1 Cervantes, Stefanie
From: Lawrence Bothen < >
Sent: Tuesday, March 5, 2024 4:21 PM
To: _City Council
Cc: Woodhouse, Kevin; Murdock, Christian
Subject: LCLUP #3 - Fiscal disaster
[CAUTION: External Email]
Dear Mayor and Councilmembers,
I just posted my takeaways from LCLUP MeeƟng #3 on Next Door as follows:
LCLUP Whitewashes a fiscal disaster for Pacifica
As it is commonly understood, negoƟaƟon, like poliƟcs, requires compromise. Both parƟes are expected to give up something they want to get something more important. Neither gets everything they want. The California Coastal Commission does not parƟcipate in either. But the City of Pacifica thinks that’s what they are doing with their LCLUP. The truth is they brought a water pistol to a gunfight.
For those Pacificans who braved the weather to aƩend the City’s LCLUP MeeƟng #3, this became more evident with each passing anecdote. Planning Director ChrisƟan Murdock outlined how SubstanƟal Structural ModificaƟons (SSM) would be used as a cudgel to bring homeowners in line with CCC’s policies to deprive of them of any form of coastal armoring.
Murdock didn’t say that. But as he went through eight hypotheƟcal case studies it became clear that even minor variables like dry rot discovered in a re‐roof or structural damage from termites could trigger an SSM because it would no longer be a simple job exempted from CCC requirements. Yet this happens all the Ɵme in home repair and remodeling.
Such things aren’t evident unƟl the work has begun. It will force work underground because the SSM penalty is too harsh to bear.
Whether you live in a Coastal Vulnerability Zone or an SRA you would have to get a Coastal Development Permit AND a building permit if it’s approved. But that’s not all. You must sign a deed restricƟon waiving your right to coastal protecƟons and guarantee the new structure can survive coastal hazards for 100 years without coastal armoring. Good luck finding an engineer or contractor who’d sign off on that. In CVZs you’d be liable for coastal engineering studies, or any other studies deemed necessary for your site at costs in the tens of thousands, with no guarantee of approval.
During an audience Q&A Murdock revealed that he doesn’t know of any other coastal ciƟes that have successfully introduced Special Resilience Areas (SRA) in their plans. It seems obvious he hasn’t collaborated with them either. He boasted Pacifica is on the “cuƫng edge” of these adaptaƟons. He also admiƩed they don’t consider the financial repercussions of lost revenue from Pacifica’s greatest stream ‐ property tax; or the costs of removing armoring. No consideraƟon is given to fiscal suicide?
He's cognizant of the cost of relocaƟng sewer and water mains, but not all of them, just the ones in Sharp Park. He didn’t answer what would happen to infrastructure in the PalmeƩo corridor from Manor south, or the SF RV Park. So, one of the poorest, most resource challenged coastal ciƟes in the state is going head to head with a dreadnought bureaucracy, outmanned and outgunned.
Every response to CCC’s redlines ends up endorsing them aŌer suggesƟng alternates. The SRAs, which were suggested by CCC staff, are a red herring. Every scenario the city counters with reverts to removing coastal armoring either now, the near future or in the murky distance.
City staff is clearly not up to the task.
A number of people at the meeƟng asked why should WE be on the cuƫng edge? The gist was let the Del Mar’s and Malibu’s fight that baƩle. Let’s see some wins, some new precedents that can clear a path for Pacifica, then follow in 2 their wake. We have ten years to figure it out. Maybe some daring poliƟcian will get a bill passed that protects coastal towns from CCC overreach. When 60 other coastal ciƟes start clamoring for relief from puniƟve regulaƟons sooner or later someone will jump in the fray and lead. But it’s not happening here.
CAUTION: This email originated from outside of the City of Pacifica. Unless you recognize the sender's email address and know the content is safe, do not click links, open aƩachments or reply. 1 826 Stanyan St., San Francisco, CA 94117 • 415-290-5718 • [email protected] March 25, 2024
Pacifica City Council
Mayor Sue Vaterlaus
540 Crespi Dr.
Pacifica, CA. 94044
Re: Pacifica City Council / April 15, 2024 / Local Coastal LUP Study Mtg., cont.
Supplement to SF Public Golf Alliance OBJECTION to proposed exclusion of Sharp Park (Golf Course), West Fairway Park and Mori Point subareas from the proposed “West Sharp Park” Special Resiliency Area.
Dear Mayor Vaterlaus and Council Members,
This is to reiterate and supplement the nonprofit San Francisco Public Golf Alliance’s OBJECTION, stated in our Letter to City Council of Feb. 27, 20241, to the exclusion of the Sharp Park (Golf Course) – West Fairway Park – Mori Point vulnerability subarea from the “West Sharp Park” Special Resiliency Area, as proposed by the Planning Department in the March 2024 Consultation Draft Local Coastal Land Use Plan presented to the City Council’s March 2, 2024 LCLUP Study Session (hereafter referred to as the “March 2024 Draft LCLUP”).2 1 Letter, SF Public Golf Alliance to Pacifica City Council, Feb. 27, 2024, incorporated by this reference:
https://drive.google.com/file/d/12cwdIvP5KlwHIw46TGtNkEA63 pRFg1/view?usp=sharing 2 City of Pacifica Local Coastal Land Use Plan March 2024 Revised Certification Draft (“March 2024 Draft LCLUP”), Attachment F (at Packet pages 105-370) to Pacifica City Council Study Mtg. Mar. 2, 2024, Agenda:
https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1517&Inline=True 2 EXECUTIVE SUMMARY: The Sharp Park (Golf Course)-West Fairway Park-Mori Point vulnerability sub-area should be included with the “West Sharp Park Special Resiliency Area.” (See our draft revised SRA map, Exhibit 1.) The March 2024 Draft LCLUP, which fixes the West Sharp Park Special Resiliency Area’s end point at Clarendon Rd., would exclude: (i) coastal lateral and beach access on the Sharp Park Levee -- a half-mile-plus section of the California Coastal Trail which also provides the only emergency and maintenance vehicle access to the Trail and to Mori Point; (ii) Pacifica’s own critical infrastructure – sanitary sewer force main and collection lines and storm sewer drain lines, outfalls, and pumphouse that serve most of the East and West Sharp Park and Fairway Park neighborhoods; (iii) the landmark Sharp Park Golf Course, with its low cost public recreation and wetlands habitat for the California redlegged frog and San Francisco Garter Snake; and (iv) moderate-cost residential neighborhoods and 20% of Pacifica’s “affordable rental” property. This would: (1) violate City Council’s “Coastal Resilience” policy goals, expressly stated in Section
6.3 of the March 2024 Draft LCLUP; (2) would be inconsistent with the “Coastal Vulnerability Zone” sub-area policies at Section 6, Subsection 6 of the March 2024 Draft LCLUP; (3) would be inconsistent with the stated criteria for Special Resiliency Areas; and (4) would violate the Coastal Commission’s Environmental Justice Policy.
1. The Sharp Park Levee itself constitutes Coastal Access – lateral and vertical pedestrian beach access, and road access for maintenance and emergency vehicles.
The wide, graded crushed rock roadway on top of the Sharp Park Levee constitutes a popular, half-mile-plus segment of the California Coastal Trail. The coastal protective structure provides lateral coastal access overlooking both the ocean and the coastal wetlands, golf course and scenic backdrop of coastal hills, with three vertical beach access points – a trail at its southern end near the pumphouse, a wheelchair-accessible concrete beach ramp at its northern end, and a concrete stairway from top of the Levee to the beach at the Levee’s midpoint.3, 4 (See photos of the
3 The Sharp Park Levee is misdescribed at page 3-7 of the March 2024 Draft LCLUP at Table 3-1, Point 13 (https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1517&Inline=True) at Pkt. Pg. 168/400) as follows: “Sharp Park, South End . . Beach access from south end of berm. Access point is reached by GGNRA’s Mori Point Trail.” This is wrong. A correct description follows: “Sharp Park Levee . . . Coastal Trail segment connecting the Beach Boulevard Promenade and the Mori Point headlands. Paved trail along top of levee between golf course and beach provides both lateral coastal access and vertical beach access. Popular for walking, jogging, biking, ocean viewing, beachcombing. Vertical beach access is by trail at the Levee’s south end near Mori Point, by beach stairway at midpoint of Levee, and by a wheelchair accessible ramp at north end of Levee. Parking available on Beach Boulevard and Clarendon Road. The Levee can also be reached on foot and bicycle by GGNRA’s Mori Point Trail.” 4 Coastal Access at the Sharp Park Levee is also misrepresented in the March 2024 Draft LCLUP at Figure 3-1, (https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1517&Inline=True), at Pkt. Pg.356/400. Only one “Coastal Access Point” – No. 13, “Sharp Park Beach” – is identified on Figure 3-1 (dated 2019). The map’s Legend uses red circles to identify “Coastal Access Points (Bluff-top View)” and white circles to identify “Coastal Access Points (Beach)”. At Sharp Park Beach Figure 3-1 shows only a single white (Beach access) circle at the south end of the Levee. This is incorrect because it omits the vertical beach access stairway at the Levee’s midpoint and the ramp at the Levee’s north end, both completed in or about 2021. (See discussion at footnote 2, above, and Exhibits 2 and 3.), Figure 3 should be revised to show 3 white circles marking “Beach Access”. Additionally, and consistent with Figure 3- 1’s treatment of the “Sharp Park Beach Promenade” and “Northern Beach Boulevard” segments (Access Points 9 and 11 on Figure 3-1), the Sharp Park Levee should also be marked with a red numbered circle designating coastal access “Bluff-top/View”.
3 north beach access and overlook, and the midpoint beach stairway and coastal wetlands-golf course-coastal hills overlook and the southern-end trail users’ amenities and wetlands-coastal hills overlook, attached hereto as Exhibits 2 and 3.) (As described in footnotes 1 and 2, above, the March 2024 Draft LCLUP’s “Coastal Access” Table 3-1 and Figure 3-1 are both out-of-date and must be revised to show San Francisco’s new vertical beach access points and trail user amenity upgrades to the Levee, which were completed in or about 2021.) The above-described new Sharp Park Levee beach access ramp and stairway, and the outlooks, signage, and visitor amenities were all completed in or about 2021 by San Francisco in compliance with public access mitigation measures required by the California Coastal Commission as special conditions for the Commission’s approval on November 8, 2017 of Coastal Development Permit No. CDP 2-17-0702 (Sharp Park Armoring) for after-the-fact authorization of the asconstructed Sharp Park Levee.5 Commission findings in support of its grant of Coastal
Development Permit CDP 2-17-0702 include, inter alia:
(i) “. . . Coastal Act policies clearly protect the sandy beach (and access to and along it) . . . for public access and recreation purposes, particularly free and low cost forms. . . .The Sharp Park complex is a popular public park that provides recreational opportunities . . In addition to the Golf Course, it offers access to coastal trails and coastal views to hikers, runners, cyclists, and visitors who may only have a short time available to see the ocean due to the easy access by car and on foot. The Park contains public pathways . . . including a heavily used pedestrian trail which exists on top of the existing armoring structure, the subject of this report. Thus, altogether, the Sharp Park complex provides significant public recreational access of a variety of forms, many of which are zero or low-cost options.”6 (ii) The Sharp Park Levee is “ . . . the primary emergency vehicular access for Mori Point, part of the Golden Gate National Recreation Area (GGNRA) which lies directly to the south of Sharp Park“.7 (See photos of emergency vehicles on the Levee responding to a Jan. 14, 2024 near-drowning of a father and young son in the ocean west of the golf course,8 attached at Exhibit 4.) (iii) The Sharp Park Levee provides “. . . access to infrastructure at the pumphouse, which is needed to control floodwaters in Sharp Park” 9 .
(See photos of the pumphouse and a circa 2008 repair at the pumphouse, involving a fleet of trucks and heavy maintenance equipment operating from the Levee, attached at Exhibit 5.)
5 Coastal Commission Staff Report re CDP 2-17-0702 (Sharp Park Armoring), at pp. 5 (Special Condition 3), 16 https://documents.coastal.ca.gov/reports/2017/11/w9a/w9a-11-2017-report.pdf 6 Coastal Commission Staff Report re CDP 2-17-0702 (Sharp Park Armoring), at p. 32 https://documents.coastal.ca.gov/reports/2017/11/w9a/w9a-11-2017-report.pdf 7 Coastal Commission Staff Report re CDP 2-17-0702 (Sharp Park Armoring), at p. 21 https://documents.coastal.ca.gov/reports/2017/11/w9a/w9a-11-2017-report.pdf 8 KGO TV News, Jan. 14.2024 Father and son rescued from ocean near Pacifica, authorities say https://abc7news.com/water-rescue-pacifica-pier-north-of-mori-point-father-son-rescued/14324379/ 9 Coastal Commission Staff Report re CDP 2-17-0702 (Sharp Park Armoring), at p. 20 https://documents.coastal.ca.gov/reports/2017/11/w9a/w9a-11-2017-report.pdf 4 2. The Sharp Park Levee Protects Pacifica’s Critical Infrastructure--Sanitary Sewer force main and gravity line, Storm Sewer lines, outfalls, and storm sewer pumphouse.
Sanitary sewer maintenance truck, Sharp Park Golf Course 18th hole cart path, Aug. 23, 2023.
At page 6 of our February 27, 2024 letter to City Council,10 we provided descriptions, copies of maps, photographs, and reports from the City’s consulting engineers showing the sanitary sewer force main and collection line11 and storm sewer lines and outfalls running through the Sharp Park Golf Course.12,
13 (See photos of sanitary sewer pump truck above, and manhole cover in the cart path by the 18th fairway of the golf course, at Exhibit 6.) The Pacifica Sea-Level Rise Vulnerability Assessment (ESA, June 2018) Hazard Mitigation-Asset Exposure Map for the Sharp Park, West Fairway Park and Mori Point vulnerability subarea shows the sanitary sewer lines (red) and storm sewer lines (blue) running through the golf course, and shows the storm sewer pumphouse, which pumps Pacifica stormwater through the Levee to the ocean -- all lying within the dark-colored “Storm Flood” hazard exposure area.
14 (A copy of the Hazard Mitigation-Asset
Exposure Map, which has a circled letter P to mark location of the pumphouse at the southwest corner of the golf course adjacent to the south end of the Levee) is attached as Exhibit 7.) 10 Letter, SF Public Golf Alliance to Pacifica City Council, Feb. 27, 2024, incorporated by this reference:
https://drive.google.com/file/d/12cwdIvP5KlwHIw46TGtNkEA63 pRFg1/view?usp=sharing 11 City of Pacifica [Sanitary Sewer] Collection System Master Plan Update, Final Report, Woodward & Curran, August 2021, Figure ES-1, at pg. 10/170
https://www.cityofpacifica.org/home/showpublisheddocument/2518/637839773773270000 12 City of Pacifica Storm Drainage System Master Plan, Carollo Engineers, February 2012, Fig. 4.1 (3 of 5), at p. 59/129 https://www.cityofpacifica.org/home/showpublisheddocument/12210/637931377778730000 13 City of Pacifica Storm Drainage System Master Plan, Carollo Engineers, February 2012, 4.2.2 at p.4-10 (65/129) https://www.cityofpacifica.org/home/showpublisheddocument/12210/637931377778730000 14 Hazard Mitigation-Asset Exposure Map, Sharp Park, West Fairway Park and Mori Point, Appendix B-3 to Pacifica Sea-Level Rise Vulnerability Assessment (ESA, June 2018), Attachment F to Dec. 10, 2018 Pacifica City Council Agenda, Pkt Pg. 768/1050:
https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1225&Inline=True 5 The near proximity of Pacifica’s storm sewer lines and outfalls and sanitary sewer lines and force main in the low-lying northeastern section of the golf course, combined with the City’s aging and fragile pipelines, renders Pacifica sanitary sewers in the area susceptible to “infiltration and inflow” problems and sewage overflows. Pacifica’s consulting engineer Woodward & Curran’s August 2021 Collection System Master Plan Final Report15 describes the problem:
“The City is subject to infiltration and inflow (I&I) of extraneous groundwater and stormwater into the [sanitary sewer] collection system, resulting in high wet weather flows during storm events. As a result, sanitary sewer overflows (SSOs) have occurred at several locations in the system during large storms.” (Pg. ES-1, at 8/170) “Approximately 7 percent of the City’s 97 miles of gravity pipelines and 30 to 35 percent of its 4 miles of force mains are exposed to coastal erosion and flooding. Surface inflow into manholes and infiltration into leaky sewer pipes in exposed areas could cause a reduction in capacity, which may lead to backups and even overflows of untreated sewage. Sanitary sewer overflows could potentially enter storm drains and the coastal ocean and pose negative impacts to coastal water quality and ecological health.” (Pg. 164/170, emphasis added)
So it is clear that the existing Sharp Park Levee provides necessary protection for Pacifica’s vulnerable existing critical infrastructure, including the sanitary sewer force main and collection lines and the storm sewer drain lines, outfalls and pumphouse.
3. The Sharp Park Levee protects low-cost public recreational assets and Pacifica Landmarks – the historic Sharp Park Golf Course and Clubhouse. The Levee also protects the Environmentally Sensitive Habitat Area (ESHA) and threatened and endangered frog and snake populations in the Sharp Park wetlands.
The March 2024 Draft LCLUP, Section 4.3 Biological Resources, identifies the Sharp Park wetlands as habitat for the California red-legged frog and San Franciso garter snake, and as “potential Environmentally Sensitive Habitat Area”.16 The California Coastal Commission’s November 8, 2017 ruling conditionally granting San Francisco’s Coastal Development Permit for the Sharp Park Levee also found the Sharp Park wetlands to be ESHA.17 To protect the frog and 15 City of Pacifica [Sanitary Sewer] Collection System Master Plan Update, Final Report, Woodward & Curran, August 2021, pages ES-1-ES-2 (8-9/170), and page 164/170.
https://www.cityofpacifica.org/home/showpublisheddocument/2518/637839773773270000 16 March 2024 Draft LCLUP, Pacifica City Council Study Mtg. Mar. 2, 2024, Agenda Packet Attachment F:
https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1517&Inline=True “Seasonal wetlands and ponds at Mori Point and Sharp Park Golf Course also known to support the California redlegged frog as well as the San Francisco garter snake.” (Pg. 4-17, at Packet pg. 225/400) “Areas around Mori Point and Sharp Park Golf Course are likely to qualify as an Environmentally Sensitive Habitat Area.” (Pg. 4-21, at Packet pg. 229).
And see Figure 403, “Potentially Environmentally Sensitive Habitat Areas,” at Packet Pg. 364/400 17 Coastal Commission Staff Report re CDP 2-17-0702 (Sharp Park Armoring) , at p. 35 (35/38) : “ , , ,the wetlands and adjacent upland areas of Laguna Salada and Horse Stable Pond are considered ESHA under Section 30240.” https://documents.coastal.ca.gov/reports/2017/11/w9a/w9a-11-2017-report.pdf 6 snake species and their wetlands habitat, the US Fish & Wildlife Service has ordered San Francisco to maintain the Sharp Park Levee.18
4. The Coastal Commission’s Environmental Justice Policy, adopted in 2019, declares “preserving and providing for lower-cost recreational facilities” to be “an environmental justice imperative,” and commits the Commission to “working with local government to adopt local coastal plan policies that protect existing affordable housing.” 19 (Emphasis added.) Pacifica’s March 2024 Draft LCLUP includes policy to “Promote Environmental Justice.” 20
The low-cost public Sharp Park golf course and the affordable homes and apartments in the mid-1950’s era West Fairway Park tract21 and the modest mixed residential triangle at the northeast corner of the golf course south of Clarendon, clearly merit the Coastal Act’s – and the Environmental Justice Policy’s – protections for low-cost public recreation and “existing” affordable housing. In both neighborhoods. The affordable housing in these neighborhoods was “existing” in 2019 when the Commission adopted its Environmental Justice Policy.
The big apartment complex at 2590 Francisco Blvd., near the northeastern corner of the golf course and south of Clarendon Road, is identified as “affordable rental” by a star on the Sharp Park, West Fairway Park and Mori Point Coastal Vulnerability Zone Map.22 (Copy attached as Exhibit 4 to our Feb. 27, 2024 letter to City Council). Pacifica’s Sea-Level Rise Vulnerability Assessment (ESA, June 2018) reports the 2590 Clarendon apartment complex constitutes 20% of Pacifica’s total affordable rental property.23 (See Exhibit 8, a copy of Table 7, at the fifth line from the top.) At City Council’s March 2, 2024 public LCLUP Study Session, Planning Director Murdock stated: “relatively few housing element sites are identified in the Coastal Zone.”24 The golf course has a proud history of racial inclusion. Decades before enactment of the Coastal Act, Sharp Park In 1955 hosted the inaugural championship tournament of the Western 18 Biological Opinion Letter, US Fish and Wildlife Service (USFWS), October 2, 2012, Conservation Measure 31, at page 19, and Incidental Take Statement, Terms and Conditions No. 1, at page 41: https://drive.google.com/open?id=0B1h0x8Eg99deRzZUWHFaLS1zcW8 19 Coastal Commission Environmental Justice Policy (Mar. 2019), “Coastal Access” and “Housing,“ Mar. 8, 2019, at pp. 7-8 (pp. 11-12/25) https://documents.coastal.ca.gov/assets/env-justice/CCC EJ Policy FINAL.pdf 20 March 2024 Draft LCLUP, at Section 6, “Coastal Resilience” Subsection 6.3, includes “Promote Environmental Justice” as a policy “to help guide the direction of the planning effort for the Coastal Resiliency Policies”. https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1517&Inline=True, at Packet Pgs. 280-281/400 21 See copy of original 1955 West Fairway Park Subdivision Map, attached hereto as Exhibit 9. 22 March 2024 Draft LCLUP, supra, Appendix B-3, Sharp Park, West Fairway Park and Mori Point, at Agenda Packet Pg. 329/400: https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1517&Inline=True 23 Sea Level Rise Vulnerability Assessment for Pacifica LCP Update, ESA. June 2018 (Attachment F to City Council Agenda Summary Report, re: Draft Local Coastal Program Policies Relating to Sea Level Rise Adaptation, Dec.10, 2018 (starting at Packet pg.113) https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1225&Inline=True , etc.
Table 7, Sharp Park, West Fairway Park and Mori Point Asset Exposure (Pkt Pg. 735/1050) 24 Mar. 2, 2024 City Council LCLUP Study Session, Pacific Coast TV video, at 3:54:05:
https://www.youtube.com/watch?v=B Ky2nPtE A&list=PLFUunuheJ0ZU25IaKfa31mnHMxGy V4Ob .) 7 States Golf Association, one of the oldest and largest African American golf organizations in the Country.25 Sharp Park’s role in the integration of golf is memorialized on a storyboard plaque next to the starter’s window at the golf course. (Photo attached hereto as Exhibit 10.)
SUMMARY AND REQUEST
All of the above-described assets in the Sharp Park-West Fairway Park-Mori Point sub-area are protected and need protection – along with the ESHA and its special status frogs and snakes – by the Sharp Park Levee coastal protective structure. The affordable rental apartments and residences in the modest residential neighborhoods, the sanitary and storm sewer systems, and the Landmark golf course and Clubhouse are all old and in need of repair and maintenance (in some cases long-deferred), which repair and maintenance would according to the Pacifica Planning Department be enabled and facilitated by (and in some cases impossible without) application of the proposed “Special Resiliency Area” policies.26 As detailed in this letter and in our February 27, 2024 letter (incorporated herein by reference), the area and neighborhoods mapped in the “Sharp Park, West Fairway Park and Mori Point” Coastal Vulnerability Zone Map, Appendix B-3 to the March 2024 Draft LCP (copy attached as Exhibit 4 to our Feb. 27, 2014 Letter) meet all of the “Special Resiliency Areas” criteria of the Coastal Resiliency Policies of Chapter 6 of the March 2024 Draft LCLUP.27 So for these reasons -- and for reasons of compliance by the City and by the Coastal Commission itself with the Coastal Commission’s Environmental Justice Policy -- we respectfully request:
that the March 2024 Consultation Draft LCLUP’s “West Sharp Special Resiliency Area” be revised to include the entire Sharp Park-West Fairway Park-Mori Point vulnerability subarea, as shown on our draft revised map attached as Exhibit 1; and that the March 2024 Consultation Draft LCLUP’s “Coastal Access” Table 3-1 and Figure 3-1 both be revised and updated to correctly identify and describe all of the coastal access points at the Sharp Park Levee, as described above at Pages 2-3, Footnotes 1 and 2, and Exhibits 2 and 3.
Respectfully submitted,
Richard Harris
President, San Francisco Public Golf Alliance
cc: City Manager Kevin Woodhouse, Planning Director Christian Murdock, Deputy Planning Director Stefanie Cervantes, Planning Commission and Commissioners, City Clerk Sarah Coffey, Phil Ginsburg, Gen. Mgr., San Francisco Recreation and Parks Dept., Spencer Potter, Esq., San Francisco Recreation and Parks Dept.
25 Washington Golf, “The 70-year Impact of the Western States Golf Association”:
https://wagolf.org/news/the-70-year-impact-of-the-western-states-golf-association/ 26 Attachment B, Case Studies, Case Study #3, to Pacifica City Council Study Mtg. Mar. 2, 2024, Agenda:
https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1517&Inline=True (at Packet pgs. 50-53) 27 March 2024 Draft LCLUP, Chapter 6, subchapter 6-6 at pg.6-17, at Packet pg. 293, Attachment F to Staff Report:
https://pacificacityca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1517&Inline=True 8 Exhibit 1 Draft revised map, West Sharp Park-West Fairway Park-Mori Point Special Resiliency Area
9 Exhibit 2 Sharp Park Levee north end beach overlook and access ramp.
Beach Overlook and entry to access ramp.
Access ramp, with maintenance truck on Levee in background. 10 Exhibit 3 Sharp Park Levee midpoint beach stair and midpoint and south overlooks Sharp Park Levee midpoint beach stairs (above) and coastal wetlands / golf / ridge view overlook (below).
Coastal trail user amenities and wetlands overlook, Sharp Park Levee south end, near beach trail. 11 Exhibit 4 Rescue vehicles on Levee Jan. 14, 2024, attending near-double drowning of a father and young son in the ocean west of Sharp Park Golf Course.
Stills from TV videos, Jan. 14, 2024, KGO-TV (above) and KTVU-TV (below). 12 Exhibit 5 Storm Sewer Pumphouse at southwest corner of Golf Course, next to Levee Pumphouse (above) and repair (circa 2008), with heavy equipment operating from the Levee (below) 13 Exhibit 6 Sanitary sewer manhole cover, Sharp Park golf cart path, 18th hole. 14 Exhibit 7 Hazard Mitigation – Assets Exposure Map, Sharp Park, West Fairway Park, Mori Point Vulnerability Sub Area, Pacifica Vulnerability Assessment (ESA, May 2018) 15 Exhibit 8 Sharp Park, West Fairway Park, etc. Assets Exposure Table (ESA, May 2018) 16 Exhibit 9 Fairway Park Subdivision Map, Recorded March 17, 1955 17 Exhibit 10 Plaque at Starter’s Window, Sharp Park Golf Course J Kremer – LCLUP Ideas, March 28, 2024 p. 1
TO: City Council, Dir. Murdock, Mngr. Woodhouse, publiccomment FROM: Jim Kremer (J )
SUBJ: Ideas for how to proceed towards a Certified LCLUP I am writing to emphasize an optimistic view of how we might proceed to a certified LCLUP. I’m submitting it well ahead of the April 15th meeting as I trust it is relevant to planning that meeting.
There is a clear path that is not only expeditious, allowing City to concentrate on other pressing issues, but also desirable in order to earn CCC Staff acceptance of Alternative Modifications, with or without consideration of SRAs.
Naïve? Presumptuous? I hope it is constructive and practical.
My view of where we are:
• There are compelling immediate real benefits to having a certified LCLUP. • The draft proffered March 2023 by CCC Staff on our behalf could be approved by City Council now.
• Once acted upon by CA Coastal Commission (CCC) presumably at their next possible meeting, City can begin proposing amendments, and such changes are normal. • City Planning Staff (Planning S.) agrees that 75% of the “Suggested Modifications” by CCC Staff in March 2023 are acceptable.
• Only 27 items have been flagged as needing more discussion, often citing effects on future development. These “greenies” are sticking points, and Planning S. has suggested its own Alternative Mods, which have not been vetted by City Council nor by CCC Staff. • Special Resilience Areas (SRAs) are proposed by the city as novel plans that exempt two areas from State Law, in exchange for mitigating actions. However such waivers can only be allowed by CCC if they further the overall goals of the CCC in meeting their state obligations/responsibilities.
• Regardless of negotiations between Planning S. and CCC Staff, much staff time and likely lengthy delays will protract the deliberations, and almost certainly the City will not gain approval for all their Alternative Mods.
• The City foresees approval of a new LCLUP in about a year, but this is uncertain at best, especially on the present path.
• On March ’23, a draft recommended by CCC Staff for Commission approval was sent to Pacifica. If this were accepted by City Council it and would immediately be in CCC Staff’s hands to bring before the CCC expeditiously – and we can be certain they will welcome this! • Regardless of the fate of SRA’s, Pacifica’s Planning S. has indicated that the March ’23 LCLUP with most or all of the Suggested Mods will probably be accepted by City Council as applicable to the rest of the City. Doesn’t that mean that the city will accept this draft in any case, with changes yet to be determined or without? • Two new meetings on this are ahead. As I heard Council request on March 2nd , they want meeting 1 to consider the CCC Staff’s Suggested Mods, in detail, line-by-line. Meeting 2 will be to deliberate among themselves on what was learned and consider the option to accept of all the Suggested Mods or to continue protracted negotiations over many details.
The first of those upcoming meetings is very important. I ask:
A) It is important iour City Council be allowed to study the green highlighted Suggested Mods individually, projected in a visual context that elucidates the rationale. (Marked-up prose from the ’23 D-LCLUP itself is easy to process, often suggesting the rationale. Note that CCC Staff’s March Staff Report provides explanations for categories of Mods in general; and for changes to policies the rationale is given for each. All this can be J Kremer – LCLUP Ideas, March 28, 2024 p. 2
viewed at once on a projected screens with windows. I’ll add that it really helps if additions and deletions are highlighted in color.)
B) The first meeting does NOT need a Staff presentation, and it is unnecessary to introduce Alternative Mods. This may go against Planning S. inclinations, but it is counter-productive.
Respect that City Council has a good grasp of the task. They have said what they need is time to study & discuss themselves. Of course Staff is there for Council to ask when input would be helpful.
Overview of this plan:
With an LCLUP certified, all Alternative Mods and SRA ideas can be again pursued with CCC Staff. Importantly, other desirable revisions will also be facilitated. Foremost may be the long term strategy of a monitoring plan and triggers. City hinted at SLR triggers leaving allusions to them in their original draft submitted Feb 2020 [e.g. “CR-I-24 (0-2 feet SLR)”]. We know CCC Staff would support this. (All these lone cryptic inserts were deleted by CCC Staff because their meaning and proposed use were not explained in the city’s submission.) The new OPR SLR Guidance: 2024 Science and Policy Update cries out to be used to our advantage. But note that the moderated predictions short-term DO NOT obviate the imperative for truly long term planning. For the 100 yr frame, the “best available science” is more uncertain but also more dire than prior predictions. Monitoring data with a hierarchical set of adaptive responses may be the only sensible way to adapt to the climate/SLR challenge, with the added merit of being endorsed by CCC, and perhaps required.
We MUST NOT try to use the 2024 OPR SLR predictions to justify a single short-term armoring alternative.
è A clear path is available now for consideration by the Coastal Commission. It appears not to have been considered seriously, but it is not too late. Accepting that LCLUP with the Suggested Mods proffered by CCC Staff in March 2023 can happen quickly, but only if Suggested Mods are accepted without the many Alternative Mods. Raising ANY is certain to delay approval.
My hope here is to support a path for certification of the critical LCLUP. There are many positive benefits to this path even beyond certification – time for other urgencies, avoiding litigation, building a good faith relationship with CCC, a step toward real long-term planning… .
The negatives diminish under the weight of the benefits.
While you know that I don't agree with a number of Pacifica’s current directions, I honestly think this path can be acceptable to “all sides.” The special sauce is that it can happen fast, and all our modifications can continue much as now, perhaps with much the same likelihood of success, without the crippling delay and public disappointment we otherwise will face.