City’s vision for the future of the Coastal Zone in Pacifica and warrant alternative modifications.
While staff has drafted alternative modifications in all chapters and the glossary, the majority are in Chapter 6: Coastal Resiliency. This is in part due to the fact that more than half of the CCC staff’s suggested modifications were in this chapter, but also due to the fact that the modifications to Chapter 6 are the most significant in terms of their relationship to and impact on existing and future development in Pacifica. The staff drafted alternative modifications, including the Special Resiliency Area (SRA) policy framework, attempt to provide a better balance between allowing development and protection of the coast. The SRAs will allow for development to continue in the City’s most prominent visitor-serving areas that contain a number of desirable land uses, including housing and commercial uses.
The summary table is similar to the one that was published for the March 2nd study session (Meeting #3); however, as described above, staff has identified additional edits needed to provide additional clarity to policy language, incorporate direction provided at Meeting #3, and to incorporate changes from further discussions with CCC staff and from public input. In order to easily identify those changes, they are shown in redline text in Attachment B and include Modification Nos. 3.7, 6.2A, 6.14, 6.15, 6.23, 6.42, 6.44, 6.46, 7.10. Many of the additional changes to Chapter 6 are due to the need to further refine the SRA policy language and adjust the SSM definition based on City Council feedback. As previously stated, to ensure that the City provides a version of the LCLUP that can get certified, close coordination on the policy text is necessary. The additional changes do not change the SRA framework and instead incorporate further clarification and detail needed for the CCC certification. The additional change to Modification No. 7.10 is needed to incorporate City Council direction provided at Meeting #3.
Similar to the March 2, 2024 report, Attachment G contains all rounds of revisions from the Pacifica City Council 9
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City’s 2020 LCLUP. The first is redline edits that were approved by City Council in October 2023 to incorporate changes that were made when the City adopted the 2040 General Plan. Then there is black text that is strikethrough or underlined, which indicates the CCC staff suggested modifications that were published for the March 8, 2023 CCC hearing. The third set of revisions are in green, these are the City staff proposed alternative modifications that coordinate with the Summary Table, Attachment B.
6. Next Steps
The key outcome of this meeting is to confirm the list of alternative modifications supported by the City Council. Once confirmed by Council, staff will schedule adoption of the resolution in Attachment A at a subsequent City Council meeting. Once adopted, staff will submit the LCLUP inclusive of the alternative modifications to CCC staff. CCC staff has indicated that they will need approximately 2-3 months to review and schedule a hearing on the City’s LCLUP once they receive the City Council resolution. The transmittal of the adopted resolution with the alternative modifications before the end of April would potentially allow for the CCC hearing to occur by August 2024. As previously mentioned, both City and CCC staff are working closely to ensure that the LCLUP revisions submitted by the City can be certified by the CCC. If this can be achieved, CCC staff will be able to take an LCLUP document to the Coastal Commission that may not require any additional modifications and will thus be in effect upon CCC certification.
PUBLIC COMMENTS
Staff has received three public comments related to the LCLUP since the March 2nd meeting.
Those comments are included in this report as Attachment H.
California Environmental Quality Act (CEQA):
Adoption of the Revised Certification Draft LCLUP with Alternative Modifications would be exempt from CEQA pursuant to Section 15266 of the CEQA Guidelines (“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 by 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.” ALTERNATIVE ACTION:
No alternative action has been identified.
RELATION TO CITY COUNCIL GOALS AND WORK PLAN:
The Local Coastal Land Use Plan Update is consistent with the following item(s) in the Counciladopted Strategic Plan and Priority Work Plan for FY 2023-24:
• Goal 4: Pursue climate change adaptation and mitigation. o Strategy C: Update Pacifica’s Local Coastal Plan and improve communications and collaboration with the California Coastal Commission.
FISCAL IMPACT:
There is no direct fiscal impact from this item.
ORIGINATED BY:
Planning Department
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ATTACHMENT LIST:
Attachment A - Draft Resolution for LCLUP (DOCX)
Attachment B - Summary Table with Alternative Modifications (PDF) Attachment C - Sharp Park CCC Jurisdiction Boundaries (PDF) Attachment D - Excerpt of CCC Staff Report w9a-11-2017 (PDF) Attachment E - Rockaway Beach (PDF)
Attachment F - West Sharp Park (PDF)
Attachment G - LCP Redlined Document (PDF)
Attachment H - Public Comments (PDF)